ML050420171

Exigent License Amendment Request (LBDCR 05-MP3-002) Emergency Generator Load Sequencer Allowed Outage Time

ML050420171
Person / Time
Site:	Millstone
Issue date:	02/10/2005
From:	Hartz L Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
05-058
Download: ML050420171 (22)

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Dominion Nuclear Connecticut, Inc.

Mill\[oii< Iowcr \ t a t i o n borninion 1 Rope I crrv R o d Kiic:ford C I Oh385 February 10, 2005 U.S. Nuclear Regulatory Commission Serial No.05-058 Attention: Document Control Desk MPS Lic/MAE RO Washington, DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 EXIGENT LICENSE AMENDMENT REQUEST (LBDCR 05-MP3-002)

EMERGENCY GENERATOR LOAD SEQUENCER ALLOWED OUTAGE TIME Pursuant to 10 CFR 50.90 and 10 CFR 50.91 (a)(6), Dominion Nuclear Connecticut, Inc.

(DNC) hereby requests to amend Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). The enclosed license amendment request proposes to revise Technical Specification 3/4.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3, by adding Action 15 (currently unused action 15), which applies only to the Emergency Generator Load Sequencer (EGLS).

The proposed change increases the allowed time to restore an inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change is consistent with the allowed outage time reflected in NUREG 1431, Standard Technical Specifications - Westinghouse Plants, Revision 3, dated March 31 , 2004.

It is requested that this license amendment request be reviewed on an exigent basis to support timely restoration from a degraded condition that has the potential to challenge the long term reliability of the A train EGLS. On January 22, 2005, the automatic test circuit for the A EGLS failed and in doing so, initiated an automatic start of a safeguards ventilation system. The automatic test feature was defeated and the EGLS was returned to service within the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed by the current specification.

However, the nature of the failure is such that any future surveillance testing utilizing the A EGLS will effectively seal in the actuation signal to this ventilation system. Reset of the actuation signal will require cycling of the EGLS power supply. The EGLS is used extensively in the MPS3 surveillance test program and thus deferring the repair would result in a substantial number of these cycles. Frequent cycling of the power to this equipment is viewed to present a reliability challenge given the sensitive nature of the associated circuitry. Repair of the equipment, with minimum allowance for contingencies, is estimated to require 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. By adopting the extended allowed outage time, time pressure is reduced as a potential error precursor during the conduct of repairs, now and in the future.

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.

Serial No.05-058 Docket No. 50-423 Exigent License Amendment Request Page 2 of 4 The Site Operations Review Committee and the Management Safety Review Committee have reviewed and concurred with the determinations.

The change in this license amendment request is not required to address an immediate safety concern. However, approval is requested on an exigent basis to support timely restoration from a degraded condition that has the potential to challenge the long term reliability of the EGLS. Approval is requested as soon as practical, but no later than February 28, 2005 to avoid unnecessary cycling of power to the EGLS. DNC requests the license amendment be made effective upon issuance, to be implemented within 5 days of the date of issuance. contains a description of the proposed Technical Specification change and the Significant Hazards Consideration. Attachment 2 contains the Technical Specifications marked-up pages and Attachment 3 contains the retyped pages.

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

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 IJ Vice President - Nuclear Engineering

Serial No.05-058 Docket No. 50-423 Exigent License Amendment Request Page 3 of 4 Attachments:

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. F. Wunder Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08-8-1A Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station

Serial No.05-058 Docket No. 50-423 Exigent License Amendment Request Page 4 of 4 COMMONWEALTH OF VIRGINIA )

1 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 *

• day of , 2005.

