ML23015A001

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Issuance of Amendment Nos. 225 and 210 to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements
ML23015A001
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 02/06/2023
From: Dennis Galvin
Plant Licensing Branch IV
To: Gerry Powell
South Texas
Galvin D
References
EPID L-2022-LLA-0113
Download: ML23015A001 (21)
v • d • e


Text

February 6, 2023 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. 225 AND 210 TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-554, REVISION 1, REVISE REACTOR COOLANT LEAKAGE REQUIREMENTS (EPID L-2022-LLA-0113)

Dear Mr. Powell:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 225 to Renewed Facility Operating License No. NPF-76 and Amendment No. 210 to Renewed Facility Operating License No. NPF-80 for South Texas Project (STP),

Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated August 9, 2022, as supplemented by letters dated September 1, 2022, and January 26, 2023.

These amendments adopt into the TSs for STP, Units 1 and 2, Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revise Reactor Coolant Leakage Requirements, Revision 1, which is an approved change to the Standard 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. 225 to NPF-76
2. Amendment No. 210 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. 225 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 9, 2022, as supplemented by letters dated September 1, 2022, and January 26, 2023, 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. 225, 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 Jennifer L. Digitally signed by Jennifer L. Dixon-Herrity Dixon-Herrity Date: 2023.02.06 15:33:58 -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: February 6, 2023

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 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 9, 2022, as supplemented by letters dated September 1, 2022, and January 26, 2023, 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. 210 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 Jennifer L. Digitally signed by Jennifer L. Dixon-Herrity Dixon-Herrity Date: 2023.02.06 15:34:38 -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: February 6, 2023

ATTACHMENT TO LICENSE AMENDMENT NOS. 225 AND 210 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 Renewed Facility Operating License Nos. NPF-76 and NPF-80 and the 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 13 13 14 14 3/4 420 3/4 420

SOUTH TEXAS RENEWED LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 225 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. 225

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 210 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. 210

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 PROCESING 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 to not interfere with the operation of Leakage Detection Systems, 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, 225 Unit 2 - Amendment No. 119,205, 210

DEFINITIONS MASTER RELAY TEST 1.17 A MASTER RELAY TEST shall be the energization of each master relay and verification of OPERABILITY of each relay. The MASTER RELAY TEST shall include a continuity check of each associated slave relay.

MEMBER(S) OF THE PUBLIC 1.18 MEMBER(S) OF THE PUBLIC means an individual in a controlled area or UNRESTRICTED AREA. However, an individual is not a member of the public during any period in which the individual receives an occupational dose.

1.19 Not Used OPERABLE - OPERABILITY 1.20 A system, subsystem, train, component or device shall be OPERABLE or have OPERABLITY when it is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

OPERATIONAL MODE - MODE 1.21 An OPERATIONAL MODE (i.e., MODE) shall correspond to any one inclusive combination of core reactivity condition, power level, and average reactor coolant temperature specified in Table 1.2.

PHYSICS TESTS 1.22 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation: (1) described in Chapter 14.0 of the FSAR, (2) authorized under the provisions of 10 CFR 50.59, or (3) otherwise approved by the Commission.

PRESSURE BOUNDARY LEAKAGE 1.23 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator tube leakage) through a fault in a Reactor Coolant System component body, pipe wall, or vessel wall. Leakage past seals, packing, and gaskets is not PRESSURE BOUNDARY LEAKAGE.

