NOC-AE-08002255, Transmittal of Proposed Amendment to Technical Specification 3.8.3.1

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Transmittal of Proposed Amendment to Technical Specification 3.8.3.1
ML080740226
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 03/06/2008
From: Bowman C
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002255, STI: 32250229
Download: ML080740226 (28)
v • d • e


Text

Nuclear Operating Company South Texas ProlectElectric Generating Station Po.Box 28.9 Wadsworth. Texas 77483 March 6, 2008 NOC-AE-08002255 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed Amendment to Technical Specification 3.8.3.1 In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) is submitting a request for an amendment to the South Texas Project Operating Licenses NPF-76 and NPF-80 to revise the required action and completion time for specific inverters governed by Technical Specification (TS) 3.8.3.1.

STP TS 3.8.3.1 allows the application of the Configuration Risk Management Program (CRMP) associated with Risk Managed Technical Specifications (RMTS) to the inverters with loads modeled in the STP Probabilistic Risk Analysis (PRA). However, the loads on the inverters and associated Distribution Panels DPOO1 and DP002 are of low risk significance and not modeled in the PRA. NEI 06-09,."Risk Managed Technical Specifications Guidelines" which is the basis for the STP RMTS does not allow the application of RMTS to components that are not modeled in the PRA where a risk-informed completion time cannot be calculated. Consequently, STPNOC may not apply RMTS to the inverters associated with DPOO1 and DP002. The proposed amendment will separate the requirements for DPOO1 and DP002 and provide these distribution panels with specified completion times consistent with the functions powered from the distribution panels.

The Enclosure provides a technical'and regulatory evaluation of the changes. Proposed TS page markups are included as attachments to the Enclosure.

STPNOC requests approval by March 6, 2009 and requests 60 days for implementation.

STI: 32250229 S A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ao(

Callaway - Comanche Peak - Diablo Canyon - Palo Verde - South Texas Project - Wolf Creek

NOC-AE-08002255 Page 2 of 3 In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

The STPNOC Plant Operations Review Committee has reviewed and concurred with the proposed change to the Technical Specifications.

If there are any questions regarding the proposed amendment, please contact Mr. Wayne Harrison at (361) 972-7298 or me at (361) 972-7454.

There are no commitments in this submittal.

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

Executed on ilarre, (0, Z0 .

Date Charles T. Bowman General Manager, Oversight awh/

Enclosure:

Evaluation of the Proposed Change

NOC-AE-08002255 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Thad Hill Senior Project Manager Eddy Daniels U.S. Nuclear Regulatory Commission Catherine Callaway One White Flint North (MS 7 D1) Brad Porlier 11555 Rockville Pike Steve Winn Rockville, MD 20852 Staney Rostad NRG South Texas LP Senior Resident Inspector Ed Alarcon U. S. Nuclear Regulatory Commission J. J. Nesrsta P. O. Box 289, Mail Code: MNl16 R. K. Temple Wadsworth, TX 77483 Kevin Pollo City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189

NOC-AE-08002255 Enclosure Page 1 of 15 ENCLOSURE Evaluation of the Proposed Change

Subject:

Proposed Amendment to Technical Specification 3.8.3.1 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification Page Markups
2. Technical Specification Bases Page Markups
3. Vital AC Distribution Panel Diagrams

NOC-AE-08002255 Enclosure Page 2 of 15 ENCLOSURE 1.0

SUMMARY

DESCRIPTION The proposed amendment will incorporate a change to Technical Specification (TS) 3.8.3.1, "Onsite Power Distribution" to create separate requirements without the option to apply the Configuration Risk Management Program (CRMP) for the Train A and Train C inverters that",

power distribution panels DPOO1 and DP002, which do not have loads modeled in the PRA. The new actions will allow specific times to re-energize the distribution panels. The proposed new times are longer than the current TS because of the low safety significance of the loads on DPOO1 and DP002.

In accordance with NEI 06-09, RMTS may be applied to the other inverters covered by Technical Specification 3.8.3.1 because the PRA models loads on the inverters and can quantify their contribution to a risk-informed completion time (RICT). The loads on DP001 and DP002 are of low risk significance and are not modeled. Consequently, they have no quantified contribution to core damage frequency (CDF) or large early release frequency (LERF). This evaluation justifies the proposed changes to the requirements for DPOO1 and DP002.

