ML043630556

License Amendment Request (LBDCR 04-MP3-013) Relocation of Selected Refueling Operations Technical Specifications

ML043630556
Person / Time
Site:	Millstone
Issue date:	12/23/2004
From:	Matthews W Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
04-713
Download: ML043630556 (31)

Text

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v Dominion Nuclear Connecticut, Inc.

hlil Istonc Iowcr S t x i o i i borninion M Ilopc Frrry I h i d N~itcrtord,CT 06385 December 23, 2004 U.S. Nuclear Regulatory Commission Serial No. 04-71 3 Attention: Document Control Desk NSS&UDF RO Washington, D.C. 20555 Docket No. 50-423 License No. N PF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 LICENSE AMENDMENT REQUEST (LBDCR 04-MP3-013)

RELOCATION OF SELECTED REFUELING OPERATIONS TECHNICAL SPECIFICATIONS Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) hereby requests to amend Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3) to relocate selected Technical Specifications related to refueling operations and the associated Bases to the MPS3 Technical Requirements Manual (TRM). These selected Technical Specifications do not fulfill any one or more of the requirements of 10 CFR 50.36(~)(2)(ii)on items for which Technical Specifications must be established.

Therefore, these Technical Specifications can be relocated verbatim to the TRM where changes are controlled under 10 CFR 50.59.

The proposed amendment does not involve a significant impact on public health and safety and does not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92 (see Significant Hazards Consideration in Attachment 1).

The Site Operations Review Committee and the Management Safety Review Committee have reviewed and concurred with the determinations.

The NRC approved a similar license amendment (No. 240) for Millstone Power Station Unit 2 on February 10, 2000. Additionally Beaver Valley received a license amendment September 7, 2000 and D. C. Cook on April 18, 2002, for relocation of specifications for their fuel building cranes.

DNC is requesting NRC staff review and approval of the proposed change by August 1, 2005 to support effective planning for the fall 2005 refueling outage.

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.

Serial No.04-713 Docket No. 50-423 Relocation of Selected Technical Specifications Page 2 of 3 If you should have any questions regarding this submittal, please contact Mr. Paul R. Willoughby at (804) 273-3572.

Very truly yours, UR-MizaL-William R. Matthews Senior Vice President - Nuclear Operations Attach ments : (3)

1. Evaluation of Proposed License Amendment

2. Marked-Up Pages

3. Re-typed Pages Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. G. Wunder Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08-B-1A Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.04-713 Docket No. 50-423 Relocation of Selected Technical Specifications Page 3 of 3 COMMONWEALTH OF VIRGINIA )

1 COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by William R. Matthews, who is Senior Vice President

- Nuclear Operations, of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he 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 his knowledge and belief.

Acknowledged before me this 93 !day o f ~ b ! ! & , w ~ ,2004.

My Commission Expires:

Notary Public (SEAL)

Serial No.04-713 Docket No. 50-423 ATTACHMENT 1 LICENSE AMENDMENT REQUEST (LBDCR 04-MP3-013)

RELOCATION OF SELECTED REFUELING OPERATIONS TECHNICAL SPECIFICATIONS EVALUATION OF PROPOSED LICENSE AMENDMENT MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 1 of 12 Evaluation of PrODOSed License Amendment 1.o DESCRlPTlON

3.0 BACKGROUND

3.1 Communications During Refueling 3.2 Fuel Handling 3.3 Reason for Proposed Amendment

4.0 TECHNICAL ANALYSIS

4.1 Details of the Proposed Amendment 4.2 Summary

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory RequirernentsKriteria 6.0 ENVlRONMENTAL CONS DERATION

Serial No.04-713 Relocation of Selected RefueIing Operations Technical Specifications Attachment 1/Page 2 of 12 1.o DESCRlPTlON Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) hereby requests to amend Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3) to relocate selected Technical Specifications related to refueling operations and the associated Bases to the MPS3 Technical Requirements Manual (TRM). These selected Technical Specifications do not fulfill any one or more of the requirements of 10 CFR 50.36(~)(2)(ii)on items for which Technical Specifications must be established.

Therefore, these Technical Specifications can be relocated verbatim to the TRM where changes are controlled under 10 CFR 50.59.

These specifications were originally proposed as candidates for relocation based on an evaluation by the Westinghouse Owners Group (WOG) in 1987. The NRC also concluded that the above-mentioned specifications did not need to be retained in the Technical Specifications in a letter from Dr. T. E. Murley to the WOG on May 9, 1988.

The basis for the conclusions in the both of these evaluations is the same as the basis for the Millstone requirements. The Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 22, 1993 (58 FR 39132), encourages licensees to upgrade their Technical Specifications by evaluating their Limiting Conditions for Operation against the 10 CFR 50.36 criteria. These changes are consistent with NUREG-I431, Standard Technical Specifications for Westinghouse Plants, Revision 3, dated March 31, 2004.

DNC is requesting NRC staff review and approval of the proposed change by August 1, 2005 to support effective planning for the fall 2005 refueling outage.

