ML13008A528

Issuance of Amendment Nos. 200 and 188, Revise Technical Specification 3.3.3.6, Accident Monitoring Instrumentation

ML13008A528
Person / Time
Site:	South Texas
Issue date:	04/25/2013
From:	Balwant Singal Plant Licensing Branch IV
To:	Koehl D South Texas
Singal B
References
TAC ME9168, TAC ME9169
Download: ML13008A528 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 25, 2013 Mr. Dennis L. Koehl President and CEO/CNO 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: REVISE TECHNICAL SPECIFICATION 3.3.3.6 FOR ACCIDENT MONITORING INSTRUMENTATION (TAC NOS. ME9168 AND ME9169)

Dear Mr. Koehl:

The Commission has issued the enclosed Amendment No. 200 to Facility Operating License No. NPF-76 and Amendment No. 188 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 1, 2012, as supplemented by letter dated April 15, 2013.

The amendments revise TS 3.3.3.6, "Accident Monitoring Instrumentation," with respect to the required actions and allowed outage times for inoperable instrumentation for Neutron Flux (Extended Range) and Neutron Flux - Startup Range (Extended Range) summarized in TS Table 3.3-10.

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,

~n~~I~~r~r~anager 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. 200 to NPF-76

2. Amendment No. 188 to NPF-80

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 200 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 August 1,2012, as supplemented by letter dated April 15, 2013, 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

- 2

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. 200, 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 90 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: Apr; 1 25. 2013

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 188 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 August 1,2012, as supplemented by letter dated April 15, 2013, 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

-2

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. 188, 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 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION AvC-;:A~

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: Apr; 1 25, 2013

ATTACHMENT TO LICENSE AMENDMENT NOS. 200 AND 188 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 License No. NPF-76 REMOVE INSERT 4 4 Facility Operating License No. NPF-80 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3/43-69 3/43-69

SOUTH TEXAS LICENSE -4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 200, 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 SO.S9 shall be reported in accordance with SO.S9(b} within one month of such change.

(S) 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.S, 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. 200

-4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 188 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, 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. 188

TABLE 3.3-10 (Continued)

ACCIDENT MONITORING INSTRUMENTATION TOTAL MINIMUM NO. OF CHANNELS INSTRUMENT CHANNELS OPERABLE ACTION

13. Containment Water Level 2 1 36 (Narrow Range)

14. Containment Water Level (Wide Range) 3 37

15. Core Exit Thermocouples **2 **1 42

16. Steam Line Radiation Monitor 1/steam line 1/steam line 40

17. Containment - High Range Radiation Monitor 2 1 39

18. Reactor Vessel Water Level (RVWL) 2* 1* 41

19. Neutron Flux (Extended Range) 2 42

20. Not Used

21. Containment Pressure (Extended Range) 2 1 36

22. Steam Generator Blowdown Radiation Monitor 1/blowdown line 1/blowdown line 40

23. Neutron Flux - Startup Rate 2 1 42 (Extended Range)

• A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, one or more in the upper section section and three or more in the lower section, are OPERABLE.

• • A channel is OPERABLE if at least two core exit thermocouples per core quadrant are OPERABLE, and at least one quadrant has at least four OPERABLE thermocouples.

SOUTH TEXAS - UNITS 1 & 2 3/43-69 Unit 1 - Amendment No. 1+, .:fe.a., 200 Unit 2 - Amendment No. ee, 188

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 200 AND 188 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 letter dated August 1, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12222A008), dated August 1, 2012, as supplemented by letter dated April 15, 2013 (ADAMS Accession No. ML13114A054), STP Nuclear Operating Company (STPNOC, the licensee) submitted a license amendment request regarding to the facility operating licenses of South Texas Project (STP), Units 1 and 2. The proposed amendment would revise Technical Specification (TS) 3.3.3.6, "Accident Monitoring Instrumentation," with respect to the required actions and allowed outage times for inoperable instrumentation for Neutron Flux (Extended Range) and Neutron Flux - Startup Rate (Extended Range) (Instrument Nos. 19 and 23).

The supplemental letter dated April 15, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 2, 2012 (77 FR 60154).

