NOC-AE-02001336, License Amendment Request - Proposed Amendment to Delete Appendix C of the Operating Licenses Re Antitrust Conditions

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License Amendment Request - Proposed Amendment to Delete Appendix C of the Operating Licenses Re Antitrust Conditions
ML022390516
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/20/2002
From: Jordan T
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-02001336
Download: ML022390516 (21)


Text

Nuclear Operating Company South T* Projct Electric Gener'aUngSttlon PC. Box 28g9 Md, T=rs 77483 /

August 20, 2002 NOC-AE-02001336 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 License Amendment Request Proposed Amendment to Delete Appendix C of the Operating Licenses Pursuant to 10CFR50.90, STP Nuclear Operating Company (STPNOC) hereby requests an amendment to Facility Operating Licenses NPF-76 and NPF-80 to delete Appendix C regarding antitrust conditions. The conditions in Appendix C are no longer applicable and are inconsistent with Texas electric industry restructuring legislation.

STPNOC has determined that the proposed amendment involves no significant hazards consideration (Attachment 1). Proposed revised Operating License pages are provided in Attachments 2 through 5.

The Plant Operations Review Committee has recommended approval of the proposed amendment and the Nuclear Safety Review Board has approved it. STPNOC has notified the State of Texas in accordance with 10CFR50.91(b).

This amendment request was not originally planned for submittal in fiscal year 2003. However, STPNOC believes that submission of the request is warranted to avoid potential confusion in the deregulated electric industry environment in Texas. The NRC approved a similar request from Comanche Peak Steam Electric Station in March 2002. STPNOC requests approval of the proposed amendment by August 31, 2003. Once approved, the amendment shall be implemented within 30 days.

If there are any questions regarding this proposed amendment, please contact Mr. Scott Head at (361) 972-7136 or Mr. George L. Edgar at Morgan, Lewis & Bockius LLP, who can be reached at (202) 739-5459.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: August 20, 2002 -*w

  • Vice President, Engineering & Technical Services STI: 31452205

NOC-AE-02001336 Page 2 of 2 Attachments:

1. Licensee's Evaluation
2. Proposed Changes to Unit 1 Operating License (Mark-up)
3. Proposed Changes to Unit 2 Operating License (Mark-up)
4. Proposed Changes to Unit 1 Operating License (Retyped)
5. Proposed Changes to Unit 2 Operating License (Retyped) cc:

(paper copy)

I (electronic copy)

Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 M. T. Hardt/W. C. Gunst Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Reliant Energy, Inc.

Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP - Central Power and Light Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-02001336 Attachment 1 Licensee's Evaluation

N NOC-AE-02001336 Attachment 1 Page 1 of 6 LICENSEE'S EVALUATION

1.0 DESCRIPTION

This letter is a request to amend Operating Licenses NPF-76 and NPF-80 for South Texas Project (STP) Units 1 and 2. The proposed change would delete Appendix C regarding antitrust conditions from both Operating Licenses. The conditions in Appendix C are no longer applicable and are inconsistent with the Texas electric industry restructuring legislation.

STP Nuclear Operating Company (STPNOC) requests approval of the proposed amendment by August 31, 2003. Once approved, the amendment shall be implemented within 30 days.

2.0 PROPOSED CHANGE

S Specifically, the proposed changes to both Operating Licenses include:

"* Delete Condition C (3) on page 4

"* Delete Enclosure 3 on the signature page

"* Delete Appendix C in its entirety

3.0 BACKGROUND

Identical antitrust conditions in Section B of Appendix C to both of the Operating Licenses consist of eleven separately numbered provisions, some with additional subparts. These antitrust conditions can be grouped into three general categories:

(1) transmission access, operations, and planning; (2) protection against market power or market power abuses; and (3) other special matters.

The change in Texas law encouraging competition and the efforts of the Public Utility Commission of Texas (PUCT) to effectuate that policy, the conclusions reached by the staff at the time the licenses were issued for STP, and the current state of competition in the electric utility industry in Texas as reported by the PUCT in its January 2001 report to the Texas legislature, are all compelling reasons to delete the antitrust license conditions. As shown below, the Texas electric restructuring legislation-, which mandates compliance with the PUCT Substantive Rules and the Protocols of the Electric Reliability Council of Texas (ERCOT),

renders the STP antitrust license conditions in each of these categories unnecessary. Moreover, in important respects, maintenance of the antitrust conditions could operate to thwart the intent and purpose of the restructuring legislation.

The antitrust conditions in the first category (Conditions 2, 3, 4, 6, 7, and 9) impose requirements i Texas Utilities Code § 39.1510).

