Soutn Profed Ekctric Genenuns Station

~ ..... Nuclear Operating Company ... ~ Soutn Tt'JCIS Profed Ekctric Genenuns Station P.Q BOK 281' ~ - Tt'JCIS 77481 ------------'VVV'v-

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

South Texas Project Units 1 & 2

January 13, 2021 NOC-AE-2000377 4 10 CFR 50.90 STI : 35103660

Docket Nos. STN 50-498, STN 50-499 License Amendment Request to Revise Technical Specification

Surveillance Requirement (SR) 4.1.1.3 a. and b. and Specification 6.9.1.6 b.

In accordance with the provisions of 10 CFR 50.90, STP Nuclear Operating Company (STPNOC) is submitting a request for an amendment to the Technical Specifications for South Texas Project (STP), Units 1 and 2.

The proposed amendment would modify Technical Specification 3/4.1.1 .3 by replacing "measured" with "verified" in Surveillance Requirement (SR) 4.1.1.3 a. and b., replacing "remeasured" with "reverified" in SR 4.1.1.3 b., deleting the footnote in SR 4.1.1.3 b., and deleting Reference 10 in Specification 6.9.1.6 b.

The Enclosure to this letter provides a description and assessment of the proposed changes.

Markup and retyped (clean) Technical Specification pages are provided in Enclosure Attachments 1 and 2, respectively. A markup copy of the Technical Specification Bases is provided for information only in Enclosure Attachment 3.

STPNOC requests approval of the proposed license amendment by February 1, 2022. STPNOC will implement the amendment no later than 30 days prior to the fall 2022 Unit 2 refueling outage (2RE22).

The proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

In accordance with 10 CFR 50.91(b), "State Consultation," STPNOC is notifying the State of Texas of this license amendment request by transmitting a copy of this letter and Enclosure to the designated State Official. The proposed amendment has been reviewed and approved by the STPNOC Plant Operations Review Committee and has undergone an independent organizational unit review.

There are no regulatory commitments in this amendment request.

If there are any questions or if additional information is needed, please contact Tim Hammons at (361) 972-7347 or me at (361) 972-7344.

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

Executed oc~ I 3, :I-OJ- I

Enclosure: Evaluation of the Proposed Change

amesConn~ Executive VP and CNO

NOC-AE-20003774 Page 2 of 2

cc: Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511

Enclosure NOC-AE-20003774 Page 1 of 7

ENCLOSURE

Evaluation of the Proposed Change Subject: License Amendment Request to Revise Technical Specification Surveillance

Requirement (SR) 4.1.1.3 a. and b. and Specification 6.9.1.6 b. 1 SUMMARY DESCRIPTION 2 DETAILED DESCRIPTION

2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Description of the Proposed Change

3 TECHNICAL EVALUATION

3.1 Evaluation Summary 3.2 Verification Approach 3.3 Conclusions

4 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration Determination Analysis 4.3 Conclusions

5 ENVIRONMENTAL CONSIDERATIONS

6 REFERENCES ------------------------------------ ATTACHMENTS: 1. Technical Specification Page Markups 2. Retyped Technical Specification Pages 3. Technical Specification Bases Page Markup (Information Only)


1 SUMMARY DESCRIPTION In accordance with 10 CFR 50.90, South Texas Project Nuclear Operating Company (STPNOC) requests an amendment to the Technical Specifications for South Texas Project (STP), Units 1 and 2. The proposed amendment would modify Technical Specifications by revising “measured” to “verified” in Surveillance Requirement (SR) 4.1.1.3 a. and b., revising “remeasured” to “reverified” in SR 4.1.1.3 b., deleting the footnote in SR 4.1.1.3 b., and deleting Reference 10 in Specification 6.9.1.6 b.

