ML16011A400

Issuance of Amendments Nos. 325 and 267 to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation

ML16011A400
Person / Time
Site:	Millstone
Issue date:	01/29/2016
From:	Richard Guzman Plant Licensing Branch 1
To:	Heacock D Dominion Nuclear
Guzman R
References
CAC MF5715, CAC-MF5716
Download: ML16011A400 (43)

Text

UNITED STATES' NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 January 29, 2016

SUBJECT:

MILLSTONE POWER STATION, UNITS.2 AND 3-ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATIONS TASK FORCE-523, REVISION 2, GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION

{CAC NOS. MF5715 AND MF5716)

Dear Mr. Heacock:

\\

The Nuclear Regulatory Commission (NRC) has issued the enclosed' Amendment No. 325 to Renewed Facility Operating License No. DPR-65 and Amendment No. 267 to Renewed Facility Operating License No. NPF-49 for Millstone Power Station, Unit Nos. 2 and 3 (MPS2 and MPS3}, in response to your application dated January 15, 2015, as supplemented by letters dated April 15, July 16, July 30, November 2, and December 1, 2015.

The amendm~,nts modify the Technical Specifications (TSs} to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The changes are consistent with NRG-approved Technical Specification Task Force-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Docket Nos. 50-336 and 50-423

Enclosures:

1. Amendment No. 325 to DPR-65

2. Amendment No. 267 to NPF-49

3. Safety Evaluation cc w/encls: Distribution via UstServ Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 DOMINION NUCLEAR CONNECTICUT, INC.

DOCKET NO. 50-336 MILLSTONE POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 325 Renewed License No. DPR-65

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Dominion Nuclear Connecticut, Inc. dated January 15, 2015, as supplemented by letters dated April 15, July 16, July 30, November 2, and December 1, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-65 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 325, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of issuance, and shall be implemented within 90 days of issuance.

Attachment:

Changes to the License and Technical Specifications Date of Issuance: January 29, 2016 FOR THE NUCLEAR REGULA TORY COMMISSION Travis L. Tate, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE* AMENDMENT NO. 325 RENEWED FACILITY OPERATING LICENSE NO. DPR-65 DOCKET NO. 50-336.

Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove 3

Replace the following pages of the Appendix A Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove 3/4 4-1c 3/4 4-1e 3/4 4-1 g 3/4 5-4 3/4 5-5 3/4 5-7 3/4 6-13 3/4 9-8a 3/4 9-8c Insert 3/4 4-1c 3/4 4-1 e 3/4 4-1g 3/4 5-4 3/4 5-5 3/4 5-7 3/4-6-13 3/4 9-8a 3/4 9-8c Connecticut, in accordance with the procedures and limitations set forth in this renewed operating license; (2)

Pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed source~ for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; (5)

Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The licensee is authorized to operate the facility at steady-state reactor core power levels not in excess of 2700 megawatts thermal.

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 325, are hereby incorporated in the renewed license.

The licensee shall operate the facility in accordance with the Technical Specifications.

Renewed License No. DPR-65 Amendment No. 325

REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power available..

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE, by verifying the secondary side water level to be ~ 10% nan*ow range at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.3.3 One reactor coolant loop or shutdown cooling train shall be verified to be in operation at the frequency specified in the Surveillance Frequency Control Program.

- NOTE - - - -

Not required to be performed until 12.hours after entering MODE 4.

4.4.1.3.4 Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNIT 2 3/4 4-lc Amendment No. 69, ~. ~

325

REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN ~ REACTOR COOLANT SYSTEM LOOPS FILLED LIMITING CONDITION FOR OPERATION (continued)

APPLICABILITY:

MODE 5 with Reactor Coolant System loops filled.

ACTION: a.

b.

With one shutdown cooling train inoperable and any steam generator secondary water level not within limits, immediately initiate action to either restore a second shutdown cooling train to OPERABLE status or restore steam generator secondary water levels to within limit.

With no shutdown cooling train OPERABLE or in operation, immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3. l. l. l and immediately initiate action to restore one shutdown cooling train to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.l The required shutdown cooling pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power available.

4.4.1.4.2 The required steam generators shall be determined OPERABLE, by verifying the secondary side water level to be 2 10% narrow range at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.4.3 One shutdown cooling train shall be verified to be in operation at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.4.4 Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNIT 2 314 4-le Amendment No.~. m, ' 325

REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - REACTOR COOLANT SYSTEM LOOPS NOT FILLED SURVEILLANCE REQUIREMENTS 4.4.1.5.1 The required shutdown cooling pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power available.