2.0 DETAILED DESCRIPTION STP TS ACTION 3.8.3.1 .c and 3.8.3.1 .d currently apply to all the distribution panels and read as shown below.

c. With one A.C. vital distribution panel either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reenergize the A.C. distribution panel or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With more than one A.C. vital distribution panel either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

NOC-AE-08002255 Enclosure Page 3 of 15 STPNOC proposes to revise TS 3.8.3.1 ACTION c ACTION d to be specific to DP1201 from LCO 3.8.3.1.d, DP1202 from LCO 3.8.3.1.e, DP1203 from LCO 3.8.3.1.f, and DP1204 from LCO 3.8.3.1 .g such that the actions for these DPs will be unchanged and retain the option of applying the CRMP.

c. With one of the A.C. vital distribution panels DP1201, DP1202, DP1203, or DP 1204 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reenergize the A.C. distribution panel or apply the requirements of the CRMP, or be in at least HOT'STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With more than one of the A.C. vital distribution panels DP1201, DP1202, DP 1203, or DP 1204 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least three of these 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least three of these A.C. vital distribution panels from their associated inverter connected to their associatedD.C. bus or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

STPNOC proposes to add two new actions for DPOO1 and DP002 that do not include the option to apply the CRMP, but which revise the completion time based on the low safety significance of the loads on these distribution panels.

e. With one of the A.C. vital distribution panels DP001 or DP002 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 7 days reenergize the A.C. distribution panel, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 30 days reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
f. - With more than one of the A.C. vital distribution panels DP001 or DP002 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least one of these A.C. distribution panels, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 7 days reenergize at least one of these A.C. vital distribution panels from their associated inverter connected to their associated D.C. bus, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Current TS ACTIONs e and f will become ACTIONs g and h, respectively, as an administrative change to accommodate the new actions.

NOC-AE-08002255' Enclosure Page 4 of 15

3.0 TECHNICAL EVALUATION

Class 1E Vital 120-vac System Design AC control power for vital instrumentation and controls is supplied by six solid-state inverter/rectifier systems (per Unit) and six 480V Voltage Regulating Transformers as bypass sources connected as shown on Attachment 3 to this Enclosure. Distribution Panels DP1201 through DP 1204 supply power to vital 120-vac Channel I through IV engineered safety feature (ESF) loads, respectively. Distribution Panels DP001 and DP002 supply 120-vac power to post-accident monitoring instrumentation. The inverter/rectifiers with auto transfer capabilities and bypass source transformers supplying power to instrumentation channels I and II are normally energized by 480-vac feeders from separate motor control centers (MCCs) of ESF Train A. The inverter/rectifiers with auto transfer capabilities and bypass source transformers supplying power to channels III and IV are normally energized by 480-vac feeders from MCCs connected to the 480-vac switchgear in Trains B and C, respectively. Upon loss of power from the 480-vac feeds, the inverter/rectifiers are automatically powered from their associated Class 1E DC system.

Upon total loss an Inverter/Rectifier, the power to DP1201 thru 1204 is automatically transferred

("make before break") to the bypass source through the inverter's transfer switch. Single-phase, vital AC power from the inverter/rectifier is distributed by the instrumentation power supply busses consisting of six Class 1E vital 120-vac distribution panels.

Each inverter/rectifier assembly has two power supplies and a bypass source transformer. The normal power supply is 480-vac fed directly from an ESF power train MCC and the backup power supply is 125-vdc from one of four busses in the Class IE DC distribution system.

Normally, both power supplies to the inverter are available, with the 480-vac line supplying rectified AC power to operate the inverter. Rectified AC input voltage is slightly higher than the DC battery feed and a diode in the positive side of the battery feed is prevented from conducting while normal rectified AC power is present. When 480-vac input to the rectifier is lost, the blocking voltage on the diode is lost and the battery instantly feeds power to the inverter. Each bypass source transformer is also powered from 480-vac fed directly from an ESF power train MCC.

Each Class 1E vital 120-vac inverter has its own dedicated voltage regulating transformer (VRT) as its alternate source. The standby diesel generator (SDG) associated with the train provides emergency power to the VRT. Manually operated, mechanically interlocked main circuit breakers allowing "break before make" action in distribution panels DPOO1 and DP002 permit energization of the bus either by the corresponding inverter/rectifier or by an alternate single-phase VRT.

