ML070880705

License Amendment Request (LBDCR 07-MP2-007) Re Containment Spray Nozzle Surveillance

ML070880705
Person / Time
Site:	Millstone
Issue date:	03/28/2007
From:	Gerald Bichof Dominion Nuclear Connecticut
To:	Document Control Desk, NRC/NRR/ADRO
References
07-0036, LBDCR 07-MP2-007
Download: ML070880705 (19)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, Virginia 2.3060 KCh Address: www.dom.com March 28, 2007 U.S. Nuclear Regulatory Commission Serial No. 07-0036 Attention: Document Control Desk NSS&L/DF RO Washington, D.C. 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 LICENSE AMENDMENT REQUEST (LBDCR 07-MP2-007)

CONTAINMENT SPRAY NOZZLE SURVEILLANCE Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) hereby requests to amend Operating License DPR-65 for Millstone Power Station Unit 2 to modify the surveillance frequency associated with containment spray nozzle testing. The proposed changes will allow performance of testing for nozzle blockage to be based on the occurrence of activities that could cause nozzle blockage rather than a fixed periodic basis. Currently the testing for nozzle blockage is performed every 10 years.

DNC proposes to change this frequency to "following maintenance that could cause nozzle blockage." The Technical Specification Bases section will be updated with applicable spray nozzle testing information and will be expanded to include visual inspection.

The proposed amendment does not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92 (see Significant Hazards Consideration in ). The Site Operations Review Committee has reviewed and concurred with this determination.

The NRC approved similar license amendments for Millstone Power Station Unit 3 on May 31, 2005 (TAC No. MC4743), Perry Nuclear Power Station on June 29, 2000 (TAC No. MA7136), South Texas Project on August 20, 2003 (TAC No. MB9101) and for Crystal River Nuclear Power Plant (TAC No. MC4878) on August 4, 2005.

DNC is requesting NRC staff review and approval of the proposed change by February 2008 with a 60 day implementation period.

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. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance 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, Gerald T. Bischof Vice President - Nuclear Engineering Attachments:

1. Evaluation of Proposed License Amendment

2. Marked-Up Technical Specification Page

3. Marked-Up Technical Specification Bases Page For Information Only Commitments made in this letter: None CC: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. V. Nerses Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8C2 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Page 3 of 3 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering, 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 a8 day of a"na/l& ,2007.

My Commission Expires: LMf 0 31, aW3 .

(SEAL)

Serial No. 07-0036 Docket No. 50-336 ATTACHMENT 1 LICENSE AMENDMENT REQUEST (LBDCR 07-MP2-007)

CONTAINMENT SPRAY NOZZLE SURVEILLANCE EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 1 of 10 EVALUATION OF PROPOSED LICENSE AMENDMENT 1.O DESCRIPTION

3.0 BACKGROUND

3.1 Containment Spray System 3.1.1 Containment Spray System Description 3.1.2 Testing 3.1.3 Maintenance History 3.2 Foreign Material Exclusion (FME) Program 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 Requirementslcriteria

6.0 ENVIRONMENTAL CONSIDERATION

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 2 of 10 1.O DESCRIPTION Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) hereby requests to amend Operating License DPR-65 for Millstone Power Station Unit 2 (MPS2) to modify the surveillance frequency associated with containment spray nozzle testing.

The proposed changes will allow performance of testing for nozzle blockage to be based on the occurrence of activities that could potentially result in nozzle blockage rather than a fixed periodic basis. Currently the testing for nozzle blockage is performed every 10 years. DNC proposes to change this frequency to "following maintenance that could cause nozzle blockage." The Technical Specification Bases section will be updated accordingly and applicable spray nozzle testing information will be expanded to include visual inspection.

This change is being requested to reflect industry operating experience and plant specific experience and practices.

The NRC approved similar license amendments for Millstone Power Station Unit 3 on May 31, 2005 (TAC No. MC4743), Perry Nuclear Power Station on June 29, 2000 (TAC No. MA7136), and for South Texas Project on August 20,2003 (TAC No. MB9101).

2.0 PROPOSED CHANGE

The proposed amendment will modify surveillance requirement (SR) 4.6.2.1.1.e frequency as follows:

Current "At least once per 10 years by verifying each spray nozzle is unobstructed."

Proposed "By verifying each spray nozzle is unobstructed following maintenance that could cause nozzle blockage."

