Text

Issuance of Amendment No. 209, Reactor Coolant System Operational Leakage (Tac No. MB3126)
	ML022040154
Person / Time
Site:	Millstone
Issue date:	08/21/2002
From:	Nerses V; NRC/NRR/DLPM/LPD1
To:	Price J; Dominion Nuclear Connecticut
	Nerses V, NRR//DLPM, 415-1484
References
	TAC MB3126
	Download: ML022040154 (14)
	v • d • e

August 21, 2002 Mr. J. A. Price Site Vice President - Millstone Dominion Nuclear Connecticut, Inc.

Mr. David A. Smith Rope Ferry Road Waterford, CT 06385

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 3 - ISSUANCE OF AMENDMENT RE: REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE (TAC NO.

MB3126)

Dear Mr. Price:

The Commission has issued the enclosed Amendment No. 209 to Facility Operating License No. NPF-49 for the Millstone Power Station, Unit No. 3, in response to your application dated October 1, 2001, and supplemented by letters dated June 26 and August 5, 2002.

The amendment will revise the Technical Specifications (TSs) limiting condition for operation and surveillance requirements associated with verification of reactor coolant system operational leakage. Conforming changes are also made to the associated TS Bases.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

Victor Nerses, Sr. Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosures:

1. Amendment No. 209 to NPF-49

2. Safety Evaluation cc w/encls: See next page

ML022040154

See previous concurrence OFFICE PDI-2/PM PDI-2/LA TSS/SC*

SRXB/SC*

OGC*

PDI-2/SC(A)

NAME VNerses TLClark RDennig FAkstulewicz SBrock JZimmerman DATE 8/13/02 8/13/02 08/06/02 08/07/02 8/12/02 8/21/02

DOMINION NUCLEAR CONNECTICUT, INC., ET AL.

DOCKET NO. 50-423 MILLSTONE POWER STATION, UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 209 License No. NPF-49

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the applicant dated October 1, 2001, and supplemented by letters dated June 26 and August 5, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

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-49 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. Dominion Nuclear Connecticut, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of issuance, and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Jacob I. Zimmerman, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 21, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 209 FACILITY OPERATING LICENSE NO. NPF-49 DOCKET NO. 50-423 Replace the following pages of the Appendix A Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 4-22 3/4 4-22 3/4 4-23 3/4 4-23 B 3/4 4-4d B 3/4 4-4d B 3/4 4-4e B 3/4 4-4e

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REACTOR COOLANT SYSTEM OPERATIONAL LEAKAGE MILLSTONE POWER STATION, UNIT NO. 3 FACILITY OPERATING LICENSE NO. NPF-49 DOCKET NO. 50-423

1.0 INTRODUCTION

By application dated October 1, 2001, as supplemented June 26 and August 5, 2002, Dominion Nuclear Connecticut, Inc. (licensee or DNC), requested changes to the Technical Specifications (TSs) for Millstone Power Station, Unit No. 3 (MP3). The supplements dated June 26 and August 5, 2002, were within the scope of the original application as published in the Federal Register and did not change the staffs proposed no significant hazards consideration determination. Specifically, the licensee proposed to:

(1) add a footnote to Limiting Condition for Operation (LCO) 3.4.6.2.f to specify that this LCO does not apply to the valves in the residual heat removal (RHR) system flow path when in, or during the transition to or from, the shutdown cooling operation; (2) delete the reactor coolant system (RCS) leakage surveillance requirements (SRs) 4.4.6.2.1.a and 4.4.6.2.1.b, which require monitoring the containment atmosphere radioactivity and containment sump inventory, respectively; (3) revise SR 4.4.6.2.1.d to specify that verification of RCS water inventory balance is performed during steady-state operations; (4) delete SR 4.4.6.2.2.c, which requires that prior to returning an RCS pressure isolation valve (PIV) to service following maintenance, repair or replacement work on a valve the operability of the valve will be verified by ensuring that valve leakage is within its limit; (5) add an identifier to the existing footnote for SRs 4.4.6.2.1 and 4.4.6.2.2 to minimize the potential for confusion with respect to the applicability of this footnote due to addition of another footnote to TS 4.4.6.2.2, (6) add a footnote to SR 4.4.6.2.2 to clarify that verification of the RCS leakage for PIVs in the RHR flow path is not required when the RHR system is aligned to the RCS in the shutdown cooling mode of operation; and (7) add guidance to the Bases to discuss the requirements of SR 4.4.6.2.1.d for performance of an RCS water inventory balance, and the requirements of SR 4.4.6.2.2 for RCS PIV leakage test conditions.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36c(2)(ii) contains the requirements to determine whether an LCO is required to be included in the TSs. This regulation provides four criteria that can be used to determine those requirements which must be included in the TSs.