The inverters for distribution panels DP 1201 through DP 1204 in both units Were recently replaced. As part of the inverter replacement, design changes were implemented which transferred Qualified Display Parameter System (QDPS) and Steam Generator Power Operated Relief Valve (SG PORV) loads from distribution panels DPOOl and DP002 to DP1201 and DP 1204, respectively.

NOC-AE-08002255 Enclosure Page 5 of 15 Subsequently, PRA model STPREV5 removed DPOO1, DP002 and their associated inverters from the model, in accordance with PRA update procedures, since they no longer support any modeled PRA functions. The unmodeled, non-RMTS TS functions powered from the DPs are of low risk significance as described in the table below. The functions powered from DPOO 1 and DP002 are the same for both DPs, but each DP powers different channels. The table lists the functions powered from the DP with the applicable TS for the function, the effect for the condition where-one of the DPs is not energized (i.e., during the 2-hour required action time of TS 3.8.3.1 .c), and the effect when the DP is energized, but not from its inverter (prior to expiration of the 24-hour required action time of TS 3.8.3.1 .c).

'Affected Functio*in ,-'< Failure Mode'andRiskAssessment

.Function-specific TS(s) DP not eneirgized DP:energized from alternate Action and Completion Time .RT) source(

Ml~ost limniting'TS for ALLI, Schannels'de-energized (both

~DPs).

One channel of Reactor Coolant 1 of 2 subcooling channels TS 3.3.3.6 function is restored to System (RCS) Subcooling failed. The monitors perform operable status. VRT is IE power Monitor no actuation function. The with emergency power from SDG.

TS 3.3.3.6 T subcooling monitor functions If not energized from inverter, o Restore in 7 days or perform a post-accident accident with LOOP and failure of shutdown' function that is not credited in the SDG will result in loss of the the PRA for the mitigation of channel since it will not be battery With both channels inoperable, any events. There is no backed. This combination of restore at least one channel in 48 quantifiable effect on CDF or initiating event and subsequent hours or shutdown 2 LERF. There is no transient or failures is a very low frequency operational impact. event. In addition the redundant channel would be available and there are other functionally redundant accident monitoring functions.

One channel of Reactor Vessel 1 of 2 RVWL channels failed. TS 3.3.3.6 function is restored to Water Level (RVWL) The monitors perform no operable status. VRT is 1E power

  • TS 3.3.3.6 actuation function and the PRA with emergency power from SDG.

o Restore in 7 days or does not credit the RVWL If not energized from inverter, submit Special indication for mitigation of any accident with LOOP and failure of Report 1 events. There is no quantifiable the SDG will result in loss of the effect on CDF or LERF. There channel since it will not be battery With both channels inoperable, is no transient or operational backed. This combination of restore within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or impact. initiating event and subsequent initiate alternate method of failures is a very low frequency monitoring and submit a Special event. In addition the redundant Report. 2 channel would be available and there are other functionally redundant accident monitoring functions.

NOC-AE-08002255 Enclosure Page 6 of 15 Affected.Function .. Failure Mode and Risk Assessment ..

" Function-specific TS(s) DP not energized DP energized from l"ternate

", Action and Completion Time source (VRT)~

  • .Most limiting'T$for ALL chann*lsde-energized (both -

DPs) ,

One channel of Extended Range One channel inoperable. There TS 3.3.3.6 function is restored to Neutron Flux is no transient or operational operable status. VRT is 1E power

" TS 3.3.3.6 impact. Extended range with emergency power from SDG.

o Restore in 7 days or neutron flux has no actuation If not energized from inverter, shutdown *functionsand is not modeled in accident with LOOP and failure of

  • TS 3.3.3.5 the PRA. There is no the SDG will result in loss of the o Restore in 30 days or quantifiable effect on CDF or channel since it will not be battery shutdown LERF. backed. This combination of
  • TS 3.3.1 (MODE 3 & 4) initiating event and subsequent o Suspend positive failures is a very low frequency reactivity changes event. In addition the redundant channel would be available and With both channels of the . there are other functionally function inoperable, restore in 48 redundant accident monitoring hours or shutdown (TS 3.3.3.6) 2 functions.

Two of the four channels of Affected channels of TS 3.3.3.6 function is restored to Steam Generator (SG) Blowdown Radiation Monitors operable status. VRT is 1E power Blowdown Radiation Monitors fail. The monitors perform no with emergency power from SDG.

