ML071860161

Proposed Technical Specifications Change Re ASME Code Reference Update (Lbdcrs 07-MP2-014 & 07-MP3-009)

ML071860161
Person / Time
Site:	Millstone
Issue date:	07/02/2007
From:	Gerald Bichof Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0207, LBDCRS 07-MP2-014, LBDCRS 07-MP3-009
Download: ML071860161 (20)

Text

Dominion Nuclear Connecticut, Inc.

5000 Ilominion Boulevard, Glen Allen, Virgin1.12.3060 X' 13,Address: www.dorn.com July 2, 2007 U. S. Nuclear Regulatory Commission Serial No. 07-0207 Attention: Document Control Desk NSS&L/DF: R2' Washington, DC 20555 Docket Nos. 50-336, 50-423 License Nos. DPR-65, NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 PROPOSED TECHNICAL SPECIFICATIONS CHANGE ASME CODE REFERENCE UPDATE JLBDCRS 07-MP2-014 & 07-MP3-009)

Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests an amendment to Facility Operating Licenses DPR-65 and NPF-49 for Millstone Power Station Unit 2 (MPS2) and Unit 3 (MPS3), respectively. The proposed amendment will modify MPS2 and MPS3 Technical Specification (TS) 4.0.5 to reference the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) instead of Section XI of the ASME Boiler and Pressure Vessel Code. Additionally the redundant requirement in TS 4.0.5 to maintain an IS1 program is being proposed for removal based on duplicate regulatory requirements in 10 CFR 50.55a.

The proposed changes are consistent with implementation of the MPS2 fourth and MPS3 third ten year lnservice Testing (IST) program in accordance with the requirements of 10 CFR 50.55a(f), "lnservice testing requirements." The MPS2 fourth ten year IST interval and MPS3 third ten year IST interval begin on April 1, 2008.

The proposed amendment is based on NFLC-approved Technical Specification Task Force (TSTF) Traveler TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a," and TSTF-497-A, Revision 0, "Limit lnservice Testing Program Application to Frequencies of 2 Years or Less."

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

To ensure MPS2 and MPS3 TS are in compliance with ASME code by the start of the next IST interval, DNC requests approval of the proposed amendments by February 1, 2008, with the amendment being implemented within 60 days of issuance.

Attachment 1 to this letter contains an evaluation of the proposed changes and a significant hazards determination. Attachments 2 and 3 contain the marked-up TS pages for MPS2 and MPS3, respectively. TS Bases pages will be modified accordingly upon receipt of the proposed amendment in accordance with the Technical Specification Bases Control Program and are not included in this submittal.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Page 2 of 3 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, Gerald T. Bischof w Vice President - Nuclear Engineering Attachments: 1. Evaluation of Proposed License Amendment

2. MPS2 Marked-Up TS Pages

3. MPS3 Marked-Up TS Pages Commitments made in this letter: None COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO 1 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 a "'day of 9 bd%$

, 2007 My Commission Expires: &@$ d / ,i b 0 8 .

O Notary Public

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. J. D. Hughey Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 83B Rockville, MD 20852-2738 Mr. R. I. Treadway 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. 07-0207 Docket Nos. 50-336, 50-423 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATIONS CHANGE ASME OM CODE REFERENCE (LBDCRS 07-MP2-014 & 07-MP3-009)

EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 1 of 9 EVALUATION OF PROPOSED LICENSE AMENDMENT 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 3.0 TECHNICAL EVALATION 3.1 Background 3.2 Technical Analysis

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory RequirementsICriteria 4.2 Precedent 4.3 Significant Hazards Consideration

6.0 REFERENCES

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 2 of 9 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests an amendment to Facility Operating Licenses IDPR-65 and NPF-49 for Millstone Power Station Unit 2 (MPS2) and Unit 3 (MPS3), respectively. The proposed amendment will modify MPS2 and MPS3 Technical Specification (TS) 4.0.5 to reference the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) instead of Section XI of the ASME Boiler and Pressure Vessel (B&PV) Code. Additionally the redundant requirement in TS 4.0.5 to maintain an IS1 program is being proposed for removal based on duplicate regulatory requirements in 10 CFR 50.55a.

