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

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

ML23052A112
Person / Time
Site:	Point Beach
Issue date:	02/21/2023
From:	Strand D Point Beach
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2023-011
Download: ML23052A112 (1)

Text

NEXTera L-2023-011 ENERGY ~ 10 CFR 50.90

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

References:

1. NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)

2. NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -

Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times - RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)

3. NRC electronic memorandum dated December 20, 2022, Final RAI - Point Beach 1 & 2 - License Amendment Request Regarding TSTF-505 (ADAMS Accession No. ML22354A161)

4. NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, Response to Requests for Additional Information (RAls) Regarding License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", January 11 , 2023 (ADAMS Accession No. ML23011A280)

5. NRC electronic memorandum dated January 31, 2022, Final RAI (Volume 2) - Point Beach 1 & 2 -

License Amendment Request Regarding TSTS-505 (EPID No. L-2022-LLA-0074)

In Reference 1, NextEra Energy Point Beach, LLC (NextEra) submitted license amendment request (LAR) 297 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach) , respectively. The proposed license amendments would modify the Point Beach Technical Specifications (TS) to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extend Completion Times - RITSTF Initiative 4b, (ADAMS Accession No. ML18183A493).

In Reference 2, the NRC notified NextEra of its intent to conduct a regulatory audit to gain understanding, verify information, or identify information requiring docketing to support a licensing or regulatory decision.

In Reference 4, NextEra responded to the NRC's request for additional information provided in Reference

3. In Reference 5, the NRC requested additional information deemed necessary to complete its review.

The enclosure to this letter provides NextEra's response to the request for additional information (RAI) of Reference 5. Attachment 1 to the enclosure provides a revised Table E1-1, List of Revised Required Actions to Corresponding PRA Functions, which aligns with the RAI responses in this letter and in

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Page 2 of 2 Reference 4. Attachment 2 provides a revised Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity. Attachment 3 provides a revised Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity. The revised Tables E1-3(1) and E1-3(2) are provided in response to information request item #14 of Reference 2 and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Tables E1-1, E1-3(1) and E1-3(2) supersede and replace the corresponding Tables E1-1, E1-3(1) and E1-3(2) of Reference 1.

The supplements included in this RAI response provide additional information that clarifies the application, do not expand the scope of the application as originally noticed, and should not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Kenneth Mack, Fleet Licensing Manager, at 561-904-3635.

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

Executed on the 2) day of February 2023.

Sincerely,

~L,,- S~

ianne Strand General Manager, Regulatory Affairs cc: USNRC Regional Administrator, Region Ill Project Manager, USNRC, Point Beach Nuclear Plant Resident Inspector, USNRC, Point Beach Nuclear Plant Public Service Commission of Wisconsin Attachments (3)

1. Table E1-1, List of Revised Required Actions to Corresponding PRA Functions (revised)

2. Table E1-3(1), Information to Support RPS Instrumentation Redundancy and Diversity (revised)

3. Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 1 of 13 Response to Request for Additional Information (RAI)

License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b" Containment and Plant Systems Branch (SCPB) Audit Questions SCPB-RAl-1 (Audit Question 25)

In Enclosure 1 of the LAR, Table E1-1 indicates for TS LCO Action 3.6.2.C that there are two emergency airlocks. Specifically, it lists one equipment hatch, one personnel airlock, and two emergency airlocks.

FSAR, Chapter 5 indicates 2 personnel airlocks (one of which is emergency). FSAR Figures 5.1-4 and 5.1-5 are unreadable in the FSAR available at the NRC.

a) Provide clear copies of the figures made available in the audit.

b) Discuss why the LAR differs from the FSAR and confirm and correct.

NextEra Response:

a) A controlled, readable copy of UFSAR Figure 5.1-5, "Containment Structure - Equipment Hatch" was made available for NRC viewing on the NextEra Online Reference Portal. Regarding UFSAR Figure 5.1-4, "Containment Structure - Personnel Lock", NextEra identified that the controlled drawing needed to be redrawn. The discovery was entered into the Point Beach corrective action program (CAP). UFSAR Figure 5.1-4 details the containment personnel lock annulus, bulkhead panels and equalizing valves. As an alternative, Point Beach controlled drawings D-2 JOB 18006_2 and D-3 JOB 18006_2, which combined provide similar detail of the containment personnel air locks, were made available for NRC viewing on the NextEra Online Reference Portal.

b) Table E1-1 of LAR Enclosure 1 required correction for TS LCO Action 3.6.2, Condition C. As specified in Point Beach FSAR Chapter 5.1.2.6, Penetrations, the Point Beach Unit 1 and 2 containments each include one equipment hatch and two personnel airlocks, one of which is for convenience access. The revised Table E1-1 is included as Attachment 1 to this RAI response.

The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1 to this RAI response.

SCPB-RAl-2 (Audit Question 26)

In Enclosure 1 of the LAR, Section 3, the licensee provides justification for TS LCO 3.6.2, "Containment Air Locks." However, it does not address the following issue: TSTF-505 Revision 2, for WOG LCO 3.6.2.C.2 reads "C.2 Verify a door is closed in the affected air lock." whereas the LAR's proposed Point Beach LCO 3.6.2.C.2 reads "C.2 Verify a bulkhead door and associated equalizing valve are closed in the affected air lock."

Provide additional information to explain: (1) how the equalizing valves function in relation to the bulkhead doors; and (2) why the difference in wording exists between the LCO of TSTF-505, Revision 2, and the LCO proposed in the LAR.

NextEra Response:

The personnel air lock equalizing valves connect the personnel lock with the interior and exterior of the containment vessel. The safety function is to isolate containment from the environment during design basis accident conditions. The equalizing valves are not "valves" in the traditional sense but consist of

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 2of13 a disc plate that seals against a base plate with a dual 0-ring seal. The disk slides along extension bars by a lever and cam linkage working through a pivot plate attached to the ends of the extension bars.

The lever is connected to the existing linkage arm driven by the door operating mechanism. Test ports are provided in the adapter flange for leak testing the 0-ring seals on one face and the flange gasket on the other.

The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is one of nomenclature since the "bulkhead" is the actual air lock door. However, the term "bulkhead" in Point Beach LCO 3.6.2, ACTION C.2, serves to underscore that the integrity of each airlock pressure boundary relies on the closure of both the bulkhead door and the associated equalizing valve. Of note is that Bases section 3.6.2 of NUREG 1431, Revision 4 (ADAMS Accession No. ML 121 OOA228), does not discuss air lock equalizing valves as part of the containment air lock pressure boundary and thereby it is not expected that the distinction would be addressed in LCO 3.6.2 of NU REG 1431, Revision 4 (ADAMS Accession No. ML12100A222), upon which LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is based. The plant-specific variation is acceptable since, consistent with LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, Point Beach LCO 3.6.2, ACTION C.2, assures the integrity of at least one air lock pressure boundary when in Condition C, "One or more containment air locks inoperable for reasons other than Conditions A or B".

The difference in wording between Point Beach LCO 3.6.2, and LCO 3.6.2, ACTION C.2, of TSTF-505, Revision 2, is a plant-specific variation that was inadvertently omitted from and is in addition to the evaluations provided in Attachment 5, Evaluation of Plant-Specific Variations, of Reference 1.

Electrical Engineering Branch (EEEB) Audit Questions In Table E1-1 of Enclosure 1 of the LAR, the licensee lists each TS Required Action Condition proposed for the Point Beach RICT Program and documents information regarding the associated SSCs credited in plant safety analyses, the analogous PRA functions, and the results of the comparison. Questions EEEB-RAl-1 thru EEEBRAl-7 pertain to the information presented in Table E1-1.

