NOC-AE-17003510, License Amendment Request to Revise Technical Specifications for Administrative Changes and to Relocate Fxy Exclusion Zones to the Core Operating Limits Reports (Colrs)

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License Amendment Request to Revise Technical Specifications for Administrative Changes and to Relocate Fxy Exclusion Zones to the Core Operating Limits Reports (Colrs)
ML17261B272
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 09/18/2017
From: Connolly J
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-17003510, STI: 34530441
Download: ML17261B272 (26)
v • d • e


Text

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Nuclear Operating Company

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South Texas Project £/edric Generating St.aUon P.Q /JQJ{ 28JJ Wadsworth, Texas 77483 September 18, 2017 NOC-AE-17003510 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 License Amendment Request to Revise Technical Specifications for Administrative Changes and To Relocate Fxv Exclusion Zones to the Core Operating Limits Reports (COLRs)

Pursuant to 10 CFR 50.90, STPNOC hereby requests a license amendment to South Texas Project (STP) Operating Licenses NPF-76 and NPF-80 to relocate the defined core plane regions where the Radial Peaking Factor limits are not applicable {Fxy exclusion zones) from Technical Specification 4.2.2.2.f to the Core Operating Limits Reports (COLRs) for Unit 1 and Unit 2. The proposed amendment will also revise COLR Administrative Controls Technical Specification 6.9.1.6 to add Fxy exclusion zones to the list of limits found in the COLRs and to the description of the methodology used to determine these values (WCAP-8385). This license amendment request also includes additional administrative changes to Technical Specifications 6.9.1.6, 4.2.2.2.f, and 4.8.1.1.2.

The Enclosure to this letter provides a description and assessment of the proposed changes including technical and regulatory evaluations and a No Significant Hazards Consideration analysis. Marked-up and re-typed (clean) Technical Specification pages are provided in Attachments 1 and 2, respectively. Attachment 3 provides an existing Technical Specification Bases page marked to show the proposed changes for information only.

STPNOC will implement the amendment within 90 days of the NRG approval date.

In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this license amendment request by transmitting a copy of this letter and Enclosure to the designated State Official. The proposed amendment has been reviewed and approved by the STPNOC Plant Operations Review Committee and has undergone an independent organizational unit review.

There are no regulatory commitments in this amendment request.

If there are any questions or if additional information is needed, please contact Wendy Brost at (361) 972-8516 or me at (361) 972-7344.

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

Executed on t/.01'!

Jim Connolly Site Vice President web

Enclosure:

Evaluation of the Proposed Change STI: 34530441

NOC-AE-17003510 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV Morgan, Lewis & Beckius LLP U.S. Nuclear Regulatory Commission Steve Frantz, Esquire 1600 East Lamar Boulevard Paul Bessette Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (08H04) NRG South Texas LP 11555 Rockville Pike Mark Walker Rockville, MD 20852 Jim von Suskil Skip Zahn NRG Resident Inspector U. S. Nuclear Regulatory Commission CPS Energy P. 0. Box 289, Mail Code: MN116 Kevin Pollo Wadsworth, TX 77483 Cris Eugster L. D. Blaylock City of Austin Elaina Ball John Wester Texas Dept. of State Health Services Helen Watkins Robert Free

Enclosure NOC-AE-17003510 Page 1 of 10 ENCLOSURE Evaluation of the Proposed Change

Subject:

License Amendment Request to Revise Technical Specifications for Administrative Changes and to Rel9cate Fxy Exclusion Zones to the Core Operating Limits Reports (COLRs)

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change
3. TECHNICAL EVALUATION
4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusions
5. ENVIRONMENTAL CONSIDERATION
6. REFERENCES ATTACHMENTS:
1. Technical Specification Page Markups
2. Retyped Technical Specification Pages
3. Technical Specification Bases Changes (for information only)

Enclosure NOC-AE-17003510 Page 2 of 10

1.

SUMMARY

DESCRIPTION The proposed amendment will revise Technical Specification 4.2.2.2.f to relocate the details regarding the defined core plane regions where the Radial Peaking Factor limits are not applicable {Fxy exclusion zones) from the Technical Specifications to the Core Operating Limits Reports (COLRs) for Unit 1 and Unit 2. The proposed amendment also includes administrative changes to COLR Administrative Controls Technical Specification 6.9.1.6 to update the list of COLR contents, update the methodology description for WCAP-8385, remove outdated information, incorporate NRG-approved topical report addenda, and clarify the applicability of the BEACON code (References 6.6, 6.7, and 6.8). Two additional administrative changes to correct typographical errors in Technical Specifications 4.2.2.2.f and 4.8.1.1.2 are also included.

2. DETAILED DESCRIPTION 2.1. System Design and Operation The Radial Peaking Factor, Fxy{Z), is defined as the ratio of the peak power density to average power density in the horizontal plane at core elevation Z. Fxy{Z) is measured periodically to provide assurance that the Hot Channel Factor, Fa (Z), remains within its limit. The Fxy limit for Rated Thermal Power (FTP), as provided in the COLRs per Technical Specification 6.9.1.6, was determined from expected power control maneuvers over the full range of burnup conditions in the reactor core (Reference 6.2).