The proposed changes are consistent with implementation of the MPS2 fourth and MPS3 third ten year lnservice Testing (IST) program in accordance with the requirements of 10 CFR 50.55a(f), "lnservice testing requirements." The MPS2 fourth ten year IST interval and MPS3 third ten year IST interval begin on April 1, 2008.

The proposed amendment is based on NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a11' and TSTF-497-A, Revision 0, "Limit lnservice Testing Program Application to Frequencies of 2 Years or Less."

To ensure MPS2 and MPS3 TS are in compliance with ASME code by the start of the next IST interval, DNC requests approval of the proposed amendment by February 1, 2008, with the amendment being implemented within 60 days of issuance.

2.0 DETAILED DESCRIPTION The MPS2 and MPS3 Technical Specification (TS) 4.0.5 establishes the requirement that inservice inspection (ISI) of ASME Code Class 1, 2, and 3 components and inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves are performed in accordance with a periodically updated version of Section XI of the ASME B&PV Code and Addenda as required by 10 CFR 50.55a. TS 4.0.5 includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME B&PV Code . This clarification is provided to ensure consistency in surveillance intervals throughout the TS. Aside from minor punctuation differences, the wording of MPS2 and MPS3 TS 4.0.5 is identical.

TSTF-479-A (Reference 6.1) was developed to indicate that the IST program include testing frequencies applicable to the ASME OM Code which replaces the ASME B&PV Code as it relates to IST of pumps and valves. TSTF-479-A was approved as an administrative change by the NRC (Reference! 6.2) and incorporated into Revision 3.1 of the improved standard Technical Specifications for Combustion Engineering (NUREG-1432) and Westinghouse (NUREG-1431) plan~ts.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 3 of 9 TSTF-497-A (Reference 6.3) was developed to provide an additional clarification that limits the provisions of surveillance requirement 3.0.2 (which permits a 25% extension of the interval specified in the frequency) to those IST frequencies specified as 2 years or less. TSTF-497-A was approved in an NF!C safety evaluation (Reference 6.4) but is not yet incorporated into the improved standard TS. Surveillance requirement 3.0.2 is a reference to the industry standard provision in NUREG-1431 and NUREG-1432. MPS2 and MPS3 contain a similar provision in T'S 4.0.2 which states "Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval."

The MPS2 and MPS3 proposed changes are in accordance with TSTF-479-A and TSTF-497-A except for the administrative differences of TS location (MPS Section 3.014.0 versus Administrative Section 5.0 in the NUREGs) and format.

To ensure consistency between the MPS2 and MPS3 proposed changes and those of the TSTFs discussed above, DNC is also proposing to remove the inservice inspection (ISI) program requirement and corresponding ASME B&PV Code referencing from TS 4.0.5. The NRC conducted a review of the Administrative Section 5.0 of the standard TS and concluded that provisions for the IS1 program (and other programs) could be relocated to other licensee documents provided changes to the provisions are adequately controlled by other regulatory requirements (Reference 6.5). In its review the NRC also provided the justification that TS should not duplicate other regulatory requirements.

Corresponding TS Bases changes will be made in accordance with the respective unit's TS Bases Control Program and have not been included for information in this submittal due to the administrative nature of the changes.

3.0 TECHNICAL EVALUATION

3.1 Background The background for the changes being proposed by this license amendment request is the same as the Background sections associated with TSTF-479-A and TSTF-497-A.

One exception is that the application of provision 3.0.2, as it relates to IST frequencies in the improved standard TS, corresponds to ithe provision 4.0.2 in MPS2 and MPS3 TS that is quoted in the previous section. This difference is not considered to be technically significant.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 4 of 9 3.2 Technical Analvsis 3.2.1 ASME OM Code Reference Update The technical analysis for the MPS2 and IMPS3 proposed changes relating to IST activities are as specified in the Technical Analysis Sections of TSTF-479-A and TSTF-497-A. One exception is the application of provision 3.0.2 as it relates to IST frequencies in the improved standard TS corresponds to the provision 4.0.2 in MPS2 and MPS3 TS that is quoted in the previous section. This difference is not considered to be technically significant.