EEEB-RAl-1 (Audit Question 27)

For each LCO proposed under TS 3.8, "Electrical Power Systems," clarify if Table E1-1 is written on a per unit basis for "SSC Function(s)" (Column 3), and "PRA Success Criteria" (Column 6), given that sharing of electrical systems is found in UFSAR.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems, required revision to clarify that Column 3, "SSC Function(s)", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" apply on a per unit basis. Specifically, for TS 3.8, Column 3 was revised to identify the SSCs associated with the LCO Condition on a per unit basis. Similarly, for TS 3.8, Columns 5 and 6 were revised to specify the minimum SSCs required to fulfill the safety function on a per unit basis. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

EEEB-RAl-2 (Audit Question 28)

The licensee stated that the "SSC Function(s)" (Column 3) for TS 3.8.1, Conditions A, B, C, D, and Fis "Power onsite safeguards buses from offsite and onsite transmission networks to support normal, safe shutdown and accident mitigation conditions." Clarify why Column 3 is inconsistent with UFSAR by not listing four Class 1E 4.16 kV electrical buses since there are two of them per unit if this table addresses both Units 1 and 2.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 3of13 NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to clarify that Column 3, "SSC Function(s)" applies on a per unit basis. The revision resolves the inconsistency with the UFSAR regarding the number of Class 1E 4.16 kV electrical buses for one versus both Point Beach nuclear units. The revision to Column 3 for TS 3.8.1, Conditions A, B, C, D, and F are listed below and were incorporated into the revised Table E-1.1, which is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Condition SSC Description Function(s)

TS 3.8.1 Power Condition A Class 1E Associated unit 4.16 kV 345/13.8 kV (X03) safeguards transformer inoperable.

buses from OR offsite Gas turbine not in operation transmission when utilizing opposite unit's networks 345/13.8 kV (X03) transformer Power Class 1E TS 3.8.1 4.16 kV Condition 8 safeguards Associated unit's 13.8/4.16 kV buses from (X04) transformer offsite inoperable transmission networks Power Class 1E TS 3.8.1 4.16 kV Condition C safeguards Associated unit's required buses from offsite power source to buses offsite A05 and A06 inoperable.

transmission OR networks and Required offsite power source on site to buses 1A05 and 2A06 emergency inoperable power sources Power Class 1E 4.16 kV TS 3.8.1 safeguards Condition D buses from One or more required offsite offsite power source(s) to one transmission or more required Class 1E networks and 4.16 kV bus(es) on site inoperable emergency power sources

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 4of13 Power Class 1E TS 3.8.1 4.16 kV Condition F safeguards One or more required buses from offsite power source to one or offsite more Class 1E 4.16 kV transmission safeguards bus(es) inoperable networks and AND Standby emergency on site power inoperable to redundant emergency equipment power sources EEEB-RAl-3 (Audit Question 29, rev 1) -TS LCO 3.8.1, Conditions A and B Explain why Columns 2 and 3 are inconsistent with LCO for SSCs specifically covered by the LCO (not addressing high voltage (HV) station auxiliary transformers X03s or low voltage (LV) station auxiliary transformers X04s) in associated unit for respective LCO condition.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions A and B. The revision reflects the availability of the offsite power sources to power 4.16 kV Class 1E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action SSC Condition Applicable SSCs Function(s)

Description TS 3.8.1 Condition A Two circuits between the Power Associated unit offsite transmission network Class 1E 345/13.8 kV (X03) via the 345/13.8 kV (X03) 4.16 kV transformer inoperable. transformers and the safeguards OR 13.8/4.16 kV (X04) buses from Gas turbine not in operation transformers, and the offsite when utilizing opposite unit's associated unit's 4.16 kV transmission 345/13.8 kV (X03) Class 1E safeguards buses) networks transformer.

Two circuits between the Power offsite transmission network Class 1E TS 3.8.1 via the 345/13.8 kV (X03) 4.16 kV Condition B transformers and the safeguards Associated unit's 13.8/4.16 13.8/4.16 kV (X04) buses from kV (X04) transformer transformers, and the offsite inoperable associated unit's 4.16 kV transmission Class 1E safeguards buses networks EEEB-RAl-4 (Audit Question 30, rev 1) -TS LCO 3.8.1, Conditions A and B Explain why Column 6 is inconsistent with LCO by not listing minimum SSCs of those listed in Column 3 (e.g., either opposite unit's HV (X03) or LV station auxiliary transformer (X04), respectively, for Condition A or B) to achieve safe shut down for a design basis accident (OBA) in opposite unit.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 5of13 NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions A and B. The revised success criteria require one circuit between the offsite transmission network and an affected unit's safeguard bus via automatic alignment with the opposite unit's X03 transformer for the condition of an inoperable X03 transformer and manual alignment with the opposite unit's X04 transformer for the condition of an inoperable X04 transformer.

Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions A and B. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Condition Design Success PRASuccess Description Criteria Criteria TS 3.8.1 One circuit Condition A between the offsite Associated unit transmission network 345/13.8 kV (X03) via a 345/13.8 kV transformer inoperable. (X03) transformer Same OR and a 13.8/4.16kV Gas turbine not in operation (X04) transformer, when utilizing opposite unit's and an associated 345/13.8 kV (X03) unit's 4.16 kV Class transformer. 1E safeguards bus One circuit between the offsite transmission network TS 3.8.1 via a 345/13.8 kV Condition B (X03) transformer Associated unit's 13.8/4.16 Same and a 13.8/4.16kV kV (X04) transformer (X04) transformer, inoperable and an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-5 (Audit Question 31, rev 1)-TS LCO 3.8.1, Conditions C and D Explain why Columns 2 and 3 are inconsistent with respective LCO in that (a) HV station auxiliary transformers X03s supplying buses A05 and A06 are not shown for TS LCO 3.8.1, Condition C and (b) also for LCO 3.8.1, Condition D including EDGs based on TS Bases (page 473).

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", required revision to specify the SSCs covered by TS 3.8.1, Conditions C and D. The revision reflects the availability of the offsite power sources, including from the opposite unit, and the onsite emergency power sources to power 4.16 kV Class 1E safeguards busses, A05 and A06. Specifically, the changes below were incorporated into Table E.1-1 for consistency with TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 6of13 Required Action SSC Condition Applicable SSCs Function(s)

Description Two circuits between the offsite TS 3.8.1 Power transmission network via the Condition C Class 1E 345/13.8 kV (X03) transformers Associated unit's 4.16 kV and the 13.8/4.16kV (X04) required offsite power safeguards transformers, and the associated source to buses A05 buses from unit's 4.16 kV Class 1E safeguards and A06 inoperable. offsite buses OR transmission AND Required offsite networks and Two onsite emergency power power source to on site sources capable of supplying the buses 1A05 and emergency associated unit's 4.16 kV Class 1E 2A06 inoperable power sources safeguards buses)

Two circuits between the offsite Power transmission network via the Class 1E TS 3.8.1 345/13.8 kV (X03) transformers 4.16 kV Condition D and the 13.8/4.16kV (X04) safeguards One or more required transformers, and the associated buses from offsite power unit's 4.16 kV Class 1E safeguards offsite source(s) to one or buses transmission more required Class AND networks and 1E 4.16 kV bus( es) Two onsite emergency power on site inoperable sources capable of supplying the emergency associated unit's 4.16 kV Class 1E power sources safeguards buses EEEB-RAl-6 (Audit Question 32, rev 1) - TS LCO 3.8.1, Conditions C and D Explain why Column 6 is inconsistent by not listing minimum required SSCs for respective LCO (a) like one unit's HV station auxiliary transformer (X03) supplying a singular bus A05 or A06 for TS LCO 3.8.1, Condition C and one unit's HV station auxiliary transformer (X03), or one EDG supplying that unit's bus A05 or A06 for TS LCO 3.8.1, Condition D.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Conditions C and D. For the condition of the associated unit's offsite power source circuit inoperable, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power source circuit. For the condition of both offsite power source circuits unavailable, the revised success criteria require an onsite emergency power source capable of supplying an associated unit's Class 1E4.16 kV safeguards bus, A05 or A06.

Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Conditions C and D. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 7of13 Required Action Design Success PRA Success Condition Criteria Criteria Description One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1 (X03) transformer Condition C and a 13.8/4.16kV Associated unit's required (X04) transformer, offsite power source to and an associated buses A05 and A06 unit's 4.16 kV Class Same inoperable. 1E safeguards bus OR OR Required offsite power One onsite source to buses 1A05 and emergency power 2A06 inoperable source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit between the offsite transmission network via a 345/13.8 kV (X03) transformer and a 13.8/4.16kV TS 3.8.1 (X04) transformer, Condition D and an associated One or more required unit's 4.16 kV Class offsite power source(s) to Same 1E safeguards bus one or more required OR Class 1E 4.16 kV bus( es)

One onsite inoperable emergency power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-7 (Audit Question 33, rev 1) -TS LCO 3.8.1, Condition F Explain why Column 6 is inconsistent with LCO by not listing minimum required SSCs one unit's HV station auxiliary transformer OR one EOG as supplying that unit's bus A05 or A06 as minimum SSCs for TS LCO 3.8.1, Condition F.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the minimum SSCs required to fulfill the safety function for TS 3.8.1, Condition F. For the condition of an inoperable offsite power source in conjunction with an inoperable onsite emergency power source, the revised success criteria require one circuit between the offsite transmission network and an associated unit's Class 1E 4.16 kV safeguards bus, A05 or A06, which can be satisfied by aligning the opposite unit's offsite power circuit. For the condition of both offsite power source circuits unavailable to the associated unit in conjunction with an inoperable onsite emergency power source, the revised success criteria require one onsite emergency power

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 8of13 source capable of supplying an associated unit's Class 1E 4.16 kV safeguards bus (A05 or A06), which can be satisfied by aligning the opposite unit's onsite emergency power source associated with the affected safeguards bus. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.1, Condition F. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Design Success PRA Success Condition Criteria Criteria Description One circuit between the offsite transmission network via a 345/13.8 kV TS 3.8.1 (X03) transformer Condition F and a 13.8/4.16kV One or more required (X04) transformer, offsite power source to and an associated one or more Class 1E unit's 4.16 kV Class Same 4.16 kV safeguards 1E safeguards bus bus(es) inoperable OR AND Standby emergency One onsite power inoperable to emergency power redundant equipment source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus EEEB-RAl-8 (Audit Question 34, rev 1) -TS LCO 3.8.4, Condition A Explain why Column 6 does not list minimum required SSCs in agreement with LCO in terms of subsystems (See TS Bases on page 504, 3rd full paragraph, 1st sentence about term "subsystem" and usage at Point Beach) and indicate if swing battery and battery chargers should be captured here.

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.4, Condition A. The DC electrical power system consists of four main distribution buses configured as two redundant electrical 125 VDC trains, with each distribution bus powered by a battery charger and backed up by a station battery.

Thereby, the applicable SSCs for TS 3.8.4, Condition A, are four 125 VDC electrical subsystems each consisting of a battery charger backed by a station battery powering the associated DC distribution bus.

The revised success criteria require two 125 VDC electrical subsystems of the same electrical train, each consisting of a battery charger backed by a station battery powering the associated DC distribution bus. Just as the normally aligned batteries and battery chargers, the swing battery and charger are sized to provide 100% of required DC power, and thereby, the swing battery and charger need not be explicitly captured in the success criteria. Specifically, the changes below were incorporated into Columns 5 and 6 of Table E-1.1 for TS 3.8.4, Condition A The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 9of13 Required Action Design Success PRASuccess Condition Applicable SSCs Criteria Criteria Description Two 125 voe Four 125 voe electrical subsystems electrical subsystems of the same electrical TS 3.8.4 each consisting of a train, each consisting Condition A battery charger of a battery charger Same One DC electrical power backed by a station backed by a station subsystem inoperable battery powering the battery powering the associated DC associated DC distribution bus distribution bus EEEB-RAl-9 (Audit Question 35, rev 1) -TS LCO 3.8.7, Condition A Explain why Column 6 does not list minimum number of inverters per channel per unit required for DBA and UFSAR Section 8.6.2 and TS Bases (page 520, 2nd paragraph, last 5 sentences).

NextEra Response:

Table E1-1 for TS 3.8, "Electrical Power Systems", Column 2, "Applicable SSC's", Column 5, "Design Success Criteria" and Column 6, "PRA Success Criteria" required revision to specify the applicable and the minimum SSCs required to fulfill the safety function for TS 3.8.7, Condition A. The 120 VAC instrument system consists of four 120 VAC instrument channels (red, white, blue, and yellow) configured as two redundant 120 VAC electrical trains. Each are allocated four buses of which two are dedicated to Unit 1 and two dedicated to Unit 2. Each of the four channels are equipped with three inverters of which one is dedicated to Unit 1, one dedicated to Unit 2, and a third, swing inverter which can be aligned to replace either Unit 1 or Unit 2 inverters with full capability. Thereby, the applicable SSCs for TS 3.8.7, Condition A, are four 120 VAC instrument channels each equipped with a 120 VAC instrument inverter powering its two 120 VAC electrical buses. Since the four 120 VAC instrument channels are configured as two redundant 120 VAC electrical trains, the revised design and PRA success criteria for TS 3.8. 7, Condition A, are two 120 VAC instrument channels of the same electrical train, each equipped with a 120 VAC instrument inverter powering two 120 VAC electrical buses.

Specifically, the changes below were incorporated into Columns 2, 5 and 6 of Table E-1.1 for TS 3.8.7, Condition A. The revised Table E1-1 is included as Attachment 1 to this RAI response. The revised Table E1-1 supersedes and replaces the corresponding Table E1-1 of Reference 1.

Required Action Design Success PRASuccess Condition Applicable SSCs Criteria Criteria Description Two 120 VAC Four 120 VAC instrument channels instrument channels TS 3.8.7 of the same electrical each equipped with a Condition A train, each equipped 120 VAC instrument Same One required inverter with a 120 VAC inverter powering two inoperable instrument inverter 120 VAC electrical powering two 120 buses VAC electrical buses Instrumentation & Controls Branch (EICB) Audit Questions EICB-RAl-1 (Audit Question 36)

In Enclosure 1 of the LAR, Table E1-3(1 ), indicates the following:

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 10of13 RPS Function Functional Unit Channels to Trip RCP breaker position - one loop FU10a 1 out of 1 per loop RCP breaker position - 2 loops FU10b Underfrequency Bus A01, A02 FU12 1 out of 1 per bus a) Explain why it is not a loss of function to support the application of risk-informed completion time.

b) Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the coincidence logic presented in the LAR.

NextEra Response:

In response to information request item #14 of the NRC's audit plan (Reference 2), Table E1-3(1),

Information to Support RPS Instrumentation Redundancy and Diversity, and Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity, were revised to identify for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip or ESFAS actuation function(s) credited in plant safety analyses. Table E1-3(1) was also revised to correct the coincidence logic for FU10a, FU10b and FU12, as described below. The revised Table E1-3(1) and Table E1-3(2) are included as Attachments 2 and 3 to this RAI response, respectively, and were also made available for NRC viewing on the NextEra Online Reference Portal. The revised Table E1-3(1) and Table E1-3(2) supersede and replace the corresponding Table E1-3(1) and Table E1-3(2) of Reference 1.

a) For Functional Units (FU) 10a, FU10b and FU12, Table E1-3(1) required correction for the coincidence trip logic column "Channels to Trip". The correct coincidence logic for these RPS functions is listed below and was incorporated into Table E1-3(1). The revised Table E1-3(1) is provided as Attachment 2 of this RAI response. The revised Table E1-3(1) supersedes and replaces the corresponding Table E1-3(1) of Reference 1.

RPS Function Functional Unit Channels to Trip 1-out-of-2 per loop RCP breaker position - one loop FU10a 1-out-of-2 per loop RCP breaker position - 2 loops FU10b taken twice 1 out of 2 per bus Underfrequency Bus A01, A02 FU12 taken twice For FU10a, "RCP Breaker Position - One Loop, when above the P-8 permissive (-35% RTP), a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on either RCP. Should an FU10a channel become inoperable, the redundant FU10a channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU1 Oa channel on either or both RCP loops is not a loss of function.

