ML15049A129

South Texas Project, Units 1 and 2 - Issuance of Amendment Nos. 204 and 192, Revise Technical Specification 6.9.1.6, Core Operating Limits Report, with Respect to Analytical Methods Used to Determine Core Operating Limits (TAC Nos. MF4639 a

ML15049A129
Person / Time
Site:	South Texas
Issue date:	02/27/2015
From:	Regner L M Plant Licensing Branch IV
To:	Koehl D L South Texas
Regner L M
References
TAC MF4640, TAC MF4639
Download: ML15049A129 (27)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Dennis L. Koehl President and CEO/CNO STP Nuclear Operating Company South Texas Project P.O. Box 289 \Nadsworth, TX 77483 February 27, 2015

SUBJECT:

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)

Dear Mr. Koehl:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 204 to Facility Operating License No. NPF-76 and Amendment No. 192 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively.

The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 14, 2014, as supplemented by letter dated December 18, 2014. The amendments modify TS 6.9.1.6, "Core Operating Limits Report (COLR)," to revise the methodology for operating at a rated thermal power of 3,853 Mega\Natts thermal (M\Nt) by reflecting a change to the feedwater flow measurement equipment.

This license amendment request and its TS change reflect only the equipment change and do not constitute approval of a measurement uncertainty recapture power uprate. The units will continue to operate with the currently licensed thermal power of 3,853 M\Nt.

D. Koehl A copy of our related Safety Evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice. Docket Nos. 50-498 and 50-499

Enclosures:

1. Amendment No. 204 to NPF-76 2. Amendment No. 192 to NPF-80 3. Safety Evaluation cc w/encls: Distribution via Listserv Lisa M. Regner, Senior Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 204 License No. NPF-76 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (GOA) (the licensees), dated August 14, 2014, as supplemented by letter dated December 18, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended {the Act), and the Commission's 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 Commission's regulations; D. The issuance of this license 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 Commission's 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 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. 204, 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. The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

Attachment:

Changes to the Facility Operating License No. NPF-76 and the Technical Specifications FOR THE NUCLEAR REGULA TORY COMMISSION Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

February 27, 2015.

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 192 License No. NPF-80 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (COA) (the licensees), August 14, 2014, as supplemented by letter dated December 18, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's regulations; D. The issuance of this license 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 Commission's 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 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. 192, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the 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.

Attachment:

Changes to the Facility Operating License No. NPF-80 and the Technical Specifications FOR THE NUCLEAR REGULA TORY COMMISSION Eric R. Oesterle, Acting Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

February 27, 2015.

ATTACHMENT TO LICENSE AMENDMENT NOS. 204 AND 192 FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Facility Operating License Nos. NPF-76 and NPF-80, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. Facility Operating License NPF-76 REMOVE INSERT Facility Operating License No. NPF-80 REMOVE REMOVE 6-16 6-17 INSERT Technical Specifications INSERT 6-16 6-17 SOUTH TEXAS LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, 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. 204 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 192 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. (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 Commission's 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.

Amendment No. 192

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 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 <YY.. Proprietary) 8.2 WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOŽ," July 2006 rfY_ Proprietary) (Methodology for Specification 3.2.2 -Heat Flux Hot Channel Factor) 9. CENPD-397-P-A, Revision 01, "Improved Flow Measurement Accuracy Using Crossflow Ultrasonic Flow Measurement Technology," May 2000. (Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt with Crossflow UFM System) 9a. 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) SOUTH TEXAS -UNITS 1 & 2 6-16 (continued)

Unit 1 -Amendment No.138, 151, 175, 198, 204 Unit 2 -Amendment No 127, 139, 163, 186, 192

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, 0!::J.. 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 0!::J.. Proprietary) (Methodology for Specification 3.2.1 -Axial Flux Difference, 3.2.2 -Heat Flux Hot Channel Factor, 3.2.3 -Nuclear Enthalpy Rise Hot Channel Factor) c. The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal-mechanical limits, core thermal-hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met. d. The COLR, including any mid-cycle revisions or supplements, shall be provided to the NRC upon issuance for each reload cycle. 6.9.1.7 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with Specification 6.8.3.o. 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, 204 Unit 2 -Amendment No 127, 132, 139, 154, 192 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 204 AND 192 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERA TING COMPANY, ET AL.

1.0 INTRODUCTION

SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 By application dated August 14, 2014 (Agencywide Documents Access and Management System (ADAMS) package Accession No. ML 14260A432), as supplemented by letter dated December 18, 2014 (ADAMS Accession No. ML 15008A088), STP Nuclear Operating Company (STPNOC, the licensee), requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Units 1 and 2. Portions of the letter dated August 14, 2014, contain sensitive unclassified non-safeguards information (proprietary) and, accordingly, those portions have been withheld from public disclosure.