3.2.2 Removal of Referencing to IS1in TS 4.0.5 During review of MPS2 and MPS3 TS 4.0.5 for implementation of TSTF-479-A and TSTF-497-A, it was determined that the surveillance frequencies table headings in TS 4.0.5 should be clarified to indicate that the !;urveillance frequencies listed in the table are applicable to IST only. For that reason, reference to IS1 activities is removed from the surveillance frequencies table headings. Likewise 4.0.5 c. and 4.0.5.d, which refer to the frequencies listed in the table, also propose removal of reference to ISI.

MPS2 and MPS3 are required by NRC regulation 10 CFR 50.55a(g)(4) to meet IS1 requirements for ASME Code Class 1, 2, and 3 components set forth in Section XI of editions of the ASME B&PV Code and Addenda incorporated by reference in 10 CFR 50.55a(b). MPS2 and MPS3 maintain (and make necessary changes to) their respective IS1 programs in accordance with approved station manuals and procedures as required by 10 CFR 50.55a(g). The current TS requirement in 4.0.5.a duplicates this regulation for IS1 requirements and its deletion will not reduce MPS's commitment to the IS1 program. Removal of IS1 will not relieve hAPS of its responsibility to seek relief from Code requirements when they are impractical1 nor will it eliminate any IS1 activities not covered by 10 CFR 50.55a. Also, the current revisions (Rev. 3.1) of NUREG-1431 and NUREG-1432 do not contain a requirement to maintain an IS1 program in accordance with 10 CFR 50.55a. Based on this discussion, removal of the IS1 program from the MPS2 and MPS3 TS is determined to be an administrative change as these requirements are specified separately within the NRC's regulations.

The table below lists the surveillance requirements (SRs) that currently reference Technical Specification (TS) 4.0.5. No other referencing to TS 4.0.5 exists in the MPS2 or MPS3 TS. The context of each reference was reviewed and, with the exception of the snubbers TS, determined to be applicable to inservice testing requirements and not inservice inspection requirements. For the snubbers TS (MPS2 TS 4.7.8 and MPS3 TS 4.7.10), the reference to TS 4.0.5 will be cha~ngedto the Inservice Inspection Program.

Deleting inservice inspection from the language in 4.0.5 will not impact any other TS.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 5 of 9 MPSZ TS 4.0.5 Title of TS Section Applicable Component Referencing 4.4.2 314.4 REACTOR COOLANT SYSTEM pressurizer code safety valves 314.4.2 SAFETY VALVES 4.4.3.1 314.4 REACTOR COOLANT SYSTEM ~ o w eo~erated r relief valves 1

314.4.3 RELIEF VALVES 4.4.9.3.1 314.4 REACTOR COOLANT SYSTENI power operated relief valves 1 1 1 314.4.9 PRESSURE TEMPERATURE LIMITS, OVERPRESSURE PROTECTION SYSTEMS 4.5.2.c,d,&e 314.5 EMERGENCY CORE COOLING high pressure safety injection, low SYSTEMS 314.5.2 ECCS SUBSYSTEMS pressure safety injection and

- Tavg r 300" F 4.6.2.1.1.b 314.6 CONTAINMENT SYSTEMS DEPRESSURIZATION AND COOLlNlG SYSTEMS. CONTAINMENT SPRAYAND COOLING SYSTEMS 4.6.3.1 314.6 CONTAINMENT SYSTEMS 314.6.3 containment isolation valves I CONTAINMENT ISOLATION VALVES 4.7.1.1 1 314.7 PLANT SYSTEMS 314.7.1 TURF= main steam safety valves I CYCLE, SAFETY VALVES 4.7.1.2.b 314.7 PLANT SYSTEMS 314.7.1 TURF= AFW pumps CYCLE, AUXILIARY FEEDWATER I SYSTEM 4.7.1.5.2 1 314.7 PLANT SYSTEMS 314.7.1 T U R E ~

main steam isolation valves I CYCLE. MAIN STEAM ISOLATION VALVES 4.7.8 314.7 PLANT SYSTEMS 314.7.8 snubbers 1 I SNUBBERS s MPS3 TS 4.0.5 Title of TS Section Applicable Component Referencing 4.4.2 314.4 REACTOR COOLANT SYSTEM pressurizer code safety valves 314.4.2 SAFETY VALVES 4.4.4.1 314.4 REACTOR COOLANT SYSTEM power operated relief valves 314.4.4 RELIEF VALVES 4.4.6.2.2 314.4 REACTOR COOLANT SYSTEM RCS pressure isolation valve 314.4.6 REACTOR COOLANT SYSTEM I LEAKAGE, OPERATIONAL LEAKAGE!