For FU10b, "RCP Breaker Position - 2 Loops", when above the P-7 permissive (-10% RTP) but below P-8 permissive, a reactor trip occurs upon one of the two RCP breaker relays sensing an open RCP breaker condition on both RCP loops. Should an FU10b channel become inoperable, it's redundant FU 1Ob channel is available to fulfill the coincidence trip logic for the affected RCP loop. Thereby, the loss of one FU10b channel on either or both RCP loops is not a loss of function.

During an audit meeting held on November 22, 2022, the NRC staff asked whether the RCP breakers are equipped with redundant relays (i.e., channels) to the RPS system, as inferred above by the '1 out of 2 per loop' trip logic associated with RPS trip functions FU1 Oa (RCP breaker position

- one loop) and FU10b (RCP breaker position - 2 loops). The table below is derived from Point

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 11of13 Beach Units 1 and 2 instrumentation & control (l&C) procedures ICP 02.029, Reactor Protection System Logic - RCP Breaker Position (RCP Loss of Power) - TADOT, which verify each train A and train B relay energize with the associated RCP breaker closed and de-energize with the RCP breaker racked-in and open. As can be seen, each RCP breaker is equipped with two, redundant matrix relays, and as such, loss of one relay does not create a loss of function. For an inoperable RCP-A-XA or RCP-A-XB relay on the 'A" RCP-breaker (or an inoperable RCP-B-XA or RCP-B-XB relay on the 'B' RCP breaker) TS 3.3.1, ACTION M would be entered for the loss of a single FU1 Oa channel when above the P-8 permissive, or ACTION N would be entered for the loss of a single FU10b channel when above P-7 but below P-8. The above discussion similarly applies to the Unit 2 'A' and 'B' RCPs. Of note is that neither ACTION M nor N address the condition of both relays associated with a single RCP breaker being inoperable, which would require LCO 3.0.3 entry for this loss of function condition. l&C procedures ICP 02.029 for Point Beach Units 1 and 2 were made available for NRC viewing on the NextEra Online Reference Portal.

RCP Train Pump Breaker Contacts Matrix Relay No.

A 3-4 RCP-A-XA 1P-1A 1A52-04 B 7-8 RCP-A-XB A 3-4 RCP-B-XA 1P-1 B 1A52-14 B 7-8 RCP-B-XB A 3-4 RCP-A-XA 2P-1A 2A52-24 B 7-8 RCP-A-XB A 3-4 RCP-B-XA 2P-1B 2A52-29 B 7-8 RCP-B-XB For FU12, "Underfrequency Bus A01, A02", when above the P-7 permissive, both RCP breakers are tripped (open) upon one of the two underfrequency relays sensing an underfrequency condition on both 4160 V buses A01 and A02. Should an FU12 channel become inoperable, its redundant FU12 channel is available to fulfill the coincidence trip logic for the affected A01 or A02 bus.

Thereby, the loss of one FU12 channel on either or both A01 and A02 buses is not a loss of function.

b) The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:

• 883D195, Sheet 4, Rev. 23, 4160 V Bus Scheme Logic

• 883D195, Sheet 15, Rev. 10, RC Trip Signal Logic

• 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach design basis document (DBD) 27, Reactor Protection System, was made available for NRC viewing on the NextEra Online Reference Portal.

EICB-RAl-2 (Audit Question 37)

In Attachment 2a of the LAR, the licensee proposes that the COMPLETION TIME for TS 3.3.1, "Reactor Protection System (RPS) Instrumentation," CONDITION U change to "48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program." CONDITION U applies to Functional Unit (FU) 19, "Reactor Trip Breaker Undervoltage and Shunt." In Enclosure 1 of the LAR, Table E1-3(1) does not include information for FU19.

a) Why is FU19 not included in the Table E1-3(1)?

b) What is the coincidence logic for FU19?

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page 12 of 13 c) If the coincidence logic is X-out-of-X (such as 1-out-of-1 or 2-out-of-2), why it is not a loss of function to support the application of risk-informed completion time?

d) Provide reference location in the UFSAR and RPS Design Basis Document (or in other available documentation) supporting the trip logic for FU19.

NextEra Response:

a) Table E1-3(1) of LAR Enclosure 1 identifies for each design basis accident and transient, at least one diverse means of achieving the primary RPS trip function(s) credited in plant safety analyses.

Table E1-3(1) specifies as one of the diverse means of achieving the primary RPS trip function, the ability to manually trip the reactor. Both the primary and diverse RPS trip functions specified in Table E1-3(1) rely on two operable logic trains of Reactor Trip Breakers (RTBs) each capable of de-energizing the associated RTB (or bypass) undervoltage coil upon receipt of an RPS signal and energizing open the associated RTB via a shunt trip device upon receipt of a manual trip signal.

Operability of both trip mechanisms on each RTB logic train ensures that no single trip mechanism failure will prevent opening any breaker on a valid RPS signal. Thereby, FU19, Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms, need not be explicitly listed in Table E1-3(1) since an operable FU19 is necessary to achieve both the primary and diverse means of achieving the specified RPS trip functions.

b) The coincidence logic for FU19 is 1-out-of-2, meaning only one of the two FU19 channels are needed to achieve the reactor trip upon receipt of a valid RPS signal.

c) With one FU19 channel inoperable, the redundant FU19 channel is capable of providing the reactor trip upon receipt of a valid RPS signal. Thereby, the loss of one FU19 channel does not result in a loss of function.

d) The following Point Beach drawings detailing the RPS trip logic for FU10a, FU10b and FU12 were made available for NRC viewing on the NextEra Online Reference Portal:

• 883D195, Sheet 2, Rev. 9, Reactor Trip Signal Logic

• 883D195, Sheet. 1, Rev. 14, Logic Diagram Index and Symbols In addition, Point Beach DBD 27, Reactor Protection System, was uploaded to the NextEra Online Reference Portal for NRC viewing in response to item #14 of the NRC's audit document request (Reference 2).

During the audit meeting held on November 22, 2022, the NRC staff asked for the plant conditions warranting entry into FU18 versus FU19 entry. FU18 addresses the operability of the RTBs exclusive of individual trip mechanisms. Two RTBs are required to ensure no single random failure can disable the RPS trip capability. FU19 addresses the operability of the RTB undervoltage and shunt trip device mechanisms. Should an RTB become inoperable independent of the corresponding trip mechanisms, TS 3.3.1, Table 3.3-1, Condition Q would be entered for an inoperable FU18-required RTB. Should either the RTB undervoltage or shunt trip device mechanism become inoperable, TS 3.3.1, Table 3.3-1, Condition U, would be entered for an inoperable FU 19-required trip mechanism. However, it would not be necessary to also enter Condition U for an inoperable FU18-required RTB since the affected RTB remains capable of tripping the unit upon receipt of a valid RPS signal. Noteworthy in both scenarios is that the redundant RTB remains available and capable of performing its function upon a valid RPS signal, and thereby entry into FU 18, FU 19 or both does not constitute a loss of function.

References:

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Enclosure Page13of13

1. NextEra Energy letter NRC 2022-0007, Point Beach Nuclear Plant, Units 1 and 2, License Amendment Request 297, Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk Informed Extended Completion Times - RITSTF Initiative 4b", May 20, 2022 (ADAMS Accession No. ML22192A152)

2. NRC letter to Florida Power & Light Company, Point Beach Nuclear Plant, Units 1 and 2 -

Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times- RITSTF Initiative 4b, August 11, 2022 (ADAMS Accession No. Ml22216A203)

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 1 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description TS 3.3.1, RPS Instrumentation (Table 3.3-1)

Condition B The operator actions for failure to One Manual 1of2 Not Modeled actuate a manual reactor trip will be (FU1) Reactor Trip Reactor Trip No Manual Rx Trip -See used as a surrogate to conservatively Two Manual Rx Trip channels Initiation channel inoperable channels comments bound the risk increase associated with (Modes 1,2) this function as permitted by NEI 06-09.

