Text

Issuance of Amendment Nos. 220 and 205 to Revise Technical Specifications to Adopt TSTF-490, Deletion of E-Bar Definition and Revision to RCS Specific Activity Tech Spec
	ML20253A046
Person / Time
Site:	South Texas
Issue date:	09/29/2020
From:	Dennis Galvin; NRC/NRR/DORL/LPL4
To:	Gerry Powell; South Texas
	Dennis Galvin-NRR/DORL 301-415-6256
References
	EPID L-2020-LLA-0207
	Download: ML20253A046 (31)
	v • d • e

September 29, 2020 Mr. G. T. Powell President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 220 AND 205 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-490, DELETION OF E-BAR DEFINITION AND REVISION TO RCS SPECIFIC ACTIVITY TECH SPEC (EPID L-2019-LLA-0207)

Dear Mr. Powell:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 220 to Renewed Facility Operating License No. NPF-76 and Amendment No. 205 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 September 26, 2019.

The amendments revise TS requirements relating to reactor coolant system (RCS) activity limits. The changes are based upon Technical Specifications Task Force (TSTF) Traveler TSTF-490, Revision 0, Deletion of E Bar [] Definition and Revision to RCS Specific Activity Tech Spec. Specifically, the new TS limits are based on a new Dose Equivalent Xe

[Xenon]-133 definition that replaces the current Average Disintegration Energy definition.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions Federal Register notice.

Sincerely,

/RA/

Dennis J. Galvin, 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. 220 to NPF-76

2. Amendment No. 205 to NPF-80

3. Safety Evaluation cc: Listserv

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 220 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 September 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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.

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. 220, 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 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 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: September 29, 2020 Jennifer L.

Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2020.09.29 13:45:12 -04'00'

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 205 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 September 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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.

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. 205 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 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 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: September 29, 2020 Jennifer L.

Dixon-Herrity Digitally signed by Jennifer L. Dixon-Herrity Date: 2020.09.29 13:45:52 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NOS. 220 AND 205 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 i

i vii vii 1-3 1-3 3/4 4-26 3/4 4-26 3/4 4-27 3/4 4-27 3/4 4-28 3/4 4-28 3/4 4-29 3/4 4-29 3/4 4-30 3/4 4-30

SOUTH TEXAS RENEWED LICENSE Renewed License No. NPF-76 Amendment No. 220 (2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 220, 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-80 Amendment No. 205 (2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 205 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 Commissions 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.

INDEX SOUTH TEXAS - UNITS 1 & 2 i

Unit 1 - Amendment No. 9, 220 Unit 2 - Amendment No. 1, 205 1.0 DEFINITIONS SECTION PAGE 1.1 ACTION...................................................................................

1-1 1.2 ACTUATION LOGIC TEST.......................................................

1-1 1.3 ANALOG CHANNEL OPERATIONAL TEST............................

1-1 1.4 AXIAL FLUX DIFFERENCE......................................................

1-1 1.5 CHANNEL CALIBRATION........................................................

1-1 1.6 CHANNEL CHECK...................................................................

1-1 1.7 CONTAINMENT INTEGRITY....................................................

1-2 1.8 CONTROLLED LEAKAGE........................................................

1-2 1.9 CORE ALTERATIONS..............................................................

1-2 1.9a CORE OPERATING LIMITS REPORT.....................................

1-2 1.10 DIGITAL CHANNEL OPERATIONAL TEST.............................

1-2 1.11 DOSE EQUIVALENT I-131.......................................................

1-2 1.12 DOSE EQUIVALENT XE-133...................................................

1-3 1.13 ENGINEERED SAFETY FEATURES RESPONSE TIME.........

1-3 1.14 FREQUENCY NOTATION........................................................

1-3 1.15 GASEOUS WASTE PROCESSING SYSTEM..........................

1-3 1.16 IDENTIFIED LEAKAGE............................................................

1-3 1.17 MASTER RELAY TEST............................................................

1-4 1.18 MEMBER(S) OF THE PUBLIC.................................................

1-4 1.19 OFFSITE DOSE CALCULATION MANUAL..............................

1-4 1.20 OPERABLE - OPERABILITY....................................................

1-4 1.21 OPERATIONAL MODE - MODE...............................................

1-4 1.22 PHYSICS TESTS......................................................................

1-4 1.23 PRESSURE BOUNDARY LEAKAGE.......................................

1-4 1.24 PROCESS CONTROL PROGRAM..........................................

1-5 1.25 PURGE - PURGING.................................................................

1-5 1.26 QUADRANT POWER TILT RATIO...........................................

1-5 1.27 RATED THERMAL POWER.....................................................