  • TS 3.3.3.6 actuation function and are not If not energized from inverter, tube o With one channel modeled in the PRA. There is rupture with LOOP and failure of inoperable, restore in no quantifiable effect on CDF the SDG will result in loss of the 30 days or submit or LERF. There is no transient channel since it will not be battery Special Report or operational impact. backed. This combination of initiating event and subsequent failures is a very low frequency With more than one channel of event. In addition the redundant the function inoperable, restore channel would be available and within 7 days or submit a Special there are other functionally Report. redundant monitoring functions that can be used to identify the ruptured steam generator.

NOC-AE-08002255 Enclosure Page 7 of 15 Affected Function

  • Failure Mode and Risk Assessment
  • Function-specific TS(s) not energized 9DP energized from alternate
  • *Action and Completion Time source (VRT)
  • Most limiting TS for ALL
channels de-energized (both

~DPs)1 + _-

Two of the four channels of SG Affected SG Main Steam TS 3.3.3.6 function is restored to Main Steam Radiation Monitor Radiation Monitors fail. There operable status. VRT is lE power

o With one channel impact. The monitors perform If not energized from inverter, tube inoperable, restore in no actuation function and are rupture with LOOP and failure of 30 days or submit not modeled in the PRA. There the SDG will result in loss of the Special Report is no quantifiable effect on CDF channel since it will not be battery or LERF. backed. This combination of initiating event and subsequent With more than one channel of failures is a very low frequency the function inoperable, restore event. In addition the redundant within 7 days or submit a Special channel would be available and Report. there are other functionally redundant monitoring functions that can be used to identify the ruptured steam generator.

One channel of RCB High Range RCB High Range Area TS 3.3.3.6 function is restored to Area Radiation Radiation Monitor fails. The operable status. VRT is 1E power

  • TS 3.3.3.6 monitor performs no actuation with emergency power from SDG.

o Restore within 30 function and there is no If not energized from inverter, days or submit a transient or operational impact. accident with LOOP and failure of Special Report The function does not affect the SDG will result in loss of the CDF or LERF and is not channel since it will not be battery modeled in the PRA. backed. This combination of With both channels of the initiating event and subsequent function inoperable, restore failures is a very low frequency within 7 days or submit a Special event. In addition the redundant Report. channel would be available and there are other functionally redundant accident monitoring functions.

NOC-AE-08002255 Enclosure Page 8 of 15

'Affected Function Failure Mode and Risk Assessment

  • Function-specific TS(s) DP not energized DP energized from alternate

" Action and Completion Time ~ < source (VRT)

"*Mostlimiting TS for ALL ~

channels de-energized (both One channel of Reactor Affected RCB Purge Radiation TS 3.3.2 function is restored to Containment Building (RCB) Monitor fails. Containment operable status. VRT is 1E power Purge Radiation Monitors Ventilation Isolation (CVI) will with emergency power from SDG.

  • 3.3.2 not actuate on high radiation If not energized from inverter, o Restore in 30 days or from affected monitor. PRA accident with LOOP and failure of maintain purge credits isolation from SI signal, the SDG will result in loss of the valves closed, not from radiation monitor. channel since it will not be battery There is no quantifiable effect backed. This combination of With both channels of the on CDF or LERF. initiating event and subsequent function inoperable, maintain the failures is a very low frequency purge valves closed, event. In addition the redundant channel would be available and the CVI function will also be initiated separately from the SI signal or manually.

One channel of Containment CVI trains actuate to the closed TS 3.3.2 function is restored to Ventilation Isolation radiation (safe) position on high radiation operable status. VRT is 1E power monitor control due to loss of power (i.e., purge with emergency power from SDG.

  • 3.3.2 valves get close signal). There If not energized from inverter, o Restore in 30 days or is no risk significance to the accident with LOOP and failure of maintain purge valves going to their safety the SDG will result in loss of the valves closed, position. The valves are channel since it will not be battery normally closed so there is no backed. This combination of With both channels of the transient operational impact. initiating event and subsequent function inoperable, maintain the failures is a very low frequency

,purge valves closed, event. In addition, loss of power causes the channel to actuate to its safe position so the battery backup is not significant.