Peaking factor margin is evaluated over the entire axial height of the active fuel for each fuel reload cycle. The values of the Fxy limits are determined by an NRG-approved methodology described in WCAP-8385 (Reference 6.1). The Fxy exclusion zones, however, are excluded from Technical Specification surveillance testing because the measurement and calculation methods were not as effective in these regions due to top and bottom edge effects and grid strap perturbations (Reference 6.1).

This proposed amendment would not change the system design or operation nor the approved calculation methodology.

2.2. Current Technical Specification Requirements The Fxy exclusion zones are currently specified in Technical Specification 4.2.2.2.f and include:

  • the lower core region from 0 to 15%, inclusive,
  • the upper core region from 85 to 100% inclusive,
  • grid plane regions at 22.4 +/- 2%, 34.2 +/- 2%, 46.0 +/- 2%, 57.8 +/- 2%, 69.5 +/-2% and 81.3 +/- 2%, inclusive, and
  • core plane regions within +/- 2% of core height (+/- 3.36 inches) about the bank demand position of the bank "D" control rods.

Enclosure NOC-AE-17003510 Page 3 of 10 Technical Specification 6.9.1.6 describes the required content of the COLRs and references the applicable NRG-approved analytical methods used to determine the core operating limits.

Changes will be required for Technical Specification 6.9.1.6.a and 6.9.1.6.b to reflect the relocation of the Fxy exclusion zone location details to the COLRs. Technical Specification 6.9.1.6.a requires core operating limits to be established prior to each fuel reload cycle and that specific operating limits be documented in the COLRs including Heat Flux Hot Channel Factor, K(Z); Power Factor Multiplier, FJP; and Fa (Z) manufacturing and measurement uncertainties for Technical Specification 3/4..2.2 (Reference 6.5). Technical Specification 6.9.1.6.b requires that only the specified NRG-approved analytical methods be used to determine the core operating limits. Technical Specification 6.9.1.6.d requires that the COLRs, including any mid-cycle revisions or supplements, be submitted to the NRC.

2.3. Reason for the Proposed Change Fxy Exclusion Zones Relocating the Fxy exclusion zone values to the COLRs allows the exclusion zones to be revised without the need for a license amendment if limiting peaks are identified in the currently excluded portion of the core.

The Fxy exclusion zones are determined using an NRG-approved methodology (Reference 6.1) and have the potential to change on a cycle-specific basis. Relocation of the Fxy exclusion zones to the COLRs would be considered a Technical Specification improvement per Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications" (Reference 6.3). The license amendment process would be an unnecessary burden on the licensee and the NRC for making a change to these values for cycle-specific changes. This proposed change would further limit the need for potential unnecessary reload license amendment requests.

STP is proposing relocating the Fxy exclusion zone values to the COLRs rather than the Technical Specification Bases because the COLRs better present unit and cycle-specific limits.

Relocating the Fxy exclusion zone values to the Technical Specification Bases could result in frequent cycle-specific changes. Relo,cation of this type of cycle-specific information to the COLRs is consistent with previously approved license amendments for STP which are described further in Section 4.2 of this Enclosure.

In conjunction with this proposed change, the relevant sections of the COLR Administrative Controls Technical Specification 6.9.1.6 would be revised to add Fxy exclusion zones to the list of limits found in the COLRs and to the methodology description for WCAP-8385 in order to align with the proposed relocation of the Fxy exclusion zones to the COLRs.

Administrative Changes The separate proposed administrative change to Technical Specification 6.9.1.6.b.9 to remove the reference to the Crossflow Ultrasonic Flow Measurement System is requested because this system is no longer utilized at STP (Reference 6.11).

The separate proposed administrative changes to Technical Specification 6.9.1.6.b.11 related to WCAP-12472-P-A (BEACON Topical Report, Reference 6.6) are being requested to improve the completeness and clarity of this Technical Specification section. The list of NRG-approved Addenda for BEACON will be updated to include Addendum 1-A (approved January 2000) and Addendum 4 (approved September 2012), which are also applicable to STP (References 6.7 and 6.8). Addendum 1-A approves the ANC Nodal Expansion Method used in BEACON and

Enclosure NOC-AE-17003510 Page 4 of 10 Addendum 4 approves a power-dependent peaking factor uncertainty method added to BEACON. A note will be added to Technical Specification 6.9.1.6. b.11 to clarify that BEACON applies to the uncertainties in the peaking factor Technical Specification, not the peaking factor limits. Additionally, the axial flux difference method reference will be removed from the Technical Specification 6.9. 1.6.b. 11 methodology description because it is not applicable to STP (Reference 6.6). STP is licensed to the Technical Specification Monitor level of BEACON and the axial flux difference method is only applicable to the Direct Margin Monitor level of BEACON.

Lastly, the separate proposed administrative changes to Technical Specifications 4.2.2.2. f and 4.8.1.1.2 are being requested to correct typographical errors.

2.4. Description of the Proposed Changes The proposed change to Technical Specification 4.2.2.2. f would relocate the specific location details of the Fxy exclusion zones from the Technical Specifications to the COLRs. The Fxy exclusion zone location details will be replaced with a statement that the values of this parameter will be maintained within the COLRs.