2.0 PROPOSED CHANGE

S Change 1 Technical Specification 3/4.9.5, Communications, will be relocated to the TRM where changes to this information will be controlled under 10 CFR 50.59. The text on the corresponding page will be deleted and replaced with, THIS PAGE INTENTIONALLY LEFT BLANK.

Change 2 Technical Specification 3/4.9.6, Refueling Machine, will be relocated to the TRM where changes to this information will be controlled under 10 CFR 50.59. The text on the corresponding page will be deleted and replaced with, THIS PAGE INTENTIONALLY LEFT BLANK.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 3 of 12 Change 3 Technical Specification 3/4.9.7, Crane Travel - Spent Fuel Storage Areas, will be relocated to the TRM where changes to this information will be controlled under 10 CFR 50.59. The text on the corresponding page will be deleted and replaced with, THIS PAGE INTENTIONALLY LEFT BLANK.

Change 4 Index pages xi, xii and xv will be revised by eliminating the sections corresponding to Technical Specifications 3/4.9.5, 3/4.9.6, and 3/4.9.7 and the associated Bases sections. The titles of these sections will be replaced with the word DELETED.

Change 5 The proposed amendment will relocate the associated Technical Specification Bases sections 3/4.9.5, 3/4.9.6, and 3/4.9.7 to the TRM. Specifically, the text associated with each section in the Bases will be deleted and the section title will be replaced with the word, DELETED. A mark-up of the changes to the Bases section is provided for information in Attachment 2.

3.0 BACKGROUND

3.1 Communications During Refueling Operations Communications are required to be established during refueling operations to ensure refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity conditions. Currently the communications equipment consists of FM radios at the two refueling areas with their base stations hardwired to a command station in the control room. Several Technical Specifications actions require suspension of fuel movement when a limiting condition for operation cannot be met.

Contact with refueling operations personnel conducting fuel movements ensures these requirements can be met promptly. Although the FSAR does not specifically address communication in this context, plant communication is generally discussed in FSAR section 9.5.2.2.

3.2 Fuel Handling System The fuel handling system consists of the equipment needed for refueling operations and is described generally in FSAR section 9.1.4.2.1 and in more detail in section 9.1.4.2.4. The refueling machine is located in containment and is used to move fuel between the reactor vessel and the fuel transfer system. The fuel transfer system moves fuel assemblies between the containment and the fuel building through the fuel transfer tube. In the fuel building, fuel assemblies are transported using the spent fuel

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 4 of 12 bridge and hoist. The new fuel handling crane is used to remove new fuel assemblies from their shipping containers and transfer them to the new fuel dry storage vault and eventually to the fuel elevator in the transfer canal. The safety features including interlocks and limit switches are discussed in detail in FSAR section 9.1.4.3.

The fuel handling accident in the fuel building assumes that one fuel assembly is dropped into the spent fuel pool onto another fuel assembly. This results in the rupture of all of the rods in the dropped assembly and fifty rods in the struck assembly. This accident and the fuel handling accident in containment are discussed in FSAR section 15.7.4. The NRC issued a license amendment (203) on February 20, 2002 related to the fuel handling accident for MPS3. The movement of heavy loads in the spent fuel storage area is addressed in FSAR section 9.1 5.

3.3 Reason for Proposed Ame ndment The proposed amendment is being requested to more closely align the content of the Refueling Operations Technical Specifications for MPS3 with NUREG 1431, Revision 3. The NRC approved a similar license amendment (No. 240) for MPS2 on February 10, 2000. Additionally Beaver Valley received a license amendment September 7, 2000 and D. C. Cook on April 18, 2002, for relocation of specifications for their fuel building cranes.

4.0 TECHNICAL ANALYSIS

4.1 Details of the Proposed Amendment Change 1 The proposed amendment will relocate Technical Specification 3/4.9.5, Communications, verbatim to the TRM where changes to this information will be controlled under 10 CFR 50.59.

This specification requires direct communication between the control room and the refueling station, to ensure any abnormal change in the facility status, as indicated on the control room instrumentation, can be communicated to refueling station personnel.

Relocation of this Technical Specification to the TRM does not imply any reduction in its importance in ensuring communication between the control room and the refueling station. This Technical Specification was a candidate for relocation during the development of the Standard Technical Specification by the Westinghouse Owners Group. The proposed change will not alter the requirement on communication between the control room and the refueling station, it will not alter any of the assumptions used in the fuel handling accident analysis, nor will it cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed change will have no adverse effect on plant safety.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment l/Page 5 of 12 10 CFR 50.36(~)(2)(ii)Criterion 1 The communication equipment ensures prompt notification to refueling personnel to alert them to potential degradation in plant operation. This Technical Specification related to communications during refueling does not cover installed instrumentation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. This specification does not satisfy Criterion 1.

10 CFR 50.36(c)(2)(ii) Criterion 2 The requirement to have communication between the refueling station and the control room is not an assumption of any design basis accident. This Technical Specification does not cover 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. This specification does not satisfy Criterion 2.