NOC-AE-08002255 Enclosure Page 9 of 15 Affected Function Failure Mode and RiskAssessment

" Function-specific TS(s) DP not energized DP energi'z"ed from alternate

" Action and Completion Time source (VRT)

  • Mostlimiting TS for ALL~

channels de-energized (both DPs),,.

One channel of CRE HVAC CRE HVAC Radiation Monitor TS 3.3.2 function is restored to Radiation Monitor channel fails and is unavailable operable status. VRT is 1E power

o Place system in If not energized from inverter, filtered make-up and TS 3.3.2 action places the accident with LOOP and failure of

.recirculation within system in a safe configuration. the SDG will result in loss of the 7 days or shutdown channel since it will not be battery backed. This combination of With both channels of the initiating event and subsequent function inoperable, within 1 failures is a very low frequency hour place system in filtered event. In addition the redundant make-up and recirculation or channel would be available and suspend movement of irradiated control room can manually align fuel assemblies, crane operations the system.

over the spent fuel pool, etc.

One channel of CRE HVAC CRE HVAC trains actuate on TS 3.3.2 function is restored to radiation monitor control high radiation due to loss of operable status. VRT is 1E power

  • TS 3.3.2 power. Actuation of the trains with emergency power from SDG.

o Place system in to the recirculation and filtered If not energized from inverter, filtered make-up and make-up mode is a safe mode accident with LOOP and failure of.

recirculation within of operation to minimize the SDG will result in loss of the 7 days or shutdown accident dose to the operators. channel since it will not be battery backed. This combination of CRE HVAC trains should initiating event and subsequent actuate to meet the TS action failures is a very low frequency requirement described above, event. In addition, the system actuates to its safety configuration on a loss of power so the battery backup is not significant.

NOC-AE-08002255 Enclosure Page 10 of 15

.. Affected Function ode' and Risk Akssessment

  • Fuiinction-specific TS(s) J DP energizedi from alternate

" Action and Completion Time source (VRT)

" Most limiting TS for ALL channels de-energized (both DPs)

One channel of FHB HVAC Affected FHB HVAC Radiation TS 3.3.2 function is restored to Radiation Monitor Monitor fails; FHB HVAC will operable status. VRT is 1E power

  • TS 3.3.2 not actuate on High Radiation with emergency power from SDG.

o Fuel movement from affected monitor. FHB If not energized from inverter, within the spent fuel radiation monitors have no accident with LOOP and failure of pool or crane potential to affect CDF or the SDG will result in loss of the operation with loads LERF and are not modeled in channel since it will not be battery over the spent fuel the PRA. backed. This combination of pool may proceed initiating event and subsequent provided the FHB TS 3.3.2 action places the failures is a very low frequency exhaust air filtration system in a safe configuration. event. In addition the redundant system is in channel would be available and operation and control room can manually align discharging through the system.

at least one train of HEPA filters and charcoal adsorbers.

With both channels of the function inoperable, the same action applies.

One channel of FHB HVAC FHB HVAC trains actuate on TS 3.7.8 function is restored to radiation monitor control high radiation due to loss of operable status. VRT is 1E power

  • TS 3.3.2 power. Actuation of filtration with emergency power from SDG.

o Same action as train is the safety function and If not energized from inverter, above has no potential as an accident accident with LOOP and failure of initiator. The function has no the SDG will result in loss of the effect on CDF or LERF and is channel since it will not be battery With both channels of the not modeled in the PRA. backed. This combination of function inoperable, the same initiating event and subsequent action applies. failures is a very low frequency event. In addition, the system actuates to its safety configuration on a loss of power so the battery backup is not siznificant.

NOC-AE-08002255 Enclosure Page 11 of 15 Affected Function Failure Mode and Risk Assessment

4. Function-specific TS(s) DP not energized DP energizedfrom alternate

" Action and Completion Time , sourced (ro alTer-a

" Most limiting TS for ALL c~hannels de-energized (both One train of Component Cooling Non-safety portions of the TS 3.7.3 function is restored to Water (CCW) Surge Tank Level affected CCW train do not operable status. VRT is IE power TS 3.7.3 T isolate on Surge Tank low with emergency power from SDG.

o Restore in 7.days or level. There is no transient or If not energized from inverter, apply CRMP operational impact. The PRA accident with LOOP, CCW leak, does not credit isolation of non- and failure of the SDG will result safety CCW for mitigation of in loss of the channel since it will With two trains of the function any events, not be battery backed. This inoperable, restore in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or combination of initiating event and apply the CRMP. subsequent failures is a very low frequency event and does not necessarily lead to complete loss of the CCW train. There is no effect on CDF or LERF.

