ML111370277

Issuance of Amendment Nos. 196 and 184, Revise Technical Specification 6.8.3.I, Containment Post Tensioning System Surveillance Program and Surveillance Requirement 4.6.1.6, Containment Prestressing System.

ML111370277
Person / Time
Site:	South Texas
Issue date:	05/27/2011
From:	Balwant Singal Plant Licensing Branch IV
To:	Halpin E South Texas
Singal, Balwant, 415-3016, NRR/DORL/LPL4
References
TAC ME3969, TAC ME3970
Download: ML111370277 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 May 27, 2011 Mr. Edward D. Halpin President and Chief Executive Officerl Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTAINMENT POST-TENSIONING SYSTEM SURVEILLANCE PROGRAM (TAC NOS. ME3969 AND ME3970)

Dear Mr. Halpin:

The Commission has issued the enclosed Amendment No. 196 to Facility Operating License No. NPF-76 and Amendment No. 184 to Facility Operating License No. NPF-80 for the South Texas Project (STP), Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated May 18, 2010, as supplemented by letters dated March 1 and May 2, 2011.

The amendments revise TS 6.8.3.1, "Containment Post-Tensioning System Surveillance Program," and the related TS Surveillance Requirement 4.6.1.6, "Containment Prestressing System," for consistency with the requirements of the containment inservice inspection program mandated by paragraph 50.55a(g)(4) of Title 10 of the Code of Federal Regulations (10 CFR),

for components classified as Code Class CC. Specifically, the amendments delete the reference to the specific American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) edition in TS 6.8.3.1 and replace it with the requirement to use the applicable ASME Code,Section XI edition and addenda for successive 10-year inservice inspection intervals in accordance with 10 CFR 50.55a. "Codes and standards." The changes have no impact on the implementation of the Containment Post-Tensioning System Surveillance Program or the design basis of STP. Units 1 and 2.

E. Halpin -2 A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, b~ \~~("-~ lh,~V Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosures:

1. Amendment No. 196 to NPF-76

2. Amendment No. 184 to NPF-80

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO, 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No, 196 License No, NPF-76

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (COA) (the licensees), dated May 18, 2010, as supplemented by letters dated March 1 and May 2, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

• STPNOC is authorized to act for NRG South Texas LP, the City Public Service Board of San Antonio, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 1

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-76 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 196, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-76 and the Technical Specifications Date of Issuance: May 27. 2011

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMEI\JT TO FACILITY OPERATING LICENSE Amendment No. 184 License No. NPF-80

1. The Nuclear Regulatory Commission (the Commission) has found that A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (COA) (the licensees), dated May 18, 2010, as supplemented by letters dated March 1 and May 2, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

• STPNOC is authorized to act for NRG South Texas LP, the City Public Service Board of San Antonio, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 2

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. NPF-80 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 184, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-80 and the Technical Specifications Date of Issuance: May 27, 2011

ATTACHMENT TO LICENSE AMENDMENT NOS. 196 AND 184 AND FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Facility Operating Licenses, Nos. NPF-76 and NPF-80, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating Licenses No. NPF-76 REMOVE INSERT 4 4 Facility Operating Licenses No. NPF-80 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3/46-9 3/4 6-9 6-11 6-11

SOUTH TEXAS LICENSE -4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 196, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SER)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) Safety Parameter Display System (Section 18, SSER No. 4)*

Before startup after the first refueling outage, HL&P[**] shall perform the necessary activities, provide acceptable responses, and implement all proposed corrective actions related to issues as described in Section 18.2 of SER Supplement 4.

(6) Supplementary Containment Purge Isolation (Section 11.5, SSER NO.4)

HL&P shall provide, prior to startup from the first refueling outage, control room indication of the normal and supplemental containment purge sample line isolation valve position.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

• • The original licensee authorized to possess, use and operate the facility was HL&P.

Consequently, historical references to certain obligations of HL&P remain in the license conditions.

Amendment No. 196

-4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 184 and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SR)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) License Transfer Texas Genco, LP shall provide decommissioning funding assurance, to be held in decommissioning trusts for South Texas Project, Unit 2 (Unit 2) upon the direct transfer of the Unit 2 license to Texas Genco, LP, in an amount equal to or greater than the balance in the Unit 2 decommissioning trust immediately prior to the transfer. In addition, Texas Genco, LP shall ensure that all contractual arrangements referred to in the application for approval of the transfer of the Unit 2 license to Texas Genco, LP to obtain necessary decommissioning funds for Unit 2 through a non-bypassable charge are executed and will be maintained until the decommissioning trusts are fully funded, or shall ensure that other mechanisms that provide equivalent assurance of decommissioning funding in accordance with the Commission's regulations are maintained.

