ML19217A060

Issuance of Amendment Nos. 217 and 203 Revision to Technical Specification Tables to Change Terminology for the P-13 Permissive Interlock Description

ML19217A060
Person / Time
Site:	South Texas
Issue date:	10/24/2019
From:	Geoffrey Miller Plant Licensing Branch IV
To:	Gerry Powell South Texas
Miller, Ed, 301-415-2481
References
EPID L-2019-LLA-0086
Download: ML19217A060 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 24, 2019 Mr. G. T. Powell President and CEO STP Nuclear Operating Company P.O. Box 289

\1\/adsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 217 AND 203 RE: REVISION TO TECHNICAL SPECIFICATION TABLES TO CHANGE TERMINOLOGY FOR THE P-13 PERMISSIVE INTERLOCK DESCRIPTION (EPID L-2019-LLA-0086)

Dear Mr. Powell:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 217 to Renewed Facility Operating License No. NPF-76 and Amendment No. 203 to Renewed 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 April 24, 2019.

The amendments revise TS Tables 2.2-1, "Reactor Trip System Instrumentation Trip Setpoints";

3.3-1, "Reactor Trip System Instrumentation"; and 4.3-1, "Reactor Trip System Instrumentation Surveillance Requirements," to change the description of the P-13 permissive interlock for the reactor trip system {RTS) instrumentation. The current phrases, "Turbine Impulse Chamber Pressure" and "Turbine Impulse Pressure," would be replaced with the phrase, "Turbine Inlet Pressure," throughout the TSs, resulting in a more generic P-13 description that does not specify a particular turbine design.

G. Powell A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sin;):

L>f>IJ,/ /(1 G. Edward Miller, 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. 217 to NPF-76

2. Amendment No. 203 to NPF-80

3. Safety Evaluation cc: L.istserv

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 RENEWED FACILITY OPERATING LICENSE Amendment No. 217 Renewed 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 April 24, 2019, 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;

8. 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 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 1

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 Renewed 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. 217, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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

~q_Q,_+~.~~ -~-~

Jennifer L Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-76 and Technical Specifications Date of Issuance: October 2 4 , 2 O1 9

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 RENEWED FACILITY OPERATING LICENSE Amendment No. 203 Renewed 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 April 24, 2019, 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 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. 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 Renewed 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. 203 and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the renewed 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

~.:i [C.S,~ J~j Jennifer L Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-80 and Technical Specifications Date of Issuance: October 2 4 , 2 O1 9

AITACHMENT TO LICENSE AMENDMENT NOS. 217 AND 203 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Renewed Facility Operating License 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.

Renewed Facility Operating License No. NPF-76 REMOVE INSERT Renewed Facility Operating License No. NPF-80 REMOVE INSERT Technical Specifications REMOVE INSERT 2-6 2-6 3/4 3-4 3/4 3-4 3/4 3-13 3/4 3-13

SOUTH TEXAS RENEWED LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 217, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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.

Renewed License No. NPF-76 Amendment No. 217

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 203 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed 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.

Renewed License No. NPF-80 Amendment No. 203

rn TABLE 2.2-1 (Continued) 0 Si

r: REACTOR TRIP SYSTEM INSTRUMENTATION TRIP SETPOINTS

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X

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rn FUNCTIONAL UNIT TRIP SETPOINT ALLOWABLE VALUE C

z 18. Reactor Trip System

~ Interlocks 0,

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Neutron FluJ, P-6

b. Low Power Reactor Trips Block, P-7

1) P-10 input .s10% of ATP** .s11.7% of RTP**

'}> 2) P-13 input .s10% ATP** Turbine .s11.7% RTP** Turbine 0)

Inlet Pressure Equivalent Inlet Pressure Equivalent

c. Power Range Neutron .s40% of RTP** .s41.7% of RTP**

Flux, P-8

d. Power Range Neutron .s50% of ATP** .s51.7% of RTP**

Flux, P-9 cc

, ::, e. Power Range Neutron 2:10% of RTP** 2:8.3% of RTP**

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• • RTP = RATED THERMAL POWER

~ TABLE 3.3-1 (Continued)

C

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REACTOR TRIP SYSTEM INSTRUMENTAT'ION iii

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CJ) MINIMUM C

• TOTAL NO. CHANNELS CHANNELS APPLICABLE z FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION

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19. Reactor Trip System lnter1ocks

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b. Low Power Reactor Trips Block, P-7 r

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.:,. or P-13 Input 2 1 2 1 8 C. Power Range Neutron Flux, P-8 4 2 3 1 8

d. Power Range Neutron Flux, P-9 4 2 3 1 8 cc

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C TABLE 4.3-1 (Continued)

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-i REACTOR TRIP SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS

~en I ANALOG TRIP ACTUATING MODES FOR C CHANNEL DEVICE WHICH z CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION SURVEILLANCE

-i FUNCTIONAL UNIT CHECKC20} CALIBRATIONC20} TEST (19}{20} TESTC20} LOGIC TEST(20} IS REQUIRED CQ

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19. Reactor Trip System N Interlocks

a. Intermediate Range Neutron Flux, P-6 N.A. (4) N.A. N.A. 2**

b. Low Power Reactor Trips Block, P-7 N.A. (4) N.A. N.A. 1

~ c. Power Range Neutron wI Flux, P-8 N.A. (4) N.A. N.A. 1

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d. Power Range Neutron Flux, P-9 N.A. (4) N.A. N.A. 1

e. Power Range Neutron Flux, P-10 N.A. (4) N.A. N.A. 1, 2

f. Turbine Inlet Pressure, cc

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20. Reactor Trip* Breaker N.A. N.A. N.A. (7, 11) N.A. 1, 2, 3*,4*, 5*