1-5

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.4 REACTOR COOLANT SYSTEM 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION Startup and Power Operation 3/4 4-1 Hot Standby 3/4 4-2 Hot Shutdown 3/4 4-3 Cold Shutdown - Loops Filled 3/4 4-5 Cold Shutdown - Loops Not Filled 3/4 4-6 3/4.4.2 SAFETY VALVES Shutdown 3/4 4-7 Operating 3/4 4-8 3/4.4.3 PRESSURIZER 3/4 4-9 3/4.4.4 RELIEF VALVES 3/4 4-10 3/4.4.5 STEAM GENERATOR TUBE INTEGRITY 3/4 4-12 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE Leakage Detection Systems 3/4 4-19 Operational Leakage 3/4 4-20 TABLE 3.4-1 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES 3/4 4-22 3/4.4.7 (This specification not used) 3/4.4.8 SPECIFIC ACTIVITY 3/4 4-26 FIGURE 3.4-1 (This figure not used)

TABLE 4.4-4 (This table not used) 3/4.4.9 PRESSURE/TEMPERATURE LIMITS Reactor Coolant System 3/4 4-31 FIGURE 3.4-2 REACTOR COOLANT SYSTEM HEATUP LIMITATIONS -

APPLICABLE UP TO 32 EFPY 3/4 4-32 SOUTH TEXAS - UNITS 1 & 2 vii Unit 1 - Amendment No. 145, 164, 220 Unit 2 - Amendment No. 133, 154, 205

DEFINITIONS DOSE EQUIVALENT XE-133 1.12 DOSE EQUIVALENT XE-133 shall be the concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

ENGINEERED SAFETY FEATURES RESPONSE TIME 1.13 The ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF Actuation Setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

FREQUENCY NOTATION 1.14 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

GASEOUS WASTE PROCESSING SYSTEM 1.15 A GASEOUS WASTE PROCESSING SYSTEM shall be any system designed and installed to reduce radioactive gaseous effluents by collecting Reactor Coolant System offgases from the Reactor Coolant System and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the environment.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

a.

Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured and conducted to a sump or collecting tank, or

b.

Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE BOUNDARY LEAKAGE, or

c.

Reactor Coolant System leakage through a steam generator to the Secondary Coolant System.

SOUTH TEXAS - UNITS 1 & 2 1-3 Unit 1 - Amendment No. 130, 220 Unit 2 - Amendment No. 119, 205

REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 Reactor Coolant System DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

a. With the Reactor Coolant System DOSE EQUIVALENT I-131 not within the limit:

1. Verify DOSE EQUIVALENT I-131 60 microCuries per gram once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and

2. Restore DOSE EQUIVALENT I-131 to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

b. With the Reactor Coolant System DOSE EQUIVALENT XE-133 not within limit, restore DOSE EQUIVALENT XE-133 to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

c. With the requirements of ACTION a or ACTION b not met or DOSE EQUIVALENT I-131 exceeding 60 microCuries per gram, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

d.

The provisions of Specification 3.0.4.c are applicable to ACTION a and ACTION b.

SURVEILLANCE REQUIREMENTS 4.4.8.1 Verify Reactor Coolant System DOSE EQUIVALENT XE-133 specific activity 540 microCuries per gram at a frequency in accordance with the surveillance frequency control program.

4.4.8.2 Verify Reactor Coolant System DOSE EQUIVALENT I-131 specific activity 1.0 microCuries per gram:

a.

At a frequency in accordance with the surveillance frequency control program, and

b.

Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after THERMAL POWER change of 15 % or greater RATED THERMAL POWER within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period.

SOUTH TEXAS - UNITS 1 & 2 3/4 4-26 UNIT 1 - Amendment No. 170, 220 UNIT 2 - Amendment No. 158, 205

(This page not used)

SOUTH TEXAS - UNITS 1 & 2 3/4 4-27 UNIT 1 - Amendment No. 220 UNIT 2 - Amendment No. 205

FIGURE 3.4-1 (This figure not used)

SOUTH TEXAS - UNITS 1 & 2 3/4 4-28 UNIT 1 - Amendment No. 220 UNIT 2 - Amendment No. 205

Table 4.4-4 (This table not used)

SOUTH TEXAS - UNITS 1 & 2 3/4 4-29 UNIT 1 - Amendment No. 188, 220 UNIT 2 - Amendment No. 175, 205

(This page not used)

SOUTH TEXAS - UNITS 1 & 2 3/4 4-30 UNIT 1 - Amendment No. 220 UNIT 2 - Amendment No. 205

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 220 AND 205 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 letter dated September 26, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19269E978), STP Nuclear Operating Company (the licensee) submitted a license amendment request to the U.S. Nuclear Regulatory Commission (NRC, the Commission) for the South Texas Project, Units 1 and 2 (STP).