2 DETAILED DESCRIPTION 2.1 System Design and Operation

The limitations on moderator temperature coefficient (MTC) are provided to ensure that the value of this coefficient remains within the limiting condition assumed in the Final Safety Analysis Report (FSAR) accident and transient analyses. The MTC values of this specification are applicable to a specific set of plant conditions; accordingly, verification of MTC values at conditions other than those explicitly stated will require extrapolation to those conditions in order to permit an accurate comparison. The most negative MTC value, equivalent to the most positive moderator density coefficient (MDC), was obtained by incrementally correcting the MDC used in the FSAR analysis to nominal operating conditions. These corrections involved: (1) a conversion of the MDC used in the FSAR analysis to its equivalent MTC, based on the rate of change of moderator density with temperature at RATED THERMAL POWER conditions, and (2) subtracting from this value the largest differences in MTC observed at End of Life (EOL), all rods withdrawn, RATED THERMAL POWER conditions, and those most adverse conditions of moderator temperature and pressure, rod insertion, axial power skewing, and xenon concentration that can occur in nominal operation and lead to a significantly more negative EOL MTC at RATED THERMAL POWER. These corrections transformed the MDC values used in the FSAR analysis into the limiting EOL MTC value specified in the CORE OPERATING LIMITS REPORT (COLR). The 300 ppm surveillance MTC value specified in the COLR represents a conservative value (with corrections for burnup and soluble boron) at a core condition of 300 ppm equilibrium boron concentration, and is obtained by making these corrections to the limiting MTC value.

2.2 Current Technical Specification Requirements

SR 4.1.1.3 states: “4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows: a. The MTC shall be measured and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and


b. The MTC shall be measured at any THERMAL POWER and compared to the 300 ppm surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm.* In the event this comparison indicates the MTC is more negative than the 300 ppm surveillance limit specified in the COLR, the MTC shall be remeasured, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle. * Measurement of the MTC in accordance with Surveillance Requirement 4.1.1.3.b may be suspended, provided that the benchmark criteria in WCAP-13749-P-A (refer to 6.9.1.6.b.10) and the Revised Prediction specified in the COLR are satisfied.” Reference 10 in Specification 6.9.1.6 b. states: “10. WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional

Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," March 1997, (W Proprietary).”

2.3 Description of the Proposed Change

SR 4.1.1.3 will be revised as follows: “4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows: a. The MTC shall be verified and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and b. The MTC shall be verified at any THERMAL POWER and compared to the 300 ppm surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm. In the event this comparison indicates the MTC is more negative than the 300 ppm surveillance limit specified in the COLR, the MTC shall be reverified, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle.” Reference 10 in Specification 6.9.1.6 b. will be deleted: “10. Not used.”

3 TECHNICAL EVALUATION 3.1 Evaluation Summary

The Technical Specifications typically do not specify how a Surveillance should be performed, only that a parameter should be within limits.

The specific details of how the Surveillance should be performed are not contained in Surveillance Requirement (SR) 3.1.3.1 and SR 3.1.3.2 in NUREG-1431, Revision 4.0,


“Standard Technical Specifications Westinghouse Plants,” (Reference 1) for the Moderator Temperature Coefficient Technical Specification (3.1.3).

SR 3.1.3.1 in NUREG-1431 states:

“Verify MTC is within upper limit.”

SR 3.1.3.2 in NUREG-1431 states:

“Verify MTC is within lower limit.”

How the Surveillance is performed is specified in Surveillance Test Procedures.

WCAP-13749-P-A, “Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement,” is not an NRC approved methodology that is used to determine the EOL MTC that is assumed in the safety analyses.

WCAP-13749-P-A is a procedure that is used to verify that the EOL MTC is within the limit assumed in the safety analyses, in lieu of measuring the EOL MTC, and should not be included in the COLR Specification (6.9.1.6.b.).

Current STP SRs 4.1.1.3 a. and b. contain the word “measured,” which precludes using another procedure to verify that the Surveillances are met.

Current STP SR 4.1.1.3 b. requires the use of WCAP-13749-P-A to verify, versus measure, the EOL MTC and does not allow the use of other procedures to verify that the Surveillance is met.

Revising the wording in SRs 4.1.1.3 a. and b. from “measured” to “verified” will allow the use of other procedures to verify that the Surveillances are met.

Deleting WCAP-13749-P-A from the COLR Specification (6.9.1.6.b.) will allow the use of other procedures to verify that the EOL MTC limit is met.