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 217 AND 203 TO RENEWED 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 April 24, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19114A535), STP Nuclear Operating Company (STPNOC, the licensee) requested changes to the technical specifications (TSs) for South Texas Project, Units 1 and 2 (STP Units 1 and 2). The proposed amendments would revise TS Tables 2.2-1, "Reactor Trip System Instrumentation Trip Setpoints"; 3.3-1, "Reactor Trip System Instrumentation"; and 4.3-1, "Reactor Trip System Instrumentation Surveillance Requirements,"

to change the description of the P-13 permissive interlock for the reactor trip system (RTS) instrumentation. The current phrases, "Turbine Impulse Chamber Pressure" and "Turbine Impulse Pressure," would be replaced with the phrase, "Turbine Inlet Pressure," throughout the TSs, resulting in a more generic P-13 description that does not specify a particular turbine design.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff reviews proposed changes to TSs for compliance with Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.36, "Technical specifications," and other regulatory requirements, including conformance with the general design criteria found in 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," to determine whether or not the proposed changes maintain adequate safety.

Licensees may revise their TSs provided that a plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered); (2) the change is more restrictive than the licensee's current requirement; or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards.

Enclosure 3

Criterion 13, "Instrumentation and control," of Appendix A to 10 CFR Part 50 is applicable to the review of this license amendment request (LAR). The criterion states:

Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

3.0 TECHNICAL EVALUATION

In the LAR dated April 24, 2019, the licensee proposed the revision of TS Tables 2.2-1, 3.3-1, and 4.3-1 to change the description of the P-13 permissive interlock for the RTS instrumentation. The phrases, "Turbine Impulse Chamber Pressure" and "Turbine Impulse Pressure," would be replaced with the phrase, "Turbine Inlet Pressure," throughout the TSs, resulting in a more generic P-13 description that does not specify a particular turbine design.

The term "impulse" in "Turbine Impulse Chamber Pressure" and "Turbine Impulse Pressure" refers to a particular type of turbine design.

The STP Units 1 and 2 are currently equipped with a combination of impulse and reaction blading with impulse blading in the first row. The licensee is planning a modification to the Unit 1 high pressure (HP) turbine that would eliminate the impulse row, converting it to a fully reaction turbine. As a result, a change of terminology within the TSs is needed. In both Table 3.3-1 and Table 4.3-1 of the STP TSs, the P-13 interlock is listed in Functional Unit 19.f.

as "Turbine Impulse Chamber Pressure, P-13." This proposed amendment would change this description to 'Turbine Inlet Pressure, P-13."

The LAR proposes no physical or design change to Function 19.f, the P-13 function, and will have no effect on the operation of the RTS. Currently, the P-13 permissive generates an interlock at a prescribed turbine pressure setpoint that is equivalent to a specified plant power level. As indicated by licensee, the only listed function of the P-13 permissive interlock is to provide an input to the P-7 permissive interlock. The P-13 signal is one of two inputs to the Low Power Reactor Trips Block, P-7. On increasing power, P-7 automatically enables reactor trips on low flow in more than one reactor coolant loop, reactor coolant pump bus undervoltage and under frequency, pressurizer low pressure, and pressurizer high level. On decreasing power, the above listed trips are automatically blocked. After approval of the LAR, the P-13 RTS interlock and signal would operate in the same manner.

The LAR proposes no changes to the other parts of Table 3.3.1-1 associated with the P-13 function (i.e., the applicable modes or other specified conditions, required channels, conditions, surveillances requirements, allowable value, or nominal trip setpoint).

The NRC staff agrees that this proposed change in the description of the STP Unit 1 turbines does not involve any physical or design change for the P-13 function and will have no effect on the operation of the reactor protection system. Therefore, the NRC staff concludes that the licensee's proposed terminology revision is acceptable because it results in a TS that is generic for turbine blade design and retains the required P-13 safety function.

Based on this evaluation, the NRC staff concludes that the proposed terminology revision is acceptable since no physical or design changes to the P-13 function are proposed. The LAR would provide greater flexibility with respect to the turbine blade design used at STP Units 1 and 2, but no changes are proposed to how the P-13 RTS interlock and signal would operate.

The NRC staff finds this change is administrative in nature and turbine design will continue to meet NRC requirements.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment on August 1, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. 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 published in the Federal Register on June 4, 2019 (84 FR 25840), and there has been no public comment on such finding.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(1 O)(v). 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) there is reasonable assurance that 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.

Principal Contributor: G. Curran Date: October 24, 2019

G. Powell

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 217 AND 203 RE: REVISION TO TECHNICAL SPECIFICATION TABLES TO CHANGE TERMINOLOGY FOR THE P-13 PERMISSIVE INTERLOCK DESCRIPTION (EPID L-2019-LLA-0086) DATED OCTOBER 24, 2019 DISTRIBUTION:

PUBLIC RidsNrrDssStsb Resource PM File Copy RidsNrrLAPBlechman Resource RidsACRS_MailCTR Resource RidsNrrPMSouthTexas Resource RidsNrrDeEicb Resource RidsRgn4MailCenter Resource RidsNrrDorlLpl4 Resource GCurran, NRR RidsNrrDssScpb Resource ADAMS Access1on No. ML19217A060 *b1y memoran d um ** via

. ema1*1 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA N RR/DSS/SCPB/BC NAME GEMiller PBlechman Sanderson*

DATE 10/21/19 9/18/19 7/10/19 OFFICE NRR/DE/EICB/BC (A) NRR/DSS/STSB/BC OGC NAME RAlvarado (WMorton for)** VCusumano** KGamin**

DATE 9/25/19 9/30/19 10/18/19 OFFICE NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM J Dixon-Herrity NAME (BSingal for) GEMiller DATE 10/24/19 10/24/19 OFFICIAL RECORD COPY