The proposed changes would revise technical specification (TS) requirements relating to reactor coolant system (RCS) activity limits. The changes are based upon Technical Specifications Task Force (TSTF) Traveler TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec, dated September 13, 2005 (ADAMS Accession No. ML052630462), which proposed changes to the Improved Standard Technical Specifications (ISTS) for RCS specific activity, including NUREG-1431, Volume 1, Standard Technical Specifications Westinghouse Plants - Specifications, Revision 3, June 2004 (ADAMS Accession No. ML041830612). The notice of availability for TSTF-490 was published in the Federal Register on March 19, 2007 (72 FR 12838), signifying NRC approval of TSTF-490.

The proposed STP changes would replace the current TS limit on RCS gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new Dose Equivalent Xe [Xenon]-133 (DEX) definition that would replace the current [E-Bar] Average Disintegration Energy definition.

2.0 REGULATORY EVALUATION

The NRC staff evaluated the impact of the proposed changes as they relate to the radiological consequences of affected design-basis accidents (DBAs) that use the RCS inventory as the source term.

2.1 Functional Description The source term assumed in radiological analyses should be based on the activity associated with either the projected fuel damage or the maximum RCS TS values, whichever maximizes the radiological consequences. The limits on RCS specific activity ensure that the offsite doses are appropriately limited for accidents that are based on releases from the RCS with no significant amount of fuel damage.

The steam generator tube rupture (SGTR) accident and main steam line break (MSLB) accident typically do not result in fuel damage; therefore, the radiological consequence analyses are generally based on the release of primary coolant activity at maximum TS limits. For accidents that result in fuel damage, the additional dose contribution from the initial activity in the RCS is not normally evaluated and is considered to be insignificant in relation to the dose resulting from the release of fission products from the damaged fuel.

For licensees using the alternative source term (AST) in their dose consequence analyses, the NRC staff uses the regulatory guidance provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water] Edition (SRP), Section 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms, Revision 0, dated July 2000 (ADAMS Accession No. ML003734190), and the methodology and assumptions stated in Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, dated July 2000 (ADAMS Accession No. ML003716792). Licensees using the AST are evaluated against the dose criteria specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67, Accident source term.

2.2 Description of the Proposed TS changes STP uses different numbering and format than the ISTS for RCS specific activity. This different numbering and format scheme results in a different description of the changes to the TSs and a different, but equivalent, final TS compared to those used in the TSTF-490 model safety evaluation. These differences are administrative and do not affect the applicability of TSTF-490 to the STP TSs and the associated technical justification from the model safety evaluation.

The licensee proposed the following changes:

1. The definition of - Average Disintegration Energy is removed from TS Section 1.0, Definitions, and the TS Index is updated to reflect this change.

2. A definition of Dose Equivalent XE-133 is added to TS Section 1.0 and the TS Index is updated to reflect this change.

3. Limiting Conditions for Operation (LCO) 3.4.8, Specific Activity, is revised from:

The specific activity of the reactor coolant shall be limited to:

a.

Less than or equal to 1 microCurie per gram DOSE EQUIVALENT I [Iodine]-131, and

b.

Less than or equal to 100/ microCuries per gram of gross radioactivity.

To:

Reactor Coolant System DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

4. LCO 3.4.8 Applicability is revised from:

MODES 1, 2, 3, 4 and 5 To:

MODES 1, 2, 3 and 4

5. The current ACTIONS for LCO 3.4.8 are removed.

6. The following ACTIONS for LCO 3.4.8 are proposed to state:

a. With the Reactor Coolant System DOSE EQUIVALENT I-131 not within limit:

1. Verify DOSE EQUIVALENT I-131 60 microCuries per gram once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , and

2. Restore DOSE EQUIVALENT I-131 to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

b. With the Reactor Coolant System DOSE EQUIVALENT XE-133 not within limit, restore DOSE EQUIVALENT XE-133 to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

c. With the requirements of ACTION a or ACTION b not met or DOSE EQUIVALENT I-131 exceeding 60 microCuries per gram, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

d. The provisions of Specification 3.0.4.c are applicable to ACTION a and ACTION b.

7. Current Surveillance Requirement (SR) 4.4.8 and its associated Table 4.4-4 are removed and the TS Index is updated to reflect this change.

8. Figure 3.4-1 is removed and the TS index is updated to reflect this change.

9. The following new SRs are added:

4.4.8.1 Verify Reactor Coolant System Dose Equivalent XE-133 specific activity 540 microCuries per gram at a frequency in accordance with the surveillance frequency control program.

4.4.8.2 Verify Reactor Coolant System Dose EQUIVALENT I-131 specific activity 1.0 microCuries per gram:

a.

At a frequency in accordance with the surveillance frequency control program, and

b.

Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after THERMAL POWER change of 15%

or greater RATED THERMAL POWER within a 1hour period.