SOUTH TEXAS - UNITS 1 & 2 1-4 Unit 1 - Amendment No. 47,52,57,151, 225 Unit 2 - Amendment No. 36,41,46,139, 210

REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE LIMITING CONDITION FOR OPERATION 3.4.6.2 Reactor Coolant System operational leakage shall be limited to:

a. No PRESSURE BOUNDARY LEAKAGE,
b. 1 gpm UNIDENTIFIED LEAKAGE,
c. 150 gallons per day of primary-to-secondary leakage through any one steam generator,
d. 10 gpm IDENTIFIED LEAKAGE from the Reactor Coolant System, and
e. 0.5 gpm leakage per nominal inch of valve size up to a maximum of 5 gpm at a Reactor Coolant System pressure of 2235 +/- 20 psig from any Reactor Coolant System Pressure Isolation Valve specified in Table 3.4-1.*

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

ACTION:

a. With any PRESSURE BOUNDARY LEAKAGE, isolate the affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b. With Reactor Coolant System operational UNIDENTIFIED or IDENTIFIED LEAKAGE greater than the above limits, reduce leakage to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
c. With primary-to-secondary leakage not within the limit, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
d. With any Reactor Coolant System Pressure Isolation Valve leakage greater than the above limit, isolate the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least two closed manual or deactivated automatic valves, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
  • Test pressures less than 2235 psig but greater than 150 psig are allowed. Observed leakage shall be adjusted for the actual test pressure up to 2235 psig assuming the leakage to be directly proportional to pressure differential to the one-half power.

SOUTH TEXAS - UNITS 1 & 2 3/4 4-20 Unit 1 - Amendment No. 83, 90, 164, 225 Unit 2 - Amendment No. 77, 154, 210

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 225 TO RENEWED FACILITY OPERATING LICENSE NO. NPF76 AND AMENDMENT NO. 210 TO RENEWED FACILITY OPERATING LICENSE NO. NPF80 STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50498 AND 50499 Application (i.e., initial and supplements) Safety Evaluation Date

  • August 9, 2022, ADAMS Accession No. February 6, 2023 ML22221A212 Principal Contributors to Safety

1.0 PROPOSED CHANGE

S STP Nuclear Operating Company (the licensee) requested changes to the technical specifications (TSs) for South Texas Project, Units 1 and 2 (STP). 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 TSs related to reactor coolant system (RCS) operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20016A233), and the associated NRC staff safety evaluation (SE) of TSTF-554 (ML20322A024).

Components that contain or transport the coolant to or from the reactor core make up the RCS.

Materials can degrade as a result of the complex interaction of the materials, the stresses they encounter, and through operational wear or mechanical deterioration during normal and upset operating environments. Such material degradation could lead to leakage of reactor coolant into containment buildings.

The RCS leakage falls under two main categories identified leakage and unidentified leakage. Identifying the sources of leakage is necessary for prompt identification of potentially adverse conditions, assessment of the safety significance of the leakage, and quick corrective action. A limited amount of leakage from the reactor coolant pressure boundary (RCPB) directly into the containment atmosphere is expected as the RCS and other connected systems cannot Enclosure 3

be made 100 percent leak tight. This leakage is detected, located, and isolated from the containment atmosphere so as to not interfere with measurement of unexpected RCS leakage detection.

The safety significance of RCS leakage varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS leakage into the containment area is necessary. Separation of identified leakage from unidentified leakage provides quantitative information to the operators, allowing them to take corrective action should leakage occur that is detrimental to the safety of the unit and the public.

1.1 Proposed TS Changes to Adopt TSTF-554 The licensee proposed changes consistent with NRC staff-approved TSTF-554 that would revise the TSs related to RCS operational leakage and the definitions of leakage. Specifically, the licensee proposed the following changes be made to the STP TSs in order to adopt TSTF-554:

  • Additionally, the IDENTIFIED LEAKAGE and PRESSURE BOUNDARY LEAKAGE definitions would be revised by other editorial changes to reflect the deletions and listed definitions.

o Existing ACTION a. would be revised to delete the phrase or with primary to secondary leakage not within limit and add the phrase isolate the affected component, pipe, or vessel from the RCS by use of a closed manual valve, closed and de-activated automatic valve, blind flange, or check valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or.

o Existing ACTION c. would be renumbered to ACTION d.

o New ACTION c. would be added to state, With primary-to-secondary leakage not within the limit, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

1.2 Additional Proposed TS Changes The application identified variations from TSTF-554. Section 3.2 of this SE provides a description of the variations and the NRC staffs evaluation.