(FU2a) 2 of4 Not Modeled The condition of one of two inoperable Reactor Trip Four Power Range Neutron No Power Range Neutron -See reactor trip breakers is used as a Initiation Flux High channels Flux- High channels comments surrogate for this condition.

(FU2b) 2 of4 Not Modeled The condition of one of two inoperable Reactor Trip Four Power Range Neutron No Power Range Neutron -See reactor trip breakers is used as a Initiation Flux Low channels Flux- Low channels comments surrogate for this condition.

(FU5) 2 of4 Not Modeled The condition of one of two inoperable Reactor Trip Four Overtemperature Lff No Overtemperature t:,.T -See reactor trip breakers is used as a Initiation channels channels comments surrogate for this condition.

2 of 4 Not Modeled The condition of one of two inoperable Condition D (FU6) Reactor Trip No Overpower t:,.T -See reactor trip breakers is used as a One channel Four Overpower!::,.T channels Initiation channels comments surrogate for this condition.

inoperable (FU?b) 2 of3 Not Modeled The condition of one of two inoperable Reactor Trip Three Pressurizer Pressure - No Pressurizer Pressure - -See reactor trip breakers is used as a Initiation High channels High channels comments surrogate for this condition.

2 of 3 (FU13) Not Modeled The condition of one of two inoperable Reactor Trip SG Water Level Low-Three SG Water Level Low-Low No -See reactor trip breakers is used as a Initiation Low channels on any channels per SG comments surrogate for this condition.

SG (FU14) One SG Water Level Two SG Water Level Low; Low coincident w/ one Not Modeled The condition of one of two inoperable Reactor Trip Coincident w/ Steam-Flow/ No Steam-Flow/ Feed- -See reactor trip breakers is used as a Initiation Feed-Flow Mismatch channels Flow Mismatch comments surrogate for this condition.

perSG channel on any SG

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 2 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action Design Success PRASuccess SSC PRA Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description 1 of 2 Condition E (FU12) Not Modeled The condition of one of two inoperable Reactor Trip Underfrequency Bus One channel Two Underfrequency Bus A01, No -See reactor trip breakers is used as a Initiation channels on both inoperable A02 channels per bus comments surrogate for this condition.

A01 and A02 (FU7a) 2 of4 Not Modeled The condition of one of two inoperable Reactor Trip Four Pressurizer Pressure - No Pressurizer Pressure - -See reactor trip breakers is used as a Initiation Low channels Low channels comments surroQate for this condition.

(FU8) 2 of 3 Not Modeled The condition of one of two inoperable Reactor Trip Three Pressurizer Water Level - No Pressurizer Water -See reactor trip breakers is used as a Initiation High channels Level - High channels comments surrogate for this condition.

Condition K One channel 2 of 3 (FU9b) inoperable Reactor Coolant Flow - Not Modeled The condition of one of two inoperable Three Reactor Coolant Flow - Reactor Trip No Low channels on both -See reactor trip breakers is used as a Low (Two loops) channels per Initiation RCS Loops when comments surrogate for this condition.

RCS Loop above P8 1of2 (FU11) Not Modeled The condition of one of two inoperable Reactor Trip Undervoltage Bus Two Undervoltage Bus A01, No -See reactor trip breakers is used as a Initiation channels on A02 channels per electrical bus comments surrogate for this condition.

A01 and A02 Condition L 2 of3 (FU9a)

One Reactor Reactor Coolant Flow - Not Modeled The condition of one of two inoperable Three Reactor Coolant Flow - Reactor Trip Coolant Flow-Low No Low channels on any -See reactor trip breakers is used as a Low (Single Loop) channels per Initiation (Single Loop) RCS Loop when below comments surrogate for this condition.

RCS Loop channel inoperable P8 Condition M One Reactor One RCP Breaker (FU10a) Not Modeled The condition of one of two inoperable Coolant Pump Reactor Trip Position channel on One RCP Breaker Position No -See reactor trip breakers is used as a Breaker Position Initiation any RCP when below (Single Loop) channel per RCP comments surrogate for this condition.

(Single Loop) P8 channel inoperable One RCP breaker Condition N (FU10b) Not Modeled The condition of one of two inoperable Reactor Trip Position channel on One inoperable One RCP breaker position (two No -See reactor trip breakers is used as a Initiation both RCPs when channel loops) channel per RCP comments surrogate for this condition.

above P8

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 3of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs *criteria Comments Function(s) Modeled Criteria Description 2 of2 (FU15a) Not Modeled The condition of one of two inoperable Reactor Trip Turbine trip - Low Three Turbine trip - Low Auto- No -See reactor trip breakers is used as a Condition 0 Initiation Auto-Stop Oil Pressure Stop Oil Pressure channels comments surrogate for this condition.

One turbine trip channels channel 2 of 3 inoperable (FU15b) Not Modeled The condition of one of two inoperable Reactor Trip Turbine trip - Stop Two Turbine trip - Stop Valve No -See reactor trip breakers is used as a Initiation Valve Closure Closure channels comments surrogate for this condition.

channels 1of2 Not Modeled The condition of one of two inoperable (FU16) Reactor Trip Condition P No SI input from ESFAS -See reactor trip breakers is used as a Two SI input from ESFAS trains Initiation One train trains comments surrogate for this condition.

inoperable 1of2 Not Modeled The condition of one of two inoperable (Modes 1,2) (FU21) Reactor Trip No Automatic Trip Logic -See reactor trip breakers is used as a Two Automatic Trip Logic trains Initiation trains comments surrogate for this condition.

Condition Q Not Modeled This SSC is used as a surrogate for One RTB (FU18) Reactor Trip 1of2 No -See other TS 3.3.1 RPS Instrumentation inoperable Two RTB trains Initiation RTB trains comments Conditions.

(Modes 1,2)

Condition U (FU19) One RTB One trip Not Modeled The condition of one of two inoperable One RTB Undervoltage and Reactor Trip Undervoltage and mechanism No -See reactor trip breakers is used as a Shunt Trip Mechanism per RTB Initiation Shunt Trip Mechanism inoperable for one comments surrogate for this condition.

train on any RTB train RTB (Modes 1,2)

TS 3.3.2, ESFAS Instrumentation (Table 3.3-2)

The operator actions for failure to 1of2 Not Modeled manually actuate SI will be used as a (FU1a) Safety Injection No Manual Initiation -See surrogate to conservatively bound the Two Manual Initiation channels Initiation Condition B channels comments risk increase associated with this One channel function as permitted bv NEI 06-09.

inoperable The condition of manual SI function Containment 1of2 Not Modeled (FU3a) inoperable is used as a surrogate for Isolation No Manual Initiation -See Two Manual Initiation channels this condition since an SI signal Initiation channels comments aenerates a Cl sianal.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 4 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description 1of2 The failure of the automatic SI signals (FU1 b)

Automatic Not Modeled will be used as a surrogate to Two Automatic Safety Injection No Actuation Logic and -See conservatively bound the risk increase Actuation Logic and Actuation Initiation Actuation Relay trains comments associated with this function as Condition C Relay trains channels oermitted bv NEI 06-09.

One train 1of2 inoperable. (FU3b) The condition of automatic SI function Containment Automatic Not Modeled Two Automatic inoperable is used as a surrogate for Isolation No Actuation Logic and -See Actuation Logic and Actuation this condition since an SI signal Initiation Actuation comments Relay trains generates a Cl signal.

Relay trains The condition of automatic SI function (FU1c) 2 of 3 Not Modeled Safety Injection inoperable is used as a surrogate for Three Containment Pressure - No Containment Pressure -See Initiation this condition since it is the same High channels - High channels comments function (SI initiation).

The condition of automatic SI function (FU1d) 2 of 3 Not Modeled Safety Injection inoperable is used as a surrogate for Three Pressurizer Pressure - No Pressurizer Pressure - -See Initiation this condition since it is the same Low channels Low channels comments function (SI initiation).