3.2 Verification Approach

The Beginning of Life (BOL) and EOL MTC Technical Specification limits that are contained in the COLR will be verified using the predicted MTC from the core design, plus uncertainties in lieu of measuring the Isothermal Temperature Coefficient (ITC). The accuracy of the predicted MTC at BOL has been demonstrated using measured to predicted (M-P) data from more than 600 startup physics tests performed over the last 20 years. This data includes experience with multiple fuel types, fuel vendors, approved prediction methods, and measurement methods. The verification approach is based on the ITC M-P difference. The BOL verification utilizes ITC measured minus predicted data that was obtained from 2000 to present. The BOL predictive uncertainty was derived from the calculated 95/95 two-sided confidence interval of this data set. This predictive uncertainty will be added to the predicted MTC that would otherwise be confirmed by ITC measurement prior to power ascension following a refueling outage at the BOL. This verification approach provides a


conservative bound on the MTC to be compared to the Technical Specification BOL limit that is contained in the COLR. The EOL verification uses the same predictive uncertainty as the BOL verification. Additional uncertainties are applied to account for differences between measured and predicted data that could potentially impact the EOL MTC, such as core burnup and axial and radial power distribution. The additional uncertainties, referred to as operational allowance uncertainties, will be added to the predicted uncertainty to determine the total uncertainty for the EOL MTC verification. If margin between the predicted MTC and the Technical Specification EOL limit contained in the COLR is greater than the total uncertainty, the EOL COLR limit is verified. This is only valid if the measured to predicted differences (core burnup, axial and radial power distribution) are within the constraints determined by the operational allowance uncertainties discussed above. The verification of the BOL and EOL Technical Specification limits, does not impact the methodologies used to determine the BOL and EOL MTC limits contained in the COLR, or the BOL and EOL MTC values assumed in the safety analyses in Chapter 15 of the UFSAR.

3.3 Conclusions

The proposed amendment does not impact the BOL and EOL Technical Specification limits, does not impact the methodologies used to determine the BOL and EOL MTC limits contained in the COLR, or the BOL and EOL MTC values assumed in the safety analyses in Chapter 15 of the UFSAR.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria

10 CFR 50.36(c)(3) states: "Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.” 10 CFR 50.36(c)(3) continues to be met because SR 4.1.1.3 is still included in the Technical Specifications. Changing the surveillance to verify rather than measure MTC does not affect the surveillance’s ability to assure that the necessary quality of systems and components is maintained, to assure that facility operation will be within safety limits, or to assure that the limiting conditions for operation will be met. 10 CFR 50, Appendix A, GDC 11 states: “Reactor inherent protection. The reactor core and associated coolant systems shall be designed so that in the power operating range the net effect of the prompt inherent nuclear feedback characteristics tends to compensate for a rapid increase in reactivity.”


10 CFR 50, Appendix A, GDC 11 continues to be met because the BOL and EOL MTC values assumed in the safety analyses in Chapter 15 of the UFSAR are not being altered and the Technical Specification limits regarding the MTC are not being revised by the proposed change.

4.2 No Significant Hazards Consideration Determination Analysis The proposed change would modify the South Texas Project (STP) Nuclear Operating Company (STPNOC) Technical Specifications by revising “measured” to “verified” in Surveillance Requirement (SR) 4.1.1.3 a. and b., revising “remeasured” to “reverified” in SR 4.1.1.3 b., deleting the footnote in SR 4.1.1.3 b., and deleting Reference 10 in Specification 6.9.1.6 b. STPNOC has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1) Does the proposed amendment involve a significant increase in the probability or