My Commission Expires: 8 /3/ /O 8

• w 4.&#

I/ Notary Public (SEAL)

Serial No.05-058 Docket No. 50-423 ATTACHMENT 1 EXIGENT LICENSE AMENDMENT REQUEST (LBDCR 05-MP3-002)

EMERGENCY GENERATOR LOAD SEQUENCER ALLOWED OUTAGE TIME EVALUATION OF PROPOSED LICENSE AMENDMENT MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 1 of 10 Evaluation of ProDosed License Amendment 1.O DESCRIPTION

3.0 BACKGROUND

3.1 Description of The Emergency Generator Load Sequencer 3.2 Reason for Proposed Amendment 4.0 JUSTIFICATION AND BASIS FOR THE EXIGENT CIRCUMSTANCES

5.0 TECHNICAL ANALYSIS

5.1 Details of the Proposed Amendment 5.2 Risk Insights 5.3 Safety Summary

6.0 REGULATORY ANALYSIS

6.1 No Significant Hazards Consideration 6.2 Applicable Regulatory RequirementsKriteria

7.0 ENVIRONMENTAL CONSIDERATION

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 2 of 10 1.O DESCRIPTION Pursuant to 10 CFR 50.90 and 10 CFR 50.91 (a)(6), Dominion Nuclear Connecticut, Inc.

(DNC) hereby requests to amend Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). The enclosed license amendment request proposes to revise Technical Specification 3/4.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3 by adding Action 15 (currently unused action 15). The proposed change increases the allowed time to restore an inoperable Emergency Generator Load Sequencer to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2.0 PROPOSED CHANGE

Action 14 of Table 3.3-3, Engineered Safety Features Actuation System Instrumentation, which applies to Functional Units 1.b, 2.b, 3.a.2, 3.b.2, 7.c, and 10 of Table 3.3-3 currently states:

ACTION 14 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

DNC is proposing to add Action 15 (currently unused action 15), which is only applicable to Functional Unit 10 of Table 3.3-3, as follows:

ACTION 15 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

3.0 BACKGROUND

3.1 Description of The Emergency Generator Load Sequencer The emergency generator loading sequencer (EGLS) is a solid-state digital system, which provides relay contact outputs to shed loads, block manual starts, and sequentially load the plant emergency AC buses during emergency conditions. The system is composed of two cabinets, one each for Train A and Train B. The primary purpose of the EGLS is to automatically control the loading of the emergency AC buses

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 3 of 10 when a loss of offsite power has occurred and the buses are being re-energized by the emergency diesel generator.

The EGLS accepts bus undervoltage (BUV), safety injection (SIS), containment depressurization actuation (CDA), recirculation (RECIRC), auxiliary reserve breaker (AR BKR) status, and diesel generator breaker (DG BKR) status input signals in the form of contact closures and provides a predetermined sequence of outputs.

The EGLS has seven operating modes. Five of these modes are for plant emergency conditions, which involve a loss of offsite power. The other two are for plant emergency conditions, which do not involve a loss of offsite power. The modes, in terms of which EGLS inputs are activated, are as follows.

1. SIS only

2. CDA only or SIS and CDA

3. Loss of Power (LOP) only

4. SIS and LOP

5. CDA and LOP or SIS and CDA and LOP

6. SIS, RECIRC, and LOP

7. CDA or SIS and CDA, RECIRC, and LOP The modes are prioritized such that a CDA mode will always take precedence over a SIS mode when both inputs are present and such that a LOP mode will always take precedence over a non-LOP mode.

In each of the LOP operating modes, the EGLS first recognizes a loss of power on the plant safety buses and immediately generates LOP and manual start block (MSB) output signals to plant safety equipment. These signals effectively strip the bus, block closing of the DG BKR for a time period sufficient to strip the bus, and temporarily inhibit the operator from restarting any loads. This allows the diesel generator time to start, achieve proper voltage and frequency and, via the DG BKR, be connected to the plant safety bus without incurring adverse loading conditions. Upon receiving a signal confirming that the DG BKR has closed, the EGLS begins generating time sequenced safeguard signals (SSS) and manual trip block (MTB) signals to plant equipment. The SSS and MTB signals, once initiated, are maintained until the EGLS is reset or a change in operating mode occurs. The EGLS automatically terminates individual LOP signals associated with the loads being started and terminates the remaining LOP signals and MSB signals automatically, 40 seconds after the DG BKR has closed.

Should a SIS or CDA input occur without a LOP, the appropriate SSS and MTB signals are generated immediately without time sequencing, and the LOP and MSB outputs remain reset. Start signals to the containment recirculation pumps are delayed during a CDA only sequence, even if there is no LOP signal. The MTB signal inhibits the operator from retripping loads once they have been automatically started.