2 of 3 The condition of automatic SI function (FU1e) Not Modeled Safety Injection Steam Line Pressure - inoperable is used as a surrogate for Three Steam Line Pressure - No -See Initiation Low channels per main this condition since it is the same Low channels per steam line comments steam line function (SI initiation).

Condition D The failure of the model logic for steam One channel (FU4c) Steam Line 2 of3 Not Modeled generator isolation will be used as a inoperable. Three Containment Pressure - Isolation No Containment Pressure -See surrogate to conservatively bound the High, High channels Initiation - High, High channels comments risk increase associated with this function as permitted bv NEI 06-09.

(FU4d) 1 of 2 High Steam Two High Steam Flow Flow channels Steam Line Not Modeled The condition of steam generator channels; Coincident with SI coincident with SI and Isolation No -See isolation function inoperable is used as and Coincident with three T avg - coincident with 2 of 3 Low, Low channels per RCS Initiation comments a surrogate for this condition.

Tavg - Low, Low loop channels (FU4e)

Steam Line Not Modeled The condition of steam generator Two High, High Steam Flow Isolation No 1 of 2 -See isolation function inoperable is used as channels per steam line; Initiation comments a surrogate for this condition.

Coincident with SI

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 5 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description High, High Steam Flow channels per steam line coincident with SI (FU5b) Feedwater 2 of3 Not Modeled The condition of steam generator Three SG Water Level - High Isolation No SG Water Level - High -See isolation function inoperable is used as channels per SG Initiation channels per SG comments a surrogate for this condition.

The failure of the model logic for these 2 of3 (FU6b) Auxiliary Not Modeled relays will be used as a surrogate to SG Water Level - Low, Three SG Water Level - Low, Feedwater No -See conservatively bound the risk increase Low channels on any Low channels per SG Initiation comments associated with this function as SG permitted bv NEI 06-09.

Condition F (FU4a) Steam Line Not Modeled The condition of steam generator One Manual Initiation One channel One Manual Initiation channel Isolation No -See isolation function inoperable is used as channel per RCS loop inoperable per RCS loop Initiation comments a surrogate for this condition.

1of2 (FU4b) Steam Line Not Modeled The condition of steam generator Automatic Actuation Two Automatic Actuation Logic Isolation No -See isolation function inoperable is used as Logic and Actuation and Actuation Relay trains Initiation comments a surrogate for this condition.

Relav trains 1of2 (FU5a) Not Modeled Condition G Feedwater Automatic Actuation The condition of AFW initiation is used Two Automatic Actuation Logic No -See One train Isolation Logic and Actuation as a surrogate for this condition.

and Actuation Relay trains comments inoperable Relay trains The failure of the model logic for these 1of2 (FU6a) Not Modeled relays will be used as a surrogate to Auxiliary Automatic Actuation Two Automatic Actuation Logic No -See conservatively bound the risk increase Feedwater Logic and Actuation and Actuation Relay trains comments associated with this function as Relay trains permitted bv NEI 06-09.

The failure of the model logic for 1 of2 Condition H (FU6d) Not Modeled starting all four AFW pumps will be Auxiliary Undervoltage Bus One channel Two Undervoltage Bus A01 and No -See used as a surrogate to conservatively Feedwater channels on inoperable A02 channels per electrical bus comments bound the risk increase associated with A01 and A02 this function as permitted bv NEI 06-09.

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 6 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s} Modeled Criteria Criteria Description TS 3.4, Reactor C.oolant System TS 3.4.11 Condition B One PORV Two Power Operated Relief RCS pressure 1 of2 Yes Same inoperable and not Valves (PORVs) control PO RVs capable of being manually cycled TS 3.4.11 Condition C Associated Block Two PORV Block Valves RCS integrity Yes Same One block valve Valve closure inoperable TS 3.5, Emergency Core Cooling System (ECCS}

1 of 2 SI pumps, and 1 of 2 RHR pumps Two ECCS trains each Emergency TS 3.5.2 comprised of one SI pump, one core cooling Condition A RHR pump, one RHR heat and post- 1 of 2 RHR pumps w/

Yes suction from Same One ECCS train exchanger and associated accident (long-inoperable RWST and containment sump term) core containment sump, flowpaths cooling supplying suction to 1 of 2 SI pumps for flowpath to RCS TS 3.6, Containment Systems TS 3.6.2 Condition C One of two The failure of the model logic for One or more One equipment hatch; ltwo containment air lock Not Modeled containment penetrations will be used Containment containment air personnel airlocks (one for No doors closed with -See as a surrogate to conservatively bound integrity locks inoperable emergency use)[MJ1J acceptable comments the risk increase associated with this for reasons other containment leakage function as permitted by NEI 06-09.

Condition A or B

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 7 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRA Success Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description TS 3.6.3 Condition A One or more penetration flow paths with one The failure of the model logic for containment 1 of2 Not Modeled containment penetrations will be used Two isolation valves on each Containment isolation valve No isolation valves per -See as a surrogate to conservatively bound containment penetration integrity inoperable penetration isolate comments the risk increase associated with this (applicable to function as permitted by NEI 06-09.

penetration flow paths with two containment isolation valves)

TS 3.6.3 Condition C One or more penetration flow paths with one The failure of the model logic for containment Each Not Modeled containment penetrations will be used One isolation valve and one isolation valve Containment closed system on each No isolation valve per -See as a surrogate to conservatively bound inoperable integrity containment penetration penetration isolates comments the risk increase associated with this (applicable to function as permitted by NEI 06-09.

penetration flow paths with one containment isolation valve and a closed system)

TS 3.7, Plant Systems TS 3.7.2 Condition A Two Main Steam Lines Steam Line One Steam equipped with one Main Steam Isolation from MSIV on affected Generator Yes Same Isolation Valve (MSIV) and one Faulted Steam steam line isolates flowpath with one Non-Return Check Valve Line or more inoperable valves in MODE 1

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 8 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

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

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 9of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description Two Component Cooling Water Heat sink for TS 3.7.7 (CCW) trains each consisting of removing 1 CCW pump and Condition B one CCW pump and one CCW process and 1 CCW HX provide One required CC heat exchanger, and one operating heat Yes heat sink to Same heat exchanger common CCW heat exchanger from safety- safety related inoperable capable of aligning to either related equipment train components Heat sink for 2 SW pumps and TS 3.7.8 Six Service Water (SW) system removing 1 SW Ring Header Condition A pumps, one common ring process and provide heat sink to One SW pump header, non-essential flowpath operating heat Yes CCW system and Same inoperable AND isolation valves and associated from safety- essential loads; auto-Both units in SW intake piping related isolate non- essential Modes 1, 2, 3, or 4 components flowpaths Heat sink for 2 SW pumps and TS 3.7.8 Six Service Water (SW) system removing 1 SW Ring Header Condition C pumps, one common ring process and provide heat sink to SW ring header header, non-essential flowpath operating heat Yes CCW system and Same continuous from safety- essential loads; auto-isolation valves and associated flowpath SW intake piping related isolates non-essential interrupted components flowpaths TS 3.7.8 Condition D One or more Heat sink for 3 SW pumps and non-essential-SW-Six Service Water (SW) system removing 1 SW Ring Header load flowpath(s) pumps, one common ring process and provide heat sink to with one required CCW system and Same header, non-essential flowpath operating heat Yes automatic isolation isolation valves and associated from safety- essential loads; auto-valve inoperable.

SW intake piping related isolates non- essential AND Affected non-components flowpaths essential flowpath(s) not isolated

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 10of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description TS 3.8, Electrical Power Systems TS 3.8.1 Condition A Power One circuit Associated unit Two circuits between the offsite Class 1E between the offsite 345/13.8 kV transmission network via the 4.16 kV transmission network (X03) 345/13.8 kV (X03) safeguards via a 345/13.8 kV transformer transformers and the buses from (X03) transformer inoperable. 13.8/4.16kV (X04) transformers, Yes Same offsite and a 13.8/4.16kV OR and the associated unit's 4.16 transmission (X04) transformer, and Gas turbine not in kV Class 1E safeguards buses networks an associated unit's operation when 4.16 kV Class 1E utilizing opposite safeguards bus unit's 345/13.8 kV (X03) transformer.