2.3 Regulatory Requirements and Guidance 2.3.1 Regulatory Requirements The NRC staffs evaluation is based upon the following regulations and guidance:

Section 50.36(a)(1) of 10 CFR, under which an applicant for an operating license must include proposed TS in its application in accordance with the requirements of 10 CFR 50.36 and [a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls.... However, per 10 CFR 50.36(a)(1), these TS bases shall not become part of the technical specifications.

Section 50.36(b) of 10 CFR, which states that each license authorizing reactor operation will include TSs derived from the analyses and evaluation included in the safety analysis report and amendments thereto.

Section 50.36(c) of 10 CFR, which requires that TS include certain items. Per 10 CFR 50.36(c)(2)(i), Limiting conditions for operation, the TSs must include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The provision also requires that [w]hen 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 [TSs] until the condition can be met.

Section 50.36(c)(3) of 10 CFR, Surveillance requirements, under which TSs must include SRs, which 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.

Section 50.67 of 10 CFR, which states that any licensee that was initially authorized to operate prior to January 10, 1997, and who seeks to revise the current accident source term in its design basis radiological consequence analyses, must apply for a license amendment under 10 CFR 50.90, Application for amendment or license, construction permit, or early site permit.

The regulation in 10 CFR 50.67(b)(2) states that, The NRC may issue the amendment only if the applicants analysis demonstrates with reasonable assurance that:

(i) An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 0.25 Sv [Sievert]

(25 rem [roentgen Equivalent man]) total effective dose equivalent (TEDE).

(ii) An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage), would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).

(iii) Adequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) total effective dose equivalent (TEDE) for the duration of the accident.

Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, Criterion 19, Control room, which states, in part:

... holders of operating licenses using an alternative source term under § 50.67, shall meet the requirements of this criterion, except that with regard to control room access and occupancy, adequate radiation protection shall be provided to ensure that radiation exposures shall not exceed 0.05 Sv (5 rem) total effective dose equivalent (TEDE) as defined in [10 CFR 50.2, Definitions,] for the duration of the accident.

2.3.2 Regulatory Guidance The NRC staffs evaluation is based upon the following RG and SRP Sections:

RG 1.183, which provides guidance to licensees on performing evaluations and reanalyses in support of the implementation of an AST.

SRP Section 15.0.1, which provides guidance for an application for the initial implementation of an AST at operating power reactors and subsequent license amendment requests from these plants regarding the NRC staffs review of said applications.

The NRC staffs guidance for review of TSs in Section 16, Technical Specifications, of the SRP, Revision 3, dated March 2010 (ADAMS Accession No. ML100351425).

The NRC staff also considered relevant information in the STP Updated Final Safety Analysis Report, which describes the DBAs and evaluates their radiological consequences.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensees application to determine if the proposed changes are consistent with the guidance, regulations, and licensing information discussed in Section 2.0 of this safety evaluation and TSTF-490, Revision 0. In accordance with 10 CFR 10.92, Issuance of amendment, in determining whether an amendment to a license will be issued, the Commission is guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. In making its determination as to whether to amend the license, the NRC staff considered those regulatory requirements that are automatically conditions of the license through 10 CFR 50.54, Conditions of licenses.

3.1 TSTF-490 Background The primary coolant specific activity level is used in DBA analyses to determine the radiological consequences of accidents that involve the release of primary coolant activity with no substantial amount of fuel damage. For events that also include significant amounts of fuel damage, the contribution from the initial activity in the primary coolant is considered insignificant and is not normally evaluated.

The maximum allowable primary coolant specific activity is governed by TSs. Due to the importance of iodine in the dose consequence analyses, the TSs specify separate dose equivalent specific activity limits for the iodine isotopes and non-iodine isotopes. The limit for iodine isotopes is specified in units of Dose Equivalent I-131 (DEI), which is the normalized quantity of I-131 that would result in the same dose consequence as the combination of the major isotopes of iodine present in the primary coolant. The TSs for DEI include both an equilibrium long-term limit as well as a higher maximum allowable short-term limit, to account for iodine spiking.

The limit for non-iodine isotopes has traditionally been based on an evaluation of the average beta and gamma disintegration energy of the total non-iodine activity in the RCS, which is referred to as. The STP TSs define as the average (weighted in proportion to the concentration of each radionuclide in the sample) of the sum of the average beta and gamma energies per disintegration (MeV/d) for the isotopes, other than iodines, with half-lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant. The RCS non-iodine specific activity limit is then expressed as the quantity 100 divided by in units of microCuries per gram. In DBA dose consequence analyses, based on releases from the RCS with no significant fuel damage, the concentration of noble gas activity in the coolant is derived from that level associated with 1 percent fuel clad defects. Based on operating experience, depending on the isotopes used to calculate and the actual degree of fuel clad defects, the routinely calculated value of may not effectively indicate the level of noble gas activity relative to the levels used in the DBA dose consequence analyses on which the limit is based.

