ML041320350

Supplemental Information Selective Implementation of the Alternative Source Term Fuel Handling Accident Analyses

ML041320350
Person / Time
Site:	Millstone
Issue date:	05/07/2004
From:	Hartz L Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-193
Download: ML041320350 (22)

Text

Dominion Nuclear Connecticut, Inc.

Mill\tonc Power Station R o p e Ferry Road W.iterford, CT 06385 May 7, 2004 U.S. Nuclear Regulatory Commission Serial No. 04- 193 Attention: Document Control Desk MPS Lic/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 SUPPLEMENTAL INFORMATION SELECTIVE IMPLEMENTATION OF THE ALTERNATIVE SOURCE TERM FUEL HANDLING ACCIDENT ANALYSES By a letter dated September 26, 2002, Dominion Nuclear Connecticut, Inc. (DNC) proposed to amend Operating License DPR-65 by incorporating changes into the Millstone Unit 2 Technical Specifications. The proposed changes selectively implement the Alternative Source Term for the Fuel Handling Accident analysis.

The values used for the gap fractions in the analysis that supported the DNC submittal dated September 26, 2002, were consistent with or bounded the gap fractions in Table 3, Non-LOCA Fraction of Fission Product Inventory in Gap, of Regulatory Guide (RG) 1.183. Footnote 11 to Table 3 of RG 1.I83 states that the values listed are acceptable for a peak rod average burnup less than 62,000 MWD/MTU provided the maximum linear heat generation rate (LHGR) does not exceed 6.3-kw/ft peak rod average power for burnups exceeding 54,000 MWD/MTU. Millstone Unit 2 typically meets the LHGR and burnup criteria, assuming that the burnup criteria of 54,000 MWD/MTU applies to the maximum assembly burnup. However, the Nuclear Regulatory Commission (NRC) staff, in discussions with DNC, indicated that the burnup criterion applies to the peak rod average burnup. Based on the current plan for 18-month cycles, Millstone Unit 2 will exceed the LHGR of 6.3 kw/ft for rod burnups in excess of 54,000 MWD/MTU for a small number of rods. No rods will exceed 62,000 MWD/MTU.

Because of the potential to exceed the LHGR and burnup criteria of footnote 11 to Table 3 of RG 1.183, DNC is submitting an alternate method to determine bounding gap fractions for these small numbers of rods. Attachment 1 contains a description of the alternative method. The calculational method used to determine the ANSVANS 5.4 gap fractions is the same as that submitted and approved on the Ft. Calhoun docket (TAC No. MB1221, Amendment 201). The proposed gap fractions for Millstone Unit 2 resulting from a Fuel Handling Accident (FHA) have no impact on the previously submitted values for Total Effective Dose Equivalent (TEDE) at the Exclusion Area Boundary (EAB), Low Population Zone (LPZ), and the Millstone Unit 2 control room.

Additionally, in conference calls with the NRC during the weeks of January 6, 2004 and February 2, 2004, the NRC staff requested modifications to the proposed Technical Specification changes in the September 26, 2002 letter.

Serial No.04-193 Alternate Source Term Page 2 of 4 The NRC staff specifically requested the following modifications:

1. Technical Specification 3/4.7.6.1, Control Room Emergency Ventilation System Change the proposed Applicability from APPLICABILITY: MODES 1, 2, 3, and 4 to:

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6

2. Technical Specification 3/4.9.4, Containment Penetrations Change proposed Action a. from

a. The equipment door closed or capable of being closed under administrative control*,

to:

a. The equipment door shall be either:

1. closed and held in place by a minimum of four bolts, or

2. open under administrative control* and capable of being closed and held in place by a minimum of four bolts, DNC agrees with the NRC staffs request. Attachment 2 contains the marked-up version of the appropriate pages of the current Technical Specifications. Attachment 3 provides the retyped pages of the Technical Specifications.

The additional information provided in this letter does not affect the conclusions of the Safety Summary and Significant Hazards Consideration discussion previously submitted in the DNC September 26, 2002, letter.

Serial No.04-193 Alternate Source Term Page 3 of 4 If you have any questions or require additional information, please contact Mr. David W.

Dodson at (860) 447-1791, extension 2346.

Very truly yours, Leslie N. Hartz Vice President - Nuclear Engineering Attachments: (3)

Commitments made in this letter: None.

cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. V. Nerses Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8C2 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station

SN: 04-193 Docket No.: 50-336

Subject:

Alternate Source Term Page 4 of 4 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO 1 The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Engineering, of Dominion Nuclear Connecticut, Inc. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this 7 day of J~A?, ,2004.