10 CFR 50.36(cN2)(ii) Criterion 3 The communication equipment does not perform any accident mitigating functions.

This Technical Specification does not cover a structure, system, or component that is part of the primary success path 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. This specification does not satisfy Criterion 3.

10 CFR 50.36(cH2Nii) Criterion 4 The operating requirement on communications between the control room and the refueling station, which is covered by this Technical Specification, has not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This Technical Specification does not cover a component or system related to key safety functions requiring risk review/unavailability monitoring in accordance with the station conduct of outages procedure. This specification does not satisfy Criterion 4.

10 CFR 50.36(c)(2)(ii) Conclusion This Technical Specification for communication during refueling operations does not fulfill any one or more of the 10 CFR 50.36(~)(2)(ii)criteria on items for which Technical Specifications must be established. Therefore, this Technical Specification can be relocated verbatim to the TRM.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 6 of 12 Change 2 The proposed amendment will relocate Technical Specification 3/4.9.6, Refueling Machine, to the TRM where changes to this information will be controlled under 10 CFR 50.59.

This specification ensures that the lifting devices on the refueling machine and auxiliary hoist have adequate capacity to lift the weight of a fuel assembly or drive rod.

Additionally, this specification ensures that the automatic load limiting device on the refueling machine and the load indicator on the auxiliary hoist are available to prevent damage to the core internals and reactor vessel in the event they are inadvertently engaged during lifting operations. The automatic load limiting device and the load indicator are not assumed to function to mitigate the consequences of a design basis accident and are checked on a periodic basis to ensure operability. There is no accident analysis based on the minimum capacity and overload cutoff limits of the cranes. Relocation of this Technical Specification to the TRM does not imply any reduction in its importance in ensuring that the lifting device on the refueling machine has adequate capacity. The proposed change will not alter the requirement that the lifting device on the refueling machine has adequate capacity, it will not alter any of the assumptions used in the accident analysis, nor will it cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed change will have no adverse effect on plant safety.

10 CFR 50.36(~)(2)(ii)Criterion 1 This Technical Specification does not cover installed instrumentation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. This specification does not satisfy Criterion 1.

10 CFR 50.36(cN2Mi) Criterion 2 This Technical Specification does not cover 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. This specification does not satisfy Criterion 2.

10 CFR 50.36(cM2Mii) Criterion 3 The automatic load limiting device and/or load indicator are not assumed to function to mitigate the consequences of a design basis accident. This Technical Specification, which ensures the lifting devices on the refueling machine and auxiliary hoist have adequate capacity, does not cover a structure, system, or component that is part of the primary success path which functions or actuates to mitigate a design basis accident or

Serial No.04-713 Relocation of Selected RefueIing Operations Technical Specifications Attachment 1/Page 7 of 12 transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This specification does not satisfy Criterion 3.

10 CFR 50.36(~)(2)(ii)Criterion 4 The operating requirement to ensure the lifting devices on the refueling machine and auxiliary hoist have adequate capacity, which are covered by this Technical Specification, have not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This Technical Specification does not cover a component or system related to key safety functions requiring risk review/unavailabiIity monitoring in accordance with the station conduct of outages procedure. This specification does not satisfy Criterion 4.

10 CFR 50.36(c)(2)(ii) Conclusion This Technical Specification for the refueling machines operability does not fulfill any one or more of the 10 CFR 50.36(~)(2)(ii)criteria on items for which Technical Specifications must be established. Therefore, this Technical Specification can be relocated verbatim to the TRM.

Change 3 Technical Specification 3/4.9.7, Crane Travel - Spent Fuel Storage Areas, will be relocated to the TRM where changes to this information will be controlled under 10 CFR 50.59.

This specification ensures loads in excess of 2200 pounds will not be moved over fuel assemblies in the spent fuel storage racks. This represents the working load of the fuel assembly plus handling tool. This specification ensures that in the event this load is dropped, the activity released will be limited to the damage and consequences incurred by the drop of one fuel assembly, consistent with the design basis accident analyses for a fuel handling accident. The load drop event is not a design basis accident and is not discussed in the FSAR.

Crane interlocks and physical stops that prevent crane travel with loads in excess of 2200 pounds are not assumed to function to mitigate the consequences of a design basis accident and are checked on a periodic basis to ensure operability. Relocation of this Technical Specification to the TRM does not imply any reduction in its importance in ensuring that loads in excess of 2200 pounds are prohibited from travel over fuel in the spent fuel pool. The proposed change will not alter the requirement that the crane interlocks and/or physical stops are operable, it will not alter any of the assumptions used in the spent fuel pool fuel handling accident analysis] nor will it cause any safety system parameters to exceed their acceptance limit. Therefore] the proposed change will have no adverse effect on plant safety.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment l/Page 8 of 12 10 CFR 50.36(c)(2)(ii) Criterion 1 This Technical Specification does not cover installed instrumentation that is used to detect, and indicate in the control room, a significant degradation of the reactor coolant pressure boundary. This specification does not satisfy Criterion 1.

