ML21319A355

Issuance of Amendment Nos. 224 and 209 to Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections

ML21319A355
Person / Time
Site:	South Texas
Issue date:	12/09/2021
From:	Dennis Galvin Plant Licensing Branch IV
To:	Gerry Powell South Texas
Galvin D
References
EPID L-2021-LLA-0151
Download: ML21319A355 (24)

Text

December 9, 2021 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. 224 AND 209 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-577, REVISION 1, REVISED FREQUENCIES FOR STEAM GENERATOR TUBE INSPECTIONS (EPID L-2021-LLA-0151)

Dear Mr. Powell:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 224 to Renewed Facility Operating License No. NPF-76 and Amendment No. 209 to Renewed Facility Operating License No. NPF-80 for the South Texas Project (STP),

Units 1 and 2, respectively. The amendments consist of changes to the technical specifications in response to your application dated August 10, 2021, as supplemented by letter dated September 9, 2021.

These amendments adopt Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, which is an approved change to the Standard Technical Specifications, into the STP, Units 1 and 2, technical specifications.

G. Powell A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly 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. 224 to NPF-76

2. Amendment No. 209 to NPF-80

3. Safety Evaluation

4. Notices and Environmental Findings cc: Listserv

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 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, and the City of Austin, Texas, dated August 10, 2021, as supplemented by letter dated September 9, 2021, 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.

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. 224, 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 Digitally signed by Jennifer L. Jennifer L. Dixon-Herrity Date: 2021.12.09 Dixon-Herrity 14:14:43 -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-76 and the Technical Specifications Date of Issuance: December 9, 2021

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 209 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, and the City of Austin, Texas , dated August 10, 2021, as supplemented by letter dated September 9, 2021, 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.

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. 209 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 Digitally signed by Jennifer L. Jennifer L. Dixon-Herrity Date: 2021.12.09 Dixon-Herrity 14:15:27 -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-80 and the Technical Specifications Date of Issuance: December 9, 2021

ATTACHMENT TO LICENSE AMENDMENT NOS. 224 AND 209 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 6-12 6-12 6-12a 6-12a 6-12b 6-12b 6-12c 6-12c 6-12d 6-12d 6-12e ---

6-12f ---

6-17 6-17

--- 6-17a

SOUTH TEXAS RENEWED LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 224 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. 224

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 209 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.

Renewed License No. NPF-80 Amendment No. 209

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

2) The ODCM shall also contain descriptions of the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating Report and the Radiological Effluent Release Report required by Specifications 6.9.1.3 and 6.9.1.4.

3) Licensee-initiated changes to the ODCM:

a) Shall be documented and records of reviews performed shall be retained.

This documentation shall contain:

1. Sufficient information to support the changes together with the appropriate analyses or evaluations justifying the changes and

2. A determination that the changes maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b) Shall become effective after approval of the plant manager.

c) Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (month and year) the change was implemented.

o. Steam Generator (SG) Program An SG Program shall be established and implemented to ensure that SG tube integrity is maintained. In addition, the SG Program shall include the following:

a. Provisions for condition monitoring assessments. Condition monitoring assessment means an evaluation of the "as found" condition of the tubing with respect to the performance criteria for structural integrity and accident induced leakage. The "as found" condition refers to the condition of the tubing during an SG inspection outage, as determined from the inservice inspection results or by other means, prior to the plugging of tubes. Condition monitoring assessments shall be conducted during each outage during which the SG tubes are inspected or plugged to confirm that the performance criteria are being met.

b. Performance criteria for SG tube integrity. SG tube integrity shall be maintained by meeting the performance criteria for tube structural integrity, accident induced leakage, and operational leakage.

SOUTH TEXAS - UNITS 1 & 2 6-12 Unit 1 - Amendment No. 151, 164, 209, 224 Unit 2 - Amendment No. 139, 154, 196, 209

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

1. Structural integrity performance criterion. All inservice SG tubes shall retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, and cooldown), all anticipated transients included in the design specification, and design basis accidents. This includes retaining a safety factor of 3.0 (3P) against burst under normal steady state full power operation primary-to-secondary pressure differential and a safety factor of 1.4 against burst applied to the design basis accident primary-to-secondary pressure differentials. Apart from the above requirements, additional loading conditions associated with the design basis accidents, or combination of accidents in accordance with the design and licensing basis, shall also be evaluated to determine if the associated loads contribute significantly to burst or collapse. In the assessment of tube integrity, those loads that do significantly affect burst or collapse shall be determined and assessed in combination with the loads due to pressure with a safety factor of 1.2 on the combined primary loads and 1.0 on axial secondary loads.