My Commission Expires:

3/ / '7 & d I -

Notary Public (SEAL)

ATTACHMENT 1 SUPPLEMENTAL INFORMATION LICENSE BASIS DOCUMENT CHANGE REQUEST 2-18-02 SELECTIVE IMPLEMENTATION OF THE ALTERNATIVE SOURCE TERM -

FUEL HANDLING ACCIDENT ANALYSES DESCRIPTION OF THE ALTERNATE METHOD TO DETERMINE BOUNDING GAP FRACTIONS MILLSTONE POWER STATION UNIT 2 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.04-193 Docket No. 50-336 Attachment 1 Page 1 of 3 Description of the Alternate Method to Determine Boundinq Gap Fractions Millstone Unit 2 has submitted a selective Alternate Source Term (AST) application regarding the Fuel Handling Accident (FHA). The values used for the gap fractions in the analysis that supported the submittal were consistent with or bounded the gap fractions in Table 3, Non-LOCA Fraction of Fission Product Inventory in Gap, of Regulatory Guide (RG) 1.183.

Footnote 11 to Table 3 of RG 1.I 83 states that the values listed are acceptable for a peak rod average burnup less than 62,000 MWD/MTU provided that the maximum linear heat generation rate (LHGR) does not exceed 6.3-kw/ft peak rod average power for burnups exceeding 54,000 MWD/MTU. Millstone Unit 2 typically meets the LHGR and burnup criteria, assuming that the burnup criteria of 54,000 MWD/MTU applies to the maximum assembly burnup. However, the Nuclear Regulatory Commission (NRC) staff, in discussions with Dominion Nuclear Connecticut, Inc. (DNC), indicated that the burnup criterion applies to the peak rod average burnup. Based on the current plan for 18-month cycles, Millstone Unit 2 will exceed the LHGR of 6.3 kw/ft for rod burnups in excess of 54,000 MWD/MTU for a small number of rods. No rods will exceed 62,000 MW D/MTU.

Because of the potential to exceed the LHGR and burnup criteria of footnote 11 to Table 3 of RG 1.183, DNC is submitting an alternate method to determine bounding gap fractions for these small numbers of rods.

Alternative methodologies for determining bounding non-LOCA gap fractions have been submitted and approved on the Ft. Calhoun Docket (TAC No. MB1221, Amendment 201) and the TMI docket (TAC No. MB3163, Amendment 249). The methods utilize ANSVANS 5.4, American Nuclear Standard Method for Calculating the Fractional Releases of Volatile Fission Products. The equilibrium equation given in ANSVANS 5.4 is used to estimate the worst-case release fractions, which are calculated using a peak fuel rod average temperature plus 200 degrees Fahrenheit at a conservative linear heat generation rate.

DNC proposes the following for non-LOCA accidents. Short lived isotopes with half-lives typically less than 30 days (i.e., 1-131, Halogens, and other Noble Gases), will use a gap fraction that will be the maximum of either the ANSVANS 5.4 value multiplied by a factor of two or the previously submitted value. Long lived isotopes with half-lives typically greater than one year (i.e., Kr-85 and Alkali metals), will use a gap fraction that will be the maximum of the previously submitted value or the value listed in Table 3 of RG 1.183 increased by a conservative estimate of additional gap activity that results from operating at a bounding rod power for burnups above 54,000 MWD/MTU. The gap fraction values currently in RG 1.183 contain a conservative margin to represent gap fractions for peak rod average burnup less than 62,000 MWD/MTU. The incremental increase in the gap fractions for long-lived isotopes uses a simplified ANSVANS 5.4

Serial No.04-193 Docket No. 50-336 Attachment 1 Page 2 of 3 methodology, which provides additional conservatism to address linear heat rates above 6.3 kw/ft for burnups above 54000 MWD/MTU.

The peak rod fuel average temperatures used in this methodology were calculated using Framatome-ANPs design code RODEX-2. Framatome-ANP is the fuel vendor for Millstone Unit 2. Best estimate temperatures were increased by 200 degrees Fahrenheit to provide margin for conservatism. The LHGR used in this methodology of 7.6 kw/ft bounds the values expected for future cycles.