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The NRC's regulatory requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR),

Part 50, Section 50.36, "Technical specifications." The TS requirements in 10 CFR 50.36 include the following categories: (1) safety limits, limiting safety systems settings and control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements (SRs),

(4) design features, (5) administrative controls, (6) decommissioning, (7) initial notification, and (8) written reports.

Enclosure 3

-2 The regulations in 10 CFR 50.36(c)(2)(i), "Limiting conditions for operation," state, in part, that Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The remedial actions in the TSs are specified in terms of LCOs, required actions, and completion times (CTs), or allowed outage times (AOTs), to complete the required actions.

When an LCO is not being met, the CTs specified in the TSs are the times allowed in the TSs for completing the specified required actions. The conditions and required actions specified in the TSs must be acceptable remedial actions for the LCO not being met, and the CTs must be a reasonable time for completing the required actions while maintaining the safe operation of the plant.

2.2 Regulatory Guidance The NRC staff considered the following guidance in this safety evaluation:

• Regulatory Guide (RG) 1.97, Revision 2, "Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," December 1980 (ADAMS Accession No. ML060750525),

provides an acceptable method for complying with the NRC's regulations to provide instrumentation to monitor plant variables and systems during and following an accident.

• NUREG-1431, "Standard Technical Specifications, Westinghouse Plants,"

Revision 4.0, April 2012, provides the NRC-endorsed standard for the improved TSs for Westinghouse plants, such as STP, Units 1 and 2, which includes the suggested standard for accident monitoring instrumentation in TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," including the remedial action for instances when the LeO, which requires the instrumentation to be operable, is not met.

The Updated Final Safety Analysis Report (UFSAR) for STP, Units 1 and 2, in Appendix 78, "South Texas Project Compliance with Regulatory Guide 1.97, Revision 2," indicates how the licensee meets Revision 2 of RG 1.97. This appendix is not being changed by this amendment request and, therefore, the licensee is not changing the manner in which it meets RG 1.97. The licensee has not adopted the improved TSs for STP, Units 1 and 2.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes TS 3.3.3.6, "Accident Monitoring Instrumentation," Table 3.3-10 requires a total of two operable channels for instruments 19, "Neutron Flux (Extended Range)," and 23, "Neutron Flux - Startup

-3 Rate (Extended Range)," and also states that the minimum amount of operable channels for each instrument is one. Table 3.3-10 directs entry into Action 36 when a single channel or both channels become inoperable.

Action 36 states:

a. With the number of OPERABLE channels one less than the Total Number of Channels requirements, restore one inoperable channel to OPERABLE status within 7 days, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. With the number of OPERABLE channels less than the Minimum Channels Operable requirements, restore at least one inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The licensee proposes to change Table 3.3-10 so that it directs entry into Action 42 instead of Action 36 for instruments 19 and 23.

Action 42 states:

a. With one required channel inoperable, restore the required channel to OPERABLE status within 30 days; otherwise, a Special Report shall be submitted within the next 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

b. With two required channels inoperable, restore one required channel to OPERABLE status within 7 days; otherwise, be in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in HOT SHUTDOWN in the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

In its letter dated August 1, 2012, the licensee stated the proposed license amendment will revise the required actions to enhance plant reliability by reducing exposure to unnecessary shutdowns and increase operational flexibility by allowing more time to effect required repairs for inoperable Neutron Flux (Extended Range) and Neutron Flux - Startup Rate (Extended Range) instrumentation. Furthermore, the licensee stated that the proposed changes are consistent with requirements generically approved as part of TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," of NUREG-1431, Revision 4, "Standard Technical Specifications, Westinghouse Plants," April 2012 (ADAMS Accession No. ML12100A222).

3.2 NRC Staff Evaluation Instrument 19, "Neutron Flux (Extended Range)," and Instrument 23, "Neutron Flux - Startup Rate (Extended Range)," are for post-accident monitoring and not for any plant protection function and are listed in UFSAR Table 7.5-1 as B1 and 02 variables to RG 1.97, Revision 2.

