ML080850843

Amended Response to Request for Additional Information Regarding Control Room Habitability

ML080850843
Person / Time
Site:	Millstone
Issue date:	03/25/2008
From:	Hartz L Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
08-0050A, TAC MD6115, TAC MD6116
Download: ML080850843 (6)

Text

Dominion Nuclear Connecticut, Inc.

\1 J11.'ili ill' Power Station I

j~\ lf1l' h__*rry Road

\\ ""rtord, CT OCdWi March 25, 2008 U. S. Nuclear Regulatory Commission Serial No. 08-0050A Attention: Document Control Desk NLOSIIMAE R3 One White Flint North Docket Nos. 50-336/423 11555 Rockville Pike License Nos. DPR-65 Rockville, MD 20852-2738 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 AMENDED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTROL ROOM HABITABILITY (TAC NOS. MD6115 AND MD6116)

On July 13, 2007, Dominion Nuclear Connecticut, Inc. (DNC) submitted a request for an amendment to the Technical Specifications (TSs) for Millstone Power Station Units 2 and 3 (MPS2 and MPS3) (Serial No. 07-0440). The proposed amendment would revise TS requirements related to control room envelope habitability consistent with the intent of NRC-approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-448, "Control Room Habitability," Revision 3. The NRC forwarded a request for additional information (RAI) on November 21,2007. DNC responded to this RAI in a letter dated December 7,2007 (Serial No. 07-0790). The NRC forwarded an additional RAI on January 28, 2008. DNC provided additional information in response to this RAI on March 5, 2008 (Serial No 08-0050).

On March 6, 2008, DNC identified that an administrative error of minor significance had occurred in processing the March 5, 2008 submittal which resulted in the unintended transmittal of an earlier revision of the letter to the NRC. This error was conveyed to the NRC on March 6, 2008 in a telephone discussion between Mr. William Bartron (ONC) and Mr. John Hughey (NRC).

ONC is revising the responses to NRC Questions 3 and 4 submitted in ONC's March 5, 2008 letter to correct the above noted administrative error. The revised responses to NRC Questions 3 and 4 are provided in the attachment to this letter and supersede the previous responses in their entirety. The additional information provided in this letter does not affect the conclusions of the Significant Hazards Consideration discussion in DNC's original submittal dated July 13, 2007.

Serial No. 08-0050A Docket Nos. 50-336 50-423 Resp. to CR Hab. RAI Page 2 of 3 Should you have any further questions in regard to this submittal, please contact Ms. Margaret A. Earle at (804) 273-2768.

Sincerely, CZ::!cr!

Vice presiden(!"Nuclear Support Services COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie Hartz, who is Vice President - Nuclear Support Services 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 ~ 5""'" day of __)~U-M=-,-,c..h=--,--_ _, 2008.

My Commission Expires:

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-UNOtary Public MARGARET eo IENNEn ~

Notary Publlc.3 'it/ .3 () J.. ~

Commonw.atth of Virginia ~

My Comml..lon Explr** Aug 31. 200. ~

Attachment Commitments made in this letter: None 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, Mail Stop 08 83 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No. OB-0050A Docket Nos. 50-336 50-423 Resp. to CR Hab. RAI Page 3 of 3 Director Bureau of Air Management Monitoring and Radiation Division CT Department of Environmental Protection 79 Elm St.

Hartford, CT 06106-5127

Serial No. 08-0050A Docket Nos. 50-336 50-423 ATTACHMENT CONTROL ROOM HABITABILITY (TAC NOS. MD6115 AND MD6116)

AMENDED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION MILLSTONE POWER STATION UNITS 2 AND 3 DOMINION NUCLEAR CONNECTICUT, INC.

Serial No. 08-0050A Docket Nos. 50-336 50-423 Resp. to CR Hab. RAI Attachment Page 1 of 2 PROPOSED TECHNICAL SPECIFICATION CHANGE CONTROL ROOM HABITABILITY AMENDED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Question 3 ONC references NEI 99-03, Revision 1, Appendix EE, in Attachment 1, Page 7 of 11 under 'Exceptions.'