The ANSVANS 5.4 methodology is considered to be conservative, particularly for the iodine and cesium isotopes, where the noble gas diffusion coefficients are increased by factors of 7 and 2, respectively. As noted in NUREG/CR-6703, more recent data demonstrates that the diffusion coefficients for these isotopes are the same as the noble gases. In the application of these gap fractions to the Non-LOCA accident, the gap fraction calculated for the bounding rod is conservatively applied to the entire assembly.

Short-lived isotope gap fractions were determined using equation 5 from ANSVANS 5.4.

The diffusion coefficient for iodine was based on the noble gas coefficient multiplied by a factor of 7. The cesium coefficient was based on the noble gas diffusion coefficient multiplied by a factor of 2. Precursor effects for Xe-133 and Xe-135 were evaluated per section 3.3 of the ANSVANS 5.4.

A simplified and conservative approach is utilized for isotopes with half-lives in excess of one year. An incremental fuel release is calculated for the time period above 54,000 MWD/MTU (assuming constant power operation) and added to the RG 1.183 gap fractions to estimate the impact of higher power operation on high burnup rods.

Based upon this methodology and assuming a bounding LHGR for the peak rod of 7.6 kw/ft, the following gap fractions were determined, as shown in Table 1.

Table 1 Nuclide Group RG 1.183 MP-2 Gap ANSVANS 5.4 Design Basis MP-2 for Non- Fractions calculated gap Gap Fractions for Non-LOCA used in fractions w/burnup LOCA w/burnup > 54 FHA > 54 GWD/MTU & GWD/MTU & LHGR 5 submittal LHGR 5 7.6 kw/ft 7.6 kw/ft I 1-131 I 0.08 I 0.08 I 0.04 I 0.08 I I Kr-85 10.10 10.10 I A = 0.043 10.15 I Other noble 0.05 0.10 0.026 0.10 gases Other halogens 0.05 0.08 0.013 0.08 I Alkali metals I 0.12 I 0.12 I A = 0.06 10.18 I

Serial No.04-193 Docket No. 50-336 Attachment 1 Page 3 of 3 An evaluation of the FHA analysis, that was submitted and is currently under review for approval, was conducted using the bounding gap fractions shown in the last column of Table 1. The two differences in the gap fractions used in the submittal and those proposed in the last column of Table 1 are those associated with Kr-85 and the alkali metals. As stated in Appendix B of RG 1.183, all particulate radionuclides released from a FHA are retained in the fuel pool or reactor cavity. Alkali metals are handled similarly; therefore the increase in the gap fraction for the alkali metals has no impact on TEDE resulting from a FHA. Although the gap fraction for Kr-85 is increased by a factor of 1.4, the increase has a negligible effect on the reported TEDE as a result of a FHA at Millstone Unit 2. This is because the effective cloud shine dose conversion factor for Kr-85 is small and does not have a significant impact on whole body dose and the whole body dose from a FHA is a small percentage of TEDE. The combination of these two facts results in no reportable difference between TEDE using the design basis gap fractions in the last column of Table 1 and those used in the current submittal.

In conclusion, DNC proposes new non-LOCA gap fractions for Millstone Unit 2 based on the methodology in ANSVANS 5.4. The new gap fractions are listed in the last column of Table 1. The calculational method used to determine the ANSVANS 5.4 gap fractions is the same as that submitted and approved on the Ft. Calhoun Docket (TAC No. MB1221, Amendment 201). The proposed gap fractions for Millstone Unit 2 have no impact on the Total Effective Dose Equivalent (TEDE) at the Exclusion Area Boundary (EAB), Low Population Zone (LPZ), and the Millstone Unit 2 control room resulting from the FHA reported in the submittal currently under NRC review. All future non-LOCA accident analyses, involving gap releases from fuel that exceed the RG 1.183 criteria, will use the gap fractions reported in the last column of Table 1. If future projected operations of Millstone Unit 2 result in LHGR for the peak rod in excess of 7.6 kw/ft, the methodologies described above will be used to calculate revised gap fractions.

ATTACHMENT 2 SUPPLEMENTAL INFORMATION LICENSE BASIS DOCUMENT CHANGE REQUEST 2-18-02 SELECTIVE IMPLEMENTATION OF THE ALTERNATIVE SOURCE TERM -

FUEL HANDLING ACCIDENT ANALYSES MARKED-UP PAGES MILLSTONE POWER STATION UNIT 2 DOMINION NUCLEAR CONNECTICUT, INC.