The supplemental letter dated December 18, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 2, 2014 (79 FR 71455). In its application, the licensee proposed changes to TS 6.9.1.6, "Core Operating Limits Report (COLR)," to revise the methodology for operating at a rated thermal power of 3,853 Megawatts thermal (MWt) by reflecting a change to the feedwater flow measurement equipment.

This license amendment request (LAR) and its TS change reflect only the equipment change and do not constitute approval of a measurement uncertainty recapture (MUR) power uprate. The units will continue to operate with the currently licensed thermal power (L TP) of 3,853 MWt. Enclosure 3

2.0 REGULATORY EVALUATION

Early revisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.46 and Appendix K to 10 CFR Part 50, required licensees to base their loss-of-coolant accident (LOCA) analysis on an assumed power level of at least 102 percent of the L TP level to account for power measurement uncertainty.

The NRC later modified this requirement to permit licensees to justify a smaller margin for power measurement uncertainty.

Licensees may apply the reduced margin to operate the plant at a level higher than the previously licensed power. NRC Regulatory Issue Summary (RIS) 2002-03, Guidance on the Content of Measurement Uncertainty Recapture

[MUR] Power Uprate Applications, dated January 31, 2002 (ADAMS Accession No. ML013530183), provides generic guidance for evaluating an MUR power uprate. Although this LAR does not constitute an MUR power uprate application, Enclosure 2 to the LAR provides the plant-specific evaluation of the relevant portion of RIS 2002-03, Attachment 1, Part I, which is the evaluation of the equipment to be used. 3.0 BACKGROUND STP, Units 1 and 2, were initially licensed to operate at a rated thermal power (RTP) of 3,800 MWt. In April 2002, the NRC approved a 1.4-percent power uprate (ADAMS Accession No. ML020800263), based on the reduced core thermal power level uncertainty associated with the more accurate measurement of feedwater flow ascribed to the Crossflow ultrasonic flow meter (UFM) System. This increased the LTP to 3853 MWt. During the previous Unit 2 refueling outage, the feedwater pipe wall in the area of the Crossflow UFM System was found to have thinned, and pipe diameter constants were adjusted in the Crossflow UFM System calculation.

When Unit 1 readings later indicated the same type of erosion, the Crossflow UFM System was taken out of service until the pipe diameter constants were adjusted in the Crossflow UFM System calculation.

The licensee contracted two independent firms to verify the actual power level at which the units were operating.

Both studies found that prior to correcting the pipe diameter in the RTP calculations, the Crossflow UFM indications of approximately 3,853 MWt were within the allowed uncertainty.

After correcting the pipe diameter, the UFM indications of approximately 3,853 MWt were higher by 1 percent to 1.3 percent compared to the studies, indicating that actual power was closer to between 3,803 MWt and 3,815 MWt. Consequently, STPNOC expects to replace the Crossflow UFM System with the Caldon Leading Edge Flow Meter (LEFM) CheckPlus System in both units during the refueling outages in 2015 in order to operate at close to the currently licensed RTP of 3,853 MWt. The Cameron LEFM CheckPlus System was developed over a number of years. Cameron submitted a topical report in March of 1997, ER-BOP that described the LEFM and included calculations of power measurement uncertainty obtained using a Check system in a typical two-loop pressurized-water reactor or a two-feedwater-line boiling-water reactor. This topical report also provided guidance for determining plant-specific power calorimetric uncertainties.

The NRC staff approved the use of this topical report in a safety evaluation (SE) dated March 8, 1999 (ADAMS Accession No. ML 11353A017}, which allowed a 1-percent power uprate. Following the publication of the changes to 10 CFR Part 50, Appendix K, which allowed for an uncertainty less than 2 percent, Cameron submitted topical report ER-160P (ADAMS Accession No. ML010510372), which is a supplement to ER-BOP. The NRG staff approved ER-160P by letter dated January 19, 2001 (ADAMS Accession No. ML010260074), for use in a power uprate request of up to 1.4 percent. Subsequently, in an SE dated December 20, 2001 (ADAMS Accession No. ML013540256), the NRG staff approved ER-157P, Revision 5 (ADAMS Accession No. ML013440078), for use in a power uprate request of up to 1.7 percent using the CheckPlus system. The NRG staff also recently approved ER-157P, Revision 8 and associated errata (ADAMS Accession Nos. ML081720323 and ML 102950246, respectively).

ER-157P, Revision 8, corrects minor errors in Revision 5, provides clarifying text, and incorporates revised analyses of coherent noise, non-fluid delays, and transducer replacement.