One train of Control Room Control Room Outside Air TS 3.7.7 function is restored to Envelope HVAC (CREHVAC) Makeup Flow damper fails operable status. VRT is 1E power Makeup Flow Control closed. with emergency power from SDG.

--. TS 3.7.7 If not energized from inverter, o Restore within 7 accident with LOOP and failure of days or shutdown the SDG will result in loss of the channel since it will not be battery With two trains of the function backed. This combination of inoperable, restore within 72 initiating event and subsequent hours or shutdown. failures is a very low frequency event. In addition the redundant channel would be available.

One train of Fuel Handling FHB Exhaust Filter Flow TS 3.7.8 function is restored to Building (FHB) Exhaust Filter damper fails closed. FHB operable status. VRT is 1E power Flow Control ventilation is not modeled in the with emergency power from SDG.

  • TS 3.7.8 PRA because it has no effect on If not energized from inverter, o Restore within 7 CDF or LERF. accident with LOOP and failure of days or shutdown the SDG will result in loss of the filtration flow control damper for the train since control will not be With two trains of the function battery backed. This combination inoperable, restore at least one of initiating event and subsequent train within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or failures is a very low frequency shutdown. event. In addition the redundant filter train would be available.

FHB exhaust has no effect on CDF or LERF.

NOC-AE-08002255 Enclosure Page 12 of 15 Affected Function . Failure Mode and Risk Assessment...

Function-specific TS(s) DP not energized DP energized from alternate

'ý.Action and Completion Time source (VRT) channels de-'energized (bioth:

One channel of Containment Affected Containment Function is restored. VRT is 1E Hydrogen Monitoring Hydrogen Monitor fails. There power with emergency power from No TS is no quantifiable effect on CDF SDG. Hydrogen monitoring has or LERF. no effect on CDF or LERF.

Notes to Table:

1. 30-day action with requirement for Special Report, consistent with NUREG-1431, is planned for a separate license amendment request.
2. 7-day shutdown, consistent with NUREG-1431, is planned for a separate license amendment request Section 3.2.2 of NEI 06-09, "Risk Managed Technical Specifications Guidelines", states, "The risk informed assessment scope of SSCs included in a plant CRM program generally includes the following:
1. Those SSCs included in the scope of the plant's Level 1 and LERF (or Level 2 if available), internal (and, if available, external) events PRA, and;
2. Those SSCs not explicitly modeled in the PRA but whose functions can be directly correlated, with appropriate documentation, to those in 1 above (e.g., actuation instrumentation for PRA modeled function)."

Subsequent to the design change described earlier, there are no functions remaining on the subject DPs that have a direct relation to a function modeled in the PRA.

Based on the requirements in TS 6.8.3.k, "Configuration Risk Management Program", and NEI 06-09, STPNOC determined that the provision for the application of the CRMP to TS 3.8.3.1 ACTION c and d could not be applied for DP001 and DP002. The TS Bases include this restriction. Only DPOO1 and DP002 are affected by the proposed change. The STP PRA incorporates the other distribution panels and associated inverters such that a RICT can be determined in accordance with TS 6.8.3.k and NEI 06-09.

The preceding table clearly illustrates from both a deterministic and risk perspective the low safety significance of the functions powered from the affected DPs. Application of the existing TS 3.8.3.1 requirements without the provision to apply the CRMP is not commensurate with the safety significance of the equipment powered from the DPs. The TS actions are unnecessarily restrictive.

STPNOC proposes to resolve the condition creating the separate actions previously described to apply to DPOO1 and DP002 and to revise the time required to energize the panels from their associated inverter connected to its associated DC bus to 30 days.

NOC-AE-08002255 Enclosure Page 13 of 15 The 7 days proposed in ACTION e for re-energizing the DP is consistent with the required completion times for the functions powered from the DP. Because of the low risk-significance of the affected functions, the availability of the redundant channel, the fact that when energized from the VRT, the functions are still powered from a diesel-backed 1E source, and the low likelihood of an initiating event and subsequent equipment failures, the 30 day completion time for energizing the DP from its associated inverter connected to its associated DC bus is acceptable for proposed ACTION e for one inoperable DP.