(6) License Transfer The master decommissioning trust agreement for Unit 2, at the time the direct transfer of Unit 2 to Texas Genco, LP is effected and thereafter, is subject to the following:

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 184

CONTAINMENT SYSTEMS CONTAINMENT STRUCTURAL INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.6 The structural integrity of the containment(s) shall be maintained as required by the Containment Post-Tensioning System Surveillance Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

If the containment is not OPERABLE, restore containment to OPERABLE status in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least HOT STANDBY in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in COLD SHUTDOWN in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.1.6 CONTAINMENT PRESTRESSING SYSTEM Verify containment structural integrity in accordance with the Containment Post-Tensioning System Surveillance Program. The provisions of SR 4.0.2 do not apply to extending the interval for this surveillance.

SOUTH TEXAS - UNITS 1 & 2 3/46-9 Unit 1 - Amendment No. +S,.::t.3+ 196 Unit 2 - Amendment No. 8,:+29 184

6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3 (continued)

I. Containment Post-Tensioning System Surveillance Program This program provides controls for monitoring any tendon degradation in pre-stressed concrete containments, including effectiveness of its corrosion protection medium, to ensure containment structural integrity. The program shall include baseline measures prior to initial operations. The Containment Post-Tensioning System Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL, of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where an alternative, exemption, or relief has been authorized by the NRC.

The provisions of SR 4.0.3 are applicable to the Containment Post-Tensioning System Surveillance Program inspection frequencies with the exception of the surveillance interval extension allowed per Surveillance Requirement 4.0.2.

m. Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the 1:S incorporated in the license or

2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d. Proposed changes that meet the criteria of Specification 6.8.3.m.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).

n. Offsite Dose Calculation Manual (ODCM)

1) The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and (continued)

SOUTH TEXAS - UNITS 1 & 2 6-11 Unit 1 - Amendment No. 137,141, 151 196 Unit 2 - Amendment No. 126,129, 139 184

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 196 AND 184 TO FACILITY OPERATING LICENSE NOS, NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY, ET AL.

SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS, 50-498 AND 50-499

1.0 INTRODUCTION

By application dated May 18, 2010 (Reference 1), as supplemented by letters dated March 1 and May 2,2011 (References 2 and 3), STP Nuclear Operating Company (the licensee),

requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Units 1 and 2. The proposed changes would revise TS 6.8.3.1, "Containment Post-Tensioning System Surveillance Program," and the related SR 4.6.1.6, "Containment Prestressing System," for consistency with the requirements of the containment inservice inspection (CISI) program mandated by paragraph 50,55a(g)(4) of Title 10 of the Code of Federal Regulations (10 CFR),

for components classified as Code Class CC. Specifically, the proposed change would delete the reference to the specific American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) edition in T.S 6.8.3.1 and replace it with the requirement to use the applicable ASME Code,Section XI edition and addenda for successive 1O-year inservice inspection (lSI) intervals in accordance with 10 CFR 50,55a. The changes have no impact on the implementation of the Containment Post-Tensioning System Surveillance Program or the design basis of STP, Units 1 and 2.

The supplemental letter dated March 1, 2011, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, but did change the U.S, Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on September 21, 2010 (75 FR 57529), The revised proposed no significant hazards consideration determination was published in the Federal Register on March 22, 2011 (76 FR 16012).

The supplemental letter dated May 2, 2011, provided additional information that clarified the application, did not expand the scope of the application as noticed on March 22,2011, and did not change the staffs revised proposed no significant hazards consideration determination as published in the Federal Register on March 22, 2011 (76 FR 16012).

Enclosure 3

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2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR Section 50.36, "Technical specifications." That regulation requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements (SRs);

(4) design features; and (5) administrative controls. However, the regulation does not specify the particular TS to be included in a plant's license.

The proposed amendment revises TS 6.8.3.1, "Containment Post-Tensioning System Surveillance Program," under TS 6.0, "ADMINISTRATIVE CONTROLS," and SR 4.6.1.6, "Containment Prestressing System." The licensee's TS amendment request relates to its Containment Post-Tensioning System Surveillance Program for containment, which is classified as ASME Code Class CC.