10 CFR 50.36(~)(2)(ii)Criterion 2 This specification ensures that loads in excess of 2200 pounds will not be moved over fuel assemblies stored in the spent fuel storage racks. Therefore, for a load drop event, the activity released is limited to that contained in the design basis fuel handling accident analysis. Restrictions on heavy load moves over irradiated fuel in the spent fuel pool also prevent any possible distortion of fuel assemblies in the storage racks from achieving a critical configuration. Criterion 2 requires design features or operating restrictions associated with the limiting condition for operation to be initial conditions of a design-basis accident. The initial condition of the design-basis fuel handling accident is the dropping of a single fuel assembly. The crane interlocks and physical stops are in place to prevent exceeding the initial condition (damage to more than the dropped assembly plus 50 rods in the second assembly) but is not an initial condition in and of itself. The heavy load limit of 2200 pounds is also not an initial condition of any analyzed accident and is provided to prevent operation in a condition that could lead to an unanalyzed load drop accident. This specification does not cover 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. Therefore, this specification does not satisfy Criterion 2.

10 CFR 50.36(~)(2)(ii)Criterion 3 This Technical Specification, which ensures loads in excess of 2200 pounds are prohibited from travel over fuel assemblies in the storage pool, does not cover a structure, system, or component that is part of the primary success path 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. This specification does not satisfy Criterion 3.

10 CFR 50.36(c)(2)(ii) Criterion 4 The operating requirement to ensure that loads in excess of 2200 pounds are prohibited from travel over fuel assemblies in the storage pool, which is covered by this Technical Specification, has not been shown to be risk significant to public health and safety by either operating experience or probabilistic safety assessment. This Technical Specification does not cover a component or system related to key safety

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 9 of 12 functions requiring risk review/unavailabiIity monitoring in accordance with the station conduct of outages procedure. This specification does not satisfy Criterion 4.

10 CFR 50.36(c)(2M) Conclusion This Technical Specification does not fulfill any one or more of the 10 CFR 50.36(c)(2)(ii) criteria on items for which Technical Specifications must be established. Therefore, this Technical Specification can be relocated verbatim to the TRM.

Changes 4 and 5 The modification of the index and Bases pages are consistent with the relocation of the Technical Specifications to the TRM. The Bases will be moved verbatim to the TRM where changes will be controlled under 10 CFR 50.59. These changes do not fulfill any of the criteria under 10 CFR 50.36(~)(2)(ii).

4.2 Summary The proposed amendment to relocate the Technical Specifications associated with communications during refueling, the refueling machine, and crane travel over the spent fuel pool agrees with the industry standard in NUREG 1431, Standard Technical Specifications for Westinghouse Plants, Revision 3. These requirements, although important to plant operation, do not meet 10 CFR 50.36 criteria as items for which a limiting condition for operation must be established in the plant Technical Specifications. In addition, these changes can be made without adverse impact to plant operations or to the health and safety of the public. Therefore these changes can be relocated to the TRM where modification to these requirements will be controlled under 10 CFR 50.59.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Refueling Operations Technical Specifications 3/4.9.5, Communications, 3/4.9.6, Refueling Machine, and 3/4.9.7, Crane Travel - Spent Fuel Storage Areas, are proposed to be relocated to the Technical Requirements Manual (TRM) where future changes will be controlled in accordance with 10 CFR 50.59. The communications specification requires communication between the control room and the refueling station to ensure any abnormal change in the facility status, as indicated on the control room instrumentation, can be communicated to the refueling station personnel. The refueling machine specification ensures the refueling equipment used for fuel movements inside containment has sufficient load capacity and ensures the core internals and pressure vessel are protected from excessive force in the event they are

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 10 of 12 inadvertently lifted. The specification for spent fuel pool crane travel provides a restriction for movement of heavy loads in excess of 2200 pounds over irradiated fuel in the spent fuel pool.

Dominion Nuclear Connecticut, Inc. (DNC) has evaluated whether or not a Significant Hazards Consideration (SHC) is involved with the proposed changes by addressing the three standards set forth in 10 CFR 50.92(c) as discussed below.

Criterion 1:

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

Response: No.

The communications equipment, refueling machine, and spent fuel pool crane are not designed to perform accident mitigation functions. The proposed change to relocate selected refueling specifications does not modify any plant equipment and does not impact any failure modes that could lead to an accident. Relocating the specifications to the TRM where changes would be controlled under the 10 CFR 50.59 process does not change the ability of the communications or refueling equipment to function as expected. Additionally, these specifications have no affect on the consequence of any analyzed accident since the equipment is not related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2:

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

Response: No.

The proposed changes do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions to move fuel safely or conduct refueling operations while in contact with the control room. No system setpoints are being modified and no changes are being made to the method in which refueling operations are conducted. No changes to the heavy loads program are being proposed by this change. No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiators or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Serial No.04-713 Relocation of Selected RefueIing Operations Technical Specifications Attachment l/Page 11 of 12 Criterion 3:

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

Response: No.