Proposed ACTION f for two inoperable DPs requires at least one of the DPs to be energized within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This completion time is unchanged from the current TS requirement and is consistent with the most restrictive completion time for the functions powered from the DPs.

ACTION f requires at least one DP to be powered from its associated inverter connected to its associated DC bus within 7 days.. The required completion time is acceptable because it is based on the completion times for loss of function for the functions powered from the DPs, the low safety significance of the functions, and the low likelihood of an event that would require the functions. Additionally, it is conservative because the functions are operable when powered from the VRT.

Based on the evaluation above, STPNOC has determined that the proposed change involves no significant change to risk and will result in completion times that are commensurate with the safety significance of the plant configuration.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following criteria generally apply to the functions powered from the subject inverters.

General Design Criteria (GDC) 13, "Instrumentation and Control," of 10 CFR 50, Appendix A, includes a requirement that instrumentation be provided to monitor variables and systems over their anticipated ranges for accident conditions as appropriate to ensure adequate safety.

GDC 19, "Control Room," of 10 CFR 50, Appendix A, includes a requirement that a control room be provided from which actions can be taken to maintain the nuclear power unit in a safe condition under accident conditions, including loss-of-coolant accidents, and that equipment, including the necessary instrumentation, at appropriate locations outside the control room be provided with a design capability for prompt hot shutdown of the reactor.

GDC 64, "Monitoring Radioactivity Releases," of 10 CFR 50, Appendix A, includes a requirement that means be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant fluid, effluent discharge paths, and plant environs for radioactivity that may be released from postulated accidents.

Regulatory Guide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 2, describes a method acceptable to the NRC staff for complying with the Commission's regulations to

NOC-AE-08002255 Enclosure Page 14 of 15 provide instrumentation to monitor plant variables and systems during and following an accident in a light-water-cooled nuclear power plant.

The referenced requirements of GDC 13, GDC 19, GDC 64, and the guidance of RG 1.97 continue to be met because the proposed changes do not delete or add any post-accident monitoring variables to the Technical Specifications, do not revise the number of instrumentation channels required for any variable, and do not revise the instrumentation ranges for any of the post-accident monitoring variables included in the Technical Specifications.

RG 1.174, "An Approach For Using Probabilistic Risk Assessment In Risk-Informed Decisions On Plant-Specific Changes To The Licensing Basis" and RG 1.177, "An Approach For Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications", describe acceptance criteria for risk-informed changes. Although risk is qualitatively assessed in the technical evaluation, this is not proposed as a risk-informed change in accordance with RG 1.174 or RG 1.177. The DPOO1/DPOO2 functions do not affect CDF or LERF and are therefore not modeled in the PRA.

4.2 Significant Hazards Consideration STP has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response

No. The proposed change does not involve the modification of any plant equipment or affect basic plant operation. The proposed change will have no impact on the design or function of any safety related structures, systems or components.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response

No. The proposed change does not involve any physical alteration of plant equipment and does not change the method by which any safety-related structure, system, or component performs its function or is tested. As such, no new or different types of equipment will be installed, and the basic operation of installed equipment is unchanged.

The methods governing plant operation and testing remain consistent with current safety analysis assumptions.

NOC-AE-08002255 Enclosure Page 15 of 15 Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response

No. The proposed change does not negate any existing requirement, and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or safety system settings that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

4.3 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c) (9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement, or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NEI 06-09 Rev. 0, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"

NOC-AE-08002255 Enclosure, Att. 1 ENCLOSURE, ATTACHMENT 1 Technical Specification Page Markups

ELECTRICAL POWER SYSTEMS For information - no changes on this page 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 ESF Bus # ElA (Unit 1), E2A (Unit 2), and
2) 480-Volt ESF Busses # ElA1 and E1A2 (Unit 1), E2A1 and E2A2 (Unit 2) from respective load center transformers.
b. Train B A.C. ESF Busses consisting of:
1) 4160-Volt ESF Bus # El B (Unit 1), E2B (Unit 2), and
2) 480-Volt ESF Busses # El B1 and El B2 (Unit 1), E2B1 and E2B2 (Unit 2) from respective load center transformers.
c. Train C A.C. ESF Busses consisting of:
1) 4160-'Volt ESF Bus # ElC (Unit 1), E2C (Unit 2), and
2) 480-Volt ESF Busses # El C1 and El C2 (Unit 1), E2C1 and E2C2 (Unit 2) from respective load center transformers.
d. 120-Volt A.C. Vital Distribution Panels DP1201 and DP001 energized from their associated inverters connected to D.C. Bus # ElAl 1* (Unit 1), E2AI 1* (Unit 2),.
e. 120-Volt A.C. Vital Distribution Panel DP1202 energized from its associated inverter connected to D.C. Bus # El D11 * (Unit 1), E2D1 1* (Unit 2),