In the Federal Register (Volume 61, Number 154, pages 41303-41312) dated August 8,1996, the Commission amended 10 CFR 50.55a, "Codes and standards," to incorporate by reference for the first time Subsections IWE and IWL of the 1992 Edition with the 1992 Addenda of the ASME Code,Section XI, Division 1, with specified modifications and a limitation, for performing containment inservice examinations (refer to paragraph (b)(2) and (b)(2)(vi) of the amended rule). The amended final rule became effective on September 9, 1996. Paragraph (g)(4) of the rule required licensees to incorporate Subsections IWE and IWL into their CISI programs.

Paragraph (g)(6)(ii)(B) of the amended rule required licensees to expedite implementation of the containment examinations in accordance with Subsections IWE and IWL by September 9, 2001.

Subsection IWL of the ASME Code,Section XI, provides rules for lSI and repair of the reinforced concrete and the post-tensioning systems of Class CC components and applies to the Containment Post-Tensioning System Surveillance Program at STP, Units 1 and 2. For ASME Code Class CC components, paragraph (g)(6)(ii)(B)(2) of the amended 1996 rule, required that licensees of all operating nuclear power plants shall implement the inservice examination which corresponds to the number of years of operation which are specified in Subsection IWL of the 1992 Edition with the 1992 Addenda in conjunction with the modifications specified in 10 CFR 50.55a(b)(2)(ix) by September 9, 2001.

In accordance with paragraph (g)(4) and g(6)(ii)(B) of the amended 199610 CFR 50.55a rule, the 1992 Edition with 1992 Addenda of the ASME Code, Subsections IWE and IWL, became the Code of record for the expedited examination and the initial (first) 120-month interval of the CISI program for STP, Units 1 and 2. However, 10 CFR 50.55a(g)(4)(ii) requires that the inservice examination during successive 120-month inspection intervals must be updated to comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of 10 CFR 50.55a, 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed in paragraph (b).

By this amendment, the licensee is proposing an administrative change to update TS Section 6.8.3.1 related to the Containment Post-Tensioning System Surveillance Program to replace the reference to the specific ASME Code,Section XI edition and addenda {I.e., the 1992 Edition

-3 with 1992 Addenda) with a requirement to be consistent with 10 CFR 50.55a(g)(4) with regard to the ASME Code,Section XI edition and addenda for initial and successive 120-month intervals of the Containment Post-Tensioning System Surveillance Program, which is part of the CISI program. The licensee is also proposing a change to the related TS SR 4.6.1.6 "Containment Prestressing System," for consistency.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes This amendment affects TS Section 6.8.3.1 and TS SR 4.6.16 as stated below.

TS 6.8.3.1, "Containment Post-Tensioning System Surveillance Program" Current TS Section 6.8.3.1 states, in part, that,

..... The Containment Post-Tensioning System Surveillance Program shall be in accordance with ASME Code Section XI, Subsection IWL, 1992 Edition with 1992 Addenda, as supplemented by 10CFR50.55a(b)(2)(viii).

Proposed TS Section 6.8.3.1 would state,

.... The Containment Post-Tensioning System Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL, of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where an alternative, exemption, or relief has been authorized by the NRC.

The provisions of SR 4.0.3 are applicable to the Containment Post-Tensioning System Surveillance Program Inspection frequencies with the exception of the surveillance interval extension allowed per Surveillance Requirement 4.0.2.

TS SR 4.6.1.6, "Containment Prestressing System" Current TS SR 4.6.1.6 states, Verify containment structural integrity in accordance with the Containment Post Tensioning System Surveillance Program.

Proposed TS SR 4.6.1.6 would state, Verify containment structural integrity in accordance with the Containment Post Tensioning System Surveillance Program. The provisions of SR 4.0.2 do not apply to extending the interval for this surveillance.

- 4 3.2 NRC Staff Evaluation The containments at STP, Units 1 and 2, are fully continuous, steel-lined, post-tensioned, reinforced-concrete structures that consist of a vertical cylinder with a hemispherical dome, supported on a flat foundation mat and are classified as Class CC components. The cylinder and dome are post-tensioned with high-strength un-bonded wire tendons in a predetermined sequence. A continuous, reinforced-concrete tendon gallery is located at the perimeter of the mat and is provided for the installation and surveillance of the vertical post-tensioning system.

The cylindrical portion and the hemispherical dome of the containment are pre-stressed by a post-tensioning system consisting of horizontal and vertical tendons. The containment post tensioning tendons are subject to the Containment Post-Tensioning System Surveillance Program, which is part of the CISI program. The SRs and reporting requirements for the post tensioning tendons are specified in TS Section 6.8.3.1.