The proposed change to Technical Specification 4.2.2.2.f is supported by the following changes to the Administrative Controls Technical Specification for the COLR, Technical Specification

6. 9. 1. 6:

STP is also proposing the following administrative changes to Technical Specifications 6.9.1.6, 4.2.2.2.f and 4.8. 1. 1.2:

  • Remove the reference for the Crossflow Ultrasonic Flow Measurement System, which is no longer utilized at STP and renumber Reference 9a as Reference 9 (Technical Specification 6.9.1.6.b.9).
  • Clarify that the BEACON reference as it relates to the peaking factor Technical Specification does not apply to the limits but to the uncertainties, as explicitly stated in
6. 9.1.6. a (Technical Specification 6.9. 1.6.b. 11).
  • Correct the typographical spelling error, core 'planes' regions {Technical Specification 4.2.2.2.f).
  • Correct the typographical indentation error that gives the appearance that two Technical Specifications are subsections of Technical Specification 4.8.1. 1. 2. e (Technical Specifications 4.8.1.1.2.f and 4.8.1.1.2. g). This error was introduced with the approval of a prior License Amendment (Reference 6. 16).

The proposed Technical Specification changes described above are shown in the marked-up Technical Specification pages provided in Attachment 1.

STP plans to add additional information regarding how Fxy exclusion zones are determined to the Technical Specification Bases. Changes to the Technical Specification Bases associated with this amendment request are provided in Attachment 3 for information only.

Enclosure NOC-AE-17003510 Page 5 of 10

3. TECHNICAL EVALUATION The proposed change for relocating the specific location details of the Fxy exclusion zones from the Technical Specifications to the COLRs has no impact upon plant operation or safety. No safety-related equipment, safety function, or plant operations will be altered as a result of this proposed change. Since applicable FSAR limits will be maintained and the Technical Specifications will continue to require operation within the core operating limits calculated by the approved methodologies, this proposed change can be considered administrative in nature.

Appropriate actions to be taken if the safety limits are violated remain in the Technical Specifications and will not be altered as a result of this proposed amendment.

The COLRs will document the specific parameter limits resulting from NRG-approved calculations, therefore the proposed change is in conformance with the requirements of 10 CFR 50.36. Any changes to the COLRs willbe made in accordance with the requirements of 10 CFR 50.59, with a copy of the revised COLRs sent to the NRC as required by Technical Specification 6.9.1.6.d.

The establishment of these limits in accordance with an NRG-approved methodology and the incorporation of these limits into the COLRs will ensure that proper steps have been taken to establish the values of these limits. Submittal of revised COLRs will allow the NRC staff to trend the values of these limits without the need for prior staff approval of these limits and without the introduction of an unreviewed safety question.

A planned addition to the Technical Specification Bases associated with this LAR is provided for information only in Attachment 3. Bases Section 3/4.2.2 and 3/4.2.3, Heat Flux Hot Channel Factor and Nuclear Enthalpy Rise Hot Channel Factor will be revised to include an explanation of why Fxy evaluations are not applicable in the exclusion zones.

4. REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the proposed change.

Generic Letter 88-16, "Removal of Cycle-specific Parameter Limits from Technical Specifications" The purpose of the Generic Letter 88-16 is to provide guidance for the removal of cycle-specific parameter limits from the Technical Specifications because processing cycle-specific limit changes is considered an unnecessary burden on both licensees and the NRC. The Generic Letter was intended to apply to those Technical Specification changes that were developed with NRG-approved methodologies. To support removal of the cycle-specific parameter limits, the Generic Letter recommended that cycle-specific parameter limit values be placed in a COLR, thereby eliminating the need for many reload license amendments. The COLR would be submitted to the NRC to allow continued trending of the cycle-specific parameters.

Generic Letter 88-16 provides guidance to licensees for removal of the values of cycle-specific parameter limits from Technical Specification including three separate actions to modify the plant's Technical Specifications: (1) the addition of the definition of a named formal report that includes the values of cycle-specific parameter limits that have been established using an NRC approved methodology and consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific

Enclosure NOC-AE-17003510 Page 6 of 10 parameter limits to the Commission for information, and (3) the modification of individual Technical Specifications to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report. STP completed actions (1) and (2) in a previous license amendment (Reference 6.9) and action (3) for this proposed amendment will be accomplished by making the changes described in Section 2.4 as shown in Attachments 1 and 2 of this submittal.

10 CFR 50.36, "Technical Specifications" 10 CFR 50.36 establishes the requirements related to the content of the Technical Specifications for operating power plants: (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation, (3) Surveillance requirements, (4)

Design features, (5) Administrative controls, (6) Decommissioning and (7) Initial notification, and (8) Written Reports. Specifically, for Surveillance Requirements 10 CFR 50.36 states:

10 CFR Part 50.36(c)(3) "Surveillance requirements". Surveillance requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed changes to the Technical Specifications do not affect conformance with 10 CFR 50.36 requirements because the safety limits and the NRG-approved methods for calculating them and limiting conditions for operation and actions to be taken if a limit is exceeded remains unchanged. The proposed change will control these parameters within the acceptance criteria using the approved methodology instead of specifying Technical Specification values.