Consistent with this approach, the four criteria to be used in determining whether particular safety functions are required to be included in the TSs, are as follows:

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 4 A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The Standard Technical Specifications (STS) were developed based on these criteria in 10 CFR 50.36(c)(2)(ii). Existing LCOs and related SRs included as TS requirements which satisfy any of these criteria specified in 10 CFR 50.36(c)(2)(ii) must be retained in the TSs.

Those requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents. The U.S. Nuclear Regulatory Commission (NRC) encourages licensees to upgrade their TSs consistent with these criteria and conforming, to the extent practical and consistent with the licensing basis for the plant, to the current STS.

MP3 uses a pressurized water type nuclear steam supply system furnished by Westinghouse Electric Corporation (W). As noted above, since the STS were developed based on the criteria in 10 CFR 50.36(c)(2)(ii), the staff reviewed the proposed TS changes (Ref. 1) in accordance with NUREG-1431 (Ref. 2), Standard Technical Specifications - Westinghouse Plants.

3.0 TECHNICAL EVALUATION

3.1 Addition of a Footnote to LCO 3.4.6.2.f The existing LCO 3.4.6.2.f limits RCS leakage to 0.5 gallons per minute (gpm) per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure of 2250 + 20 psia from any RCS PIV specified in TS Table 3.4-1, including the PIVs in the RHR system. The licensee indicated that the PIVs in the RHR flow path are maintained open during shutdown cooling (SDC) operations to provide heat removal for the reactor core. Verification of the leakage limits for those valves in the RHR flow path during SDC operations does not provide benefit in maintaining RCS inventory or in minimizing the release of the radioactive material from the RCS. The licensee proposed to add a footnote to LCO 3.4.6.2.f to clarify that this LCO does not apply to those PIVs in the RHR system flow path during SDC operations. The staff agrees with the licensees rationale for revising the TS and finds that the change is consistent with LCO 3.4.14, RCS Pressure Isolation Valve (PIV) Leakage, of WSTS (Ref. 2.). The WSTS LCO 3.4.14 requires that leakage from each RCS PIV be within its limits. Its APPLICABILITY statement specifies, in part, that the requirements of PIV leakage verification are applicable for MODE 4 operations except valves in the RHR flow path when in, or during the transition to or from, the RHR mode of operation. Note 2 to WSTS SR 3.4.14.1 also specifies that the SR for the leakage limit verification is not required on the RCS PIVs located in the RHR flow path when in the SDC mode of operation. Therefore, the staff concludes that this change to the TS is acceptable.

3.2 Deletion of SRs 4.4.6.2.1.a and 4.4.6.2.1.b The licensee proposed to delete SRs 4.4.6.2.1.a and 4.4.6.2.1.b. These SRs require monitoring the containment atmosphere radioactivity and containment sump inventory, respectively, but do not require measuring the amount of RCS leakage, which is necessary to make a decision that the RCS is being operated within its allowed leakage limits required by TS 3.4.6.2, Reactor Coolant System - Operational Leakage. These two systems are leakage detection systems, which provide early indication that the RCS is leaking. The SR 4.4.6.2.1.d, which requires that an RCS water inventory balance be performed during steady state operation, provides the means necessary to measure the amount of leakage to ensure that the RCS is being operated within its leakage limits. The containment atmosphere radioactivity monitor and containment sump inventory have surveillance requirements in SRs 4.4.6.1.a and 4.4.6.1.b, respectively, which will continue to ensure the operability of these leakage detection systems. Since the proposed deletion of SRs 4.4.6.2.1.a and 4.4.6.2.1.b does not change the current TS requirements for verification of leakage limits, the staff considers the change to be acceptable. In addition, the staff finds the deletion of SRs 4.4.6.2.1.a and 4.4.6.2.1.b to be consistent with TS 3.4.13, RCS Operational LEAKAGE, of WSTS (Ref. 2), which does not contain the similar SRs.

3.3 Revision of SR 4.4.6.2.1.d Current SR 4.4.6.2.1.d requires performance of an RCS water inventory balance at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The licensee indicated that verification of leakage limits by performing a water inventory balance when steady-state conditions do not exist is difficult and does not always result in an accurate assessment of RCS leakage. Thus the RCS water inventory balance must be met with the reactor at steady state operating conditions. For RCS operational LEAKAGE determination by water inventory balance, steady state is defined in the revised bases as stable RCS pressure, temperature, power level, pressurized and makeup tank levels, makeup and letdown flows. The licensee proposed to revise the SR such that verification of RCS water inventory balance will be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of achieving steady-state operation and at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months thereafter during steady state operation. The licensee indicated that the 12-hour time allowance is needed to collect and process all necessary data. The staff agrees with the licensees rationale for conducting the required RCS leakage test during steady-state operation and agrees that the proposed 12-hour is a reasonable time allowance for conducting the leakage tests. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance is acceptable since it provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Since performance of RCS water balance during steady-state will result in a more accurate verification of RCS leakage, the staff considers that the revised SR is acceptable and notes that the revision meets the intent of the WSTS. SR 3.4.13.1 (Ref 2) which requires that the RCS inventory balance be performed at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with a note specifying that the SR is not required to be performed in Mode 3 or 4 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of steady state operation.