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 4 of 10 LOP outputs also are generated for plant equipment which does not have an associated EGLS SSS output signal. In some cases, the LOP outputs are terminated at the end of the 40-second period. In other cases, the LOP outputs are not terminated until the EGLS is manually reset. In some of the cases, the LOP outputs are also generated by a SIS only or CDA only input.

Initiation of the RECIRC and LOP operating modes differs from the other LOP operating modes in as much as that during recirculation, the SIS or CDA input must have occurred and been reset prior to the loss of power. Otherwise, even though the RECIRC input is present, the EGLS will respond in a SIS and LOP or CDA and LOP operating mode. Internal memories, which must be manually reset, retain the information necessary to allow the EGLS to differentiate between RECIRC and non-RECIRC operating modes.

Station LOP and sequencer LOP memories, which also must be manually reset, are used to retain information concerning the initial loss of power and re-energization of the bus by the diesel generator. Two memories are employed to prevent the EGLS from responding to transient voltage dips appearing on the bus during loading. Normally, the EGLS would not respond to a second loss of power if both memories had not been reset, but circuitry in the EGLS provides a subsequent LOP detection window between the sequencer LOP reset and station LOP reset during which the EGLS responds to a second or subsequent LOP occurring during reset procedures.

Post maintenance testing to ensure operability of the EGLS is in accordance with station procedures.

3.2 Reason for Proposed Amendment This extension to the EGLS allowed outage time is requested in order to provide reasonable time to conduct an orderly repair and return to service from a degraded condition.

4.0 JUSTIFICATION AND BASIS FOR THE EXIGENT CIRCUMSTANCES It is requested that this license amendment request be reviewed on an exigent basis to support timely restoration from a degraded condition that has the potential to challenge the long term reliability of the A train EGLS. On January 22, 2005, the automatic test circuit for the A EGLS failed and in doing so, initiated an automatic start of a safeguards ventilation system. The automatic test feature was defeated and the EGLS was returned to service within the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed by the current specification.

However, the nature of the failure is such that any future surveillance testing utilizing the A EGLS will effectively seal in the actuation signal to this ventilation system. Reset of the actuation signal will require cycling of the EGLS power supply. The EGLS is used

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 5 of 10 extensively in the MPS3 surveillance test program and thus deferring the repair would result in a substantial number of these cycles. Frequent cycling of the power to this equipment is viewed to present a reliability challenge given the sensitive nature of the associated circuitry. Repair of the equipment, with minimal allowance for contingencies, is estimated to require 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. By adopting the extended allowed outage time, time pressure is reduced as a potential error precursor during the conduct of repairs, now and in the future.

5.0 TECHNICAL ANALYSIS

5.1 Details of the Proposed Amendment The enclosed license amendment request proposes to revise Technical Specification 3/4.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-3, by adding Action 15 (currently unused action 15). The proposed change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

In the event of a loss of preferred power, the engineered safety features (ESF) electrical loads are automatically connected to the emergency diesel generator (EDG)s in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a design basis accident (DBA) such as a loss of coolant accident (LOCA). Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the EDGs in the process. Within minutes after the initiating signal is received, all loads needed to recover the unit or maintain it in a safe condition are returned to service. Proper sequencing of loads, including tripping of nonessential loads, is a required function for EDG operability.

The initial conditions of DBA and transient analyses in the Final Safety Analysis Report (FSAR), assume ESF systems are operable. The AC electrical power sources including the EDG are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, reactor coolant system (RCS), and containment design limits are not exceeded.

The operability of the AC electrical power sources including the EDG is an initial assumption of MPS3 accident analyses. It is assumed that at least one train of the onsite or offsite AC sources will be operable during accident conditions in the event of:

a. An assumed loss of all offsite power or all onsite AC power and

b. A worst case single failure.

The AC sources and sequencers are required to be operable in Modes 1, 2, 3, and 4 to ensure that:

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 6 of 10

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of anticipated operational occurrences (AOOs) or abnormal transients and

b. Adequate core cooling is provided and containment operability and other vital functions are maintained in the event of a postulated DBA.

The EGLS is an essential support system to the EDG associated with a given ESF bus.