Therefore, the proposed change is in conformance with 10 CFR 50.36.

Technical Specification 314.2.2, Heat Flux Hot Channel Factor- FQ(Z)

The proposed change does not eliminate or alter the limits or required actions described in this Technical Specification, it merely relocates the detail regarding locations of the Fxy exclusion zones to the COLRs. All safety analysis limits will continue to be confirmed to be bounding on a cycle-specific basis using the methodologies described in Technical Specification 6.9.1.6.

Technical Specification 6.9.1.6, Core Operating Limits Report Technical Specification 6.9.1.6.b describes the NRG-approved analytical methods used to determine the core operating limits for STP. The NRG-approved calculation methodology for determining the Fxy exclusion zones is WCAP-8385 (Reference 6.1) so it can be added to the list of methodologies for Technical Specification 3/4.2.2.: This proposed amendment will not alter the input parameters or the methodologies for determining the Fxy exclusion zones, it merely relocates the specific values to the COLRs.

Similarly, Addenda 1-A and 4 to WCAP-12472 have been approved by the NRG and are applicable to STP so they can be added to the list of approved methodologies for Technical Specifications 3.2.2 and 3.2.3. WCAP-12472 is not the method for determining axial flux difference for STP, so Technical Specification 3.2.1 should be removed from the references for this WCAP.

Lastly, the Crossflow Ultrasonic Flow Measurement System is no longer utilized at STP, so this reference can be removed from this Technical Specification.

Enclosure NOC-AE-17003510 Page 7 of 10

4. 2. Precedent The NRC has previously approved similar STP license amendment requests related to the relocation of cycle specific parameters to the COLRs.

In June 1989, Houston Lighting and Power Company (HL&P), a previous operator of STP Electric Generating Station, proposed a license amendment to delete the cycle-specific parameters for axial flux difference and control rod insertion limits from the Technical Specifications and relocate them to the COLRs in accordance with Generic Letter 88-16 (Reference 6.9). This amendment request was approved by the NRC in July 1989 (Reference 6.10).

In September 1989 and January 1991, as amended in May 1991, HL&P proposed license amendments to relocate additional cycle-specific parameter limits to the COLRs (References 6.12, 6.13 and 6.14). These limits included:

  • Moderator Temperature Coefficient limits,
  • Shutdown rod insertion limits,
  • Axial flux difference limits and target band,
  • Heat flux hot channel factor (Fo) limit at rated thermal power,
  • Normalized Fo limit as a function of core height K(z),
  • Fxy limits for rated thermal power, and
  • Nuclear enthalpy rise hot channel factor (F ).

As part of these proposed amendments, Technical Specification 6.9.1.6 was also revised to include the changes in Technical Specification 6.9.1.6.a and to add additional NRG-approved methodologies in Technical Specification 6.9.1.6.b. One of the added methodologies was WCAP-8385 for Technical Specification 3.2.1 for Axial Flux Difference. These proposed amendments were approved by the NRC in September 1991 (Reference 6.15).

Similar to these previously-approved amendments, this proposed license amendment would relocate information to the COLRs that has the potential for changing on a cycle-by-cycle basis while retaining the licensed methods in the Technical Specifications.

4. 3. No Significant Hazards Consideration Analysis STP Nuclear Operating Company (STPNOC) requests approval of a change to the STP Unit 1 and Unit 2 Technical Specifications. The proposed change would relocate the specific details of the Fxy exclusion zone locations from Technical Specification 4.2.2.2.f to the Core Operating Limits Reports (COLRs) for Unit 1 and Unit 2.

STP is also proposing administrative changes to Technical Specifications 6.9.1.6, 4.2.2.2.f and 4.8.1.1.2 that do not impact the operation of the facility in a manner that involves significant hazards considerations.

Enclosure NOC-AE-17003510 Page 8 of 10 STPNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The relocation of the Fxy exclusion zones to the COLRs has no impact on the accidents analyzed in the STPNOC UFSAR and is not an accident initiator. Since the change does not impact any conditions that would initiate an accident, the probability or consequences of previously analyzed events is not increased. The proposed amendment does not change the actions to be taken if a core operating limit is exceeded and there are no physical changes associated with this proposed amendment.

For each core reload, each accident analysis addressed in the STP UFSAR will continue to be examined with respect to changes in the cycle-dependent parameters, which are obtained from the use of NRG-approved reload design methodologies, to ensure that the transient evaluation of new reloads are bounded by previously accepted analyses. This examination, which will be conducted per the requirements of 10 CFR 50.59, will ensure that future core reloads will not involve a significant increase in the probability or consequences of an accident previously evaluated.

Therefore, there is no impact to the probability or consequences of an accident previously evaluated due to the proposed change.

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

Response: No.

The relocation of the Fxy exclusion zone details from the Technical Specifications to the COLRs will not create the possibility of a new or different kind of accident from any accident previously evaluated. No safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. No new operator actions are created as a result of the proposed change. The cycle-specific variables are determined using the NRC approved methods and the COLRs are submitted to the NRC to allow the staff to continue to trend the values of these limits. The Technical Specifications will continue to require operation within the core operating limits and appropriate actions will be required if these limits are exceeded.