consequences of an accident previously evaluated? Response: No. The proposed changes of revising “measured” to “verified” in Surveillance Requirement (SR) 4.1.1.3 a. and b., revising “remeasured” to “reverified” in SR 4.1.1.3 b., deleting the footnote in SR 4.1.1.3 b., and deleting Reference 10 in Specification 6.9.1.6 b. do not impact the BOL and EOL MTC values assumed in the safety analyses in Chapter 15 of the UFSAR. The safety analyses are not impacted, and therefore the probability and consequences of the accidents are not impacted, and therefore the licensing basis limits are not impacted. The change does not affect any plant structures, systems and components (SSCs), impact plant operation, any design functions or analysis that verifies design functions. The BOL and EOL MTC are not a precursor to any accident previously evaluated. There is no degradation in the performance of, or an increase in the number of challenges to any SSC assumed to function during any postulated accident. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated? Response: No. The proposed changes do not involve a physical modification to the plant or a change in the methods governing normal plant operation – no new or different type of equipment will be installed. The proposed change does not adversely affect the design function or operation of any SSCs important to safety. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced because of the proposed changes. The SSCs continue to function in the same manner as assumed in the safety analyses, and there is no reliance on additional systems or procedures. The BOL and EOL MTC values are not accident initiators. A change to how the BOL and EOL limits are met does not create a new or different kind of accident. The proposed changes do not impact the malfunction of any safety-related SSCs that are assumed to function in the accident analyses. No


new failure mode has been created and no new equipment performance burdens are imposed. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed amendment involve a significant reduction in a margin of safety? Response: No. The safety analyses are not impacted by how the BOL and EOL MTC limits are met, and therefore the licensing basis limits are not impacted. The design bases and safety limits are not impacted by the proposed changes. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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

5 ENVIRONMENTAL EVALUATION 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 a 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 REFERENCES 6.1 NUREG-1431, Revision 4,0, “Standard Technical Specifications Westinghouse Plants,”

Volume 1.

Enclosure NOC-AE-20003774 Attachment 1

Attachment 1

Technical Specification Pages Markup

REACTIVITY CONTROL SYSTEMS

SURVEILLANCE REQUIREMENTS

4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows:

a. The MTC shall be measured verified and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and

b. The MTC shall be measured verified at any THERMAL POWER and compared to

the 300 ppm surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm.* In the event this comparison indicates the MTC is more negative than the 300 ppm surveillance limit specified in the COLR, the MTC shall be remeasured reverified, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle.

* Measurement of the MTC in accordance with Surveillance Requirement 4.1.1.3.b may be suspended, provided that the benchmark criteria in WCAP-13749-P-A (refer to 6.9.1.6.b.10) and the Revised Prediction specified in the COLR are satisfied.

SOUTH TEXAS - UNITS 1 & 2 3/4 1-7 Unit 1 – Amendment No. 27, 144 Unit 2 – Amendment No. 17, 132

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6 (continued)

10. WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient

Measurement," March 1997, (W Proprietary). Not Used. (Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient) 11. WCAP 12472-P-A, “BEACON Core Monitoring and Operations Support

System,“ August 1994 (W Proprietary), including Addenda 1-A (January 2000) and 4 (September 2012)

(Methodology for uncertainties in Specification 3.2.2 – Heat Flux Hot Channel Factor and 3.2.3 – Nuclear Enthalpy Rise Hot Channel Factor)

c. The core operating limits shall be determined so that all applicable limits (e.g., fuel

thermal-mechanical limits, core thermal-hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid-cycle revisions or supplements, shall be provided to the NRC upon issuance for each reload cycle.

6.9.1.7 Steam Generator Tube Inspection Report

A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 6.8.3.o. The report shall include:

a. The scope of inspections performed on each SG, b. Degradation mechanisms found, c. Nondestructive examination techniques utilized for each degradation mechanism, d. Location, orientation (if linear), and measured sizes (if available) of service induced

indications,

e. Number of tubes plugged during the inspection outage for each degradation mechanism,

f. The number and percentage of tubes plugged to date, and the effective plugging

percentage in each steam generator. g. The results of condition monitoring, including the results of tube pulls and in-situ

testing, 6.9.2 Not Used SOUTH TEXAS - UNITS 1 & 2 6-17 Unit 1 - Amendment No. 138, 144, 151, 164, 204, 209, 213 Unit 2 - Amendment No. 127, 132, 139, 154, 192, 196, 199


Attachment 2

Retyped Technical Specification Pages


SURVEILLANCE REQUIREMENTS

4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows:

a. The MTC shall be verified and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and

b. The MTC shall be verified at any THERMAL POWER and compared to the 300 ppm

surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm. In the event this comparison indicates the MTC is more negative than the 300 ppm surveillance limit specified in the COLR, the MTC shall be reverified, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle.