2.0 REGULATORY EVALUATION

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2) requires that TSs include limiting conditions for operation (LCOs). Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation 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 technical specifications until the condition can be met.

The regulation at 10 CFR 50.2 defines RCPB as all those pressure-containing components of boiling and pressurized water-cooled nuclear power reactors, such as pressure vessels, piping, pumps, and valves Regulatory Guide (RG) 1.45, Revision 1, Guidance on Monitoring and Responding to Reactor Coolant System Leakage, dated May 2008 (ML073200271), section B, Discussion Leakage Separation, provides information related to separation between identified and unidentified leakage.

The NRC staffs guidance for the review of TSs is in chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), dated March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared standard technical specifications (STS) for each of the LWR nuclear designs.

Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with NUREG1431, 1 as modified by NRC-approved travelers. Traveler TSTF-554 revised the STS related to RCS operational leakage and the definition of the term LEAKAGE.

The NRC-approved TSTF-554, under the CLIIP on December 18, 2020 (ML20324A083).

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-554 The NRC staff compared the licensees proposed TS changes in section 1.1 of this SE to the changes approved in TSTF-554. In accordance with the SRP chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-554 are applicable to the STP TSs because STP is a Westinghouse pressurized-water reactor (PWR) and the NRC staff approved the TSTF-554 changes for PWR designs. The NRC staff finds that the licensees proposed changes to the STP TSs in section 1.1 of this SE are consistent with those the staff found acceptable in TSTF-554.

In the SE of TSTF-554, the NRC staff concluded that TSTF-554 changes to the STS 1.1 definition of LEAKAGE and to STS 3.4.13, the LCO addressing conditions and required actions when RCS pressure boundary leakage exists, are acceptable. The NRC staff found that removing the term nonisolable provides a clearer definition of pressure boundary leakage, and that the source of the leakage is not relevant to this capability provided that separate, appropriate limits on pressure boundary leakage have been established. Therefore, the proposed change to the definition of identified leakage was acceptable as it did not conflict with 1

U. S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG 1431, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively)

the RCPB definition in 10 CFR 50.2 and was consistent with RG 1.45. The NRC staff further found that the proposed revision to STP TS 3.4.6.2, Action a regarding pressure boundary leakage, which is consistent with the proposed new STS 3.4.13, Condition A on pressure boundary leakage, including the new STS associated Required Action A.1 and Completion Time, is acceptable because the LCO revisions continue to specify the lowest functional capability of equipment, identify remedial actions and require shutdown of the reactor if the remedial actions cannot be met.

Based on the discussions above, the NRC staff finds that the proposed changes to the STP TS 1.16 item b and TS 1.23 definitions and to LCO 3.4.6.2 correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i). Also, the remedial actions to be taken until each LCO can be met provide protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).

3.2 Technical Evaluation of Additional Proposed TS Changes 3.2.1 Editorial Changes The licensee noted that the STP TSs have different numbering than the STS. Specifically, in the STP TSs, the Operational Leakage specification is numbered 3.4.6.2. In the STS on which TSTF-554 is based, the TS is numbered 3.4.13.

The NRC staff finds that the different TS numbering is acceptable because it does not substantively alter TS requirements.

3.2.2 Other Variations The STP TSs contain requirements that differ from the STS on which TSTF-554 was based but are encompassed by the TSTF-554 justification.

  • The licensee noted that the STP TSs are based on NUREG-0452, Standard Technical Specifications, Westinghouse Plants, specifically draft Revision 5 (ML20141J199).

TSTF-554 is based on NUREG-1431 of the same title. The STP TSs have a different format than the NUREG1431 and TSTF554. In the STP TSs, the actions statements are in a narrative format while in NUREG1431 and TSTF554 the actions statements are in a column format.