4.4.9.3.2 1 314.4 REACTOR COOLANT SYSTEM I RHR suction relief valve 314.4.9 PRESSURE TEMPERATURE LIMITS, OVERPRESSURE PROTECTION SYSTEMS 4.5.2.f 314.5 EMERGENCY CORE COOLING ECCS subsystem - pumps SYSTEMS 314.5.2 ECCS SUBSYSTEIMS

- Tavg GREATER THAN OR EQUAL 'TO 350" F

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 6 of 9 Referencing Title of TS Section I Applicable Component 4.6.2.1.b 314.6 CONTAINMENT SYSTEMS 314.6.2 containment quench spray (QSS)

DEPRESSURIZATION AND COOLING -

subsystem pump SYSTEMS, CONTAINMENT QUENCI-I SPRAY SYSTEM 314.6 CONTAINMENT SYSTEMS 314.6.2 recirculation spray (RSS) pump DEPRESSURIZATION AND COOLING SYSTEMS, RECIRCULATION SPRAY SYSTEM 314.6 CONTAINMENT SYSTEMS 314.6.3 containment isolation valves 314.7 PLANT SYSTEMS CYCLE, SAFETY VALVES CYCLE. AUXILIARY FEEDWATER I SYSTEM 314.7 PLANT SYSTEMS 314.7.1 TURBINE I main steam isolation valves CYCLE, MAIN STEAM ISOLATION VALVES 314.7 PLANT SYSTEMS SNUBBERS

4.0 REGULATORY EVALUATION

4.1 Applicable Reaulatorv Reauirementslcriteria NRC regulation 10 CFR 50.55a defines the requirements for applying industry codes to each licensed nuclear powered facility. 10 CFR 50.55a(f)(4)(i) requires programs to perform inservice testing of certain ASME Code Class 1, 2, and 3 pumps and valves during the initial 120-month interval. The regulations require that programs be developed utilizing the latest edition and addenda incorporated into paragraph (b) of 10 CFR 50.55a on the date 12 months before the date of issuance of the operating license. Likewise, 10 CFR 50.55a(f)(4)(ii) requires licensees to comply with the requirements of the latest edition and addenda of the ASME OM code incorporated by reference in 10 CFR 50.55a(b) 12 months before the start of successive 120-month intervals. NRC regulation 10 CFR 50.55a(g)(4)(i) and (ii) provide similar requirements for the inservice inspection of ASME Code Class 1, 2, and 3 components.

4.2 Precedent The NRC staff recently approved license amendments for Kewaunee Power Station on December 14, 2006 (TAC No. MD3055), Watts Bar Nuclear Plant Unit 1 on December 18, 2006 (TAC No. MD2380) and for Point Beach Nuclear Plant on June 8, 2006 (TAC No. MC8929). These precedents incorporated updating to the ASME OM Code and clarification of IST frequencies. The staff approved a license amendment for Surry

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment IPage 7 of 9 Power Station on July 15, 2005 (TAC Ncrs. MC5034 and MC5035) that included removing the IS1 program from TS 4.0.5. The Surry license amendment also relocated IST requirements and replaced all referencing to 4.0.5 throughout the TS with that of the IST program. However, MPS has limited the scope of this proposed change to removal of ISI, due to the impact on other specifications and the need for NRC approval of the ASME Code update to support the start of the! intervals.

4.3 Significant Hazards Consideration The proposed change modifies the Millstone Power Station Unit 2 (MPS2) and Unit 3 (MPS3) Technical Specifications Surveillance Requirement 4.0.5 to replace the reference to Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code with a refere~nceto ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) to be consistent with the requirements of 10 CFR 50.55a(f)(4). The proposed changes also clarify applicable inservice testing (IST) frequencies of ASME Code Class 1, 2, and 3, pumps and valves.