The relocation of the Fxy exclusion zones to the COLRs has no impact on the accidents analyzed in the STPNOC Updated Final Safety Analysis Report (UFSAR) and is not an accident initiator. Since this change does not impact any conditions that would initiate an accident, there is no possibility of a new or different kind of accident resulting from this change.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Enclosure NOC-AE-17003510 Page 9 of 10

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

Response: No The relocation of the Fxy exclusion zone details from the Technical Specifications to the COLRs will not affect the margin of safety. The margin of safety presently provided by the Technical Specifications remains unchanged. They will be incorporated into the COLR which is submitted to the NRC, therefore appropriate measures exist to control the values of these limits. The development of the limits for future reloads will continue to conform to those methods described in NRG-approved documentation. STPNOC will continue to confirm all safety analysis limits remain bounding on a cycle-specific basis using an NRC approved methodology. Each core reload will involve a Reload Safety Evaluation to assure that operation of the unit within the cycle specific limits will not involve a significant reduction in the margin of safety.

The proposed amendment does not affect the design of the facility or system operating parameters, does not physically alter safety-related systems and does not affect the method in which safety-related systems perform their functions.

Therefore, the proposed change does not impact margin of safety.

Based on the above, STPNOC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4. Conclusion 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.

5. ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Enclosure NOC-AE-17003510 Page 10 of 10

6. REFERENCES 6.1. WCAP-8385, "Power Distribution and Load Following Procedures Topical Report,"

September 1974 (Westinghouse Proprietary) 6.2. Technical Specification Bases 3/4.2.2 and 3/4.2.3, Heat Flux Hot Channel Factor and Nuclear Enthalpy Rise Hot Channel Factor 6.3. NRC Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," October 4, 1988 (ML031150407) 6.4. Technical Specification 3/4.2.2, Heat Flux Hot Channel Factor- Fq(Z) 6.5. Technical Specification 6.9.1.6, Core Operating Limits Report (COLR) 6.6. WCAP-12472-P-A, "BEACON Core Monitoring and Operations Support System," August 1994 (Westinghouse Proprietary) 6.7. WCAP-12472-P-A Addendum 1-A, "BEACON Core Monitoring and Operations Support System (WCAP-12472-P-A) Addendum 1, January 2000 (Westinghouse Proprietary) 6.8. WCAP-12472-P-A Addendum 4, Revision 0, "BEACON Core Monitoring and Operations Support System (WCAP-12472-P-A) Addendum 1, September 2012 (Westinghouse Proprietary) 6.9. Letter from G.E. Vaughn, Houston Lighting & Power Company, to US Nuclear Regulatory Commission, "Proposed Amendment to the Unit 1 and Unit 2 Technical Specifications,"

June 1, 1989 (ST-HL-AE-003103)(NRC Legacy ADAMS accession number 8906060408) 6.10. Letter from G.F. Dick, Jr., NRC, to J.H. Goldberg, Houston Lighting & Power Company, "Issuance of Amendment Nos. 9 and 1 to Facility Operating License Nos. NPF-76 and NPF South Texas Project, Units 1 and 2 (TAC Nos. 73323 and 73324, " July 31, 1989, (ST-AE-HL-092205)(ML021290303) 6.11. Letter from L.M. Regner, NRC, to D.L. Koehl, STPNOC, "South Texas Project, Units 1 and 2- Issuance of Amendments Re: Revision to Administrative Controls Technical Specification 6.9.1.6, "Core Operating Limits Report" (TAC Nos. MF4639 and MF4640},"

February 27, 2015, (AE-NOC-15002635)(ML15049A129) 6.12. Letter from G.E. Vaughn, Houston Lighting & Power, to NRC Document Control Desk, "Proposed Amendment to the Unit 1 and Unit 2 Technical Specifications," September 15, 1989 (ST-HL-AE-003208)(NRC Legacy ADAMS accession number 8909280061) 6.13. Letter from W.H. Kinsey, Jr., Houston Lighting & Power, to NRC Document Control Desk, "Proposed Amendment to the Unit 1 and Unit 2 Technical Specifications," January 8, 1991 (ST-HL-AE-003635)(NRC Legacy ADAMS accession number 9101150382) 6.14. Letter from W.H. Kinsey, Jr., Houston Lighting & Power, to NRC Document Control Desk, "Clarifications to Proposed Amendment to the Unit 1 and Unit 2 Technical Specifications, "

May 23, 1991 (ST-HL-AE-003756)(NRC Legacy ADAMS accession number 9105310174) 6.15.. Letter from G.F. Dick, Jr., NRC, to D.P. Hall, Houston Lighting & Power, "Issuance of Amendment Nos. 27 and 17 to Facility Operating License Nos. NPF-76 and NPF South Texas Project, Units 1 and 2 (TAC Nos. 79390, 79391, 74891 and 74892),"

September 9, 1991 (ST-AE-HL-092838)(ML021280384) 6.16. Letter from M.C. Thadani, NRC, to E.D. Halpin, STPNOC, "South Texas Project, Units 1

& 2- Issuance of Amendments to Relocate Surveillance Test Intervals to Licensee Controlled Program (Risk-Informed Initiative 5-b) (TAC Nos. MD7058 and MD7059), '