3.2 Technical Evaluation of TSTF-490 TS Changes 3.2.1 Deletion of the Definition of and the Addition of a New Definition for DEX The new definition for DEX is similar to the definition for DEI. The determination of DEX will be performed in a similar manner to that currently used in determining DEI, except that the calculation of DEX is based on the acute dose to the whole body and considers the noble gases krypton (Kr)-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135,

and Xe-138 actually present, which are significant in terms of contribution to whole-body dose.

Some noble gas isotopes are not included due to low concentration, short half-life, or small dose conversion factor (DCF). The calculation of DEX would use either the average gamma disintegration energies for the nuclides or the effective DCFs from Table III.1 of the U.S. Environmental Protection Agency (EPA) Federal Guidance Report No. 12. Using this approach, the limit on the amount of noble gas activity in the primary coolant would not fluctuate with variations in the calculated values of. If a specified noble gas nuclide is not detected, the new definition states that it should be assumed that the nuclide is present at the minimum detectable activity. This will result in a conservative calculation of DEX.

When is determined using a design-basis approach in which it is assumed that 1.0 percent of the power is being generated by fuel rods having cladding defects, and it is also assumed that there is no removal of fission gases from the letdown flow, the value of is dominated by Xe-133. The other nuclides have relatively small contributions. However, during normal plant operation, there are typically only a small amount of fuel clad defects, and the radioactive nuclide inventory can become dominated by tritium and corrosion and/or activation products, resulting in the determination of a value of that is very different than would be calculated using the design-basis approach. Because of this difference, the accident dose analyses become disconnected from plant operation, and the LCO becomes essentially meaningless. This difference also results in a TS limit that can vary during operation as different values for are determined.

This proposed change will implement an LCO that is consistent with the whole-body radiological consequence analyses, which are sensitive to the noble gas activity in the primary coolant but not to other non-gaseous activity currently captured in the definition. TS LCO 3.4.8 specifies the limit for reactor coolant specific activity of the RCS as 100/ microCuries per gram. The current definition includes radioisotopes that decay by the emission of both gamma and beta radiation. The current Action B of TS LCO 3.4.8 would rarely, if ever, be entered for exceeding 100/, since the calculated value is very high (the denominator is very low) if beta emitters such as tritium are included in the determination, as required by the definition.

The following TS 1.12 definition -AVERAGE DISINTEGRATION ENERGY is deleted:

shall be the average (weighted in proportion to the concentration of each radionuclide in the sample) of the sum of the average beta and gamma energies per disintegration (MeV/d) for the isotopes, other than iodines, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.

The new definition DOSE EQUIVALENT XE-133, replaces the above -AVERAGE DISINTEGRATION ENERGY definition. The added definition for DEX states:

DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

The licensees proposed deletion of the above-stated definition for and addition of a new definition for DEX in TS 1.12 is acceptable from a radiological dose perspective since it will result in an LCO that more closely relates the non-iodine RCS activity limits to the dose consequence analyses that form their bases.

3.2.2 Revision of TS 3.4.8, LCO STP TS LCO 3.4.8 is modified to specify that iodine specific activity in terms of DEI and noble gas specific activity in terms of DEX shall be within limits. The proposed change replaces the current language, quoted above in Section 2.2, the specific activity of the reactor coolant with new language that limits Reactor Coolant System DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity. The modified TS LCO 3.4.8 would state, Reactor Coolant System DOSE EQUIVALENT I-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits. The NRC staff finds that this proposed change is technically equivalent to the current LCO and clarifies that the RCS specific activity limits are DEI and DEX and thus is acceptable.

3.2.3 TS 3.4.8 Applicability The current STP TS 3.4.8 has one action statement with applicability Modes 1-5 and a second set of three action statements with applicability Modes 1-3. The set of three action statements only applies with the RCS average temperature (Tavg) greater than or equal to 500 °F. TS 3.4.8 Applicability is modified to remove the different sets of action statements based on Tavg and to remove Mode 5, such that there is now one group of action statements with applicability Modes 1-4. The LCO needs to apply during Modes 1 through 4 to limit the potential radiological consequences of an SGTR or MSLB that may occur during these Modes. In Mode 5, with the RCS loops filled, the steam generators are specified as a backup means of decay heat removal by natural circulation. In this Mode, however, due to the reduced temperature of the RCS, the probability of a DBA involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required. In Mode 5, with the RCS loops not filled, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary-to-secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required. The proposed change to modify the TS 3.4.8 Applicability to include Modes 1, 2, 3, and 4 is necessary to limit the potential radiological consequences of an SGTR or MSLB that may occur during these Modes and is, therefore, acceptable from a radiological dose perspective.