The relocation of Technical Specification 3/4.9.5, Refueling Operations, Communications, to the TRM does not imply any reduction in its importance in insuring communication between the control room and the refueling station. The proposed change will not alter the requirement on communication between the control room and the refueling station, it will not alter any of the assumptions used in the fuel handling accident analysis, nor will it cause any safety system parameters to exceed their acceptance limit. The relocation of Technical Specification 3/4.9.6, Refueling Machine to the TRM does not alter the requirement for the lifting device on the refueling machine to have adequate capacity or for the interlocks to be demonstrated operable prior to fuel movement. The assumptions used in the accident analysis are not impacted by this change and no impact to any safety system parameters will result.

The relocation of Technical Specification 3/4.9.7, Crane Travel - Spent Fuel Storage Areas, to the TRM will not alter the requirement that the crane interlocks and/or physical stops are operable, nor will it alter any of the assumptions used in the fuel handling accident analysis. Heavy load lifts are administratively controlled by a safe load path and crane interlocks. The proposed changes do not modify any heavy load path criteria. Administrative changes associated with the proposed revision such as relocation of associated Technical Specification Bases to the TRM will not have an impact on any established safety margins.

The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the Bases for Technical Specifications covered in this License Amendment Request.

In summary, DNC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

5.2 Applicable Regulatory RequirementsEriteria Existing Technical Specification Limiting Conditions for Operation that do not meet the criteria set forth in 10 CFR 50.36(~)(2)can be relocated to another licensee controlled document.

Serial No.04-713 Relocation of Selected Refueling Operations Technical Specifications Attachment 1/Page 12 of 12 The 10 CFR 50.36(~)(2)criteria is as follows:

(ii) A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) 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.

(6)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.

(C) 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.

(D) 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 Millstone Power Station Unit 3 Technical Requirements Manual is controlled by station administrative procedures and all changes to the requirements are evaluated using the 10 CFR 50.59 process.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance 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.

6.0 ENVlRONMENTAL CONS1DERATION DNC has determined that the proposed amendment would change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, or would change inspection or surveillance requirements. DNC has evaluated the proposed change and has determined that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(~)(9).Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No.04-713 Docket No. 50-423 ATTACHMENT 2 LICENSE AMENDMENT REQUEST (LBDCR 04-MP3-013)

RELOCATION OF SELECTED REFUELING OPERATIONS TECHNICAL SPECIFICATIONS MARKED-UP PAGES MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

. February2. 2001 INDEX LIMITING'CONDITIONS FOR OPERATION~ N SWRWILUNCE D I~QUE~EMENTS SECTION PAGE 3/4.8 ELECTRICALPOWER SYSTEMS 3/4.8.1 A.C. SOURCES Operating.................................................................................................. 314 8-1 DELETED ................................................................................................ 314 8-9 Shutdown ................................................................................................. 3/4 8:10 314.8.2 D.C. SOURCES Operating.................................................................................................. 3/4 8-11 TABLE 4.8-2a BATTERY SURVEILLANCE REQUIREMENTS ............................... 3/48-13 TABLE 4.8-26 3AITERY CHARGERCAPACITY-.............................. I..................... 314 8-14 Shutdown .................................................................................................. 3/4 8-15 314.8.3 ONSXTE POWER DISTRIBUTION Operating.................................................................................................. 3/4 8-16 Shutdown ................................................................................................. 3/4 8-18 3i4.8.4 ELECTRICAL EQUIPMENT PROTECI'IVE DEVICES DELETED ................................................................................................3/4 8 .19 DELETED ................................................................................................ 314 8-21 DELETED .......................... .....,..

...............................................................314 8-22 314.9 REFUELING OPERATIONS 314.9.1 BORON CONCENTRATION ...................................................................... 3/49-1 3i4.9.2 INSTRUMENTATION ................................................................................. 314 9-2 314.9.3 . DECAY TIME ............................................................................................... 314 9-3 314,9.4 CONTAINMENT BUILDING PENETRATIONS .......................................3/4 9-4 314.9.5 .................................................................................. 314 9-5 .I MILLSTONE .UNIT 3 xi Amendment No . 64.424.4%. 194

March 17.2004 INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCEREQUIREMENTS SECTION 'bLETGn PAGIE.

314.9.6 # - ............................. 1 1

1.

1 4

, ........,...,................ 314 9-6 314.9.7 1 .

.....................314 9-7 314.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION High Water Level .-.............................,,........,......................,,......;..............3I4 9-8 Low Water Level.........................,.............,............................ ...................314 9-9 314.9.9 DELETED ................. ........,....... .. .....,..............,..

I.. ...I .I......-.,.+.s... ............. 314 9-10 314.9.10 WATERLEVEL- REACTORVESSEL......................................... ......,... 3/4 9-11 314.9.1 1 WATER LEVEL .STORAGE POOL ....,...............................................,.. 3/4 9-12 314.9.12 DELETED ..................................................................