October 31, 2008 (AE-NOC-08001822)(ML082830172)

Enclosure NOC-AE-17003510 Attachment 1 Attachment 1 Technical Specification Page Markups

POWER DISTRIBUTION LIMITS Page Includes Non-Administrative Change SURVEILLANCE REQUIREMENTS (Continued)

2) When F is less than or equal to the FTP limit for the appropriate measured core plane, additional core power distribution measurements shall be taken and F compared to FTP and F at least once per 31 E FPD.
e. The Fxy limits used in the Constant Axial Offset Control analysis for RATED THERMAL POWER (FTP) shall be provided for all core planes containing bank "D" control rods and all unrodded core planes as specified in the COLR per Specification 6.9.1.6;
f. The F limits of S ecification 4.2.2.2e., above, are not a plane1 regions
g. With F exceeding F, the effects of Fxy on Fa(Z) shall be evaluated to determine if Fa(Z) is within its limits.

4.2.2 .3 When Fa(Z) is measured for other than Fxy determinations, an overall measured Fa(Z) shall be obtained from core power distribution measurement and increased by the applicable manufacturing and measurement uncertainties as specified in the COLR.

SOUTH TEXAS - UNITS 1 & 2 3/4 2-8 Unit 1 - Amendment No. 2:1..,

Unit 2 - Amendment No. 4-7,

ELECTRICAL POWER SYSTEMS Administrative Change Only SURVEILLANCE REQUIREMENTS (Continued)

13) Demonstrating the OPERABILITY of the automatic load shed bypass and the manual load shed reinstatement features of the load sequencer.
f. At a frequency in accordance with the Surveillance Frequency Control Program or after any modifications which could affect standby diesel Align as subsection generator interdependence by starting all standby diesel generators under 4.8.1.1.2 simultaneously, during shutdown, and verifying that all standby diesel generators accelerate to at least 600 rpm in less than or equal to 10 seconds; and
g. At a frequency in accordance with the Surveillance Frequency Control Program by draining each fuel tank, removing the accumulated Align as subsection sediment and cleaning the tank.

under 4.8.1.1.2 4.8.1.1.3. (Not Used)

SOUTH TEXAS - UNITS 1 & 2 3/4 8-6 Unit 1 - Amendment No. 102, 122 Ill Unit 2 - Amendment No. 89, 110 Im j

Administrative Change Only 6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6a (Continued) Fxy Exclusion Zones, TP

8. Heat Flux Hot Channel Factor, K(Z), Power Factor Multiplier, F ' and Fa(Z) manufacturing and measurement uncertainties for Specification 3/4.2.2,
9. Nuclear Enthalpy Rise Hot Channel Factor, Power Factor Multiplier, and FH measurement uncertainties for Specification 3/4.2.3, and
10. DNB related parameters for Reactor Coolant System Tav9 Pressurizer Pressure, and the Minimum Measured Reactor Coolant System Flow fcir Specification 3/4.2.5.

The COLR shall be maintained available in the Control Room.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRG, specifically those described in the following documents:
1. WCAP-9272-P-A, "Westinghouse reload safety evaluation methodology," July 1985 (W Proprietary).

(Methodology for Specification 3.1.1.1 - Shutdown Margin, Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Rod Insertion Limit, 3.1.3.6 - Control Bank Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 - Heat Flux Hot Channel Factor, 3.2.3 - Nuclear Enthalpy Rise Hot Channel Factor, and 3.2.5 - DNB Parameters.)

2. WCAP-12942-P-A, '.'safety evaluation supporting a more negative eol Moderator temperature coefficient technical specification for the south texas project electric generating station units 1 and 2."

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient)

3. WCAP-8745-P-A, "Design Basis for the Thermal Overpower T and Thermal Overtemperature T Trip Functions," September 1986 (Westinghouse Proprietary Class 2).

(Methodology for Specification 2.1 - Safety Limits, and 2.2 - Limiting Safety System Settings)

4. WCAP 8385, "power distribution and load following procedures topical report,"

September, 1974 (Yj_ Proprietary).

for S ecification 3.2.1 - Axial Flux Difference Constant Axial Offset and 3.2.2 - Heat Flux Hot Channel Factor (Fxv Exclusion Zones)}

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-15 Unit 1 - Amendment No. 115, 150, 151, Ill Unit 2 - Amendment No. 1oa, 1as, 1a9, ill

6.0 ADMINISTRATIVE CONTROLS Administrative Change Only 6.9 Reporting Requirements 6.9.1.6b (Continued)

5. Westinghouse Letter NS-TMA-2198, T.M. Anderson (Westinghouse) to K.

Kniel (Chief of Core Performance Branch, NRC) January 31, 1980 -

Attachment:

Operation and Safety Analysis Aspects of an Improved Load Follow Package.

(Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control). Approved by NRC Supplement No. 4 to NUREG-0422, January 1981, Docket Nos. 50-369 and 50-370.)

6. NUREG-0800, Standard Review Plan, U. S. Nuclear Regulatory Commission, Section 4.3, Nuclear Design, July 1981. Branch Technical Position CPB 4.3-1, Westinghouse Constant Axial Offset Control (CAOC),

Rev. 2, July 1981.

(Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control).)

7. WCAP-10266-P-A, Rev. 2, WCAP-11524-NP-A Rev. 2, "The 1981 Version of the Westinghouse ECCS Evaluation Model Using the BASH Code,"

Kabadi, J.N., et al., March 1987; including Addendum 1-A, "Power Shape Sensitivity Studies," December, 1987 and Addendum 2-A, "BASH methodology Improvements and Reliability Enhancements," May 1988.

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor) 8.1 WCAP-12610-P-A, "Vantage+ Fuel Assembly Reference Core Report,"

April 1995 0!f_ Proprietary) 8.2 WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO', July 2006 0!f_ Proprietary)

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor) 91 Cameron Measurement Systems/Caldon Ultrasonics Engineering Report: ER-157(P-A)

Rev. 8 and Rev. 8 Errata, "Supplement to Caldon Topical Report ER-SOP: Basis for Power Uprates with an LEFM Check or an LEFM CheckPlus System," May 2008.

(Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt with LEFM CheckPlus System)

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-16 Unit 1 - Amendment No. 138, 151, 175, 198, 111 Unit 2 - Amendment No. 127, 139, 163, 186, lU]

Administrative Change Only 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, 00/_ Proprietary).

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient)

11. WCAP 12472-P-A, "BEACON Core Monitorin and 0 erations Su ort System," August 1994 (':!::!.. Proprietary , including Addenda 1-A (January 2000)

J uncertainties in I . rn rn

  • a d 4 (September 2012)

(Methodology for Specification - 3.2.2 - Heat Flux Hot Channel Facto rl uclear 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. The report shall include:

a. The scope of inspections performed on each SG,
b. Active degradation mechanisms found,
c. Nondestructive examination techniques utilized for each degradation mechanism,
d. Location, orientation (if linear}, and measured sizes (if available) of service induced indications,
e. Number of tubes plugged during the inspection outage for each active degradation mechanism,
f. Total number and percentage of tubes plugged to date,
g. The results of condition monitoring, including the results of tube pulls and in-situ testing, 6.9.2 Not Used SOUTH TEXAS - UNITS 1 & 2 . 6-17 Unit 1 - Amendment No. 138, 144, 151, 164, IB Unit 2 - Amendment No. 127, 132, 139, 154, B

Enclosure NOC-AE-17003510 Attachment 2 Attachment 2 Retyped Technical Specification Pages

POWER DISTR IBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

2) When F i s less than o r equal t o the FTP limit for the appropriate measured core plane, additional core power distribution measurements shall be taken and F compared to FTP and F at least once per 31 E FPD.
e. The Fxy limits used in the Constant Axial Offset Control analysis for RATED THERMAL POWER (FTP) shall be provided for all core planes containing bank "D" control rods and all unrodded core planes as specified in the C O LR per Specification 6.9.1.6;
f. The Fxy limits of Specification 4.2.2.2e., above, are not applicable in the core plane regions specified in the COLR.
g. With F exceeding F, the effects of Fxy on Fa(Z) shall be evaluated to determine if Fa(Z) is within its limits.

4.2 .2.3 When Fa(Z) is measured for other than Fxy determinations, an overall measured Fa(Z) shall be obtained from core power distribution measurement and increased by the applicable manufacturing and measurement uncertainties as specified in the COLR.

SOUTH TEXAS - UNITS 1 & 2 3/4 2-8 Unit 1 - Amendment No. 2:7., 41&

Unit 2 - Amendment No. 4+,

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

13) Demonstrating the OPERABILITY of the automatic load shed bypass and the manual load shed reinstatement features of the load sequencer.
f. At a frequency in accordance with the Surveillance Frequency Control Program or after any modifications which could affect standby diesel generator interdependence by starting all standby diesel generators simultaneously, during shutdown, and verifying that all standby diesel generators accelerate to at least 600 rpm in less than or equal to 1 O seconds; and
g. At a frequency in accordance with the Surveillance Frequency Control Program by draining each fuel tank, removing the accumulated sediment and cleaning the tank.

4.8.1.1.3. (Not Used)

SOUTH TEXAS - UNITS 1 & 2 314 8-6 Unit 1 - Amendment No. 102, 122, 188 Unit 2 - Amendment No. 89, 110, 175

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6a (Continued)

8. Heat Flux Hot Channel Factor, K(Z), Fxy Exclusion Zones, Power Factor*

Multiplier, FTP, and Fo(Z) manufacturing and measurement uncertainties for Specification 3/4.2.2,

9. Nuclear Enthalpy Rise Hot Channel Factor, and Power Factor Multiplier, and FH measurement uncertainties for Specification 3/4.2.3, and
10. DNB related parameters for Reactor Coolant System Tavg Pressurizer Pressure, and the Minimum Measured Reactor Coolant System Flow for Specification 3/4.2 .5.

The COLR shall be maintained available in the Control Room.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRG, specifically those described in the following documents:
1. WCAP-9272-P-A, "Westinghouse reload safety evaluation methodology," July 1985 (W Proprietary).