3.0 BACKGROUND

3.1 Containment Spray System Engineered safety features (ESFs) serve to mitigate the consequences of postulated events such as a loss-of-coolant accident (LOCA) and to protect the public by preventing or minimizing the release of fission products. The ESFs are described in Chapter 6 of the MPS2 Final Safety Analysis Report (FSAR). The containment spray system is an ESF designed to remove heat from the containment atmosphere by spraying the containment with cool borated water. The sprayed water collects in the

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 3 of 10 containment sump and is then cooled by the reactor building closed cooling water system through shutdown cooling heat exchangers and re-circulated to the containment atmosphere. The design criteria for the containment spray system is described in detail in FSAR section 6.4.1.2 and material specifications are provided in FSAR Table 6.4-1.

3.1.1 Containment Spray System Description The containment spray system is designed to activate upon receipt of a containment spray actuation signal on high containment pressure. The containment spray system removes initial heat generated by a design basis LOCA or main steam line break. In the event of a LOCA, the containment spray system is also credited for removing airborne iodine from the containment atmosphere. The containment spray system consists of two independent subsystems. Each subsystem consists of a containment spray pump, shutdown cooling heat exchanger, spray nozzles, piping, valves and instrumentation. Ring headers consisting of a total of 193 nozzles are located at three elevations in the dome of the containment structure. The upper and lower ring headers are served by the facility one subsystem and the facility two subsystem serves the middle ring. Either facility provides full coverage of containment. The minimum distance between the highest structure in containment and the ring headers is 65 feet.

The two pumps are located in the ESF rooms in the auxiliary building adjacent to the containment structure. The piping and spray nozzles are fabricated of Type 304 or 316 stainless steel.

Each containment spray pump draws water independently from the refueling water storage tank (RWST) and delivers flow through the shutdown cooling heat exchangers and motor-operated isolation valves to separate risers, which then discharge the water into the spray rings. When the RWST level drops to a specified setpoint, a sump recirculation actuation signal (SRAS) occurs and suction for the containment spray pumps shifts to the containment sump. In the SRAS mode, the containment spray pumps take the hot water from the containment sump and pump it through the shutdown cooling heat exchangers and motor operated isolation valves and back to the spray headers. Each containment spray discharge line also contains a check valve inside containment. The motor-operated isolation valves, located outside containment, are normally closed and open upon receipt of a containment spray actuation signal.

In modes 1 and 2, borated water in the RWST is maintained at a minimum temperature of 50 degrees F by circulating the RWST water through heat exchangers. Periodic sampling of the RWST water monitors the water chemistry and provisions are made to purify the water when necessary. The RWST is fabricated of Type 304 stainless steel plates. Additional design data for the RWST is provided in FSAR Table 6.2-1.

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 4 of 10 3.1.2 Testing The inspection and testing requirements for the containment spray system are described in FSAR section 6.4.4.2 and are summarized below.

For the initial system test, the manual header isolation valves were closed, and the spray nozzles were isolated during the testing of the containment spray pumps. Water was taken from the RWST and pumped through the shutdown cooling heat exchangers and returned to the RWST via the recirculation lines. No water was flowed through the spray nozzles during this portion of the system startup test.

The initial containment spray headers flow verification pre-operational test was performed in 1974 using air and by observing movement of streamers attached to the nozzles or by hand. The containment spray header manual isolation valves were closed, the downstream piping drained, and an air supply was attached via valves downstream of the header manual isolation valves. The containment spray header motor operated isolation valves were opened and air was admitted to the containment spray headers. This first test identified eight nozzles that did not have air flow.

Subsequent maintenance identified and removed a "Flexitallic" gasket with tape on one side that blocked air flow to eight nozzles on the " A header inner ring. After removal of the blockage, the eight nozzles passed their air test as well, as described in FSAR Section l3.A.31.

Periodic in-place air flow tests through the containment spray nozzles have been conducted at the interval specified in Technical Specifications. The air flow test is performed by closing the containment spray pump discharge isolation valves and connecting an external air source to a temporary flange on a downstream check valve.

Air flow is then verified through each associated spray nozzle.

Specifically the containment spray nozzle test history is as follows:

Test 1 Performed as part of the preoperational test on 11/07/1974 and 11/16/1974 Test 2 Performed on 09126-2711980 during refueling outage 3 Test 3 Performed on 04/19/1985 during refueling outage 6 Test 4 Performed on 02116-1711989 during refueling outage 9 Test 5 Performed on 02/2011995 - 03/03/1995 during refueling outage 12 Test 6 Performed on 05/06/2000 during refueling outage 13 The results of each test demonstrated unobstructed flow through each nozzle. These tests confirmed that the system was free from construction debris and that no debris that could cause obstructions had entered the systems following startup and operation of MPS2.