It also adds two new appendices, Appendix C and Appendix D, which describe the assumptions and data that support the coherent noise and transducer replacement calculations, respectively.

4.0 ULTRASONIC

FLOW METER DESIGN AND CHARACTERISTICS To determine volumetric flow rate, the Cameron/Caldon UFM transmits an acoustic pulse along a selected path and records the arrival of the pulse at the receiver.

Another pulse is transmitted in the opposite direction and the time for that pulse is recorded.

Since the speed of an acoustic pulse will increase in the direction of flow and will decrease when transmitted against the flow, the difference in the upstream and downstream transit times for the acoustic pulse provides information on flow velocity.

Once the difference in travel times is determined, the average velocity of the fluid along the acoustic path can be determined.

Therefore, the difference in transit time is proportional to the average velocity of the fluid along the acoustic path. Cameron/Caldon provides an array of ultrasonic transducers installed in a spool piece, 16 transducers to determine average velocity in each of 8 paths in the CheckPlus, housed in fixtures on the spool piece. The transducers are arranged such that they form parallel and precisely defined acoustic paths. Using the resulting time measurements and the known path lengths, the average fluid velocity along each path length is determined.

To obtain the actual average flow velocity, a meter factor is applied to the integrated average flow velocity indicated by the UFM. The meter factor for the Cameron/Caldon UFMs is determined through meter testing at the Alden Research Laboratory and is equal to the true area averaged flow velocity divided by the flow velocity averaged along the meter paths to correlate the meter readings to the average velocity and hence to the average meter volumetric flow. The mass flow rate is found by multiplying the spool area by the average flow velocity and density. Use of a spool piece and chordal paths improves the dimensional uncertainties including the time measurement of the ultrasonic signal and enables the placement of the chordal paths at precise locations generally not possible with an externally mounted UFM. This allows a chordal UFM to integrate along off-diameter paths to more efficiently sample the flow cross section. In addition, a spool piece has the benefit that it can be directly calibrated in a flow facility, improving measurement uncertainty compared to externally mounted UFMs that were historically installed in nuclear power plant feedwater lines. Typically, measured correction factors for the CheckPlus are a fraction of a percent in contrast to several percent for an externally mounted UFM. Thus, determination of a correction factor is less sensitive to error in the CheckPlus.

5.0 TECHNICAL

EVALUATION

5.1 Proposed

TS Change Current TS 6. 9.1. 6b states, in part, that: 9. CENPD-397-P-A, Revision 01, "Improved Flow Measurement Accuracy Using Crossflow Ultrasonic Flow Measurement Technology," May 2000. (Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt) Revised TS 6.9.1.6b would state, in part, that: 9. CENPD-397-P-A, Revision 01, "Improved Flow Measurement Accuracy Using Crossflow Ultrasonic Flow Measurement Technology," May 2000. (Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt with Crossflow UFM System) 9a. Cameron Measurement Systems/Caldon Ultrasonics Engineering Report: ER-157(P-A)

Rev. 8 and Rev. 8 Errata, "Supplement to Caldon Topical Report ER-BOP: 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) 5.2 NRC Staff Evaluation During the next refueling outage in each unit, the licensee intends to replace the existing Crossflow UFM System with a Caldon LEFM CheckPlus System as the normal (preferred) feedwater flow indication.

The venturi-based feedwater flow instruments (venturis) will continue to provide inputs to other indication, protection, and control systems, and will be used for feedwater flow indication if the LEFM CheckPlus System is non-functional as defined in plant procedures.

The physical changes to the plant will be completed under the 1 O CFR 50.59 process and are not part of this LAR. The proposed TS change would revise the methodology for operating at an RTP of 3,853 MWt to reflect the change of feedwater flow measurement equipment.

This LAR does not approve a power uprate nor was a power uprate requested.

While this proposed license amendment is not an MUR application for power uprate, the information presented in Cameron Measurement System topical report ER-157P, Revision 8, and Errata, "Supplement to Topical Report ER-SOP," remains valid as a review standard and supports this proposed amendment.