Therefore, loss of an ESF bus sequencer affects every major ESF system in the associated train. The allowed time to restore the inoperable EGLS to operable status (currently 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) provides a period of time to correct the problem commensurate with the importance of maintaining sequencer operability. This time period also ensures that the probability of an accident (requiring sequencer operability) occurring during periods when the sequencer is inoperable is minimal. Increasing the allowed outage time from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has no impact on the probability of an accident (requiring sequencer operability) occurring during this period. Furthermore, increasing the allowed outage time to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> gives the necessary additional time to replace the defective equipment and to conduct required post repair operability retest of the EDG without the need to commence an otherwise unnecessary shutdown of the unit.

The proposed change is consistent with industry wide practices and with NUREG 1431, Standard Technical Specification - Westinghouse Plants, Revision 3, dated March 31, 2004.

5.2 Risk Insights While this is not a risk-informed submittal in accordance with NRC Regulatory Guides 1.174 or 1.177, DNC nevertheless evaluated the change for its risk impact. The EGLS is explicitly modeled in the Millstone Unit 3 PRA model. Unavailability of the sequencer does not render the EDG from being able to start and run in manual mode since loads can be manually sequenced onto the EDGs. The PRA model includes an operator error for failing to perform this manual sequencing as a recovery basic event.

The long term average annual unavailability of the EGLSs is not expected to change following repair of the existing degraded condition since there are no long term changes planned to the sequencer surveillances or maintenance as a result of obtaining this change. Therefore, the long-term increase in core damage and large early release frequency from this change is negligible. The following results from the PRA evaluation of the short-term impacts of the change meet the acceptance criteria in NRC Regulatory Guides 1.174 and 1.177:

Average core damage frequency (CDF) increase: 2.8E-08 per year (this year only)

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 7 of 10 0 Average large early release frequency (LERF) increase: 2.2E-10 per year (this year o nIy) 0 Ineremental conditional core damage probability (ICCDP): 2.8E-08 0 Incremental conditional large early release probability (ICLERP): 2.2E-10 These results were calculated using the Millstone Unit 3 EOOS risk monitor with average test and maintenance included and a cutset truncation limit of 1E-09.

As a point of reference] the importance of the highest worth EGLS for the Maintenance Rule risk ranking is:

Risk achievement worth (RAW) importance: 1.OO 0 Fussell-Vesely (FV) importance: 4.7E-04 5.3 Safety Summary The proposed change increases the allowed time to restore the inoperable SGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change does not alter any of the assumptions used in the safety analyses] 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. Additionally, these changes can be made without adverse impact to plant operations or to the health and safety of the public.

6.0 REGULATORY ANALYSIS

6.1 No Significant Hazards Consideration The proposed change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

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 proposed change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident.

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 8 of 10 Additionally, the proposed change has no affect on the consequence of any analyzed accident since the change does not affect the function of any equipment credited for 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 change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. It does not modify any plant equipment and there is no impact on the capability of existing equipment to perform its intended functions. No system setpoints are being modified and no changes are being made to the method in which plant operations are conducted. 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.

Criterion 3:

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

Response: No.

The proposed change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed change does not affect any of the assumptions used in the accident analysis, nor does it affect any operability requirements for equipment important to plant safety. Therefore, the proposed change 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).

6.2 Applicable Regulatory Requirements/Crite ria The AC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii). Additionally, 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants, states in part:

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 9 of 10 Criterion 17- Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (I) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Criterion 18- Inspection and testing of electric power systems. Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically ( I ) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

The proposed change increases the allowed time to restore the inoperable EGLS to operable status from 6 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident. In addition, no surveillance requirements will be altered as a result of this change. Therefore, Criterion 3 of 10 CFR 50.36(~)(2)(ii)and Criteria 17 and 18 of 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," continue to be met.