3.4 Deletion of SR 4.4.6.2.2.c SR 4.4.6.2.2.c requires that prior to returning an RCS PIV to service following maintenance, repair, or replacement work on a valve, the operability of the valve be verified by ensuring that valve leakage is within its limit. The licensee indicated that post-maintenance testing following maintenance activities, which is controlled by plant procedures, would specify this verification if the associated work could adversely affect valve leakage. The determination of the appropriate post-maintenance testing will be based on the work performed. By allowing flexibility in determining the appropriate testing based on work performed, unnecessary post-maintenance testing can be avoided. The staff concluded that this justification was inadequate in that it lacked a regulatory basis for the deletion of the TS.

The purpose of SR 4.4.6.2.2.c is to verify OPERABILITY of the RCS PIVs following their maintenance, repair or replacement. The proposed deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. This equipment continues to be tested in a manner and at a frequency necessary to give confidence that the equipment can perform its assumed safety function. Any time the OPERABILITY of a system or component has been affected by repair, maintenance, modification, or replacement of a component, post maintenance testing is required to demonstrate the OPERABILITY of the system or component. This is required by SR 4.0.1 and described in the Bases for WSTS SR 3.0.1. In addition, the requirements of 10 CFR 50, Appendix B, Section XI (Test Control) provide adequate controls for test programs to ensure that testing incorporate applicable acceptance criteria. Compliance with 10 CFR 50, Appendix B is required under the unit operating license. As a result, post-maintenance testing will continue to be performed and an explicit requirement in the TS is not necessary.

Furthermore, current SR 4.4.6.2.2.e will remain unchanged and continue to ensure (Ref. 3) that the testing of a PIV following maintenance, repair, or replacement work is performed in accordance with the requirements of the Inservice Test (IST) Program. The requirements of the IST Program are specified in American Society of Mechanical Engineers (ASME) OM Code

- 1995, Section ISTC, Inservice Testing of Valves in Light Water Reactor Power plants.

Specifically, Subsection ISTC 3.4 states, in part, that When a valve or its control system has been replaced, repaired, or has undergone maintenance that could affect the valves performance, a new reference value shall be determined or the previous value reaffirmed by an inservice test run before the time it is returned to service or immediately if not removed from service.....

Based on the discussions above, the NRC staff determined that the deletion of SR 4.4.6.2.2.c will not remove the required post-maintenance testing. Therefore, the NRC staff concludes that the deletion is acceptable.

3.5 Addition of an Identifier to the Existing Footnote for SRs 4.4.6.2.1 and 4.4.6.2.2 A (1) will be added to SR 4.4.6.2.2 and to the existing footnote for the SR. The existing footnote states that the provisions of TS 4.0.4 are not applicable for entry into Mode 3 or 4. The addition of an identifier for the existing footnote will minimize the potential for confusion of this footnote due to the addition of another footnote for SR 4.4.6.2.2. This change provides clarification and is an editorial change. Therefore, it is acceptable.

A (1) is also added to SR 4.4.6.2.1. The staff found that the existing footnote is not applicable to current SR 4.4.6.2.1 and the proposed TS addition is not an editorial change claimed by the licensee. The staff requested the licensee to provide additional information to address the acceptability of the TS change. In response (Ref. 4), the licensee agreed that the existing footnote is not applicable to current SR 4.4.6.2.1 and withdrew the (1)" from the proposed SR 4.4.6.2.1. Instead, the licensee proposed to add a (1) to SR 4.4.6.2.1.d, which provides test requirements for the RCS water inventory balance. In the TS Bases section for the revised TS, the licensee indicated that the RCS water inventory balance must be met with the reactor at steady state operation conditions. Therefore, the footnote (1) is added to SR 4.4.6.2.1.d given that this SR is not required to be performed in Mode 3 or 4 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state. The staff notes that the TS change will require the RCS water inventory balance be performed at temperature and pressure conditions corresponding to the applicable modes of operation for SR 4.4.6.2.1.d, and determines that it meets the purpose of this SR for accurate measurement of the RCS leakage. Therefore, the staff concludes that this TS change is acceptable.