3.2.4 TS 3.4.8 Action a Revision The STP TS 3.4.8 current Action statements use a different numbering and format scheme than the ISTS. Both the current STP Action a and the unnumbered action contain equivalent actions to the initial ISTS Condition A (i.e., DEI greater than 1 microCurie per gram). The language in those action statements equivalent to ISTS Condition A reads, With the specific activity of the reactor coolant greater than 1 microCurie per gram DOSE EQUIVALENT I-131. These actions are replaced with a new Action a that is equivalent to the post-TSTF-490 ISTS Condition A (i.e.,

With the Reactor Coolant System DOSE EQUIVALENT I-131 not within limit). The site-specific DEI limit of 1 microCurie per gram in Action a is relocated to the new SR 4.4.8.2. These numbering and format changes are to be equivalent with the modified ISTS and have no impact from the radiological dose perspective.

The STP TS 3.4.8 current Action c, which states, Specification 3.0.4.c is applicable, is equivalent to the ISTS Note in the Required Action for Condition A without TSTF-490 implemented and the TSTF-490 proposed Note to be added to the Required Action for Condition B in the ISTS. STP TS 3.4.8 current Action c is renumbered as Action d and revised to state, The provisions of Specification 3.0.4.c are applicable to ACTION a and ACTION b.

This is to reformat the Actions for STP TS 3.4.8 to be equivalent to the ISTS. This is an administrative change, and therefore, is acceptable.

The current STP Action a and the unnumbered Action contain actions equivalent of the initial ISTS Required Action A.1 without TSTF-490 implemented. Under initial ISTS Required Action A.1 licensees must [v]erify Dose Equivalent I-131 within the acceptable region of Figure 3.4.16-1, with a Completion Time (CT) of once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The STP current Action a requires a shutdown for exceeding the limit line shown on Figure 3.4-1, Dose Equivalent I-131 Reactor Coolant Specific Activity Limit Versus Percent of Rated Thermal Power With The Reactor Coolant Specific Activity > 1 µCi/gram Dose Equivalent I-131. STP Figure 3.4-1 is equivalent to the initial ISTS Figure 3.4.16-1. The STP current unnumbered Action requires the performance of the sampling and analysis requirements of Item 4.a) of Table 4.4-4, until the specific activity of the reactor coolant is restored to within its limits. STP Table 4.4-4, Reactor Coolant Specific Activity Sample And Analysis Program, Item 4.a) requires, in part, the isotopic analysis for iodine once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , whenever the specific activity exceeds 1 microCurie per gram DEI. Combined, STP Action a and the unnumbered Action then are equivalent to ISTS Required Action A.1. The new Action a.1 removes the reference to Figure 3.4-1 and inserts a limit of less than or equal to the site-specific DEI spiking limit, which is 60 microCuries per gram.

The TSTF-490 change to the ISTS requires licensees to [v]erify DOSE EQUIVALENT I-131

[60] microCuries per gram once every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . These two changes are, therefore, equivalent.

The radiological dose consequence analysis for the SGTR and MSLB accidents take into account the pre-accident iodine spike and does not consider the elevated RCS iodine specific activities permitted by Figure 3.4-1 for operation at power levels below 80 percent rated thermal power. Instead, the pre-accident iodine spike analyses assume a DEI concentration 60 times higher than the corresponding long-term equilibrium value, which corresponds to the specific activity limit associated with 100 percent rated thermal power operation. It is acceptable that TS 3.4.8 Action a.1 is based on the short-term, site-specific DEI spiking limit to be consistent with the assumptions contained in the radiological consequence analyses.

The current STP Action a states, With the specific activity of the reactor coolant greater than 1 microCurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval,.... This action is equivalent to the initial ISTS Required Action A.2 (i.e., Restore Dose Equivalent I-131 to within limit with a CT of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ). STP Action a is replaced with a new Action a.2 that is equivalent to the ISTS change in TSTF-490. This numbering and format change is to be equivalent with the modified ISTS and has no impact from the radiological dose perspective.

3.2.5 TS 3.4.8 Action b Revision to Include Action for DEX Limit STP TS 3.4.8 Action b is modified to provide an Action for when DEX is not within limit, and to remove the limit associated with gross activity of the reactor coolant (). This change is made to be consistent with the change to TS LCO 3.4.8, which requires the DEX specific activity to be within limits, as discussed above in Section 3.2.2. This change is equivalent to the change to Condition B in the ISTS implemented by TSTF-490. The DEX limit is site-specific, and the

numerical value of 540 microCuries per gram is contained in new SR 4.4.8.1. The site-specific limit of 540 microCuries per gram DEX is established based on the maximum accident analysis RCS activity corresponding to 1 percent fuel clad defects with sufficient margin to accommodate the exclusion of those isotopes based on low concentration, short half-life, or small DCFs. The primary purpose of TS LCO 3.4.8 on RCS specific activity and its associated conditions is to support the dose analyses for DBAs. The whole-body dose is primarily dependent on the noble gas activity, not the non-gaseous activity currently captured in the definition.