5.3 Review

of RIS 2002-03. Attachment 1, Part 1 Criteria Licensee's Description of Items A through C The LAR requests a change in the TSs made necessary by a plant equipment change. The LAR does not include an MUR power uprate request. However, the licensee's description of the information requested in RIS 2002-03, Attachment 1, Guidance on the Content of Measurement Uncertainty Recapture Power Uprate Applications, Part 1, Feedwater flow measurement technique and power measurement uncertainty, regarding the LEFM CheckPlus System is provided below. The feedwater flow measurement system to be installed at STP Unit 1 & Unit 2 is an LEFM CheckPlus ultrasonic multi-path transit time flow meter. The LEFM [CheckPlus System is] an advanced ultrasonic

[system] that accurately

[determines] the volume flow and temperature of feedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM [CheckPlus System], mass flow can be determined and, along with the temperature output, is used with plant data to compute reactor core thermal power. The technology underlying the LEFM Check System ultrasonic instruments and the factors affecting their performance are described in Topical Report ER-SOP and a supplement to this topical report, ER-160P. The LEFM CheckPlus System, which is made up of two LEFM Check subsystems, is described in another supplement to the LEFM Check System topical report, and is numbered ER-157P. The LEFM CheckPlus System in each STP unit [will consist] of a spool piece containing sixteen transducers (in eight chordal paths) installed in each of the four feedwater flow loops, with eight transmitters and two central processing units located in the Turbine Generator Building.

Each flow element will be installed at least five diameters downstream from the original feedwater venturis and the last pipe bend, and at least two diameters upstream from the next 90° bend. The installation location of each LEFM flow element will conform to the requirements in Cameron Topical Reports ER-BOP, ER-160P, and ER-157P. A. The reference Topical Reports are as follows: i. ER-SOP "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM Check System," dated March 1997 ii. ER-160P "Supplement to Topical Report ER-SOP: Basis for a Power Uprate with the LEFM Check System," dated May 2000 ([ADAMS Accession No.] ML003723720)

B. C. iii. ER-157P "Supplement to Topical Report ER-80P: Basis for a Power Uprate with the LEFM Check or CheckPlus System," dated May 2009 ([ADAMS Accession No.] ML091340322)

i. ii. iii. The NRC approved the Topical Reports on the following dates: ER-BOP NRC SER dated March 8, 1999 ER-160P NRC SER dated January 19, 2001 ([ADAMS Accession No.] ML010260074)

ER-157P NRC SER dated August 16, 2010 ([ADAMS Accession No.] ML 102160694)

The LEFM CheckPlus System will be permanently installed in STP Unit 1 & Unit 2 in accordance with the requirements of ER-BOP, ER-160P, and ER-157P. It will be used for continuous calorimetric power determination by direct link with the plant computer and will incorporate self-verification features to ensure that hydraulic profile and signal processing requirements are met within its design basis uncertainty analysis.

The LEFM CheckPlus System will be calibrated in a site-specific model test at Alden Research Laboratories with traceability to National Standards.

A copy of the Alden Labs certified calibration report will be in the Design Basis Uncertainty Analysis for the system. The LEFM CheckPlus System will be installed and commissioned in accordance with Cameron procedures, including verification of ultrasonic signal quality and hydraulic velocity profiles as compared to those tested during site-specific model testing. NRG Staff Evaluation of Items A through C Items A and B: In its LAR, the licensee identified approved Topical Reports as applicable to the Cameron LEFM CheckPlus System: Item C: In its response to Item C, the licensee stated that the LEFM CheckPlus System will be permanently installed in STP Unit 1 and Unit 2 according to the requirements specified in Topical Reports ER-BOP and ER-157P. In addition, the licensee stated the LEFM CheckPlus System will be calibrated in a site-specific model test at Alden Research Laboratories (ARL) with traceability to national standards, and a copy of the certified calibration report will be in the design basis uncertainty analysis for the system. Finally, the LEFM CheckPlus System will be installed and commissioned in accordance with Cameron procedures, including verification of ultrasonic signal quality and hydraulic velocity profiles as compared to those tested during site-specific model testing. Based on its review of the. licensee's submittals as discussed above, the NRC staff concludes that the licensee has sufficiently addressed the plant-specific implementation of the Cameron LEFM CheckPlus System using proper topical report guidelines.

Therefore, the licensee's description of the proposed feedwater flow measurement technique follows the guidance in Items A through C of Section I of Attachment 1 to RIS 2002-03 and meets the regulatory requirements of 10 CFR 50, Appendix K. Licensee's Description of Item D Item D in Section I of Attachment 1 to RIS 2002-03 guides licensees in addressing four criteria to be addressed by each licensee.

The licensee described the four criteria and provided a discussion of how each will be satisfied as follows: Criterion 1 Discuss maintenance and calibration procedures that will be implemented with the incorporation of the LEFM, including processes and contingencies for inoperable LEFM instrumentation and the effect on thermal power measurements and plant operation.

Criterion 2 For plants that currently have LEFMs installed, provide an evaluation of the operational and maintenance history of the installed installation and confirmation that the installed instrumentation is representative of the LEFM system and bounds the analysis and assumptions set forth in Topical Report ER-BOP. Criterion 3 Confirm that the methodology used to calculate the uncertainty of the LEFM CheckPlus System in comparison to the current feedwater instrumentation is based on accepted plant set point methodology (with regard to the development of instrument uncertainty).