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 5 of 10 3.1.3 Maintenance History A review of the maintenance history of the MPS2 containment spray system was performed to determine work that took place since the last airlsmoke tests on the system that could potentially have resulted in minor issues with respect to cleanliness.

A review of maintenance work orders indicates that no work activities that could have introduced foreign material into the system were conducted on the containment spray nozzles/headers since the most recent flow tests were performed.

During Refueling Outage (RFO) 17 (fall 2006), foreign material, not attributed to systemic maintenance issues, was found in both shutdown cooling heat exchangers and was subsequently removed during the outage. A search to determine the source of the foreign material was conducted during the outage, but it was not definitive. It was concluded that the foreign material was most likely "Flexitallic" type 304 stainless steel gasket winding material. An engineering evaluation of the impact of the foreign material found in the channel head of the "B" shutdown cooling heat exchanger (X23B) for Mode 1, 2, and 3 operations was documented in Condition Report Engineering Disposition (CRED) CR-06-11063, dated November 15, 2006. The CRED concluded that the shutdown cooling heat exchangers act as strainers and trap most of the foreign material entering them. Very little foreign material passes through the shutdown cooling heat exchangers. With respect to functional capability, the full flow test of the containment spray system through the shutdown cooling heat exchangers and back to the RWST flushes the system and demonstrates proper operation of the flow path upstream of the normally closed containment spray header isolation valves. In addition, the piping configuration, i.e., long vertical risers downstream of the normally closed motor operated isolation valves, minimizes the probability that the debris could migrate to the containment spray nozzles. The CRED made the following statement in relation to material that could remain in the system: "Spray nozzle performance could be altered by foreign material but the amount of foreign material in the system is considered inconsequential and spray nozzle performance would not be impacted." Therefore, it was concluded that the RFO 17 shutdown cooling heat exchanger event did not and does not warrant testing the containment spray nozzles with air or smoke.

3.2 Foreign Material Exclusion (FME) Program The site-wide FME program at Millstone is governed by approved work control procedures. These procedures ensure that the appropriate precautions are taken as needed to minimize the inadvertent and uncontrolled introduction of foreign materials into plant systems and components.

FME training is required for all personnel performing work planning activities, maintenance, modifications, repairs, testing or inspections on plant equipment and components. Breached fluid or piping systems are required to be covered when not being directly accessed for inspection or maintenance. Administrative FME controls

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 6 of 10 also delineate program requirements for maintaining cleanness of plant systems and components. For example, for maintenance activities that create debris, cleanness inspections are required. For safety class systems and components the final cleanness inspection is performed by quality control inspectors.

If FME integrity is lost through the intrusion or discovery of foreign material, procedures direct the worker(s) to initiate a condition report which would require an evaluation be performed to determine if any actions are needed to ensure system integrity. Where special circumstances require activities to be performed by an outside vendor or contractor who has not received FME training, their work must be continuously supervised or monitored by FME qualified Millstone personnel.

3.3 Reason for Proposed Amendment This change is being requested based on industry and plant experience which indicates that blockage of the containment spray nozzles during normal plant operation is unlikely. This proposed change eliminates unnecessary testing of the spray nozzles by requiring the test be performed based on activities or conditions that could potentially cause nozzle blockage. The surveillance requires workers to verify air flow at each nozzle located at high elevations inside containment, and the potential reduction in the frequency of performance should enhance personnel safety. Similarly, the proposed changes are expected to result in a reduction in personnel exposure and outage costs associated with performing airflow/smoke tests. Industry and plant specific experience has shown that the proposed change more accurately reflects when verification of spray nozzle operability is appropriate.

4.0 TECHNICAL ANALYSIS

4.1 Details of the Proposed Amendment The proposed amendment will modify SR 4.6.2.1.1.e to change the frequency for verifying spray nozzles are unobstructed. Currently, the surveillance requires the verification of containment spray nozzle operability to be performed every 10 years and the Technical Specification Bases describes the operability determination is performed by blowing low pressure air or smoke through the nozzles and verifying flow. Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation, dated September 27, 1993, was used as the basis for the current MPS2 10-year surveillance frequency due to the stainless steel construction of the nozzles and piping. No coating material which could potentially cause clogging of the spray nozzles, similar to that used on carbon steel piping, is used in the piping or nozzles at MPS2. DNC proposes to replace the current periodic frequency for spray nozzle operability determination with a qualifying statement that would identify that operability evaluation is required following "maintenance that could cause nozzle blockage. Since containment spray header or nozzle maintenance

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 7 of 10 occurs infrequently, the proposed surveillance frequency should result in less spray nozzle testing.