4.4.1.5.2 One shutdown cooling train shall be verified to be in operation at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.5.3 Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNIT 2 3/4 4-lg Amendment No.~' m 325

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

- NOTE - -

Not required to be met for system vent flow paths opened under administrative control.

a.

At the frequency specified in the Surveillance Frequency Control Program by verifying each Emergency Core Cooling System manual, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in positiqn, is in the correct position.

b.

At the frequency specified in the Surveillance Frequency Control Program by verifying that the following valves are in the indicated position with power to the valve operator removed:

Valve Number 2-81~306 2-81-659 2-Sl-660 Valve Function Shutdown Cooling Flow Control SRAS Recirc.

SRAS Recirc.

Valve Position Open*

Open**

Open**

Pinned and locked at preset throttle open position.

To be closed prior to recirculation following LOCA.

c.

By verifying the developed head of each high pressure safety injection pump at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5.

d.

By verifying the developed head of each low pressure safety injection pump at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5.

e.

By verifying the delivered flow of each ch;irging pump at the required discharge pressure is greater than or equal to the required flow when tested pursuant to Specification 4.0.5.

f.

At the frequency specified in the Sw*veillance Frequency Control Program by verifying each Emergency Core Cooling System automatic 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.

g.

At the frequency specified in the Surveillance Frequency Control Program by verifying each high pressure safety injection pump and low pressure safety injection pump starts automatically on an actual or simulated actuation signal.

MILLSTONE - UNIT 2 3/4 5-4 Amendment No.~. H9, ~. ~.

~325

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

h.

At the frequency specified in the Surveillance Frequency Control Program by*

verifying each low pressure safety injection pump stops automatically on an actual or simulated actuation signal.

1.

By verifying the correct position of each electrical and/or mechanical position stop for each injection valve in Table 4.5-1:

I.

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after completion of valve operations.

2.

At the frequency specified in the Surveillance Frequency Control Program.

j.

At the frequency specified in the Surveillance Frequency Control Program by verifying through visual inspection of the containment sump that each Emergency Core Cooling System subsystem suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.

k.

At the frequency specified in the Surveillance Frequency Control Program by verifying the Shutdown Cooling System open permissive interlock prevents the Shutdown Cooling System inlet isolation valves from being opened with an actual or simulated Reactor Coolant System pressure signal of~ 300 psia.

1.

At the frequency specified in the Surveillance Frequency Control Program by verifying that ECCS locations susceptible to gas accumulation are sufficiently filled with water.

MILLSTONE ~ UNIT 2 3/4 5-5 Amendment No. ::t, #, £!, 6+, -l-9-1-,

m,+&1:-, ~. m, m,w, ;,oo, ' 32s

EMERGENCY CORE COOLING SYSTEMS ECCS SUBSYSTEMS - Te_yg < 300°F LIMITING CONDITION FOR OPERATION 3.5.3 One high pressure safety injection subsystem shall be OPERABLE.

- NOTES- -

l.

The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 4 for the high pressure safety injection pump that is inoperable pursuant to Specification 3.4.9.3 provided the high pressure safety injection pump is restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after entering MODE 4.

2.

In MODE 4, the requirement for OPERABLE safety injection and sump recirculation

• actuation signals is satisfied by use of the safety injection and sump recirculation trip pushbuttons.

3.

In MODE 4, the OPERABLE HPSI pump is not required to sta1t automatically on a SIAS.

Therefore, the pump control switch for this OPERABLE pump may be placed in the pull-to-lock position without affecting the OPERABILITY of this pump; APPLICABILITY:

MODES 3* and 4.

ACTION:

a.

With no high pressure safety injection subsystem OPERABLE, restore at least one high pressure safety injection subsystem to OPERABLE status within one hour or be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b..

In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

SURVEILLANCE REQUIREMENTS 4.5.3. l The high pressure safety injection subsystem shall be demonstrated OPERABLE per the applicable portions of Surveillance Requirements 4.5.2.a, 4.5.2.b, 4.5.2.c, 4.5.2.f, 4.5.2.g, 4.5.2.i, 4.5.2.j, and 4.5.2.1.

• With pressurizer pressure < 1750 psia.

MILLSTONE - UNIT 2 3/4 5-7 Amendment No. 39, '*~.US, m,m32s

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS 4.6.2. l.1 Each containment spray train shall be demonstrated OPERABLE:

- NOTE - -

Not required to be met for system vent flow paths opened under administrative control.

a.

At the frequency specified in the Surveillance Frequency Control Program by verifying each containment spray manual, power operated, and automatic valve in the spray train flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

b.