If an alternative approach is used, the application should be justified and applied to both venturi and ultrasonic flow measurement instrumentation installations for comparison.

Criterion 4 For plants where the ultrasonic meter (including LEFM) was not installed and flow elements calibrated to a site-specific piping configuration (flow profiles and meter factors not representative of the plant specific installation), additional justification should be provided for its use. The justification should show that the meter installation is either independent of the plant specific flow profile for the stated accuracy, or that the installation can be shown to be equivalent to known calibrations and plant configurations for the specific installation including the propagation of flow profile effects at higher Reynolds numbers. Additionally, for previously installed calibrated elements, confirm that the piping configuration remains bounding for the original LEFM installation and calibration assumptions.

NRC Staff Review of Item D Criteria 1 and 2: The NRC staff's review indicates that implementation of the license amendment will include developing the necessary procedures and documents required for operation, maintenance, calibration, testing, and training with the new LEFM CheckPlus System. Plant maintenance and calibration procedures will be developed to incorporate Cameron's maintenance and calibration requirements to assure that the LEFM CheckPlus System is properly maintained and calibrated.

The NRC staff notes that Criterion 2 is not applicable to STP, Units 1 and 2, which currently do not have LEFMs installed.

Based on its review of the licensee's submittals, the NRC staff concludes the licensee acceptably addressed Criteria 1 and 2. Criterion 3: The licensee stated that the LEFM system's random and systematic uncertainties are treated according to the recommendations of the American Society of Mechanical Engineers (ASME) PTC 19.1 methodology, the American National Standards Institute (ANSI) I International Society of Automation (ISA) standard ANSl/ISA-67.04.01 and Recommended Practice ISA-RP67.04.02 methodology, which are consistent with the methodology used in the current thermal power uncertainty calculation for the existing feedwater flow measurement instrumentation.

Based on the discussion above, the NRC staff concludes the licensee has acceptably addressed Criterion

3. Criterion 4: A complete LEFM CheckPlus uncertainty analysis based on calibration testing already conducted was provided with the LAR as Attachment

1. This analysis documents the +/-0.5 percent flow uncertainty for the LAR, including the effects of velocity profile and upstream hydraulics on the LEFM CheckPlus.

The licensee established the calibration factor for each LEFM CheckPlus flow element by holding tests of these spools at ARL in January, 2015 for Unit 2. The NRC staff witnessed portions of this testing during an audit at ARL. The calibration factor for the Unit 1 LEFM CheckPlus flow elements will be established in the same laboratory later in 2015. These tests included a full-scale model of the STP, Units 1 and 2, hydraulic geometry and parametric tests. An ARL data report for these tests and a Cameron engineering report evaluating the test data will be on file. The calibration factor used for the LEFM CheckPlus System at STP, Units 1 and 2, will be based on these reports. The uncertainty in the calibration factor for the spools will be based on the Cameron engineering report. The site-specific uncertainty analysis will document these analyses.

This document will be maintained on file as part of the technical basis for STP, Units 1 and 2. The licensee stated that final acceptance of the site-specific uncertainty analyses will occur after completion of the commissioning process. The commissioning process verifies the test data and provides final positive confirmation that the instrument will perform as expected following installation in the plant. Following installation and commissioning of the LEFM CheckPlus System, Cameron will provide a Commissioning Letter documenting that the installed LEFM CheckPlus System uncertainty meets the uncertainty defined in the LAR, Attachment 1 analysis and meets the requirements of Topical Reports ER BOP and ER 157P as accepted by the NRG for referencing in licensing applications for an MUR power uprate. The power level will not exceed 3,B3B MWt until the licensee completes the Commissioning Letter. Upon completion of the Commissioning Letter, STPNOC will use the LEFM for determining RTP at the currently licensed level of 3,B53 MWt. Final commissioning is expected to be completed during the startup following the upcoming Units 1 and 2 refueling outages. Based on the information above and the NRG staff's review of the licensee's submitted calibration data in Cameron Engineering Reports ER-1059 and ER-1060, the NRG staff concludes that the licensee adequately addressed Criterion

4. Based on its review of the licensee's submittals as discussed above, the NRG staff finds the licensee has sufficiently addressed the plant-specific criteria stated in the SEs for Topical Reports ER-BOP and ER-157P. Therefore, the staff concludes the licensee followed the guidance in Item D of Section I of Attachment 1 to RIS 2002-03 and meets the regulatory requirements of 10 CFR 50, Appendix K. The NRG staff notes that the final acceptance of the site-specific uncertainty analyses will occur after completion of the commissioning process. The commissioning process verifies bounding calibration test data (see Appendix F of ER-BOP), which provides final positive confirmation that actual performance in the field meets the uncertainty bounds established for the instrumentation.