Additionally, the proposed change removes ;a TS requirement to maintain an inservice inspection (ISI) program for ASME Code Class 1, 2, and 3 components in deference to the regulatory requirements in 10 CFR 50.55a(g) which duplicates the MPS2 and MPS3 TS requirement. Dominion Nuclear Connecticut, Inc. (DNC) has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident. Additionally, the proposed change has no effect on the consequence of any analyzed accident since the change does not affect the function of any equipment credited for accident mitigation. The proposed change incorporates revisions to the ASME Code that result in a net improvement in the measures for testing pumps and valves. Removing from TS the duplicate requirement in the regulations to maintain an IS1 program in accordance with ASME codes and standards does not impact any accident initiators or analyzed events or mitigation of events. No reduction in previous commitments to 10 CFR 50.55a(g) are being proposed by this change.

Based on the discussion above, the proposed change does not involve a significant increase in the probability or consequences 01 an accident previously evaluated.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 8 of 9

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 does not involve a modification to the physical configuration of the plant (i.e., no new equipment will be! installed) or adversely affect methods governing normal plant operation. The proposed change will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or malfunction mechanism. The proposed chalnge does not alter existing test criteria or frequencies. Additionally, there is no change in the types or increases in the amounts of any effluent that may be released off-site and there is no increase in individual or cumulative occupational exposure. The proposed changes incorporate revisions to the ASME Code that result in a net improvement in the measures for testing pumps and valves. Removal of the duplicate TS requirement to maintain an IS1 program will not alter the commitment to the current IS1 program requirements in 10 CFR 50.55a or any other TS requirements related to inservice inspection.

Based on the discussion above, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change revises TS 4.0.5 regarding inservice testing of ASME Code Class 1, 2, and 3 pumps and valves, for consistency with the requirements of 10 CFR 50.55a(f)(4). The proposed change incorpolrates an administrative clarification to the frequencies for IST and incorporates revisioris to the ASME Code that result in a net improvement in the measures for testing pumps and valves. No setpoints or safety limit settings are being revised. The safety function of the affected pumps and valves will continue to be confirmed through inspection and testing. Removal of the IS1 program requirement from TS 4.0.5 does not remove the requirement from regulations, and therefore, will not diminish the current station approved programs and procedures that implement the regulatory criteria of 10 CFR 50.55a(g) to maintain an acceptable IS1 program in accordance with the ASME Code.

Based on the discussion above, the proposled change does not involve a significant reduction in a margin of safety.

Serial No. 07-0207 Docket Nos. 50-336, 50-423 ASME OM Code Reference Attachment 1 Page 9 of 9

5.0 ENVIRONMENTAL CONSIDERATION

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 it 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 niay 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 'I 0 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

REFERENCES TSTF-479-A, Revision 0, "Changes to IReflect Revision of 10 CFR 50.55a,11dated December 19,2005.

USNRC letter from T. H. Boyce to members of the TSTF, "Status of TSTF 343, 479,482, 485," dated December 6, 2005.

TSTF-497-A, Revision 0, "Limit Inservice Testing Program Application to Frequencies of 2 Years or Less," datedl July 12, 2006.

USNRC letter from T. J. Kobetz to menibers of the TSTF, "Safety Evaluation TSTF 497 Limit Inservice Testing Prog~amApplication to Frequencies of 2 Years or Less," dated October 4, 2006.

USNRC letter from W. T. Russell to chairpersons of the TS Committee, "Content of Standard Technical Specifications, Section 5.0, Administrative Controls," dated October 25, 1993.