NOC-AE-02001336 Attachment 1 Page 2 of 6 for access to transmission, and for coordination of operation and planning. These conditions address such topics as maintenance, reserve requirements, interconnection, bulk power service, and construction. These conditions are no longer necessary because of changes in the Texas electric market. Recently, the NRC deleted similar antitrust conditions from the Comanche Peak Steam Electric Station licenses because the competitive situation in the Texas electric utility market has changed favorably since the license conditions were imposed. The Texas Legislature and the PUCT have taken additional steps to further encourage competition in this market and to ensure this competition through regulation.

Wholesale transmission open access has been a requirement under Texas law since 1995 and retail open access has been required since January 1, 2002, with the commencement of retail competition under the Texas legislation.-2 All buyers and sellers of electricity enjoy nondiscriminatory open access to the transmission systems now run by the owners of STP'-. The PUCT exercises jurisdiction over the ERCOT transmission grid, including those portions of the grid operated by the four owners of STP. The PUCT Substantive Rules require transmission service providers to interconnect with electric utilities and non-utility generators alike.-4 Further, the PUCT has adopted a Standard Generation Interconnection Agreement to be used for new generators.5- Additionally, ERCOT Protocol § 3.5 addresses the interconnection of new generation resources to the ERCOT transmission grid, and provides adequate protection for entities desiring to interconnect.

Wholesale transmission rates will continue to be regulated by the PUCT, whose Substantive Rules contain terms and conditions for the provision of transmission service, including the planning and construction of facilities.-6 These rules expressly require transmission utilities to 2

consider customer's load in transmission system planning and construction of facilities.

ERCOT Protocols and PUCT Substantive Rules require transmission utilities to plan, construct, operate and maintain their systems in accordance with good operating practice as defined by PUCT Substantive Rule § 25.5(31).'

Texas Utilities Code §§ 35.004 (Wholesale Open Access) and 39.203 (Retail Open Access).

Texas Utilities Code § 39.051.(Unbundling) requires the two investor owned licensees to separate their power generation and transmission business activities into different corporate entities. When this requirement is fully implemented, their ownership of STP will be in different corporate entities than their transmission and distribution activities.

PUC Subst. R. Ch. 25, Subch. I.

Id.

6 PUC Subst. R. §§ 25.195(b) (Transmission Service Provider responsibilities), and 25.195(e) (Construction of new facilities).

_ PUC Subst. R. § 25.195(b).

8 Id.; ERCOT Protocols § 3.1.

NOC-AE-02001336 Attachment 1 Page 3 of 6 The Texas legislation, PUCT Substantive Rules, and ERCOT Protocols ensure nondiscriminatory transmission access to buyers and sellers of electricity in the wholesale market. Additionally, these requirements adequately address transmission coordination, planning, reliability, and information exchange. Accordingly, antitrust Conditions 2, 3, 4, 6, 7, and 9 are unnecessary.

The antitrust conditions in the second category (Conditions 5 and 6) impose requirements to guard against market power or the potential abuse of that power. The Texas electric restructuring legislation delegates new authority to the PUCT and creates mandatory mechanisms to protect against these concerns. As discussed above, a comprehensive regulatory structure guards against anticompetitve practices in the transmission market. The legislation also includes a comprehensive statutory framework to protect against generation market power abuses in the new competitive environment. Beginning on January 1, 2002, a Power Generation Company (PGC) is prohibited from owning or controlling more than 20% of the installed generation capacity within ERCOT.2 For purposes of this calculation, the statute includes the ERCOT generating capacity of the PGC's affiliates, collectively.- Moreover, the legislation contains comprehensive provisions for monitoring generation market power, mandatory capacity auctions, and remedial actions to mitigate generation market power if discovered.'

Additionally, the Texas Legislature granted the PUCT the authority and responsibility to monitor market power associated with the generation, transmission, distribution and sale of electricity in Texas.)- This authority applies to the two licensees to which antitrust conditions 5 and 6 apply.

Should the PUCT find that market power abuses have occurred, the PUCT must require reasonable mitigation by:

(1) ordering the construction of additional transmission or distribution facilities; (2) seeking an injunction or civil penalties; (3) imposing administrative penalties; or (4) suspending, revoking, or amending a Retail Electric Provider's certificate or a PGC's registrationP The statute defines market power abuses as:

practices by persons possessing market power that are unreasonably discriminatory or tend to unreasonably restrict, impair, or reduce the level of competition, including practices that tie unregulated products or services to regulated products or services. For purposes of this section, "market power abuses" includes predatory pricing, withholding of production, precluding entry, and collusion. A violation of the code of conduct provided 2 Texas Utilities Code § 39.154.