Licensee's Description and NRG Staff Review of Item E Item E in Section I of Attachment 1 to RIS 2002-03 guides licensees in the submittal of a specific total power measurement uncertainty calculation, explicitly identifying all parameters and their individual contributions to the power uncertainty.

To address Item E of RIS 2002-03, the licensee provided Cameron Engineering Report ER-1059, Revision 1, "Bounding Uncertainty Analysis for Thermal Power Determination at South Texas Project Units 1 and 2 Using the LEFM CheckPlus System," and Cameron Engineering Report ER-1060, Rev 1, "Meter Factor Calculation and Accuracy Assessment for South Texas Project Units 1 and 2." The NRC staff reviewed these reports and determined the licensee properly identified the parameters associated with the thermal power measurement uncertainty, provided individual measurement uncertainties, and calculated the overall thermal power uncertainty.

STPNOC also stated that it uses the square root sum of the squares methodology in the development of the majority of its calculated instrument uncertainties.

As a result, the NRC staff concludes the licensee has provided calculations of the total power measurement uncertainty at the plant, explicitly identifying all parameters and their individual contributions to the overall thermal power uncertainty.

Therefore, the licensee has acceptably addressed the guidance in Item E of Section I of Attachment 1 to RIS 2002-03 and has met the regulatory requirements of 10 CFR 50, Appendix K. Licensee's Description and NRG Staff Review of Item F Item F in Section I of Attachment 1 to RIS 2002-03 guides licensees in providing information to address the specified aspects of the calibration and maintenance procedures related to all instruments that affect the power calorimetric.

In the LAR, the licensee addressed each of the five aspects of the calibration and maintenance procedures listed in Item F of RIS 2002-03, as follows: (1) Maintaining Calibration The licensee stated calibration and maintenance will be performed by STPNOC using site procedures developed from the Cameron technical manuals. All work is to be performed in accordance with the site work control program. Routine preventive maintenance procedures may include physical inspections, power supply checks, back-up battery replacements, and internal oscillator frequency verification based on Cameron recommendations.

Ultrasonic signal verification and alignment is to be performed automatically with the LEFM CheckPlus System. Signal verification is possible by review of signal quality measurements performed and displayed by the LEFM CheckPlus System. Instrumentation and Controls (l&C) personnel will be trained and qualified in accordance with the l&C training program on the LEFM CheckPlus System before work or calibration may be performed.

Formal training by Cameron will be provided to site personnel prior to commissioning the system in Unit 2. (2) Controlling Hardware and Software Configuration The licensee stated the LEFM CheckPlus System is designed and manufactured in accordance with Cameron's 1 O CFR 50 Appendix B Quality Assurance (QA) Program and its Verification and Validation (V&V) program. Cameron's V&V program fulfills the requirements of ASME NQA-2-2009 Subpart 2.7, "Quality Assurance Requirements for Computer Software for Nuclear Facility Applications." The software falls under the STPNOC Appendix B QA program with a software QA plan in place. (3) Performing Corrective Actions The licensee stated that corrective actions involving maintenance will be performed by plant l&C personnel qualified in accordance with the l&C Training Program and formally trained on the LEFM CheckPlus System. (4) Reporting Deficiencies to the Manufacturer The licensee stated the LEFM CheckPlus System is included in the System Health Plan and the preventive maintenance program at STP, Units 1 and 2, and is monitored by the System Engineer for reliability.

The licensee further stated that as a plant system, any equipment problems are governed by the STPNOC work control process. All conditions that are adverse to quality are documented under the Corrective Action Program using a Condition Report, and the software falls under the STPNOC Appendix B QA program with a software QA plan in place. Procedures are maintained for notification of deficiencies and error reporting.

(5) Receiving and Addressing Manufacturer Deficiency Reports The licensee stated the STP Unit 1 & Unit 2 LEFM CheckPlus System is under Cameron's V&V Program and procedures are maintained for user notification of important deficiencies.

Based on its review of the above information, the NRC staff found the licensee addressed the calibration and maintenance aspects of the Cameron LEFM CheckPlus System and all other instruments affecting the power calorimetric.

Therefore, the NRC staff concludes that the licensee has met the guidance in Item F of Section I of Attachment 1 to RIS 2002-03 and the regulatory requirements of 10 CFR 50, Appendix K. Licensee's Description and NRG Staff Review of Items G and H Items G and H in Section I of Attachment 1 to RIS 2002-03 guide licensees to provide a proposed allowed outage time (AOT) for the instrument and to propose actions to reduce power if the AOT is exceeded.