7.0 ENVl RONMENTAL CONS1DERATION DNC has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it 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

Serial No.05-058 Docket No. 50-423 Exigent Technical Specifications Change Attachment 1 Page 10 of 10 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.05-058 Docket No. 50-423 ATTACHMENT 2 EXIGENT LICENSE AMENDMENT REQUEST (LBDCR 05-MP3-002)

EMERGENCY GENERATOR LOAD SEQUENCER ALLOWED OUTAGE TIME MARKED-UP PAGES MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

TABLE 33-3 CContinudL ENGINEERED S A F l E T Y F E A ~ACTU s A'ITON SYSmM ON m

I MINIMUM 2

4 FUNCTIONALUNIT TOTAL NO. CHANNELS OFCHANNELS TOTRIP CHANNELS OPERABLE APPLICABLE MODES ACTION

9. Engineering Safety Features Actuation System hterlocks

a. Pressurizer Pressure, 3 2 2 P-11 1 7 27 3 21 w

2 b. LOW-LOW Tavg,P-12 4 2 w 3 21 tL w c. Reactor Trip, P-4 2 2 2 10- Emergency Generator 2 1 2 Load Sequencer 2:

P L

zf: I

- J W L E 33-3 Koatinued)

1. The Steamline Isolation Logic and Safety Injection Logic for this trip function may be blocked in this MODE below the P-11(Pressurizer Pressure Interlock) Setpoint.

• MODES 1,2,3,4,5and 6.

During fuel movement within containment or the spent fuel pool.

• • • • Trip knction automatically blocked above P-11 and may be blocked below P-11 when Safety Injection on low steam line pressure is not blocked.

ACTION STATEMENTS ACTION 14 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

,. + . I ACTION 15 -

ACTION 16 - With the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed until performance of the next required ANALOG CHANNEL OPERATIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACTION 17 - With the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is met. One additional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.I.

ACTION 18 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 7 days.

After 7 days, or if no channels are OPERABLE, immediately suspend fuel movement, if applicable, and 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 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 />.

ACTION 19 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 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 />.

MILLSTONE - UNIT 3 3/43-24 C / Y 9 Amendment No. S , X , 84, M y 243,W,

Insert A to Page 3/4 3-24 With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE.

Serial No.05-058 Docket No. 50-423 ATTACHMENT 3 EXIGENT LICENSE AMENDMENT REQUEST (LBDCR 05-MP3-002)

EMERGENCY GENERATOR LOAD SEQUENCER ALLOWED OUTAGE TIME RE-TYPED PAGES MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC.

z Y

c I

m TABLE 3.3-3 (Continued) 8Z ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION mI MINIMUM TOTAL NO. CHANNELS CHANNELS APPLICABLE 7 FUNCTIONAL UNIT OF CHANNELS TO TRIP OPERABLE MODES ACTION

9. Engineering Safety Features Actuation System Interlocks

a. Pressurizer Pressure, 3 2 2 1,2,3 21 P-1 I Y b. LOW-LOW TavgyP-12 4 P 2 3 1Y2Y3 21 k.'

N w c. Reactor Trip, P-4 2 2 2 1Y2Y3 23

10. Emergency Generator 2 1 2 1,2Y 334 15 Load Sequencer

TABLE 3.3-3 (Continued)

TABLE NOTATIONS

1. The Steamline Isolation Logic and Safety Injection Logic for this trip function may be blocked in this MODE below the P-11 (Pressurizer Pressure Interlock) Setpoint.

• MODES 1 , 2 , 3 , 4 , 5 and 6.

During fuel movement within containment or the spent fuel pool.

• • • • Trip function automatically blocked above P-1 1 and may be blocked below P-1 1 when Safety Injection on low steam line pressure is not blocked.

ACTION STATEMENTS ACTION 14 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1 ,provided the other channel is OPERABLE.

ACTION 15 With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 />; however, one channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1, provided the other channel is OPERABLE ACTION 16 - With the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed until performance of the next required ANALOG CHANNEL OPERATIONAL TEST provided the inoperable channel is placed in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

ACTION 7 - With the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition and the Minimum Channels OPERABLE requirement is met. One additional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per Specification 4.3.2.1.

ACTION 8 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 7 days.

After 7 days, or if no channels are OPERABLE, immediately suspend fuel movement, if applicable, and 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 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 />.

ACTION 19 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 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 />.

MILLSTONE - UNIT 3 3f4 3-24 Amendment No. %,38,89,W,W, w,