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent Control Room Emergency Ventilation Trains shall be OPERABLE.

• APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6.

iv ~ d i - t r 4 During,fuel movement within containment or the spent fuel pool. Bcw;s' w i n g movement of a shielded cask over the spent fuel pool ca laydown area.

ACTION :

MODES 1, 2, 3, and 4:

a. With one Control Room Emergency Ventilation Train inoperable, restore the inoperable train to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With both Control Room Emergency Ventilation Trains specified in ACTION c., immediately suspend the assemblies within the spent fuel poolJS?iTth e m o v e m n t o sni e (over the spent fuel pool cask laydown a r e 6 Restore at least one inoperable train to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

PIQcW

c. With both Control Room Emergency Ventilatio rains inoperable due to an i r r r Ji&d inoperable Control Room boundary, immediate suspend the movement of H fuel assemblies within the spent fuel poolsnd the movement of shielded) tasks over t e SDent fuel pool Cask laydown areaJ. Restore the Control Room boundar: to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be i n HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

• The Control Room boundary may be opened intermittently under administrative control.

MILLSTONE - UNIT 2 3/4 7-16 Amendment No. 7p, l p p , I%$, pp$,

Pas, P%S, fff 7

PLANT SYSTEMS f314.7. i n J LIMITIN6 CONDITION FOR OPERATION PCTIoN (continued) ivvrd i r td FwP m overem+ &th;+, &,+ninMn j Or +he 5 p J - F w ) I p d 1)

MODES 5 and 6, and CD'

d. With one Control Room Emergency Ventilation Train inoperable, restore the inoperable train to OPERABLE status within 7 days. After 7 days, either of initiate and maintain operation o f the remaining OPERABLE Control Room hfl*+Li Emergency Ventilation Train in the recirculation mode o f operation, immediately suspend CORE ALTERATIONS, ,the movement of, fuel assembl - ie e movement o f shielded CaSKs o v e r m e spent tuel p@l casK iaya and irrd*+ed

e. With both Control Room Emergency &tilation Trains i;operable, or with (f the OPERABLE Control Room Emergency Ventilation Train required to be in the recirculation mode by ACTION d. not capable o f being powered by an OPERABLE normal and emergency power source, immedi ate1 y susDend CORF f ALTERATIONS, the movement of,fuel- assemblies and the movement of shielde sks over Jhe spent tuel ppoi c ask laydown area/

t an&

1 be ktd irrrrlrhtcl

• • In MODES 5 and 6, when a Control Room Emergency Ventilation Train is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose o f satisfying the requirements of 3.7.6.1 Limiting Condition f o r Operation, provided: (1) its corresponding normal emergency power source is OPERABLE; and (2) all o f its redundant system (s), subsystem (s), train (s), component (s) and device(s) are OPERABLE, or likewise satisfy the requirements o f the specification. Unless both conditions (1) and (2) are satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then ACTION 3.7.6.1.d or 3.7.6.1.e shall be invoked as applicable.

MILLSTONE - UNIT 2 3/4 7-16a Amendment No. ?P!,  ?#PI #f,

COYX h & - h h 0 4 PLANT SYSTEMS March 10, 1999 SURVEILLANCE REQUIREMENTS 4 . 7 . 6 . 1 Each Control Room Emergency Ventilation Train shall be demonstrated I OPERABLE :

a. A t least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying t h a t t h e control room a i r temperature is I( 100'F.

b. A t l e a s t once per 31 days on a STAGGERED TEST BASIS by i n i t i a t i n g from the control room, flow through the HEPA f i l t e r s and charcoal absorber t r a i n and verifying t h a t the t r a i n operates f o r a t l e a s t 1 15 minutes.

c. A t l e a s t once per 18 months o r (1) a f t e r any s t r u c t u r a l maintenance on the HEPA f i l t e r o r charcoal adsorber housings, o r (2) following painting, f i r e or chemical release i n any v e n t i l a t i o n zone communi-cating with t h e t r a i n by: i

1. Verifying t h a t the cleanup t r a i n s a t i s f i e s t h e in-place 1 t e s t i n g acceptance c r i t e r i a and uses the t e s t procedures of Regulatory Positions C.5.a, C.5.c and C.5.d o f Regulatory Guide 1.52, Revision 2, March 1978, and t h e t r a i n flow r a t e i s 2500 I cfm 5 10%.