The NRC staff reviewed the licensee variation resulting from the format differences. Prior to the development of NUREG1431, the improved STS for Westinghouse plants, NUREG0452 contained the STS for Westinghouse plant designs such as STP. The issuance of NUREG-1431 considered the specifications of NUREG-0452.

As described in the Abstract to the improved STS, licensees are encouraged to upgrade their TSs consistent with the improved STS. However, licensees adopting portions of the improved STS can also achieve a degree of standardization and consistency when adopting all related requirements to that portion, as applicable. In this LAR, the licensee is upgrading a portion of the STP TSs to achieve a degree of standardization and consistency with the improved STS associated with reactor coolant leakage requirements. Although the licensee proposed changes are incorporated into the STP TS format, which is based on an earlier version of the STS, the NRC staff finds the

variation acceptable because the licensees proposed STP TS changes remain consistent with the NRC-approved TSTF-554.

  • The licensee noted that in the STS on which TSTF-554 is based, all leakage definitions appear as part of the single defined term, LEAKAGE. In the STP TSs, the terms related to leakage are separate definitions. However, the licensee noted that the changes to the affected defined terms IDENTIFIED LEAKAGE and PRESSURE BOUNDARY LEAKAGE are the same as the changes made to those terms in TSTF-554.

The NRC staff reviewed the licensees variation described above and finds that separating these definitions does not change their meanings or substantively alter the TS requirements from TSTF554, and thus, the STP TS changes remain consistent with NRC-approved TSTF-554. Therefore, the NRC staff finds the revised definitions acceptable.

The NRC staff reviewed the licensees variation described above and finds that the licensees approach does not substantively alter the TS requirements from TSTF554, and thus, the STP TS changes remain consistent with NRC-approved TSTF-554.

Therefore, the NRC staff finds the ordering of the STP TS 3.4.6.2 Actions acceptable.

  • The licensee stated that the STP TS shutdown requirements are included in each Action. Specifically, the TSTF-554 shutdown actions in STS 3.4.13 Condition C are contained in STP LCO 3.4.6.2, revised Action a and new Action c. The licensee indicated that the STP TS shutdown requirements are consistent with TSTF-554.

The NRC staff reviewed the licensees variation described above and finds that the licensees approach does not substantively alter the TS requirements from TSTF554, and thus, the STP TS changes remain consistent with NRC-approved TSTF-554.

Therefore, the NRC staff finds the STP TS treatment of the shutdown requirements acceptable.

In summary, based on the discussion above, the NRC staff finds that the licensees proposed variations from TSTF-554 are acceptable because the variations are consistent with NRC-approved TSTF-554 and do 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 guidance for customary terminology and formatting in chapter 16.0 of the SRP and NUREG1431. The NRC staff finds that the proposed changes are consistent with these documents 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. 225 TO RENEWED FACILITY OPERATING LICENSE NO. NPF76 AND AMENDMENT NO. 210 TO RENEWED FACILITY OPERATING LICENSE NO. NPF80 STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50498 AND 50499 Application (i.e., initial and supplements) Safety Evaluation Date

1.0 PROPOSED CHANGE

S STP Nuclear Operating Company (the licensee) requested changes to the technical specifications (TSs) for South Texas Project, Units 1 and 2. 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 TSs related to reactor coolant system operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20016A233), and the associated NRC staff safety evaluation of TSTF-554 (ML20322A024).

The supplement dated January 26, 2023, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 4, 2022 (87 FR 60217).

2.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments on January 13, 2023. The State official had no comments.

Enclosure 4

3.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to 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 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 October 4, 2022 (87 FR 60217), 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.

ML23015A001 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC NAME DGalvin PBlechman VCusumano DATE 1/19/2023 1/19/2023 1/9/2023 OFFICE OGC / NLO NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME KDowling JDixon-Herrity DGalvin DATE 2/3/2023 2/6/2023 2/6/2023

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