I ,.......................... ,... 3/49-13 314.9.13 SPENT FUEL POOL .REACTIVITY ..........................,......................... .. 3/4 9-16 314.9.14 SPENT FUEL POOL .STORAGE PATTERN.........................................314 9-17 FIGURE 3.9-1 MINIMUM FUEL ASSEMBLY BUI(NUP VERSUS NOMMAL INITIAL ENRICHMENT FOR R)EOION 1 4-OUT-OF4 STORAGE CONFIGURATION ........................................................... 3/49-18 FIGURE 3.9-2 REGION 1 3-OUT-OF-4 STORAGE FUEL ASSEMBLY LOADING SCHEMATIC ...................................................................314 9-19 FIGURE:3.9-3 MINIMUM FUEL ASSEMBLY B U R " VERSUS NOMINAL INITIAL ENRICHMENT FOR MGLON 2 STORAGE CONFIGURATION .......................................................... 3/4 9-20 FIGURE 3.9-4 MINIMUM FUEL ASSEMBLY BURNUP AND DECAY TIME VERSUS NOMINAL INITIAL ENRICHMENT FOR REGION 3 STORAGE CONFIGURATION .......................................................... 314 9-21 314.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN ............................................................................ 314 10-1 314.102 GROUP HEIGHT, INSERTION,AND POWER DISTRIBUTION LIMITS 314 10-2 3/4.10.3 PHYSICS TESTS ....................................................................................... 314 10-4 314.10.4 REACTOR COOLANTLOOPS ................................................................ 314 10-5 314.10.5 DELETED 314.11 DEJ vETED 314.11.1 DELETED

.3/4.11.2 DELETED 3/4.11,3 DELETED MILLSTONE - UNIT 3 xii Amendment No. 39,89,W, M,W, M,219

March 17,2004 INDEX BASES sJ3XIQN &u.E 3/4.7.11 DELETED .............. ..I.........., ...... ......., ..,........,................,..... .....,,......,B 3/4 7-25 I .I 3/4.7.12 DELETED 3/4.7,13 DELETED 314.7.14 AREA TEMPERATUREMONITORING....... .......,................ B 3/4 7-25 314.8 ELECTRTCAL POWER SYSTEMS 3/4.8.1,3/4.8.2, and 3/4.8.3 A.C. SOURCES, D.C. SOURCES, AND ONSITE POWER DISTRIBUTION ......................................................,....... B 3/48-I 3i4.8.4 DELETED .......................................................................................................B 3/48-3 3/4.9 REFUELING O P mTIONS 3/4.9.1 BORON CONCENTRATION .................................................................. ......B 314 9-1 314.9.2 INSTRUMENTATION--.. ..........-. ...................................................-.....,. B 314 9-1

.......a 314.9.3 DECAY TIME................................................................................................. B 3/49-1 314.9.4 CONTAINMENT BUILDING PENETRATIONS ............................,............B 314 9-1 EL Is 3/4.9.5 -G .o ................................... 3 3/4 9-1 1

L..........................,..................

3/4.9.6 ................*... ....................,........................,..............B 3/49-2 e7-m 3/4.9.7 c c....................,...,......B 3/4 9-2 3/4.9.8-' RESIDUALHEATREMOVALAND COOLANTCIRCULATION ...........B 3/4 9-2 DELETED................................. .................................................................B 3/4 9-7 3/4.9.9 314.9.10and314.9.11 WATERLEVEL- REACTORVESSEL AND

...a.

STORAGE POOL..................................,..............................._... .,...........,........B 3/4 9-8 01."

314.9.12 DELETED ..............+ .....................................................,...............................,..B 3/49-8 3j4.9.13 SPENTFUELPOOL-REACTIVITY. ..................................,................. ....B 3149-8 . I 314.9.14 SPENTFWEL POOL - STORAGE PATTERN..... ...............................B 3/49-8 314.10 SPECIAL TEST EXCEPTlONS 3/4-10.] SHUTDOWN MARGIN ..........,......... .

.... ..................,................. ....... I .,..I* ....B 314 10-1 3/4.10.2 GROUP HEIGHT,INSERTION, AND POWER DISTRlBU'MON LIMITS ......,................,................,.......,..........................................,...~....,.....B 314 10-1 314.10.3 PHYSICS TESTS ..............................................................~..,......................., B 314 10-1 314.10-4 REACTORCOOLANTLOOPS............... ..............,................,....................B 314 10-1 314.10.5 DELETED ................ ..I.........I........*...,... ..........................,,,......,................. B 314 10- 1 I

MILLSTONE - UNIT 3 xv .. Amendment No. 84,439, W, W ,449, a, W,W, W ,244,219

REFUELING OPERATIONS 3/4.9.5 COMMUNICATIONS DELETE LIMITING CONDITION FOR OPERATION 3.9.5 Direct communications shall be maintained room and personnel a t the refueling station.

APPLICABILITY: Ouri ng CORE ALTERATIONS.

ACTION:

/

When d i r e c t communication and personnel a t the refueling station cannot CORE ALTERATIONS.