For Item G, the licensee proposed a 72-hour AOT for operation with a non-functional LEFM CheckPlus System, provided steady state conditions persist with no power change in excess of 10 percent. In its LAR, the licensee provided the following four bases for the proposed time period: 1. There is an on-line calibration of the venturi instruments to be used if the LEFM CheckPlus System is non-functional for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. These alternate instruments will be calibrated to the last good value provided by the LEFM CheckPlus System and their accuracy will gradually degrade over time. The gradual accuracy degradation is likely to be imperceptible for a 72-hour period provided steady state conditions persist. 2. Seventy-two hours gives plant personnel time to make repairs and to verify normal operation of the LEFM CheckPlus System within its original uncertainty bounds at the same power level and indications as before the failure. 3. STPNOC will operate based on the calibrated venturi instruments as soon as an LEFM CheckPlus System is non-functional.

Performing a de-rate evolution could in many cases be avoided altogether since a repair would most likely be accomplished prior to the expiration of the 72-hour period. 4. If the plant experiences a power change of greater than 10% during the 72-hour period, then the permitted maximum power level would be reduced upon return to full power in accordance with the power levels described in Section h. [of Enclosure 2 of the LAR], since a plant transient may result in calibration changes of the venturi instruments.

For Item H, the licensee stated that STP's plant procedures govern operation at the existing licensed RTP of 3,853 MWt when the Crossflow UFM System is functional, and operation at 3,838 MWt when the Crossflow UFM System is non-functional.

The licensee stated that plant procedures will be revised to govern operation when the LEFM CheckPlus System is functional and non-functional.

The licensee stated that the LEFM System has uncertainty values which support operating at the existing RTP of 3,853 MWt. Further, the licensee specified that the redundant CheckPlus mode has the lowest uncertainty value and the Check mode has a higher, more conservative, uncertainty value of less than 0.6 percent. Operating in either the CheckPlus or the Check mode will ensure that the secondary power is within the existing licensed 0.6 percent uncertainty and therefore within the RTP of 3,853 MWt. The licensee stated that operation of the LEFM CheckPlus system as described below will ensure the plant continues to operate within the uncertainty analyses.

• During commissioning, the venturis will be corrected to match the LEFM CheckPlus flow indication.

This in-situ calibration value will be captured in the plant procedure for venturi calibration.

While the LEFM is functioning in either the CheckPlus or Check mode of operation, the plant computer will trend a ratio between the individual loop LEFM indications and the individual loop venturi indications (in-situ calibrated venturis).

• The redundant LEFM central processing units continuously monitor system performance and the mode of operation.

Alerts are sent through the plant computer to the operator when the LEFM System changes from the CheckPlus mode of operation to another mode, including a nonfunctional or "Fail" mode.

• The LEFM System will alert the operator if the LEFM System is in the "Fail" mode. At that time, the LEFM System will be declared nonfunctional and a 72-hour repair window will be initiated.

Additionally, at that time the LEFM System alert will "freeze" the plant computer ratio between the LEFM and the in-situ calibrated venturis and apply it as a correction factor to the in-situ calibrated venturis, producing a "corrected venturi" indication.

During the repair window, the units can continue to operate at the 3,853 MWt RTP value using the corrected venturis as long as neither the 72-hour window expires nor a 10-percent power change occurs. If either the 72-hour window expires or a 10-percent power change occurs, plant procedures will direct operators to limit power to 3,838 MWt by the calibrated venturis.

This is the current approved limit for operation with the Crossflow UFM System non-functional.

• Station procedures will control LEFM calibration, maintenance, and trending activities, and the frequency of each. In addition, long-term trending and data collection of other plant parameters will be performed.

Plant parameters that may be trended are the ratio of generator output to circulating water temperature, the output from independent secondary calorimetric software, measurements of high-pressure turbine first stage pressure, and the difference between hot-leg and cold-leg primary temperature.

These parameters will be evaluated for use as proposed methods in substantiating the accuracy of the LEFM System. Based on the above discussion and the NRC staff's review of the licensee's LAR and Cameron engineering reports, the NRC staff concludes that the licensee provided sufficient justifications for the proposed AOT and the proposed power reduction actions if the AOT is exceeded.

Therefore, the licensee has followed the guidance in Items G and Hof Section I of Attachment 1 to RIS 2002-03 and has met the regulatory requirements of 10 CFR 50, Appendix K. 5.4 Impact of the Changeover to the CheckPlus System on the Accident Analysis The proposed TS change would revise the methodology for operating at an RTP of 3,853 MWt to reflect the change of feedwater flow measurement equipment.