The CT for new TS 3.4.8 Action b requires restoration of DEX to within the limit in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

This is consistent with the proposed CT for TS 3.4.8 Action a.1 for DEI. The radiological consequences for the SGTR and the MSLB accidents demonstrate that the calculated thyroid doses are generally a greater percentage of the applicable acceptance criteria than the calculated whole-body doses. It then follows that the CT for noble gas activity being out of specification in new Action b should be at least as great as the CT for iodine specific activity being out of specification in revised Action a.2. Therefore, the CT of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for new Action b.1 is acceptable from a radiological dose perspective because it is expected that if there were a xenon spike in the normal coolant, iodine concentration would be restored within this time period. In addition, there is a low probability of an SGTR or a MSLB occurring during this time period.

The STP TS 3.4.8 current Action c, Specification 3.0.4.c is applicable, is equivalent to the Note in the Required Action for Condition A and the Note added to the Required Action for Condition B in the ISTS. STP TS 3.4.8 current Action c is renumbered as Action d and revised to state, The provisions of Specification 3.0.4.c are applicable to ACTION a and ACTION b.

This Action would allow entry into a Mode or other specified condition in the LCO Applicability when LCO 3.4.8 is not being met. The proposed Note would allow entry into the applicable Modes from Mode 4 to Mode 1 (power operation) while the DEX limit is exceeded and the DEX is being restored to within its limit. This Mode change is acceptable due to the significant conservatism incorporated into the DEX specific activity limit; the low probability of an event occurring, which is limiting due to exceeding the DEX specific activity limit; and the ability to restore transient specific excursions while the plant remains at, or proceeds to power operation.

3.2.6 TS 3.4.8 Action c Revision Initial ISTS Condition C states, Required Action and associated Completion Time of Condition A not met OR [DEI] in the unacceptable region of Figure 3.4.16-1. If this condition is met, under the associated Required Action licensees must [b]e in MODE 3 with Tavg [less than]

500°F. Per the relevant CT, they must do this within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The STP equivalent to this is found in the current STP Action a which states, With the specific activity of the reactor coolant greater than 1 microCurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval, or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with Tavg less than 500 °F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

TSTF-490 revises Condition C to include Condition B (DEX not within limit) if the Required Action and associated CT of Condition B is not met. An equivalent change is made to STP TS 3.4.8 by renumbering Action a to Action c and replacing the first part of Action a to state, With the requirements of ACTION a or ACTION b not met. This is consistent with the changes made to Action b, which now provides the same CT for both components of RCS specific activity as discussed in the revision to Action b. The change to ISTS Condition C also replaces

the limit on DEI from the deleted figure with a site-specific value. An equivalent change is included in the new STP Action c by replacing the limit on DEI from the deleted Figure 3.4-1 with a site-specific value of 60 microCuries per gram. This change makes new STP Action c consistent with the changes made to Action a.1.

The initial ISTS Required Action C.1 is Be in MODE 3 with Tavg 500 °F, with a CT of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

STPs current equivalent requirement is in the current STP Action a as be in at least HOT STANDBY with Tavg less than 500°F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The proposed change to STP TS 3.4.8 Action a, which is renumbered to STP TS 3.4.8 Action c, deletes the requirement for average RCS temperature to be less than 500 °F and adds a new requirement for the plant to be in COLD SHUTDOWN (i.e. Mode 5) within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This is equivalent to the changes to ISTS Required Action C.1, the addition of a new Required Action C.2, and the associated CTs.

These changes are consistent with the changes made to the Applicability, discussed above.

The revised LCO is applicable throughout all of Modes 1 through 4 to limit the potential radiological consequences of a SGTR or MSLB that could occur during these Modes. In Mode 5 with the RCS loops filled, the steam generators are specified as a backup means of decay heat removal via natural circulation. In this Mode however, due to the reduced temperature of the RCS, the probability of a DBA involving the release of significant quantities of RCS inventory is greatly reduced. Therefore, monitoring of RCS specific activity is not required.

In Mode 5 with the RCS loops not filled and in Mode 6, the steam generators are not used for decay heat removal, the RCS and steam generators are depressurized, and primary-to-secondary leakage is minimal. Therefore, the monitoring of RCS specific activity is not required.

The new CT of Action c of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with the new CT in the ISTS and is reasonable, based on operating experience, to reach Mode 5 from full-power conditions in an orderly manner and without challenging plant systems and the value of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with other TSs, which have a CT to reach Mode 5.