The spray nozzles are a passive system. The greatest potential for introduction of debris that could result in blocking of the nozzles is during maintenance activities on the spray header or nozzles or downstream of the normally closed spray header isolation valves. However, the FME program contains the appropriate level of controls to provide a high level of confidence that foreign materials will not be introduced when the containment spray system boundaries are breached for maintenance or testing. FME controls are in place during maintenance or testing activities on the spray header or nozzles and require post-maintenance verification of system cleanness to ensure no foreign materials have been introduced into open systems. Because of the corrosion-resistant material of the nozzles, degradation of the nozzles is not expected to be a cause of nozzle plugging. The need to test for nozzle blockage following maintenance activities is currently addressed by the post-maintenance testing program which evaluates work scope to determine appropriate retests. However, unanticipated activities, such as an inadvertent spray actuation, a major configuration change, or a loss of foreign material control when working within the respective system boundary, may require surveillance performance. An evaluation, based on the specific situation, will determine the appropriate test method (e.g., visual inspection, air or smoke flow test) to verify no nozzle obstruction. This information regarding the evaluation for proposed testing methods will be added to the Technical Specification Bases section.

The Technical Specification Bases page mark-up is provided for information only in . The MPS2 Technical Specification Bases are controlled in accordance with Technical Specification Section 6.23, "Technical Specification Bases Control Program."

It is recognized that the potential exists for nozzle blockage caused by solid boric acid accumulation in the spray lines or nozzles due to evaporated borated water. The containment spray headers are normally maintained dry above the RWST static height.

However, should there be inadvertent fluid flow through the nozzles, such as the result of spurious actuation, DNC would evaluate testing and methods for determining the nozzles have remained unobstructed.

4.2 Summary The proposed amendment is expected to reduce unneeded surveillance testing of the containment spray nozzles. Thorough inspection and flow testing was performed for the containment spray system during the preoperational test. Subsequent periodic flow test results have indicated no nozzles were obstructed. The spray nozzles are a passive component and the most likely introduction of nozzle blockage would occur during maintenance activities. FME controls provide assurance that the potential for nozzle obstruction will continue to be low by providing protection against the introduction of foreign materials into open piping. Should foreign material with the

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 8 of 10 potential to obstruct the spray nozzles be discovered in a portion of the system, the corrective action program will direct that the extent of condition be evaluated, and cleanliness restored and whether surveillance testing is required. In addition, based on the corrosion-resistant material of the spray system piping and nozzles, degradation that could potentially cause nozzle plugging is unlikely.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The proposed amendment modifies the Millstone Power Station Unit 2 Technical Specifications surveillance frequency for verifying that the containment spray nozzles are unobstructed. The surveillance is being changed from a 10 year interval to a performance-based frequency. Specifically, the verification of no nozzle obstruction would only be performed following maintenance activities that could subject the system to possible sources of nozzle blockage. The proposed change is considered to be more reflective of plant operating experience, which has demonstrated that the introduction of spray nozzle blockage during normal plant operation is unlikely.

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 spray nozzles and the associated containment spray system are designed to perform accident mitigation functions only. The containment spray system and associated components are not considered as initiators of any analyzed accidents. The proposed change does not modify any plant equipment. The proposed change modifies the frequency for performance of a surveillance test which does not impact any failure modes that could lead to an accident. The proposed frequency change does not affect the ability of the spray nozzles or spray system to perform its accident mitigation function as assumed and therefore there is no affect on the consequence of any accident. Verification of no blockage continues to be required, but now as a function of activities that could result in blockage rather than an arbitrary surveillance frequency. Based on this discussion, the proposed amendment does not increase the probability or consequence of an accident previously evaluated.

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 9 of 10 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 containment spray system is not being physically modified and there is no impact on the capability of the system to perform accident mitigation functions. No system setpoints are being modified and no changes are being made to the method in which borated water is delivered to the spray nozzles. The testing requirements imposed by this proposed change to check for nozzle blockage following activities that could cause nozzle blockage do not introduce new failure modes for the system. 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 does not change or introduce any new setpoints at which mitigating functions are initiated. No changes to the design parameters of the containment spray system are being proposed. No changes in system operation are being proposed by this change that would impact an established safety margin. The proposed change modifies the frequency for verification of nozzle operability in such a way that continued high confidence exists that the containment spray system will continue to function as designed. Therefore, based on the above, the proposed amendment does not involve a significant reduction in a margin of safety.