10 Texas Utilities Code § 39.154(c).

Li Texas Utilities Code §§ 39.153 (capacity auction), 39.156 and 39.157 (mitigation of violations), and 39.158(a) (mergers).

12 Texas Utilities Code § 39.157.

13 Id.

NOC-AE-02001336 Attachment 1 Page 4 of 6 by § 39.157(d) that materially impairs the ability of a person to compete in a competitive 4

market shall be deemed to be an abuse of market power.-

As shown above, the Texas Legislature put in place a comprehensive system to regulate competition in the wholesale and retail markets in Texas including an express delegation of authority and responsibility to the PUCT to monitor market power and police against anticompetitive practices. These protections of electric competition in the Texas market obviate the need for antitrust Conditions 5 and 6 in the STP Operating Licenses, conditions that 5 are at best redundant of state protections and potentially a hindrance to the statutory design.'

Condition 8, requiring access to participation in any future nuclear units, is unnecessary for the additional reason that the NRC licensing process for new units contemplates pre-licensing antitrust review on a case-by-case basis.-L6 The propriety of access to future nuclear units is better decided if and when any new license applications are presented. Accordingly, this antitrust condition should be removed. The remaining antitrust conditions (Conditions 1, 10, and

11) contain provisions that were unique to a particular issue, that are no longer necessary, or have expired on their own terms.

The Texas legislation that requires compliance with PUCT Substantive Rules and ERCOT Protocols creates a robust, competitive generation market in Texas. Transmission, however, will remain pervasively regulated under this scheme, including requirements for nondiscriminatory open access to transmission. The antitrust conditions in the STP Operating Licenses were crafted for another era in the electric power industry, when electric utilities were vertically integrated, state franchised monopolies. The conditions describe tools suited to that environment. Today, the competitive market has replaced the hand of the regulator. In this environment, the old tools are no longer appropriate and have already been replaced.

Accordingly, the NRC should remove the antitrust conditions from the STP Operating Licenses.

4.0 TECHNICAL ANALYSIS

The proposed changes will have no impact on the continued operation of STP because the proposed changes are solely administrative in nature. The proposed changes involve only a removal of antitrust conditions. The proposed changes do not alter any technical content of the Operating Licenses or the STP Technical Specifications requirements, nor do they have any programmatic effect on the STP Operations Quality Assurance Program. The change will have 14 Texas Utilities Code § 39.157(a).

15 For example, one of the conditions requires bulk power sales to entities with generating capacity less than 200 MW at cost of service rates. The Texas legislation removes cost of service rates for energy sales in favor of market pricing. The mechanisms to determine cost of service pricing for generation will no longer exist once generation is moved outside this regime.

16 10 C.F.R. § 50.33a.

NOC-AE-02001336 Attachment 1 Page 5 of 6 no impact on the design, function, or operation of any plant structure, system, or component, either technically or administratively.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration STPNOC has determined whether a significant hazards consideration is involved with the proposed amendment by focusing on the three criteria set forth in 10CFR50.92 as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No This request involves an administrative change only. The Operating Licenses are being changed to remove unnecessary and outdated antitrust conditions. No actual plant equipment or accident analyses will be affected by the proposed changes. Therefore, this request will have no impact on the probability or consequences of any type of accident:

new, different, or previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No This request involves an administrative change only. The Operating Licenses are being changed to remove unnecessary and outdated antitrust conditions. No actual plant equipment or accident analyses will be affected by the proposed change and no failure modes not bounded by previously evaluated accidents will be created. Therefore, this request will have no impact on the possibility of any type of accident: new, different, or previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel and fuel cladding, Reactor Coolant System pressure boundary, and containment structure) to limit the level of radiation dose to the public. This request involves an administrative change only. The Operating Licenses are being changed to remove unnecessary and outdated antitrust conditions.

NOC-AE-02001336 Attachment 1 Page 6 of 6 No actual plant equipment or accident analyses will be affected by the proposed change.

Additionally, the proposed change will not relax any criteria used to establish safety limits, safety systems settings, or any limiting conditions of operation. Therefore, this request will not impact margin of safety.