2. Verifying w i t h i n 31 days a f t e r removal that a laboratory analysis o f a representative carbon sample obtained i n accor-dance w i t h Regulatory Position C.6.b o f Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory t e s t i n g c r i t e r i a of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978.* The carbon sample shall have a removal efficiency of 2 95 percent.

3. Verifying a train flow r a t e of 2500 cfm & 10% during t r a i n I operation when tested i n accordance w i t h ANSI N510-1975.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying w i t h i n 31 days a f t e r removal t h a t a laboratory analysis of a repre-sentative carbon sample obtained i n accordance w i t h Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 , March 1978, meets the laboratory t e s t i n g criteria o f Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978."

• ASTM 03803-89 shall be used in place of ANSI N509-1976 as referenced in t a b l e 2 o f Regulatory Guide 1.52. The laboratory t e s t of charcoal should be conducted a t a temperature of 30'C and a r e l a t i v e humidity o f 95% w i t h i n the tolerances specified by ASTM D3803-89.

MILLSTONE .. UNIT .2

PLANT SYSTEMS March 10, 1999 SURVEILLANCE REQUIREMENTS (Continued)

e. A t l e a s t once per 18 months by:

1. Verifying t h a t the pressure drop across the combined HEPA f i l t e r s and charcoal adsorber banks i s less than 3.4 inches Water Gauge while operating t h e t r a i n a t a f l o w r a t e o f 2500 cfm 10%. I

2. Verifying t h a t on a r e c i r c u l a t i o n signal, w i t h t h e Control Room Emergency Ventilation Train opepating i n t h e normal mode and the smoke purge mode, the t r a i n automatically switches i n t o a r e c i r c u l a t i o n mode o f operation with f l o w through the HEPA f i1t e r s and charcoal adsorber banks.

MILLSTONE - UNIT.2

PLANT SYSTEMS March 10, 1999 SURVEILLANCE REQUIREMENTS (Continued)

3. Verifying that control room air in-leakage i s l e s s than 130 SCFM w i t h the Control Room Emergency Ventilation System I operating i n the recirculation/filtration mode.

f. After each complete or partial replacement of a HEPA f i l t e r bank by verifying that the HEPA f i l t e r banks remove greater than o r equal t o 99% o f the DOP when they are tested in-place i n accordance w i t h ANSI N510-1975 while operating the t rai n a t a flow r a t e of 2500 cfm 10%. I

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal t o 99% of a halogenated hydrocarbon refrigerant t e s t gas when they ar e tested in-place i n accordance w i t h ANSI N510-1975 while operating the tr ain a t a flow rate of 2500 cfrn & 10%. I MILLSTONE - UNIT 2 314 7-18 Amendment No. 7z, fy9, J#$, 228

REFUELING OPERATIONS CONTAINMENT PENETRATIONS LIMITING CONDITION FOR OPERATION 3.9.4 .The containment penetrations shall be in the following status:

a.

c The equipment door closed and held in place by a minimum four bolts, 09 The personnel air lock shall be either:

1. closed by one personnel air lock door, or

2. capable of being closed by an OPERABLE d admini strative control?@itn q n operation3 and C. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. Closed by a manual or automatic isolation valve, blind APPLICABILITY: (During CORE ALTERATION? D8 &?w During movement of irradiated fuel assemblies within k containment.

ACTION.:

pc?ctL(r With the requirements o f the abovexpecifi satisfied, immediately suspend a1 1 operations i nvol vi ng GORE ALTE movement of irradiated fue14in the containment.

SURVEILLANCE REQUIREMENTS 4.9.4.1 Verify each required containment penetration is in the required status at least once per 7 days. 9 s tcJkh ~c c #,

1' bite+&

rify each required containment purge valve actuates to t isolation position on an actual or simulated actuation signal at ast once per 18 months. 1 MILLSTONE - UNIT 2 3/4 9 - 4 0633a

Insert J to page 3/4 9-4

a. The equipment door shall be either:

1. closed and held in place by a minimum of four bolts, or

2. open under administrative control* and capable of being closed and held in place by a minimum of four bolts,

Insert C to Page 3/4 9-4

• Administrative controls shall ensure that appropriate personnel are aware that the equipment door, personnel air lock door and/or other containment penetrations are open, and that a specific individual@) is designated and available to close the equipment door, personnel air lock door and/or other containment penetrations within 30 minutes if a fuel handling accident occurs. Any obstructions (e.g. cables and hoses) that could prevent closure of the equipment door, a personnel air lock door and/or other containment penetration must be capable of being quickly removed.

i

ATTACHMENT 3 SUPPLEMENTAL INFORMATION LICENSE BASIS DOCUMENT CHANGE REQUEST 2-18-02 SELECTIVE IMPLEMENTATION OF THE ALTERNATIVE SOURCE TERM -

FUEL HANDLING ACCIDENT ANALYSES RETYPED PAGES MILLSTONE POWER STATION UNIT 2 DOMINION NUCLEAR CONNECTICUT, INC.