3.6 Addition of a Footnote to SR 4.4.6.2.2 A (2) will be added to SR 4.4.6.2.2 and an associated footnote will be added to the bottom of the affected page. Footnote (2) states that: This surveillance is not required to be performed on Reactor Coolant System Pressure Isolation Valves located in the RHR flow path when in, or during the transition to or from, the shutdown cooling mode of operation. The added footnote is consistent with the changes to LCO 3.4.6.2.f. As discussed in Section 3.1, the staff has concluded that the revised LCO 3.4.6.2.f is acceptable. With the acceptable LCO 3.4.6.2.f, the change to SR 4.4.6.2.2 is acceptable.

3.7 Addition of Clarification to Bases for SRs 4.4.6.2.1.d and 4.4.6.2.2 The following paragraphs are added to the Bases of TS 3/4.4.6.2:

Paragraph 1: steady state operation is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and reactor coolant pump seal injection and return flow. The 12-hour allowance time for SR 4.4.6.2.1.d provides sufficient time to collect and process all necessary data after stable plant conditions are established. The staff finds that the added information related to the definition of the steady-state operation and testing allowance time is acceptable and consistent with the guidance in the Bases for WSTS SR 3.4.13.1 (Ref. 2).

Paragraph 2: Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions for performance of Surveillance Requirement 4.4.6.2.2 (including Surveillance Requirement 4.4.6.2.2.d) for RCS pressure isolation valves which can only be leak-tested at elevated RCS pressures. The requirements of Surveillance Requirement 4.4.6.2.2.d to verify that a pressure isolation valve is OPERABLE shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the required RCS pressure has been met.

During the course of the review, the staff requested the licensee to provide clarification between the SR and the added Bases information related to the PIV test conditions. In response, the licensee revised (Ref. 3) the proposed changes (Paragraph 2) to TS Bases 3/4.4.6.2 as follows:

In Modes 1 and 2, the plant is at normal operating pressure and Surveillance Requirement 4.4.6.2.2.d shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of valve actuation due to automatic or manual action or flow through the valve. In Modes 3 and 4, Surveillance Requirement 4.4.6.2.2.d shall be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of valve actuation due to automatic or manual action or flow through the valve if and when RCS pressure is sufficiently high for performance of this surveillance.

The staff finds that the added information is acceptable because it provides clarification for the leakage test conditions and has met the intent of WSTS SR 3.4.14.1 that requires, in part, the leakage test be performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after the PIV has been reseated during Modes 1 through 4.

4.0

SUMMARY

The staff has reviewed the licensees proposed TS changes and supporting documentation.

Based on its review presented above, the staff determined that the changes to TS 3.4.6.2 and associated Bases are acceptable and consistent with the applicable Sections of WSTS 3.4.13 and 3.4.14 (Ref. 2).

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Connecticut State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (66 FR 57120). Accordingly, the amendment meets 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 amendment.

7.0 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) such activities will be conducted in compliance with the Commissions 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.

8.0 REFERENCES

1.

Letter from J. A. Price (DNC) to NRC, Millstone Power Station, Unit No. 3, - Technical Specifications Change Request 3-11-01, Reactor Coolant System Operational Leakage, dated October 1, 2001.

2.

Technical Specification 3.4.13, RCS Operational LEAKAGE, and Technical Specification 3.4.14, RCS Pressure Isolation Valve (PIV) Leakage, in NUREG-1431, Westinghouse Standard Technical Specifications, dated April 7, 1995.

3.

Letter from J. A. Price (DNC) to NRC, Millstone Power Station, Unit No. 3, - Response to a Request for Additional Information, Technical Specifications Change Request 3-11-01, Reactor Coolant System Operational Leakage, dated June 26, 2002.

4.

Letter from J. A. Price (DNC) to NRC, Millstone Power Station, Unit No. 3, - Additional Information Relating to Technical Specifications Change Request 3-11-01, Reactor Coolant System Operational Leakage, dated August 5, 2002.

Principal Contributor: S. Sun R. Giardina V. Nerses Date: August 21, 2002

Millstone Power Station Unit 3 cc:

Ms. L. M. Cuoco Senior Nuclear Counsel Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Edward L. Wilds, Jr., Ph.D.

Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Mr. P. J. Parulis Manager - Nuclear Oversight Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. W. R. Matthews Vice President and Senior Nuclear Executive - Millstone Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Ernest C. Hadley, Esquire P.O. Box 1104 West Falmouth, MA 02574-1104 Mr. John Markowicz Co-Chair Nuclear Energy Advisory Council 9 Susan Terrace Waterford, CT 06385 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Mr. D. A. Christian Senior Vice President - Nuclear Operations and Chief Nuclear Officer Innsbrook Technical Center - 2SW 5000 Dominion Boulevard Waterford, CT 06385 Senior Resident Inspector Millstone Nuclear Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. G. D. Hicks Director - Nuclear Station Safety and Licensing Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. D. A. Smith Manager - Licensing Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870