The NRC staff has not reviewed NEI 99-03, Revision 1. Therefore, exceptions used in Appendix EE of NEI 99-03, Revision 1, have not been reviewed by the NRC staff.

Please identify alternate plant-specific ASTM E741 exceptions and provide a detailed explanation justifying the acceptability of these exceptions.

DNC Response It is recognized that the NRC staff has not reviewed or formally endorsed NEI 99-03, Revision 1. The proposed exception, as allowed by TSTF-448, to Sections C.1 and C.2 of Regulatory Guide 1.197, is necessary because the required testing methodology, ASTM E741, was not originally intended for nuclear power plant CRE testing. The proposed exception is identical to the exception proposed by San Onofre Nuclear Generating Station (SONGS) on April 17,2007, (ML071140209) and approved by the NRC on October 31, 2007 in SONGS 2 and 3 Amendments 214 and 206, respectively (ML072890012, TAC Nos. M05328 and M05329). The reference to NEI 99-03, Revision 1, Appendix EE was provided to add clarity regarding exceptions typically taken by ASTM E741 test vendors. While not an all-inclusive list, the exceptions listed in Appendix EE provide examples of the type of exceptions that will be allowed by the proposed Control Room Envelope Habitability Program. Any exceptions to the test methodology will be documented in the individual test report to ensure that the testing performed is in accordance with the Control Room Envelope Habitability Program requirements of proposed Technical Specifications 6.27 (MPS2) and TS 6.8.4.h (MPS3).

NRC Question 4 ONC stated in Attachment 1, Page 7 of 11 under 'Exceptions,' that exceptions to the Regulatory Guide (RG) 1.196, and the RGs referenced therein, are consistent with the intent, but are not in verbatim compliance with the regulatory positions established in each RG.

Serial No. 08-0050A Docket Nos. 50-336 50-423 Resp. to CR Hab. RAI Attachment Page 2 of 2 Please provide a categorical listing of the plant specific exceptions to the Regulatory Guides referenced in RG 1.196 (i.e., RG 1.52, RG 1.78 and RG 1.183). Also, identify specific MPS2 Updated Final Safety Analysis Report (UFSAR) and Millstone Power Station, Unit 3 UFSAR sections showing where these exceptions are addressed with their proper justification.

DNe Response As discussed in conference calls between DNC and the NRC on November 15, 2007 and December 20, 2007, the intent of the above referenced statement was to identify that adopting TSTF-448 will not change the degree of compliance currently documented in the MPS2 and MPS3 licensing basis documents for compliance with RGs 1.52, 1.78, 1.95 and 1.83.

Due to the age of MPS2 and MPS3, the differences between RG 1.196 and the current licensing basis (CLB) of the units are related to differences in version numbers associated with RG 1.52 (Rev. 2 in CLB vs. Rev. 3 in RG 1.196) and RG 1.78 (Rev. 0 in CLB and Rev. 1 in RG 1.196). As stated in the July 13, 2007 submittal, the MPS2 and MPS3 commitment to RG 1.52, 1.78, and 1.183 is described in the following licensing basis documents:

MPS2

• RG 1.52, Rev. 2, 1978 - TS 4.6.5.1

• RG 1.78, Rev. 0, 1974 - Technical Evaluation MG-EV-04-001, Rev. 0

• RG 1.95, Rev. 1, 1977 - Technical Evaluation MG-EV-04-001, Rev. 0

• RG 1.183, July 2000 - UFSAR Section 14 MPS3

• RG 1.52, Rev. 2, 1978 - UFSAR 1.8 and 6.5.1.2

• RG 1.78, Rev. 0, 1974 - UFSAR 1.8 and 6.4.4.2

• RG 1.95, Rev. 1, 1977 - UFSAR 1.8 and 6.4.4.2

• RG 1.183, July 2000 - UFSAR 1.8 and 15