Power One circuit Two circuits between the offsite Class 1E between the offsite transmission network via the TS 3.8.1 4.16 kV transmission network 345/13.8 kV (X03)

Condition B safeguards via a 345/13.8 kV transformers and the Associated unit's buses from (X03) transformer 13.8/4.16kV (X04) transformers, Yes Same 13.8/4.16kV (X04) offsite and a 13.8/4.16kV and the associated unit's 4.16 transformer transmission (X04) transformer, and kV Class 1E safeguards buses inoperable networks an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1 Two circuits between the offsite Power One circuit Condition C transmission network via the Class 1E between the offsite Associated unit's 345/13.8 kV (X03) 4.16 kV transmission network required offsite transformers and the safeguards via a 345/13.8 kV power source to 13.8/4.16kV (X04) transformers, buses from (X03) transformer buses A05 and and the associated unit's 4.16 offsite and a 13.8/4.16kV Yes Same A06 inoperable. kV Class 1E safeguards buses transmission (X04) transformer, and OR AND networks and an associated unit's Required offsite Two onsite emergency power on site 4.16 kV Class 1E power source to sources capable of supplying emergency safeguards bus buses 1A05 and the associated unit's 4.16 kV power sources OR 2A06 inooerable Class 1E safequards buses One onsite emerqencv

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 11 of 12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRASuccess Condition Applicable SSCs Comments Function(s) Modeled Criteria Criteria Description power source capable of supplying an associated unit's 4.16 kV Class 1E safeguards bus One circuit Two circuits between the offsite Power between the offsite transmission network via the Class 1E transmission network TS 3.8.1 345/13.8 kV (X03) 4.16 kV via a 345/13.8 kV Condition D transformers and the safeguards (X03) transformer One or more 13.8/4.16kV (X04) transformers, buses from and a 13.8/4.16kV required and the associated unit's 4.16 offsite (X04) transformer, and offsite power kV Class 1E safeguards buses transmission an associated unit's Yes Same source(s) to one or AND networks and 4.16 kV Class 1E more required Two onsite emergency power on site safeguards bus, OR Class 1E 4.16 kV sources capable of supplying emergency One onsite emergency bus( es) the associated unit's 4.16 kV power sources power source capable inoperable Class 1E safeguards buses of supplying an associated unit's 4.16 kV Class 1E safeguards bus TS 3.8.1 One circuit Condition F Power between the offsite Two circuits between the offsite One or more Class 1E transmission network transmission network via the 4.16 kV required via a 345/13.8 kV 345/13.8 kV (X03) offsite power safeguards (X03) transformer transformers and the source to one or buses from and a 13.8/4.16kV 13.8/4.16kV (X04) transformers, more Class 1E offsite (X04) transformer, and and the associated unit's 4.16 4.16 kV transmission Yes an associated unit's Same kV Class 1E safeguards buses safeguards networks and 4.16 kV Class 1 E AND bus(es) inoperable on site safeguards bus Two onsite emergency power AND Standby emergency OR sources capable of supplying emergency power power sources One onsite emergency the associated unit's 4.16 kV inoperable to power source capable Class 1E safeguards buses redundant of supplying an equipment associated unit's 4.16

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 1 Page 12of12 Table E1 List of Revised Required Actions to Corresponding PRA Functions (revised)

Required Action SSC PRA Design Success PRA Success Condition Applicable SSCs Comments Function{s) Modeled Criteria Criteria Description kV Class 1E safeguards bus Supply Two 125 VDC required DC electrical subsystems TS 3.8.4 Four 125 VDC electrical motive and of the same electrical Condition A subsystems each consisting of control power train, each consisting One DC electrical a battery charger backed by a to shut down Yes of a battery charger Same power subsystem station battery powering the the reactor backed by a station inoperable associated DC distribution bus and maintain it battery powering the in a safe associated DC condition distribution bus Supply Two 120VAC Four 120 VAC instrument 120 VAC instrument channels of TS 3.8.7 channels each equipped with a battery-backed the same electrical Condition A 120 VAC instrument inverter power to train, each equipped Yes Same One required powering two 120 VAC various safety- with a 120 VAC inverter inoperable electrical buses related instrument inverter instrument powering two 120 VAC racks electrical buses

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 1 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Source range high FU4 neutron flux Intermediate range high FU3 Uncontrolled Rod Withdrawal Power range high neutron neutron flux 14.1.1 FU2b 2 out of 4 from Subcritical flux (low setting)

Power range high FU2a neutron flux (low setting)

FU1 Manual Trip FU6 Overpower LlT FU2a Power range high neutron 2 out of 4 Pressurizer pressure -

FU7b flux (high setting) High Uncontrolled Rod 14.1.2 Withdrawal at Power FU8 Pressurizer Level - High FU5 Overtemperature LlT 2 out of 4 FU1 Manual Trip FU5 Overtemperature LlT FU6 Overpower LlT Rod Cluster Control 14.1.3 NA No primary Rx trip credited NA Assembly (RCCA) Drop Pressurizer Pressure -

FU7a Low FU1 Manual Trip Chemical and Volume FU2a Power range high neutron 2 out of 4 14.1.4 FU6 Overpower LlT Control System Malfunction flux (high setting)

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 2 of?

Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Source range high FU4 neutron flux (during Assuming at-power FU5 Overtemperature LlT 2 out of 4 startup) dilution with no operator action FU1 Manual Trip Power range high FU2b Startup of an Inactive neutron flux (low setting).

14.1.5 NA No primary Rx trip credited NA Reactor Coolant Loop FU5 Overtemperature LlT Power range high FU2b neutron flux (low setting).

FU5 Overtemperature LlT Reduction in Feedwater 14.1.6 FU2b No primary Rx trip credited NA Enthalpy Incident FU6 Overpower LlT FU1 Manual Trip Power range high FU2a neutron flux (high settino).

FU5 Overtemperature LlT Excessive Load Increase 14.1.7 NA No primary Rx trip credited NA Incident FU6 Overpower LlT Pressurizer Pressure -

FU? a Low

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 3 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

FU1 Manual Trip FU10a RCP breaker position -

FU10b (single loop) (two loops)

Underfrequency Bus RCS Flow - Low 1 out of 2 FU12 FU9a A01, A02 (single loop) (two loops) per loop FU9b Loss of Reactor Coolant 14.1.8 FU5 Overtemperature LlT Flow FU11 Pressurizer pressure -

Undervoltage Bus A01, A02 1 out of 2 FU?b per bus high taken twice FU1 Manual Trip FU8 Pressurizer Level - High Power range high Turbine trip causes Rx FU? a Pressurizer pressure - High 2 out of 3 FU2a neutron flux (high trip above P9 Loss of External Electrical settinQ).