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent Control Room Emergency Ventilation Trains shall be OPERABLE.*

APPLICABIL1TY:MODES 1 , 2 , 3 , 4 , 5 and 6.

During irradiated fuel movement within containment or the spent fuel pool.

I ACTION:

MODES 1,2,3, and 4:

a. With one Control Room Emergency Ventilation Train inoperable, restore the inoperable train to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With both Control Room Emergency Ventilation Trains inoperable, except as specified in ACTION c., immediately suspend the movement of irradiated fuel assemblies within the spent fuel pool. Restore at least one inoperable train to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWN within the I

following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

C. With both Control Rooms Emergency Ventilation Trains inoperable, due to an inoperable Control Room boundary, immediately suspend the movement of irradiated fuel assemblies within the spent fuel pool. Restore the Control Room boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, I

and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

• The Control Room boundary may be opened intermittently under administrative control.

MILLSTONE - UNIT 2 3/4 7- 16 Amendment No. 72,&20,.f49,%,

.2;38, ?45, a,

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION ACTION (continued)

MODES 5 and 6, and during irradiated fuel movement within containment or the spent fuel pool:** I

d. With one Control Room Emergency Ventilation Train inoperable, restore the inoperable train to OPERABLE status within 7 days. After 7 days, either initiate and maintain operation of the remaining OPERABLE Control Room Emergency Ventilation Train in the recirculation mode of operation, or immediately suspend CORE ALTERATIONS, and the movement of irradiated fuel assemblies. I

e. With both Control Room Emergency Ventilation Trains inoperable, or with the OPERABLE Control Room Emergency Ventilation Train required to be in the recirculation mode by ACTION d. not capable of being powered by an OPERABLE normal and emergency power source, immediately suspend CORE ALTERATIONS, and the movement of irradiated fuel assemblies. I

• • In MODES 5 and 6, when a Control Room Emergency Ventilation Train is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of 3.7.6.1 Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device(s) are OPERABLE, or likewise satisfy the requirements of the specification. Unless both conditions (1) and (2) are satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then ACTION 3.7.6.1.d or 3.7.6.1.e shall be invoked as applicable.

MILLSTONE - UNIT 2 314 7-16a Amendment No. 245, W ,2.54,

REFUELING OPERATIONS CONTAINMENT PENETRATIONS LIMITING CONDITION FOR OPERATION

~

3.9.4 The containment penetrations shall be in the following status:

a. The equipment door shall be either:

1. closed and held in place by a minimum of four bolts, or

2. open under administrative control* and capable of being closed and held in place by a minimum of four bolts,

b. The personnel air lock shall be either:

1. closed by one personnel air lock door, or

2. be capable of being closed by an OPERABLE personnel air lock door, under administrative control *, and

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. Closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. Be capable of being closed ,under administrative control

• APPLICABIL1TY:During movement of irradiated fuel assemblies within containment.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving movement of irradiated fuel assemblies in the containment.

• Administrative controls shall ensure that appropriate personnel are aware that the equipment door, personnel air lock door and/or other containment penetrations are open, and that a specific individual(s) is designated and available to close the equipment door, personnel air lock door and/or other containment penetrations within 30 minutes if a fuel handling accident occurs. Any obstructions (e.g. cables and hoses) that could prevent closure of the equipment door, a personnel air lock door and/or other containment penetration must be capable of being quickly removed.

MILLSTONE - UNIT 2 314 9-4 Amendment No. #,85,%, 245,

REFUELING OPERATIONS CONTAINMENT PENETRATIONS SURVEILLANCE REQUIREMENTS 4.9.4.1 Verify each required containment penetration is in the required status at least once per 7 days.

4.9.4.2 Deleted I MILLSTONE - UNIT 2 314 9-5 Amendment No. %I