Serial No. 07-0207 Docket No. 50-336 ATTACHMENT 2 PROPOSED TECHNICAL SF'ECIFICATIONS CHANGE ASME CODE REFEIRENCE UPDATE MARKED-UP TECHNICAL SlPEClFlCATlONS PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER.STATION UNIT 2

SURVEILLANCE REQUIREMENTS (Continued)

I ecifications :

S J h s d Code and applicable Required frequencies f o r Addenda termi no1 ogy f o r performing inservice inservice 7 testing testing a c t i v i t i e s - activities Week7 y A t l e a s t once per 7 days Monthly A t l e a s t once per 31 days

- Quarterly o r every 3 months A t l e a s t once per 92 days Semiannually o r every 6 months A t l e a s t once per 184 days Yearly or annual 1y A t l e a s t once per 366 days Biennially o r every 2 years A t l e a s t once per 731 days

c. The provisions of Specification 4.0.2 a r e applicable t o the above performing inservice 1.

Performance of t h e above inservice +testing activities 1 shall be i n a d d i t i pecified Surveil lance Requirements.

e. Nothing i n t h e ASM construed t o super

&code s h a l l be i rements of any Technical Specifica-I tion.

MILLSTONE - UNIT 2 3/4 0-3 Amendment No. flz, 78, J ~ J , $?,

z,, ZH/f

PLANT SYSTEMS 3/4.7.8 SNUBBERS 1I M T T f N G FflR nPFRATrnN 3.7.8 All snubbers shall be OPERABLE. 'The only snubbers excluded from t h e requirements are those i n s t a l 1ed on nonsafety-re1 ated systems and then only i f t h e i r f a i l u r e o r f a i l u r e of t h e system oin which they are i n s t a l l e d would have no adverse e f f e c t on any safety-related system.

APPLICABILITY: MODES 1, 2, 3, and 4 . MODES 5 and 6 f o r snubbers located on systems required OPERABLE in those MODES.

ACT I ON :

With one o r more snubbers inoperable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> rep1 ace or r e s t o r e the inoperable snubber(s t o OPERABLE s t a t u s and perform an en ineering evaluation per Specification 4. .8.d on the attache'd component o r dec are t h e attached system inoperable and follow the appropriate ACTION statement f o r the system.

9 4.7.8 Each snubber shall be demonstrated OPEWBLE by performance of the following

. . augmented inservice~msrir'\cc'Lmspec+-.~on inspection program and the requirements r s w , of 3

As used in this specification, "type of snubber" s h a l l mean snubbers of t h e same design and manufacturer, i r r e s p e c t i v e o f capacity.

Visual inspections Snubbers are categorized as inaccessible o r accessible during r e a c t o r operation. Each of these categories (inaccessible and accessible) may be inspected independently according t o t h e schedule determined by Table 4.7-3. The visual inspection interval f o r each type of snubber s h a l l be determined based upon t h e c r i t e r i a provided in Table 4.7-3 and t h e f i r s t inspection interval determined using t h i s c r i t e r i a s h a l l be based upon the previous inspection interval as established by t h e requirements in e f f e c t before Amendment 160.

Visual inspections s h a l l v e r i f y t h a t (1) t h e snubber has no v i s i b l e indications of damage or impaired OPERABILITY, (2) attachments t o the foundation o r supporting s t r u c t u r e a r e functional, and (3) f a s t e n e r s f o r the attachment of the snubber t o the component and t o t h e snubber anchorage are functional. Snubbers which appear inoperable a s a r e s u l t of visual inspections shall be c l a s s i f i e d a s unacceptable and may be r e c l a s s i f i e d acceptable f o r the purpose of establ ishing the next visual inspection interval, provided t h a t (1) the cause o f the r e j e c t i o n i s c l e a r l y establ ished and remedied f o r t h a t p a r t i c u l a r snubber and f o r other snubbers irrespective of type MILLSTONE - UNIT 2

Serial No. 07-0207 Docket No. 50-423 ATTACHMENT 3 PROPOSED TECHNICAL SF'ECIFICATIONS CHANGE ASME CODE REFERENCE UPDATE

{LBDCR 07-~MP3-009)

MARKED-UP TECHNICAL SPECIFICATIONS PAGES DOMINION NUCLEAR C:ONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance 6

f i; within the specified survei 11 ance interval shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4 . 0 . 3 . Surveil1 ances I do not have to be performed on inoperable equipment or variables outside specified 1 imits. d f j r 4.0.2 Each Survei 1 lance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the survei 11 ance interval .