Based on the above, STPNOC concludes that the proposed amendment involves no significant hazards consideration under the criteria set forth in 10CFR50.92 and, accordingly, a finding of "no significant hazards consideration" is justified.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(10). Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 PRECEDENT I REFERENCE Comanche Peak Steam Electric Station, Units 1 and 2 (March 2002)

Letter, D. H. Jaffe to C. L. Terry, "Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2 - Issuance of Amendments re: Deletion of Antitrust Conditions (TAC Nos. M[B3609 and MB36 10)," dated March 22, 2002

NOC-AE-02001336 Attachment 2 Proposed Changes to Unit 1 Operating License (Mark-up)

SOUTH TEXAS LICENSE -4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 93, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Usd

'VA4xk.tnt~us Conditi6iis'..N&V

_to*lo niia (4)~~~~~~ee 0144t:o 14"SR)

Tesatru;rga nhy changsto the'npInitialPocfp Te Pot lih46'n anl~ Sectin 14 f theFina am esrigeoi (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.

Amendment No. 0

SOUTH TEXAS LICENSE I. Effective Date and Expiration This license is effective as of the date of issuance and shall expire at midnight on August 20, 2027.

FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix A, Technical Specifications (NUREG-1305)
2. Appendix B, Environmental Protection Plan Date of Issuance: March 22, 1988

NOC-AE-02001336 Attachment 3 Proposed Changes to Unit 2 Operating License (Mark-up)

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 80, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) So*t -Useb.d (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(bo) within one month of such change.

D. Exemptions The following exemptions are authorized by law and will not endanger life or property or the common defense and security, and certain special circumstances are present. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

(1) The facility requires a technical exemption from the requirements of 10 CFR Part 50, Appendix J, Section III.D.2(b)(ii). The justification for this exemption is contained in Section 6.2.6 of Supplement 3 to the Safety Evaluation Report. The staff's environmental assessment was published on December 16, 1986 (53 FR 50605). Therefore, pursuant to 10 CFR 50.12(a)(1),

  • The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 5

contingency plans previously approved by the Commission and all amendments and revisions to such plans made pursuant to the authority under 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "South Texas Project Electric Generating Station Physical Security Plan," with revisions/amendments submitted through September 30, 1988; "South Texas Project Electric Generating Station Security Personnel Qualification and Training Plan" with revisions submitted through March 4, 1988, and "South Texas Project Electric Generating Station Safeguards Contingency Plan," with revisions/amendments submitted through July 19, 1988.

G. Not Used H. Financial Protection The Owners shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

I. Effective date and Expiration This license is effective as of the date of issuance and shall expire at midnight on December 15, 2028.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By: James H. Sniezek/for Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix A, Technical Specifications (NUREG-1346)
2. Appendix B, Environmental Protection Plan F77, peni Anit~ Con7itidW Date of Issuance: March 28, 1989 Amendment No. 0

NOC-AE-02001336 Attachment 4 Proposed Changes to Unit 1 Operating License (Retyped)

SOUTH TEXAS LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 93, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SER)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 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.

Amendment No.

SOUTH TEXAS LICENSE I. Effective Date and Expiration This license is effective as of the date of issuance and shall expire at midnight on August 20, 2027.

FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix A, Technical Specifications (NUREG-1305)
2. Appendix B, Environmental Protection Plan Date of Issuance: March 22, 1988 I

Amendment No.

NOC-AE-02001336 Attachment 5 Proposed Changes to Unit 2 Operating License (Retyped)

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 80, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SR)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

D. Exemptions The following exemptions are authorized by law and will not endanger life or property or the common defense and security, and certain special circumstances are present. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

(2) The facility requires a technical exemption from the requirements of 10 CFR Part 50, Appendix J, Section Il.D.2(b)(ii). The justification for this exemption is contained in Section 6.2.6 of Supplement 3 to the Safety Evaluation Report. The staff's environmental assessment was published on December 16, 1986 (53 FR 50605). Therefore, pursuant to 10 CFR 50.12(a)(1),

  • The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No.

contingency plans previously approved by the Commission and all amendments and revisions to such plans made pursuant to the authority under 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "South Texas Project Electric Generating Station Physical Security Plan," with revisions/amendments submitted through September 30, 1988; "South Texas Project Electric Generating Station Security Personnel Qualification and Training Plan" with revisions submitted through March 4, 1988, and "South Texas Project Electric Generating Station Safeguards Contingency Plan," with revisions/amendments submitted through July 19, 1988.

G. Not Used H. Financial Protection The Owners shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

I. Effective date and Expiration This license is effective as of the date of issuance and shall expire at midnight on December 15, 2028.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By: James H. Sniezek/for Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix A, Technical Specifications (NUREG-1346)
2. Appendix B, Environmental Protection Plan Date of Issuance: March 28, 1989 Amendment No.