As discussed in Section 2.0 of this safety evaluation, the licensee's Code of record for the Containment Post-Tensioning System Surveillance Program for the expedited examination and during the initial (first) 120-month interval of its CISI program is the 1992 Edition and 1992 Addenda of the ASME Code,Section XI. This Code edition and addenda is explicitly specified in the current TS Section 6.8.3.1. However, 10 CFR SO.SSa(g)(4) requires that the CISI program for successive 120-month intervals be updated to comply with the latest ASME Code edition and addenda incorporated by reference as specified in 10 CFR SO.SSa(g)(4)(ii). Therefore, the language of the existing TS Section 6.8.3.1, which makes specific reference to the 1992 Edition and 1992 addenda of the ASME Code, is not consistent with the requirement in 10 CFR SO.SSa(g)(4) for successive 120-month intervals. Based on 10 CFR SO.SSa(g)(4)(ii) in the current rule, the ASME 2004 Edition becomes applicable to STP, Units 1 and 2 in the next 10-year lSI interval, as modified and supplemented by specified conditions.

By this amendment, the licensee is proposing an administrative change to update TS Section 6.8.3.1 related to the Containment Post-Tensioning System Surveillance Program to remove the reference to the specific ASME Code edition and addenda and to be consistent with 10 CFR SO.SSa(g)(4) with regard to the Code edition and addenda for successive 120-month intervals of the CISI program.

During its review of Reference 1, the NRC staff identified areas where additional information was needed to complete its review. The NRC staff requested additional information bye-mail dated January 24, 2011 (Reference 4). By letter dated March 1, 2011 (Reference 2), the licensee provided a revised proposed amendment to TS 6.8.3.1 that incorporated the responses to the staff's requests for additional information (RAls), which are discussed below.

In its RAI, the NRC staff noted an apparent inconsistency in the Reference 1 submittal when reviewing the suggested wording that was proposed to be incorporated into TS 6.8.3.1 for the revised Containment Post-Tensioning System Surveillance Program. Specifically, the licensee referenced 10 CFR SO.SSa(b)(2)(viii) in the new, proposed TS wording. However, 10 CFR SO.SSa(b)(2)(viii) only provides the regulatory conditions that apply when using Subsection IWL of specific Code editions and addenda, included by reference in the rule, but does not provide information that would determine the Code edition and addenda to be used in any given 120-month lSI interval. As such, the proposed TS language did not cite the appropriate paragraph in the regulations that would determine the Code edition and addenda to be used in

- 5 the subsequent 120-month lSI intervals. The appropriate determination of the Code edition and addenda and the applicable regulatory conditions is made based on the provisions in paragraph 10 CFR 50.55a(g)(4), but not those in 10 CFR 50.55a(b)(2){viii). The NRC staff requested that the applicant clarify this discrepancy and provide the appropriate reference to the regulations in the proposed wording of TS 6.8.3.1 in the license amendment request (LAR).

In its response to the RAI (Reference 2), the licensee provided an LAR supplement. The licensee referenced the 10 CFR 50.55a rule as a whole, rather than citing the regulatory conditions that apply when using Subsection IWL of specific Code editions and addenda. The revised TS wording presented in Reference 2 ensures that the Code edition and addenda for each successive 120-month lSI interval will be updated in accordance with 10 CFR 50.55a and specifically 10 CFR 50.55a(g)(4)(ii) and is, therefore, acceptable.

During its review of the Reference 2 submittal, however, the NRC staff identified areas where additional information was needed to complete its review. The revised wording proposed in Reference 2 also stated that the provisions of SR 4.0.3 are applicable to the TS 6.8.3.1 surveillance program inspection frequencies. SR 4.0.3 further invokes SR 4.0.2. SR 4.0.2 states that, Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

This statement presented an apparent conflict between grace periods in the proposed TS language and the ASME Code for performing the surveillances that are part of the Containment Post-Tensioning System Program, as discussed below.