(Methodology for Specification 3.1.1.1 - Shutdown Margin, Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Rod Insertion Limit, 3.1.3.6 - Control Bank Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 - Heat Flux Hot Channel Factor, 3.2 .3 - Nuclear Enthalpy Rise Hot Channel Factor, and 3.2.5 - DNB Parameters.)

2. WCAP-12942-P-A, "safety evaluation supporting a more negative eol Moderator temperature coefficient technical specification for the south texas project electric generating station units 1 and 2."

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient)

3. WCAP-8745-P-A, "Design Basis for the Thermal Overpower AT and Thermal Overtemperature AT Trip Functions," September 1986 (Westinghouse Proprietary Class 2).

(Methodology for Specification 2.1 - Safety Limits, and 2.2 - Limiting Safety System Settings)

4. WCAP 8385, "power distribution and load following procedures topical report,"

September, 1974 (W Proprietary).

(Methodology for Specification 3.2.1 - Axial Flux Diffrence (Constant Axial Offset Control) and 3.2.2 - Heat Flux Hot Channel Factor (Fxy Exclusion Zones))

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-15 Unit 1 - Amendment No. 115, 150, 151, +e Unit 2 - Amendment No. 103, 138, 139, 4W

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6b (Continued)

5. Westinghouse Letter NS-TMA-2198, T.M. Anderson (Westinghouse) to K. Kniel (Chief of Core Performance Branch, NRC) January 31, 1980 -

Attachment:

Operation and Safety Analysis Aspects of an Improved Load Follow Package.

(Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control). Approved by NRC Supplement No. 4 to NUREG-0422, January 1981, Docket Nos. 50-369 and 50-370.)

6. NUREG-0800, Standard Review Plan, U. S. Nuclear Regulatory Commission, Section 4.3, Nuclear Design, July 1981. Branch Technical Position CPS 4.3-1, Westinghouse Constant Axial Offset Control (CAOC),

Rev. 2, July 1981.

(Methodology for Specification 3.2.1 - Axial Flux Difference (Constant Axial Offset Control).)

7. WCAP-10266-P-A, Rev. 2, WCAP-11524-NP-A Rev. 2, "The 1981 Version of the Westinghouse ECCS Evaluation Model Using the BASH Code,"

Kabadi, J.N., et al., March 1987; including Addendum 1-A, "Power Shape Sensitivity Studies," December, 1987 and Addendum 2-A, "BASH methodology Improvements and Reliability Enhancements," May 1988.

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor) 8.1 WCAP-12610-P-A, "Vantage+ Fuel Assembly Reference Core Report,"

April 1995 fYJ._ Proprietary) 8.2 WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO', July 2006 fYJ._ Proprietary)

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor)

9. Cameron Measurement Systems/Caldon Ultrasonics Engineering Report: ER-157(P-A)

Rev. 8 and Rev. 8 Errata, "Supplement to Caldon Topical Report ER-SOP: Basis for Power Uprates with an LEFM Check or an LEFM CheckPlus System/' May 2008.

(Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt with LEFM CheckPlus System)

(continued)

SOUTH TEXAS - UNITS 1 & 2 6-16 Unit 1 - Amendment No. 138, 151, 175, 198, 2G4 Unit 2 - Amendment No. 127, 139, 163, 186, 92

6.0 ADMINISTRATIVE CONTROLS 6.9 Reporting Requirements 6.9.1.6 (continued)

10. WCAP-137 49-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 2 012)

(Methodology for uncertainties in Specifications 3.2.2 - Heat Flux Hot Channel Factor and 3.2.3 and 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. The report shall include:

h. The scope of inspections performed on each SG,
i. Active degradation mechanisms found,
j. Nondestructive examination techniques utilized for each degradation mechanism,
k. Location, orientation (if linear), and measured sizes (if available) of service induced indications, I. Number of tubes plugged during the inspection outage for each active degradation mechanism,
m. Total number and percentage of tubes plugged to date,
n. The results of condition monitoring, including the results of tube pulls and in-situ testing, 6.9.2 Not Used SOUTH TEXAS - UNITS 1 & 2 6-17 Unit 1 - Amendment No. 138, 144, 151, 164, 2-G4 Unit 2 - Amendment No. 127, 132, 139, 154, 4-92

Enclosure NOC-AE-17003510 Attachment 3 Attachment 3 Technical Specification Bases Changes (for information only)

Enclosure NOC-AE-17003510 Attachment 3 Page 1 of 1 Add the following paragraphs to the end of Bases page 3/4 2-4 Fxy evaluations are not applicable in the excluded zones at the top and bottom of the core, at grid locations, or near the Control Bank D RCCA demand position. These core regions are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions.

Due to the axial fuel features of the reactor fuel used at STP (e.g. annular pellets, axial blankets with reduced enrichment, Integral Fuel Burnable Absorbers (IFBA) and cutback zones between IFBA, and axial blanket regions) limiting peaking factor margins can potentially occur in the top and bottom exclusion zones. This could result in a change to the exclusion zones if limiting peaks are identified in the formerly excluded region.

The amount of the axial core region that may be excluded during the performance of Surveillance Requirement 4.2.2.2f may be reduced on a cycle-specific basis as determined during the core reload design process. The specific exclusion zones for each unit and cycle are identified in the COLRs.

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