SURVEILLANCE REQUIREMENTY 4.9.5 between the control room and personnel a t the withtn 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior t o the start of ALTERATIONS.

~ ...

MILLSTONE - UNIT 3 J/4 9-5

REFUELING OPERATIONS 314.9.6 . REFUELING MACHINE L I M I T I N G CONDITION FOR OPERATION 3.9.6 The refueling machine and auxili drive rods or fuel assemblies and shall

a. The refueling machine used f o

1) A minimum capacity o f 4000 pounds, and

2) An overload c u t o f f limit

b. The auxiliary hoist used for having:

I) A minimum capacity o f 30

2) A load indicator which s i n excess o f 1000 pounds.

APPLICABILITY: During rods or fuel assemblies within the reactor vessel.

ACTION:

With the requirements d/or hoist OPERASILITY not satisfied, suspend use o f any Snoperab'le crane and/or auxi 1 i ary hoi st from operations nvol v i ng- the movement ds and fuel assemblies w i t h i n the reactor vessel.

SURVEILLANCE REQUIREM used f o r movement o f fuel assemblies wfthin 1 1 be demonstrated OPERABLE w i t h i n 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to ations by performing a load t e s t o f a t least 4000 pounds utomatic load cutoff when the crane load exceeds hoist and associated load indicator used for movement e reactor vessel shall be demonstrated OPERABLE w i t h i n start of such operations by performing a load t e s t o f MILLSTONE - UNIT 3 314 9-6

I REFUELING O P E R A T US /

November ,2000 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE AREAS LIMITING CONDITION FOR OPERATION

/

3.9.7 Loads i n excess o f o h i b i t e d from t r a v e l over fuel assemblies i n t h e sto APPLICABILITY : With fuel ECT I ON :

a. With t h e r e q u i r i o n not s a t i s f i e d ,

p l a c e t h e crane

6. The provisions o SURVEILLANCE REQUIREMENTS d physical stops which prevent crane t r a v e l w i t h loads over the f u e l storage p o o l shall be demonstrated I i rior t o crane use and a t least once per 7 days r a t i o n . Administrative controls may be used i n l i e u for handling f u e l racks, spent f u e l pool MILLSTONE - UNIT 3 , 3/4 9-7 Amendment No. 27, 189

eling station personnel ore reactivity conditions 3149.6 The OPERABILITY requirements for machines will be used for movement of drive The restriction on mov 3/4.9.8 R F ! ! UAL HEAT REMOVAL AND COOLANT CIRCULATION 34.9.8.1 HIGH W-VEL BACKGROUND

" h e purpose of the Residual Heat Removal (RWR) System in MODE 6 is to remove decay heat and sensible heat from the Reactor Coolant System (RCS), as required by GDC 34, to provide mixing of borated coolant and to prevent boron stratification, Heat is removed from the RCS by .

circulating reactor cooIant through the RHR heat exchanger@),where the heat is transferred to the Reactor Plant Component Cooling Water System. The cooIantis then returned to the RCS via the RCS cold leg(s). Operation of the RKR system for normal cooldown or decay heat removal is manually accomplishedfrom the control room. The heat removal is manually accomplished from the control room. The heat removal rate is adjusted by controlling the flow of reactor coolant through the RHR heat exchanger@)and the bypass. Mixing of the reactor coolant is maintained by this continuous circulation of reactor coolant through the RHR system, MILLSTONE - UNIT 3 B 3/4 9-2a Amendment No.219 I

?

Serial No.04-713 Docket No. 50-423 ATTACHMENT 3 LICENSE AMENDMENT REQUEST (LBDCR 04-MP3-013)

RELOCATION OF SELECTED REFUELING OPERATIONS TECHNICAL SPECIFICATIONS RE-TYPED PAGES MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 314.8 ELECTRICAL, POWER SYSTEMS 314.8.1 A.C. SOURCES Operating.................................................................................................. 314 8-1 DELETED................................................................................................ 314 8-9 Shutdown ................................................................................................. 314 8-10 314.8.2 D.C. SOURCES Operating.................................................................................................. 314 8-11 TABLE 4.8-2a BATTERY SURVEILLANCE REQUIREMENTS ................................ 314 8-13 TABLE 4.8-2b BATTERY CHARGER CAPACITY ...................................................... 3/4 8-14 Shutdown ................................................................................................. 3/4 8-15 314.8.3 ONSITE POWER DISTRIBUTION Operating.................................................................................................. 314 8-16 Shutdown ................................................................................................. 314 8-18 314.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES DELETED................................................................................................ 314 8-19 DELETED ................................................................................................ 314 8-21 DELETED ................................................................................................ 314 8-22 314.9 REFUELING OPERATIONS 314.9.1 BORON CONCENTRATION....................................................................... 314 9-1 314.9.2 INSTRUMENTATION.................................................................................. 314 9-2 314.9.3 DECAY TIME ............................................................................................... 314 9-3 314.9.4 CONTAINMENT BUILDING PENETRATIONS........................................ 314 9-4 314.9.5 DELETED ..................................................................................................... 314 9-5 I MILLSTONE .UNIT 3 xi Amendment No . 64.424.4-92.494.