2. Accident induced leakage performance criterion. The primary-to-secondary accident induced leakage rate for any design basis accident, other than a SG tube rupture, shall not exceed the leakage rate assumed in the accident analysis in terms of total leakage rate for all SGs and leakage rate for an individual SG. Accident induced leakage is not to exceed 1 gpm total for all four SGs in one unit.

3. The operational leakage performance criterion is specified in LCO 3.4.6.2, Reactor Coolant System Operational Leakage.

c. Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.

d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed.

The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what locations.

1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation.

SOUTH TEXAS - UNITS 1 & 2 6-12a Unit 1 - Amendment No. 164, 209, 224 Unit 2 - Amendment No. 154, 196, 209

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

2. After the first refueling outage following SG installation, inspect 100% of the tubes in each SG at least every 96 effective full power months, which defines the inspection period.

3. If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall be at the next refueling outage. If definitive information, such as from examination of a pulled tube, diagnostic nondestructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack.

e. Provisions for monitoring operational primary-to-secondary leakage.

p. Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, which includes the following:

1) Actions to restore battery cells discovered with float voltage < 2.13 V;

2) Actions to equalize and test battery cells found with electrolyte level below the top of the plates;

3) Actions to verify that the remaining cells are > 2.07 V when a cell or cells are found to be

< 2.13 V; AND

4) Actions to ensure that specific gravity readings are taken prior to each discharge test.

q. Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Makeup and Cleanup Filtration System, CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident. The program shall include the following elements:

1. The definition of the CRE and the CRE boundary.

2. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.

SOUTH TEXAS - UNITS 1 & 2 6-12b Unit 1 - Amendment No. 164, 209, 224 Unit 2 - Amendment No. 154, 196, 209

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

3. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

1) C.1.2 -- No peer reviews are required to be performed.

4. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by two trains of the Control Room Makeup and Cleanup Filtration System, operating at the flow rate required by the Surveillance Requirement 4.7.7.c.3, at a Frequency of 18 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.

5. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph 3. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

6. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs 3 and 4, respectively.

SOUTH TEXAS - UNITS 1 & 2 6-12c Unit 1 - Amendment No. 209, 224 Unit 2 - Amendment No. 196, 209

6.0 ADMINISTRATIVE CONTROLS 6.8 Procedures, Programs, and Manuals 6.8.3.r Surveillance Frequency Control Program This program provides controls for surveillance frequencies. The program shall ensure that surveillance requirements specified in the technical specifications are performed at intervals sufficient to assure the associated limiting conditions for operations are met.

1) The Surveillance Frequency Control Program shall contain a list of frequencies of those surveillance requirements for which the frequency is controlled by the program.

2) Changes to the frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1.

STP takes the following exception to NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1:

a. STP will use the Independent Decisionmaking Panel (IDP) described in the applications approved by the NRC for the Graded Quality Assurance Program and the Exemption from Certain Special Treatment Requirements, augmented by the Surveillance Test Coordinator and Subject Matter Expert(s), to perform the IDP function.

3) The provisions of Surveillance Requirements 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

SOUTH TEXAS - UNITS 1 & 2 6-12d Unit 1 - Amendment No. 164, 180, 185, 209, 224 Unit 2 - Amendment No. 154, 167, 172, 196, 209

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6 (continued)

10. WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," March 1997, (W Proprietary).

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient)

11. WCAP 12472-P-A, "BEACON Core Monitoring and Operations Support System," August 1994 (W Proprietary), including Addenda 1-A (January 2000) and 4 (September 2012)

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

c. The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met.

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

6.9.1.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 6.8.3.o, "Steam Generator (SG) Program." The report shall include:

a. The scope of inspections performed on each SG;

b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;

c. For each degradation mechanism found:

1. The nondestructive examination techniques utilized;

2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4. The number of tubes plugged during the inspection outage.

SOUTH TEXAS - UNITS 1 & 2 6-17 Unit 1 - Amendment No.138, 144, 151, 164, 204, 209, 213, 224 Unit 2 - Amendment No 127, 132, 139, 154, 192, 196, 199, 209

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.7 (continued)

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;

e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and

f. The results of any SG secondary side inspections.