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 Requirementslcriteria The applicable criterion from 10 CFR 50 Appendix A, General Design Criteria (GDC) for Nuclear Plants, associated with the containment spray system are criterion 16, "Containment Design," 38, "Containment Heat Removal," 39, "Inspection of Containment Heat Removal System," 40, "Testing of Containment Heat Removal System," and 50, "Containment Design Basis." In particular, GDC-40 requires that the containment heat removal system be designed to permit periodic testing. The

Serial No. 07-0036 Docket No. 50-336 Containment Spray Nozzle Surveillance Attachment 1 Page 10 of 10 containment spray system is a containment heat removal system. The proposed surveillance requirement frequency modification does not impact conformance to the applicable GDCs.

The design of the containment spray system is to reduce containment pressure following an accident in order to meet the requirements of 10 CFR 50.49 and 10 CFR 100. System operability requirements, combined with the requirement to verify no nozzle obstruction following maintenance should minimize the potential for nozzle obstruction and provide confidence that the system can perform its designated safety function. Therefore, the proposed change from a fixed 10-year interval to a performance-based frequency to verify each spray nozzle is unobstructed is consistent with all applicable regulatory requirements or criteria.

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 Commission's 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 ENVIRONMENTAL CONSIDERATION

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, but would change an inspection or surveillance requirement. 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. 07-0036 Docket No. 50-336 ATTACHMENT 2 LICENSE AMENDMENT REQUEST (LBDCR 07-MP2-007)

CONTAINMENT SPRAY NOZZLE SURVEILLANCE MARKED-UP TECHNICAL SPECIFICATION PAGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

September 9,2004 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b.

c.

By verifying the developed head of each containment spray pump at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5, At least once per 18 months by verifying each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

riI I;

d. At least once per 18 months by verifying each containment spray pump starts automatically on an actual or simulated actuation signal.

c.

Der I Qmw by verifying each spray nozzle is unobstructed.

t 4.6.2.1.2 Each containment air recirculation and cooling unit shall be demonstrated OPERABLE: ' 9

a. At Ieast once per 3 1 days by operating each containment air recirculation and cooling unit in slow speed for 2 15 minutes.

b. At least once per 3 1 days by verifying each containment air recirculation and cooling unit cooling water flow rate is 2 500 gpm.

c. At least once per 18 months by verifying each containment air recirculation and cooling unit starts automatically on an actual or simulated actuation signal.

MILLSTONE UNIT 2 Amendment No. ?l4,283

Serial No. 07-0036 Docket No. 50-336 ATTACHMENT 3 LICENSE AMENDMENT REQUEST (LBDCR 07-MP2-007)

CONTAINMENT SPRAY NOZZLE SURVEILLANCE MARKED-UP TECHNICAL SPECIFICATION BASES PAGE FOR INFORMATION ONLY DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

September 9,2004 CONTAINMENT SYSTEMS --.. -l BASES J F ~A C 1nformdt10ylA &

314.6.2.1 CONTAINMENT SPRAY AND COOLlNG SYSTEMS Continuedl Surveillance Requirement 4.6.2.1. i .b, which addresses periodic surveillance testing of the containment spray pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems, is required by Section XI of the ASME Code. This type of testing may be accomplished by measuring the pump developed head at onIy one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is grater than or equal to the performance assumed in the unit safety analysis. The surveitlance requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and frequencies necessary to satisfy the requirements.

containment spray valve actuates to the required position on an actual or simulated actuation signal (CSAS or SRAS), and that each containment spray pump starts on receipt of an actual or simulated actuation signal (CSAS). This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrativecontrols. The 18 month frequency is based on the need to perform these surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the surveillances were performed with the reactor at power. The 18 month frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

The actuation logic is tested as part of the Engineered Safety Feature Achration System (ESFAS) testing, and equipment performance is moni that all associated controls are functioning properly. It also ensures fan or motor failure can be detected and corrective action taken. The 3 1 day frequency considers the known reIiability of the fan units and controls, the two train redundancy available, and the low probability of a significant degradation of the containment air recirculation and cooling unit occuning between surveillances.

This frequency has been shown to be acceptable through operating experience.

MILLSTONE UNIT 2- B 314 6-3a Amendment No. W ,215,236,278, 283

INSERT A for page B 314 6-3a Surveillance Requirement 4.6.2.1.I .e requires verification that each spray nozzle is unobstructed following maintenance that could cause nozzle blockage. Normal plant operation and maintenance activities are not expected to trigger performance of this surveillance requirement. However, activities, such as an inadvertent spray actuation that causes fluid flow through the nozzles, a major configuration change, or a loss of foreign material control when working within the respective system boundary may require surveillance performance. An evaluation, based on the specific situation, will determine the appropriate method (e.g., visual inspection, air or smoke flow test) to verify no nozzle obstruction.