Since 1996, the requirements for the CISI program, which includes tendon surveillance, is mandated by the regulations (10 CFR 50.55a(g)) to be performed in accordance with Subsections IWE (for Class MC components and metallic liners) and Subsection IWL (for Class CC components) of ASME Section XI, as incorporated by reference and conditioned in 10 CFR 50.55a. For the tendon surveillance program of Class CC containment, the Code provisions in Subsection IWL include reasonable grace periods for licensees to conduct the inspections required, as stated in IWL-2400. The grace period of 25 percent, of the Code specified surveillance frequency of 5 years for tendon surveillance, allowed by SR 4.0.2 would result in a grace period of 1.25 years, which is not consistent with the grace period allowed in the Subsection IWL provisions. Therefore, allowing the use of an extension period as stated in SR 4.0.2 creates a deviation from the ASME Code requirements incorporated by reference in 10 CFR 50.55a. This would be inconsistent with the regulations. This inconsistency was discussed and clarified with the licensee via conference call on April 6, 2011. By letter dated May 2, 2011 (Reference 3), the licensee submitted an LAR supplement in which the proposed TS language, shown in Section 3.1 of this safety evaluation, removed the inconsistency discussed previously.

The revised TS language in Enclosure 2 of Reference 3 states that the aforementioned provisions of SR 4.0.2 for extending the surveillance interval are not applicable to TS 6.8.3.1.

Furthermore, the licensee revised the related TS SR 4.6.1.6, which contains the SRs corresponding to Limiting Condition for Operation (LCO) 3.6.1.6 for Containment Structural

- 6 Integrity. The revised TS SR 4.6.1.6, shown in Section 3.1 of this safety evaluation, states that the provisions of SR 4.0.2 for extending the surveillance interval are not applicable to LCO 3.6.1.6. Therefore, the NRC staff concludes that the revised proposed TS language discussed above ensures that the grace period used in tendon surveillance program would be consistent with the inspection schedule requirements in Subsection IWL of the ASME Code. The NRC staff concludes that this is consistent with the regulations in 10 CFR 50.55a(g)(4) and, therefore, resolves the inconsistency issue discussed previously.

Based on the above, the NRC staff concludes that the proposed changes to TS 6.8.3.1 and TS SR 4.6.1.6, as stated in Section 3.1 of this safety evaluation, are consistent with the regulations in 10 CFR 50.55a(g)(4) for Class CC components and are, therefore, acceptable.

Based on the NRC staff's review of the licensee's submittal of May 18, 2010 (Reference 1), as supplemented by letters dated March 1 and May 2, 2011 (References 2 and 3), the staff concludes that the proposed changes to TS Section 6.8.3.1 and TS SR 4.6.1.6, related to the Containment Post-Tensioning System Surveillance Program at STP, Units 1 and 2, are consistent with the regulations in 10 CFR 50.55a(g)(4), satisfy the requirements of 10 CFR 50.36, and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on March 22,2011 (76 FR 16012). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

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7.0 REFERENCES

1. Powell, G.T., STP Nuclear Operating Company, letter to U.S. Nuclear Regulatory Commission, "Proposed Amendment to Technical Specification 6.8.3.1 for Containment Post-Tensioning System Surveillance Program," dated May 18, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML101450414).

2. Powell, G.T., STP Nuclear Operating Company, letter to U.S. Nuclear Regulatory Commission, "Revised Proposed Amendment to Technical Specification 6.8.3.1 for Containment Post-Tensioning System Surveillance Program," dated March 1, 2011 (ADAMS Accession No. ML110690223).

3. Powell, G.T., STP Nuclear Operating Company, letter to U.S. Nuclear Regulatory Commission, "Proposed Amendment to Technical Specifications for Containment Post Tensioning System Surveillance Program (Revision 2)," dated May 2,2011 (ADAMS Accession No. ML11129A027)

4. Thadani, M. C., U.S. Nuclear Regulatory Commission, e-mail to Philip Walker and Albon Harrison, STP Nuclear Operating Company, RAI for Request to Revise Technical Specification 6.8.3 [Containment] Tendons {TAC Nos. ME3969 and ME3970)," dated January 24, 2011 (ADAMS Accession No. ML110240385).

Principal Contributor: Juan Uribe, NRRIDE/EMCB Date: May 27, 2011

E. Halpin - 2 A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRAI Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosures:

1. Amendment No. 196 to NPF-76

2. Amendment No. 184 to NPF-80

3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDeEmcb Resource RidsNrrDirsltsb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrPMSouthTexas Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JUribe, NRR/DE/EMCB ADAMS Accession No. ML111370277 Memo dated 5/18/11 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRRIDIRS/ITSB/BC NAME BSingal JBurkhardt RElliott DATE 5/19/11 5/18/11 5/23/11

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OFFICE OGC R/LPL4/PM NAME AJones ingal DATE 5/25/11 5/27/11 5/27/11 OFFICIAL RECORD COpy