6.9.2 Not Used SOUTH TEXAS - UNITS 1 & 2 6-17a Unit 1 - Amendment No. 224 Unit 2 - Amendment No. 209

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-76 AND AMENDMENT NO. 209 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-80 STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 Application (i.e., initial and supplements) Safety Evaluation Date August 10, 2021, ADAMS Accession No. December 9, 2021 ML21222A227 Principal Contributors to Safety Evaluation September 9, 2021, ADAMS Accession Clinton Ashley No. ML21252A758

1.0 PROPOSED CHANGE

S STP Nuclear Operating Company (the licensee) requested changes to the technical specifications (TSs) for South Texas Project (STP), Units 1 and 2, by license amendment request (application). In its application, as supplemented, the licensee requested that the U.S.

Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendments under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the STP, Units 1 and 2, TS 6.8.3.o, Steam Generator Program and TS 6.9.1.7, Steam Generator Tube Inspection Report based on Technical Specifications Task Force (TSTF)

Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21060B434), and the associated NRC staff safety evaluation (SE) of TSTF-577 (ADAMS Accession No. ML21098A188).

The tubes within a steam generator (SG) function as an integral part of the reactor coolant pressure boundary and, in addition, isolate fission products in the primary coolant from the secondary coolant and the environment. SG tube integrity means that the tubes are capable of performing this safety function in accordance with the plant design and licensing basis.

STP Units 1 and 2 SGs have Alloy 690 thermally treated tubes.

Enclosure 3

1.1 Proposed TS Changes to Adopt TSTF-577 In accordance with NRC staff-approved TSTF-577, the licensee proposed changes that would revise STP, Units 1 and 2, TS 6.8.3.o and TS 6.9.1.7.

1.1.1 TS 6.8.3.o The introductory paragraph to TS 6.8.3.o would be revised by replacing steam generator with SG in a couple instances.

TS 6.8.3.o.d.2 would be revised by deleting the requirement to base inspection frequency on the more restrictive metric between either the effective full power months (EFPM) or refueling outage and to use just the EFPM metric.

TS 6.8.3.o.d.2 would be revised by deleting the requirement to inspect 100 percent of the tubes during each period in paragraphs d.2.a, d.2.b, d.2.c, and d.2.d (144, 120, 96, and 72 EFPM, respectively) and by adding the requirement to inspect 100 percent of the tubes every 96 EFPM.

TS 6.8.3.o.d.2 would be revised by deleting the allowance to extend the inspection period by 3 EFPM months and by deleting the discussion of prorating inspections.

TS 6.8.3.o.d.3 would be revised by replacing shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspections) with shall be at the next refueling outage.

1.1.2 TS 6.9.1.7 Existing reporting requirement b. would be renumbered as c. and be revised by editorial and punctuation changes.

New reporting requirement b. would be added to require the nondestructive examination techniques utilized for tubes with increased degradation susceptibility be reported.

Existing reporting requirement c. would be renumbered as c.1. and be revised by editorial and punctuation changes.

Existing reporting requirement d. would be renumbered as c.2. and be revised to note that the location, orientation (if linear), measured size (if available), and voltage response do not need to be reported for tube wear indications at support structures that are less than 20 percent through-wall. However, the total number of tube wear indications at support structures that are less than 20 percent through-wall would be reported.

New reporting requirement d. would be added to require an analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection relative to the applicable performance criteria, including the analysis, methodology, inputs, and results.

Existing reporting requirement e. would be renumbered as c.4. and be revised by editorial and punctuation changes.

Existing reporting requirement f. would be renumbered as e. and be revised by editorial and punctuation changes.

New reporting requirement f. would be added to require the results of any SG secondary side inspections be reported.

Existing reporting requirement g. would be renumbered as c.3. and be revised to add the requirements to report the margin to the tube integrity performance criteria and a comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment. In addition, the requirement to report the results of tube pulls and in situ testing would be deleted.

1.2 Additional Proposed TS Changes In addition to the changes proposed consistent with the traveler discussed in Section 1.1, the licensee identified three variations. For the first variation, the licensee noted that STP TSs have different numbering than standard technical specifications (STSs). For the second variation, the licensee noted that STP, Units 1 and 2, TS 6.8.3.o title, introductory paragraph, and paragraph b are revised to use the initialism SG in place of steam generator. For the third and final variation, the licensee noted that STP, Units 1 and 2, TS 6.9.1.7 is revised to add the title of TS 6.8.3.o.

2.0 REGULATORY EVALUATION

The regulations in Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.36(c)(5),

Administrative controls, state that [a]dministrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in

[10 CFR] 50.4. Technical Specification Section 5.0, Administrative Controls, requires that an SG Program be established and implemented to ensure that SG tube integrity is maintained.