14.1.9 Load Assuming no PORV or SG Water Level - Low, FU5 Overtemperature .6.T 2 out of 4 FU13 Steam dump valve Low release Turbine trip on low oil FU15a pressure

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 4 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Turbine trip on stop valve FU15b closure SG Water Level Low; coincident w/ Steam FU14 Flow I Feed Flow Mismatch Pressurizer pressure -

FU?b high FUS Pressurizer Level - High Turbine trip causes Rx 14.1.10 Loss of Normal Feedwater FU13 SG Water Level - Low, Low 2 out of 3 FU5 Overtemperature ti.T trip above P9 Turbine trip on low oil FU15a pressure Turbine trip on stop valve FU15b closure FU1 Manual Trip SG Water Level Low; Loss of All AC Power to coincident w/ Steam 14.1.11 FU13 SG Water Level - Low, Low 2 out of 3 FU14 Station Auxiliaries Flow I Feed Flow Mismatch

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 5 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Pressurizer pressure -

FU7b high FUS Pressurizer Level - High FU5 Overtemperature Lff Turbine trip on low oil FU15a pressure Turbine trip on stop valve FU15b closure FU9a RCS Flow - Low FU9b (single loop) (two loops)

Undervoltage Bus A01, FU11 A02 Underfrequency Bus FU12 A01, A02 Likelihood ofTurbine-14.1.12 NA Rx trip not credited NA NA Rx trip not credited Generator Unit Overspeed 14.2.1 Fuel Handling Accident NA Rx trip not credited NA NA Rx trip not credited Accidental Release-Recycle 14.2.2 NA Rx trip not credited NA NA Rx trip not credited or Waste Liquid Accidental Release-Waste 14.2.3 NA Rx trip not credited NA NA Rx trip not credited Gas Steam Generator Tube FU? a Pressurizer Pressure - Low 2 out of 3 Safety Injection (SI) Input 14.2.4 FU16 Rupture - from ESFAS

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 6 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

FU5 Overtemperature Lff 2 out of 4 FU1 Manual Trip Power range high FU2a neutron flux (high settinQ).

FU6 Overpower Lff 14.2.5 Rupture of a Steam Pipe FU7a Pressurizer Pressure - Low 2 out of 3 Safety Injection (SI) Input FU16 from ESFAS FU1 Manual Trip FU2a Power range high neutron 2 out of 4 FU6 Overpower Lff Rupture of a Control Rod flux (high setting) 14.2.6 Mechanism Housing -

RCCA Ejection FU2b Power range high neutron 2 out of 4 FU1 Manual Trip flux (low setting)

Inadvertent Opening of a Bounded by 'Rupture of a 14.2.7 NA NA NA NA NA SIG Relief or Safety Valve Steam Pipe' event Safety Injection (SI) Input FU16 from ESFAS Analysis assumes Small Break Loss-of-Coolant 14.3.1 FU7a Pressurizer Pressure - Low 2 out of 3 beyond Charging pump Accident FU5 Overtemperature /::,. T capacity Safety Injection (SI) Input FU16 from ESFAS Large Break Loss-of- FU9a RCS Flow - Low 14.3.2 FU7a Pressurizer Pressure - Low 2 out of 3 Coolant Accident FU9b (single loop) (two loops)

FU1 Manual Trip

Point Beach Nuclear Plant, Units 1 and 2 L-2023-011 Docket Nos. 50-266 and 50-301 Attachment 2 Page 7 of 7 Table E1-3(1) - Information to Support RPS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse Trip Primary Trip Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Core and Internals Integrity See Large Break LOCA 14.3.3 NA NA NA NA NA Analysis event Containment Integrity See Large Break LOCA 14.3.4 NA NA NA NA NA Evaluation event Radiological Consequences See Large Break LOCA 14.3.5 NA NA NA NA NA of Loss-of-Coolant Accident event Reactor Vessel Head Drop 14.3.6 NA NA NA NA NA Rx trip not credited Event

(*)Functional Unit (FU)# from Point Beach TS Table 3.3.1-1

Point Beach Nuclear Plant, Units 1 and 2 L-2023-003 Docket Nos. 50-266 and 50-301 Attachment 3 Page 1 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

FSAR FSAR described Functional Channels Functional Diverse ESFAS Primary ESFAS Function Comments Section transient/accident Unit (FU)* to Trip Unit (FU)* Function(s)

Uncontrolled Rod Withdrawal 14.1.1 NA NA NA NA NA No credited ESF actuation from Subcritical Uncontrolled Rod 14.1.2 NA NA NA NA NA No credited ESF actuation Withdrawal at Power Rod Cluster Control 14.1.3 NA NA NA NA NA No credited ESF actuation Assembly (RCCA) Drop Chemical and Volume 14.1.4 NA NA NA NA NA No credited ESF actuation Control System Malfunction Startup of an Inactive 14.1.5 NA NA NA NA NA No credited ESF actuation Reactor Coolant Loop Reduction in Feedwater 14.1.6 NA NA NA NA NA No credited ESF actuation Enthalpy Incident Excessive Load Increase 14.1.7 NA NA NA NA NA No credited ESF actuation Incident Loss of Reactor Coolant 14.1.8 NA NA NA NA NA No credited ESF actuation Flow Loss of External Electrical 14.1.9 NA NA NA NA NA No credited ESF actuation Load AFW on Undervoltage Bus FU6d A01 and A02 FU6c AFW on Safety Injection (SI)

AFW on SG Water Level -

14.1.10 Loss of Normal Feedwater FU6b 2-out-of-3 Low, Low FU1a AFW on Manual SI NA AFWonAMSAC

Point Beach Nuclear Plant, Units 1 and 2 L-2023-003 Docket Nos. 50-266 and 50-301 Attachment 3 Page 2 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

AFW on Undervoltage Bus FU6d A01 and A02 Loss of All AC Power to AFW on SG Water Level -

14.1.11 FU6b 2-out-of-3 FU6c AFW on Safety Injection (SI)

Station Auxiliaries Low, Low FU1a AFW on Manual SI Likelihood ofTurbine-14.1.12 NA NA NA NA NA No credited ESF actuation Generator Unit Overspeed 14.2.1 Fuel Handling Accident NA NA NA NA NA No credited ESF actuation Accidental Release-Recycle 14.2.2 NA NA NA NA NA No credited ESF actuation or Waste Liquid Accidental Release-Waste 14.2.3 NA NA NA NA NA No credited ESF actuation Gas Steam Generator Tube SI on Pressurizer Pressure -

14.2.4 FU1d 2-out-of-3 FU1a Manual SI Rupture Low SU on SG Flow - High, FU4d coincident with SI and Low Tavq SU on Containment FU4c Pressure - High, High Steam Line Isolation (SU)

FU4e on SG Flow - High, High, 1-out-of-2 FU6c AFW on Safety Injection (SI) coincident with SI 14.2.5 Rupture of a Steam Pipe FU1e SI on SG Pressure - Low SI on Pressurizer Pressure -

2-out-of-3 FU1d Low FU6b AFW on SG Level - Low, 2-out-of-3 SI on Containment Pressure Low FU1c

-High, High FU1a Manual SI

Point Beach Nuclear Plant, Units 1 and 2 L-2023-003 Docket Nos. 50-266 and 50-301 Attachment 3 Page 3 of 3 Table E1-3(2), Information to Support ESFAS Instrumentation Redundancy and Diversity (revised)

FU4a Manual SU Rupture of a Control Rod 14.2.6 Mechanism Housing - NA NA NA NA NA No credited ESF actuation RCCA Ejection Inadvertent Opening of a Bounded by 'Rupture of 14.2.7 NA NA NA NA NA SIG Relief or Safety Valve Steam Pipe' Event SI on Containment Pressure FU1c SI on Pressurizer Pressure - High Small Break Loss-of-Coolant Analysis assumes beyond 14.3.1 FU1d 2-out-of-3 Accident -Low Charging pump capacity FU1a Manual SI SI on Containment Pressure FU1c

- High FU1d SI on Pressurizer Pressure 2-out-of-3 Large Break Loss-of- -Low 14.3.2 FU1a Manual SI Coolant Accident FU2c CS on Containment 2-out-of-Pressure - High, High 3** FU 2a Manual CS Core and Internals Integrity See Large Break LOCA 14.3.3 NA NA NA NA NA Analysis event Containment Integrity CS on Containment See Large Break LOCA 14.3.4 FU4c NA NA NA Evaluation Pressure - High, High event Radiological Consequences CS on Containment See Large Break LOCA 14.3.5 FU4c NA NA NA of Loss-of-Coolant Accident Pressure - High, High event Reactor Vessel Head Drop 14.3.6 NA NA NA NA NA No credited ESF actuation Event

(*) Functional Unit (FU)# from Point Beach TS Table 3.3.2-1

(**) 2 out of 3 taken twice; RICT not requested