Each of these two instruments has two channels providing indication on the Qualified Display Parameter System (QDPS) in the control room. As stated in RG 1.97, Revision 2, Type B

-4 variables provide information to indicate whether plant safety functions are being accomplished and Type D variables provide information to indicate the operation of individual safety systems and other systems important to safety. RG 1.97, Revision 2, lists Neutron Flux as a Type B, Category 1. variable. RG 1.97 also defines Type A variables as variables to be monitored to provide primary information required to permit the control room operators to take specific manual actions for which no automatic control is provided and is required for safety system to accomplish their safety functions for design basis accident events.

In its letter dated August 1, 2012, as supplemented by letter dated April 15. 2013, the licensee stated, in part, that Neutron Flux (Extended Range) is used immediately following an accident or receipt of a reactor trip signal to confirm subcriticality. The operators will determine the need for a manual reactor trip based on rod bottom lights, indication that reactor trip breakers are open, and decreasing neutron flux. The extended range neutron flux indication can provide indication of decreasing neutron flux to confirm subcriticality. If the extended range neutron flux indication is not available. an alternate method of monitoring subcriticality is a combination of either the intermediate range or source range neutron flux indications.

After subcriticality is achieved, the extended range neutron flux monitor can be used to confirm continued subcriticality by monitoring the startup rate. A positive startup rate indicates that core reactivity is changing in a direction that may result in a criticality. This extended range neutron flux startup rate indication can be used as a backup to the extended range neutron flux indication during shutdown to determine whether sufficient negative reactivity (e.g., boron, Reactor Coolant System (RCS) temperature during RCS cooldown) is available for long term subcriticality. If the extended range startup rate indication is not available, an alternate method of monitoring startup rate is a combination of either the intermediate range or source range neutron flux indications.

Upon discovery of a failure to meet an LCO, the TSs specify time limits for completing Actions of the associated TS Conditions. Actions establish remedial measures that must be taken within specified AOTs. AOTs specify limits on the duration of plant operation in a degraded condition.

Incorporating longer AOTs is acceptable because such AOTs continue to be based on the operability status of redundant TS-required features, the capacity and capability of remaining TS-required features, provision of a reasonable time for repairs or replacement of required features, vendor-developed standard repair times, and the low probability of a design-basis accident occurring during the repair period.

The NRC staff has concluded that the 3~-day AOT is acceptable because one channel of instrumentation remains operable, the instrument provides an indication only (Le .. no automatic actuations are required to occur from the associated instrumentation post-accident), and there is a low probability of an event requiring post-accident monitoring instrumentation during this 3~-day interval. The action to submit a special report (within next 14 days) in lieu of a plant shutdown is acceptable because alternative actions are identified before a loss of functional capability. and there is low likelihood of plant conditions that would require information provided by this instrumentation. Also, the TS requires that the report discuss the root cause of the

-5 inoperability and identify proposed plans and schedule for restoring the instrumentation channel to operable status. The 7-day AOT, with two required channels inoperable, is acceptable because of the low probability of an event requiring post-accident monitoring instrumentation operation and the availability of alternate means to obtain the required information and is based on the operating experience. If the extended range neutron flux or startup rate indication is not available, an alternate method of monitoring subcriticality or startup rate is a combination of either the intermediate range or source range neutron flux indications. Therefore, requiring restoration of one inoperable channel limits the risk that the post-accident monitoring function will be in a degraded condition should an accident occur.

In addition, the proposed actions and AOTs are consistent with those approved in NUREG 1431, Revision 4, and TS 5.6.5, "Post Accident Monitoring Report."

Based on the above, the NRC staff concludes that the proposed changes are 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 October 2, 2012 (77 FR 60154). 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 wi" not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments wi" not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Kristy Bucholtz, NRRfDSSfSTSB Subinoy Mazumdar, NRRfDEfEICB Date: Apr i1 25, 2013

ML13008A528 *8E memo dated OFFICE NRRlDORLlLPL4/PM NRRlDORLlLPL4/LA NRRlDSS/STSB/BC NRRlDE/EICB/BC NAME BSingal JBurkhardt RElliott* JThorp*

DATE 3/7/13 3/5/13 11123/12 8119112 OFFICE !OGC-NLO NRR/DORULPL4/BC NRRlDORLlLPL4/PM MYoung MMarkley BSingal E 4/22/13 4/23/13 4/25/13