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS SECTION PAGE 314.9.6 DELETED .................................................................................. ,.............,... 314 9-6 314.9.7 DELETED ............................,....................................................................... 314 9-7 314.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION High Water Level ..................................................................................... 314 9-8 Low Water Level ........................................................................................ 314 9-9 314.9.9 DELETED ....................................,.,.......................................................... 314 9- 10 314.9.10 WATER LEVEL - REACTOR VESSEL .................................................... 314 9-1 1 314.9.11 WATER LEVEL - STORAGE POOL ........................................................ 314 9-12 314.9.12 DELETED ...................................................... ............................................ 314 9-13 314.9.13 SPENT FUEL POOL - REACTIVITY ....................................................,. 314 9- 16 314.9.14 SPENT FUEL POOL - STORAGE PATTERN........................... ,..............3/4 9-17 FIGURE 3.9-1 MINIMUM FUEL ASSEMBLY BURNUP VERSUS NOMINAL INITIAL ENRICHMENT FOR REGION 1 4-OUT-OF-4 STORAGE CONFIGURATION...,...................................................,....314 9- 18

~~

FIGURE 3.9-2 REGION 1 3-OUT-OF-4 STORAGE FUEL ASSEMBLY LOADING SCHEMATIC ............,....................................................... 314 9- 19 FIGURE 3.9-3 MINIMUM FUEL ASSEMBLY BURNUP VERSUS NOMINAL INITIAL ENRICHMENT FOR REGION 2 STORAGE CONFIGURATION........................................................... 314 9-20 FIGURE 3.9-4 MINIMUM FUEL ASSEMBLY BURNUP AND DECAY TIME VERSUS NOMINAL INITIAL ENRICHMENT FOR REGION 3 STORAGE CONFIGURATION ........................................................,,. 314 9-2 1 314.10 SPECIAL TEST EXCEPTIONS 314.10.1 SHUTDOWN MARGIN ............................................................................ 314 10-1 314.10.2 GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS 314 10-2 314.10.3 PHYSICS TESTS ....................................................................................... 314 10-4 314.10.4 REACTOR COOLANT LOOPS ..................................,............................. 314 10-5 314.10.5 DELETED 314.11 DELETED 314.11.1 DELETED 314.11.2 DELETED 3/4.11.3 DELETED MILLSTONE - UNIT 3 xii Amendment No. 39,89,+88,M, M, w,214,

INDEX BASES SECTION PAGE 3/4.7.11 DELETED .................................................................................................... B 3/4 7-25 3/4.7.12 DELETED 3/4.7.13 DELETED 3j4.7.14 AREA TEMPERATURE MONITORING .................................................... B 3/4 7-25 3/43 ELECTRICAL POWER SYSTEMS 3/4.8.1, 314.8.2, and 3/4.8.3 A.C. SOURCES, D.C. SOURCES. AND ONSITE POWER DISTRIBUTION .............................................................. B 3/4 8-1 3/4.8.4 DELETED ....................................................................................................... B 3/4 8-3 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION ......................................................................... B 3/4 9- 1 314.9.2 INSTRUMENTATION.................................................................................... B 3/4 9- 1 314.9.3 DECAY TIME ................................................................................................. B 3/4 9-1 314.9.4 CONTAINMENT BUILDING PENETRATIONS.......................................... B 314 9- 1 3/4.9.5 DELETED ....................................................................................................... B 3/4 9- 1 3/4.9.6 DELETED ....................................................................................................... B 3/4 9-2 314.9.7 DELETED ....................................................................................................... B 314 9-2 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION.............B 3/4 9-2 314.9.9 DELETED ....................................................................................................... B 3/4 9-7 3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL AND STORAGE POOL ............................................................................................ B 3/4 9-8 3/4.9.12 DELETED ....................................................................................................... B 3/4 9-8 3/4.9.13 SPENT FUEL POOL - REACTIVITY ........................................................... B 3/4 9-8 3/4.9.14 SPENT FUEL POOL .STORAGE PATTERN ............................................... B 3/4 9-8 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN ............................................................................... B 3/4 10-1 3/4.10.2 GROUP HEIGHT, INSERTION, AND POWER DISTRIBUTION LIMITS .......................................................................................................... B 3/4 10-1 3/4.10.3 PHYSICS TESTS .......................................................................................... B 3/4 10-1 3/4.10.4 REACTOR COOLANT LOOPS ................................................................... B 314 10-1 3/4.10.5 DELETED ..................................................................................................... B 3/4 10-1 MILLSTONE .UNIT 3 xv Amendment No .84.89.M.4-W.4%.

a. =.*.287.w.=.

THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 3 314 9-5 Amendment No.

THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 3 314 9-6 Amendment No.

THIS PAGE INTENTIONALLY LEFT BLANK MILLSTONE - UNIT 3 314 9-7 Amendment No. 53,449,