Programs established by the licensee, including the SG Program, are listed in the administrative controls section of the TS to operate the facility in a safe manner.

The NRC staffs guidance for the review of TSs is in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor]

Edition (SRP), Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs.

Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with NUREG-14311, as modified by NRC-approved travelers.

TSTF-577 revised the STSs related to SG tube inspections and SG tube inspection reporting requirements. The NRC approved TSTF-577, under the CLIIP on April 14, 2021 (ADAMS Package Accession No. ML21099A086).

1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4, April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-577 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against the changes approved in TSTF-577. In accordance with SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-577 are applicable because STP is a pressurized-water reactor (PWR) design plant and the NRC staff approved the TSTF-577 changes for PWR designs. The NRC staff finds that the licensees proposed changes to the STP, Units 1 and 2, TSs in Section 1.1 of this SE are consistent with those found acceptable in TSTF-577.

In the SE of TSTF-577, the NRC staff concluded that the TSTF-577 changes to STS 5.5.9, Steam Generator (SG) Program, and STS 5.6.7, Steam Generator Tube Inspection Report, were acceptable because, as discussed in Section 3.0 of that SE, they continued to ensure SG tube integrity and, therefore, protected the public health and safety. In particular, the structural integrity performance criterion and accident-induced leakage performance criterion (explained in STS 5.5.9.b, items 1 and 2, respectively) will continue to be met with the proposed revised SG inspection intervals (maximum allowable time between SG inspections) and inspection periods (maximum allowable time between 100 percent of SG tubes inspections). Additionally, the proposed changes to the reporting requirements will provide more detailed and consistent information to the NRC. Therefore, the NRC staff found that the proposed changes to the SG program and inspection reporting requirements were acceptable because they continued to meet the requirements of 10 CFR 50.36(c)(5) by providing administrative controls necessary to assure operation of the facility in a safe manner. For these same reasons, the NRC staff concludes that the corresponding proposed changes to the STP, Units 1 and 2, TSs in Section 1.1 of this SE continue to meet the requirements of 10 CFR 50.36(c)(5).

3.2 Additional Proposed TS Changes 3.2.1 Editorial Variations The licensee identified three variations. For the first variation, the licensee noted that STP TSs have different numbering than the STS on which TSTF-577 was based. The NRC staff finds that different TS numbering is acceptable because it does not substantively alter TS requirements. For the second variation, the licensee noted that STP, Units 1 and 2, TS 6.8.3.o title, introductory paragraph, and paragraph b are revised to use the initialism SG in place of steam generator. The NRC staff finds the use of SG in place of steam generator is consistent with TSTF-577 and is acceptable because it does not substantively alter TS requirements. For the third and final variation, the licensee noted STP, Units 1 and 2, TS 6.9.1.7 is revised to add the title of TS 6.8.3.o. The NRC staff finds that adding the TS title is consistent with TSTF-577 and is acceptable because it does not substantively alter TS requirements.

3.3 TS Change Consistency The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16.0 of the SRP and are therefore acceptable.

4.0 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.

NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-76 AND AMENDMENT NO. 209 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-80 STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 Application (i.e., initial and supplements) Safety Evaluation Date August 10, 2021, ADAMS Accession No. December 9, 2021 ML21222A227 September 9, 2021, ADAMS Accession No. ML21252A758

1.0 INTRODUCTION

STP Nuclear Operating Company (the licensee) requested changes to the technical specifications (TSs) for South Texas Project (STP), Units 1 and 2, by license amendment request (application). In its application, as supplemented, the licensee requested that the U.S.

Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendments under the Consolidated Line Item Improvement Process. The proposed changes would revise the STP, Units 1 and 2, Steam Generator Program and the Steam Generator Tube Inspection Report TSs based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21060B434), and the associated NRC staff safety evaluation of TSTF-577 (ADAMS Accession No. ML21098A188).

2.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments on November 10, 2021. The State official had no comments.

3.0 ENVIRONMENTAL CONSIDERATION

The amendments relate, in part, to changes in recordkeeping, reporting, or administrative procedures or requirements. The amendments also relate, in part, to changing requirements with respect to the installation or use of facility components located within the restricted area as defined in Title 10 of the Code of Federal Regulations (10 CFR) Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no Enclosure 4

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 5, 2021 (86 FR 55013). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10). 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.

ML21319A355 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC (A)

NAME DGalvin PBlechman NJordan DATE 11/19/2021 12/8/2021 9/25/2021 OFFICE OGC / NLO NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME MSpencer JDixon-Herrity DGalvin DATE 12/7/2021 12/9/2021 12/9/2021