3.2.7 SR 4.4.8.1 DEX Surveillance The combination of the current STP LCO 3.4.8.b; SR 4.4.8; and Item 1 of Table 4.4-4, which is the SR for gross radioactivity determination, are equivalent to the initial ISTS SR 3.4.16.1, the surveillance for RCS gross specific activity. Equivalent to the TSTF-490 change, these are replaced by a new SR 4.4.8.1 with a requirement to verify that the RCS DEX specific activity is less than or equal to 540 microCuries per gram, which is the site-specific limit for STP. This change provides a surveillance for the new LCO limit added to TS 3.4.8 for DEX. The revised SR 4.4.8.1 surveillance requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant in accordance with the surveillance frequency control program, which is the same frequency required under the current SR 4.4.8 for RCS gross non-iodine specific activity. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the reactor coolant sample taken to perform the revised SR 4.4.8.1. The surveillance provides an indication of any increase in the noble gas specific activity. The results of the surveillance on DEX allow proper remedial actions to be taken before reaching the LCO limit under normal operating conditions; therefore, the deletion of SR 4.4.8 regarding gross radioactivity determination and the addition of SR 4.4.8.1 are acceptable.

3.2.8 SR 4.4.8.2 DEI Surveillance The combination of the current STP TS LCO 3.4.8.a, SR 4.4.8, and Items 2 and 4.b of Table 4.4-4 are equivalent to initial ISTS SR 3.4.16.2, the surveillance for DEI specific activity.

These are replaced with a new SR 4.4.8.2, with SR 4.4.8.2.a replacing Item 2 of Table 4.4-4 and SR 4.4.8.2.b replacing Item 4.b of Table 4.4-4. This is a format change to more closely resemble the corresponding SR in the ISTS and is administrative and is therefore acceptable.

3.2.9 Deletion of E Bar Determination Surveillance The combination of the current STP SR 4.4.8 and Item 3 of Table 4.4-4, which is the radiochemical for determination, is equivalent to the initial ISTS, SR 3.4.16.3, the surveillance for the determination of. As with the TSTF-490 change, this surveillance is deleted. This is acceptable since TS LCO 3.4.8 on RCS specific activity supports the dose analyses for DBAs in which the whole-body dose is primarily dependent on the noble gas concentration, not the non-gaseous activity currently captured in the definition. With the elimination of the limit for RCS gross specific activity and the addition of the new LCO limit for noble gas specific activity, this SR to determine is no longer required.

With the relocation of STP TS Table 4.4-4 Items 1, 2, 3, and 4b to SRs 4.4.8.1 and 4.4.8.2, and the relocation of STP Table 4.4-4 Item 4a to Action a.1, SR 4.4.8 and Table 4.4-4 are no longer needed and the NRC staff finds their deletion acceptable.

3.3 Technical Evaluation Conclusion

The NRC staff reviewed the licensees changes to revise the STP TSs with changes equivalent to those found in TSTF-490. This includes, replacing the current specific activity of the reactor coolant limits with limits on RCS DEI and DEX specific activity. The NRC staff reviewed the proposed changes to (1) delete the reactor coolant gross activity limit, its associated conditions, required actions, and SRs, (2) delete the determination of, and (3) add a new DEX limit, its associated conditions, required actions, and SRs, and has concluded that the changes are consistent with the methodology used to analyze the radiological consequences of the SGTR and MSLB accidents.

The NRC staff reviewed the proposed changes and determined, based on the preceding discussions, that the TSs, as revised by the proposed changes, meet the standards for TSs in 10 CFR 50.36(b) and 10 CFR 50.36(c). Further, based on the preceding discussions, the proposed SRs assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met and satisfy 10 CFR 50.36(c)(3). Additionally, the changes to the TS were reviewed for technical clarity and consistency with customary terminology and format in accordance with SRP Section 16. The NRC staff concludes that the TS, as amended by the proposed changes, meet the requirements stated in 10 CFR 50.36 and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments on September 4, 2020. 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 or SRs. 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, as published in the Federal Register on December 31, 2019 (84 FR 72388) 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)(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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions 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: Sean Meighan Date: September 29, 2020

ML20253A046

via email concurrence OFFICE NRR/DORL/LPL4/PM*

NRR/DORL/LPL4/LA*

NRR/DRA/ARCB/BC*

NAME DGalvin PBlechman KHsueh DATE 9/11/2020 9/11/2020 7/1/2020 OFFICE NRR/DSS/STSB/BC*

OGC*

NRR/DORL/LPL4/BC*

NAME VCusumano Mertz JDixon-Herrity DATE 9/9/2020 9/23/2020 9/29/2020 OFFICE NRR/DORL/LPL4/PM*

NAME DGalvin DATE 9/29/2020

v t e Letter Sequence Approval
EPID:L-2019-LLA-0207, TSTF-490 (Approved, Closed) EPID:L-2020-LLA-0207, (Approved, Closed)
Initiation Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2020-09-29 [Table View]

ML20253A046

Text

SUBJECT:

Dear Mr. Powell:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

3.3 Technical Evaluation Conclusion

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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