There is no MUR power uprate associated with this LAR. Additionally, since this LAR does not increase the l TP, there will be no impact to the STP Revised Thermal Design (NOC-AE-14003161)

Procedure, which was previously evaluated up to 3,853 MWt. The uncertainty created by the LEFM system will be bounded by the uncertainty analysis for the "Departure from Nucleate Boiling Revised Thermal Design Procedure" (ADAMS Accession No. ML 14260A432).

Therefore, the NRC staff concludes that there are no changes to the previously approved STP accident analyses.

5.5 Transducer

Installation Sensitivity Transducers are typically removed after Alden Laboratory testing to avoid damage to the spool piece during shipping to the plant, and are later re-installed.

Further, transducers may be replaced following failure or deterioration during operation.

Replacement potentially introduces a change in position within the transducer housing that could affect the chordal acoustic path. Appendix D of the ER-157P, Revision 8, addresses replacement sensitivity by describing tests performed at the Cameron/Caldon Ultrasonics flow loop, and provides a comparison of test results to the analyses of potential placement variations.

The comparison shows that the test results are bounded by predicted behavior.

The NRC staff expects some uncertainty associated with the test loop, even if nothing was changed. Even though this has not been addressed in ER-157P, Revision 8, the licensee conservatively assumed all of the test uncertainty to be due to transducer replacement.

Further, as the licensee stated, the analyses predict a larger uncertainty than obtained during testing, and the analysis uncertainty is used for transducer replacement uncertainty.

The NRC staff considers this approach to be sufficient to cover the inability of the test loop to achieve flow rates comparable to those obtained in plant installations, and to cover any analysis uncertainty associated with applications with pipe diameters that differ from the tests. Therefore, the NRC staff concludes that transducer replacement processes and procedures as described in ER-157P, Revision 8, that will be used in the commissioning process, is acceptable.

5.6 Items

Not Addressed in ER-157P Topical Report Evaluation of the Effect of Downstream Piping Configurations on Calibration The turbulent flow regimes that exist when the plant is near full power result in limited upstream flow profile perturbation from downstream piping. Consequently, the effects of downstream equipment need not be considered for normal CheckPlus operation provided changes in downstream piping, such as the entrance to an elbow, are located greater than two pipe diameters downstream of the chordal paths. However, if the CheckPlus is operated with one or more transducers out of service, the acceptable separation distance is likely a function of transducer to elbow orientation.

In such cases, if separation distance is less than five pipe diameters, it should be addressed.

Evaluation of the Effect of Upstream Flow Straighteners on CheckP/us Calibration There will be no tubular flow straighteners in the feedwater piping upstream of the LEFM CheckPlus System in STP, Unit 1 or Unit 2. Therefore, the NRC staff concludes that upstream flow straighteners do not impact the CheckPlus Calibration.

5.7 Commissioning

Report STP will conduct an in-depth evaluation of the UFM following installation at its plant that includes consideration of any differences between the test and in-plant results, and will prepare a report that describes the results of the evaluation and the STP acceptance of the test results. Performance of the Commissioning Report, which addresses such items as calibration traceability, potential loss of calibration, and cross-checks with other plant parameters during operation to reasonably ensure consistency between thermal power calculations based upon the LEFM and other plant parameters, will satisfy the limitation described in this safety evaluation.

The Commissioning Report shall be available to NRC inspectors for review.

5.8 NRC Staff Conclusion

The NRC staff reviewed the licensee's proposed plant-specific implementation of the feedwater flow measurement device and the thermal power uncertainty calculations.

Based on its review of the licensee's LAR, uncertainty calculations, and referenced topical reports, the NRC staff finds that the licensee's proposed amendment is consistent with the approved Cameron Topical Report ER-BOP and its supplement Topical Report ER-157P, as well as with the guidance of RIS 2002-03. Therefore, the licensee's proposed amendment meets the relevant requirements of 10 CFR 50, Appendix K. The NRC staff finds the thermal-hydraulics and instrumentation and control aspects of the proposed LAR are acceptable.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment.

The State official had no comments.

7.0 ENVIRONMENTAL

CONSIDERATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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, and there has been no public comment on such finding published in the Federal Register on December 2, 2014 (79 FR 71455). 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.

8.0 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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributors:

D. Warner, NRR/DE/EICB F. Forsaty, NRR/DSS/SRXB Date: February 27, 2015.

D. Koehl A copy of our related Safety Evaluation is also enclosed.

The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice. Docket Nos. 50-498 and 50-499

Enclosures:

Sincerely, IRA/ Lisa M. Regner, Senior Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

1. Amendment No. 204 to NPF-76 2. Amendment No. 192 to NPF-80 3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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