.f. 120-Volt A.C. Vital Distribution Panel DP1 203 energized from its associated inverter connected to D.C. Bus # E1B11* (Unit 1), E2B11* (Unit 2),

g. 120-Volt A. C. Vital Distribution Panels DP1204 and DP002 energized from their associated inverters connectedto D. C. Bus # El C11 * (Unit 1), E2Cl 1* (Unit 2),
h. 125-Volt D. C. Bus ElAl 1 (Unit 1) E2A1 1 (Unit 2) energized from Battery Bank E1Al 1 (Unit 1), E2A1 1 (Unit 2),
i. 125-Volt D. C. Bus El D1 1 (Unit 1) E2D1 1 (Unit 2) energized from Battery Bank EI.D11 (Unit 1), E2D11 (Unit 2),
j. 125-Volt D. C. Bus El B1 1 (Unit 1) E2B1 1 (Unit 2) energized from Battery Bank El B1 1 (Unit 1), E2B1 1 (Unit 2), and
k. 125-Volt D. C. Bus El C11 (Unit 1) E2C1 1 (Unit 2) energized from Battery Bank EIC1l (Unit 1), E2C1l (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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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

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, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> reenergize the train or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With more than one of the required trains of A.C. ESF busses not fully energized, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least two trains or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With one of the A.C. vital distribution panels DP1 201, DP1 202, DP1 203, or DP1 204 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reenergize the A.C. distribution panel or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With more than one of the A.C. vital distribution panels DP1201, DP1 202, DP1203, or DP1 204 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least
  • three of these 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least gPýthree of these A.C. vital distribution panels from their associated inverter connected to their associated D.C. bus or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
e. With one of the A.C. vital distribution panels DP001 or DP002 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 7 days reenergize the A.C.

distribution panel, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 30 days reenergize the A.C. vital distribution panel from its associated inverter connected to its associated D.C. bus, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

f. With more than one of the A.C. vital distribution panels DP001 or DP002 either not energized from its associated inverter, or with the inverter not connected to its associated D.C. bus: (1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least one of these A.C. distribution panels, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; and (2) within 7 days reenergize at least one of these A.C. vital distribution panels from their associated inverter connected to their associated D.C.

bus, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

eg. With one D.C. bus not energized from its associated battery bank, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reenergize the D.C. bus from its associated battery bank or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

fg. With more than one D.C. bus not energized from its associated battery bank, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reenergize at least three D.C. buses from their associated battery banks or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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.

NOC-AE-08002255 Enclosure, Att. 2 ENCLOSURE, ATTACHMENT 2 Technical Specification Bases Page Markups

NOC-AE-08002255 Enclosure, Att. 2 Page 1 of 1 Information Only 3.8.3.1 ACTIONs c and d of TS 3.8.3.1 allow the option of calculating risk-informed completion time (RICT) for DP1 201, DP1202, DP1203, DP1204 in accordance with the requirements of the CRMP. This option may not be applied for DP001 or DP002 because none of the functions on these distribution panels are modeled in the PRA. TS 3.8.3.1 establishes separate ACTIONs e and f for these distribution panels that provides 30 days to energize the affected panel from its associated inverter connected to their associated DC bus.Although the functions are not risk SnRi*,"*a,-,Because of the low risk-significance of the affected functions on DP001 and DP002, the fact that, once energized from the voltage regulating transformer, the functions are still powered from a diesel-backed 1 E source, and the low likelihood of an initiating event and subsequent equipment failures, the 30 day completion time is acceptable.

a RIOT cannot be quantified in accordance with the requirements of TS 6.8.3.

NOC-AE-08002255 Enclosure, Att. 3 ENCLOSURE, ATTACHMENT 3 Vital AC Distribution Panel Diagrams

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