SOUTH TEXAS - UNITS 1 & 2 3/4 1-7 Unit 1 – Amendment No. 27, 144 Unit 2 – Amendment No. 17, 132

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6 (continued)

10. Not Used. 11. WCAP 12472-P-A, “BEACON Core Monitoring and Operations Support

System,“ August 1994 (W Proprietary), including Addenda 1-A (January 2000) and 4 (September 2012)

(Methodology for uncertainties in Specification 3.2.2 – Heat Flux Hot Channel Factor and 3.2.3 – Nuclear Enthalpy Rise Hot Channel Factor)

c. The core operating limits shall be determined so that all applicable limits (e.g., fuel

thermal-mechanical limits, core thermal-hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid-cycle revisions or supplements, shall be provided to the NRC upon issuance for each reload cycle.

6.9.1.7 Steam Generator Tube Inspection Report

A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 6.8.3.o. The report shall include:

a. The scope of inspections performed on each SG, b. Degradation mechanisms found, c. Nondestructive examination techniques utilized for each degradation mechanism, d. Location, orientation (if linear), and measured sizes (if available) of service induced

indications,

e. Number of tubes plugged during the inspection outage for each degradation mechanism,

f. The number and percentage of tubes plugged to date, and the effective plugging

percentage in each steam generator. g. The results of condition monitoring, including the results of tube pulls and in-situ

testing, 6.9.2 Not Used SOUTH TEXAS - UNITS 1 & 2 6-17 Unit 1 - Amendment No. 138, 144, 151, 164, 204, 209, 213 Unit 2 - Amendment No. 127, 132, 139, 154, 192, 196, 199


Attachment 3

Technical Specification Bases Pages Markup (Information Only)


BASES

MODERATOR TEMPERATURE COEFFICIENT (Continued)

The most negative MTC value, equivalent to the most positive moderator density coefficient (MDC), was obtained by incrementally correcting the MDC used in the FSAR analysis to nominal operating conditions. These corrections involved: (1) a conversion of the MDC used in the FSAR analysis to its equivalent MTC, based on the rate of change of moderator density with temperature at RATED THERMAL POWER conditions, and (2) subtracting from this value the largest differences in MTC observed at EOL, all rods withdrawn, RATED THERMAL POWER conditions, and those most adverse conditions of moderator temperature and pressure, rod insertion, axial power skewing, and xenon concentration that can occur in nominal operation and lead to a significantly more negative EOL MTC at RATED THERMAL POWER. These corrections transformed the MDC values used in the FSAR analysis into the limiting EOL MTC value specified in the CORE OPERATING LIMITS REPORT (COLR). The 300 ppm surveillance MTC value specified in the COLR represents a conservative value (with corrections for burnup and soluble boron) at a core condition of 300 ppm equilibrium boron concentration, and is obtained by making these corrections to the limiting MTC value.

The Surveillance Requirements for measurement verification of the MTC at the

beginning and near the end of the fuel cycle are adequate to confirm that the MTC remains within its limits since this coefficient changes slowly due principally to the reduction in RCS boron concentration associated with fuel burnup.

3/4.1.1.4 MINIMUM TEMPERATURE FOR CRITICALITY

This specification ensures that the reactor will not be made critical with the Reactor Coolant System average temperature less than 561°F. This limitation is required to ensure: (1) the moderator temperature coefficient is within its analyzed temperature range, (2) the trip instrumentation is within its normal operating range, (3) the pressurizer is capable of being in an OPERABLE status with a steam bubble, and (4) the reactor vessel is above its minimum RTNDT temperature.

3/4.1.2 NOT USED

SOUTH TEXAS - UNITS 1 & 2 B 3/4 1-2 Unit 1 – Amendment No. 05-1034-10 Unit 2 – Amendment No. 05-1034-10

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