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveil lance interval, then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, .up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance o f the Surveil 1ance. A risk evaluation shall be performed for any Surveil 1 ance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the Limiting i /

Condition for Operation must immediately be declared not met, and the applicable j F Condition(s) must be entered. t {

When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not 1;(1J met, and the applicable Condition(s) must be entered.

!d ar 4.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation has been perfarmed within the stated survei 11 ance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requi rernents.

4.0.5 Survei 11 ance Requirements for inservi ce testing o f ASME Code Class 1, 2, and 3 as follows: !i Surveillance interv 1s specified in d c o d e and appl icabl e Addenda

~~vi+i-es--requr'.red--by-th&ASE4ENbi-l.er-h~d~

S p p 4 - U - d d e J J d a C s h a l 1 be appl i cabl e as follows in these Technical Specifications:

MILLSTONE - UNIT 3 3/4 0-2 Amendment No. $9 g7, Jjq, 179, M

APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued)

Required frequencies f o r Code and a p p l i c a b l e Addenda performing inservice terminology f o r inservice 7 testing 3jmti.B.a-afte t e s t i n q a c t i v i t i e s activities Weekly At least once per 7 days Monthly At feast once per 31 days Q u a r t e r l y o r e v e r y 3 months At least once per 92 days S e m i a n n u a l l y o r e v e r y 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly o r annually At l e a s t once per 366 days B i e n n i a l l y o r every 2 years At l e a s t once per 731 days

c. The p r o v i s i o n s o f S p e c i f i c a t i o n 4.0.2 a r e a p p l i c a b l e t o t h e above r e q u i r e d frequencies f o r performing i n s e r v i c e n testing activities; t.

f af 9 I

d. Performance o f t h e above i n s e r v i c e h s p e & 4 n - - a d J t e s t i n g activities 1 s h a l l be i n a d d i t i o n t o o t h e r s p e c i f i e d S u r v e i l 1ance Requirements ;

and

e. N o t h i n g i n t h e ASME s h a l l be construed t o supersede the requirements of any Technical #

I Specification.

MILLSTONE - UNIT 3 3/4 0-3 Amendment No. $$, y7, a, jag, 7, , / j

PLANT SYSTEMS 3/4.7.10 SNUBBERS N FOR OPFRATfflN 3.7.10 All snubbers shall be OPERABLE. The only snubbers excluded from the requirements are t h o s e installed on nonsafety-related systems and then only i f t h e i r f a i l u r e or f a i l u r e of the system on which they are installed would have no adverse effect on any safety-related system.

APPLICABILITY: MODES 1, 2, 3, and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE i n those MODES.

ACT ION :

W i t h one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation er Specification 4.7.109. on the attached component 8

or declare the attache system inoperable and follow the appropriate ACTION statement f o r t h a t system.

NTS 4.7.10 Each snubber shall be demonstrated OPERABLE by performance of the fol lowing

. . augmented inservice inspection program and the requirements of

, ,.. S\neTli~szru*\tc 'I_nspec+\on 'Pro rchrcr.

\

a. Inspection Types As used in t h i s specification, "type of snubber" shall mean snubbers of the same design and manufacturer, irrespective of capacity .

b. Visual Inspections Snubbers are categorized as inaccessible or accessible during reactor operation. Each of these categories (inaccessi bl e and c.

accessi b7 e) may be inspected independently according t o the schedule determined by Table 4.7-2.

the c r i t e r i a provided in Table 4.7-2.

Visual Inspection Acceptance Criteria Visual inspections shall verify that (1) the snubber has no visible The visual inspection interval for each type of snubber shall be determined based upon

~ n d i c a t i o n s of damage or impaired OPERABILITY, ( 2 )

4 attachments t o the foundation or supporting structure are functional, and ( 3 fasteners for the attachment of the snubber t o the component and to the snubber anchora e are functional.

9 Snubbers which ap ear inoperable as a result o visual inspections shall be c l a s s i 8 e d a s unacceptable and may be reclassified acceptable for the purpose of establishing the next visual 6

inspection interval, provided that 1) the cause of the rejection i s clearly establ ished and remedlie for that particular snubber and for other snubbers irrespective of MILLSTONE - UNIT 3 3/4 7-22 Amendment No. 3?&