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.

c.

At the frequency specified in the Surveillance Frequency Control Program 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.

d.

At the frequency specified in the Surveillance Frequency Control Program by verifying each containment spray pump starts automatically on an actual or simulated actuation signal.

e.

By verifying each spray nozzle is unobstructed following activities that could cause nozzle blockage.

f.

At the frequency specified in the Surveillance Frequency Control Program by verifying the Containment Spray System locations susceptible to gas accumulation are sufficiently fi1led with water.

4.6.2.1.2 Each containment ail' recirculation and cooling unit shall be demonstrated OPERABLE:

a.

At the frequency specified in the Surveillance Frequency Control Program by operating each containment air recirculation and cooling unit in slow speed for 2: 15 minutes.

b.

At the frequency specified in the Surveillance Frequency Control Program by verifying each containment air recirculation and cooling unit cooling water flow.

rate is 2: 500 gpm.

c.

At the frequency specified in the Surveillance Frequency Control Program by verifying each containment air recirculation and cooling unit starts automatically on an actual or simulated actuation signal.

MILLSTONE ~ UNIT 2 314 6-13 Amendment No. ;!-1-S-, '-* W, m,

~325

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION* HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION ACTION:

With no shutdown cooling train OPERABLE or in operation, perform the following actions:

a.

Immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1 and the loading of irradiated fuel assemblies in the core; and

b.

Immediately initate action to restore one shutdown cooling train to OPERABLE status and operation; and

c.

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> place the containment penetrations in the following status:

1.

Close the equipment door and secure with at least four bolts; and

2.

Close at least one personnel airlock door; and

3.

Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be closed with a manual or automatic isolation valve, blind flange, or equivalent.

SURVEILLANCE REQUIREMENTS 4.9.8. 1.1 One shutdown cooling train shall be verified to be in operation and circulating reactor coolant at a flow rate greater than or equal to l 000 gpm at the frequency specified in the Surveillance Frequency Control Program.

4.9.8.1.2 Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE" UNIT 2 3/4 9-8a Amendment No..++, -!-&§, ~. ~.

~.' 325

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION" LOW WATER LEVEL LIMITING CONDITION FOR OPERATION (continued)

c.

Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be closed with a manual or automatic isolation valve, blind flange, or equivalent.

SURVEILLANCE REQUIREMENTS 4.9.8.2.1 One shutdown cooling train shall be verified to be in operation and circulating reactor coolant at a flow rate greater than or equal to 1000 gpm at the frequency specified in the Surveillance Frequency Control Program.

4.9.8.2.2 The required shutdown cooling pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power available.

4.9.8.2.3 Locations susceptible to gas accumulation in the required shutdown cooling trains shaU be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE

• UNIT 2 314 9~8c Amendment No.~.~ 325

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DOMINION NUCLEAR CONNECTICUT, INC.

DOCKET NO. 50-423 MILLSTONE POWER STATION, UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERA TING LICENSE Amendment No. 267 Renewed License No. NPF-49

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Dominion Nuclear Connecticut, Inc. dated January 15, 2015, as supplemented by letters dated April 15, July 16, July 30, November 2, and December 1, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

• C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-49 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 267 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. DNC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of issuance, and shall be implemented within 90 days of issuance.

Attachment:

Changes to the License and Technical Specifications Date of Issuance: January 29, 2016 FOR THE NUCLEAR REGULA TORY COMMISSION Travis L. Tate, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 267 RENEWED FACILITY OPERATING LICENSE NO. NPF-49 DOCKET NO. 50-423 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Insert 4

4 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert 3/4 4-4 3/4 4-4 3/4 4-5a 3/4 4-5a 3/4 4-6a 3/4 4-6a 3/4 5-4 3/4 5-4 3/4 9-8 3/4 9-8 3/4 9-9 3/4 9-9 (2)

Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 267 and the Environmental Protection Plan contained in Appendix 8, both of which are attached hereto are hereby incorporated into the license. DNC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

DNC shall not take any action that would cause Dominion Resources, Inc.

(ORI) or its parent companies to void,. cancel, or diminish DNC's Commitment to have sufficient funds available to fund an extended plant shutdown as represented in the application for approval of the transfer of the licenses for MPS Unit No. 3.

(4)

Immediately after the transfer of interests in MPS Unit No. 3 to.ONG, the amount in the decommissioning trust fund for MPS Unit No. 3 must, with respect to the interest in MPS Unit No. 3, that DNC would then hold, be at a level no less than the formula amount under 10 CFR 50.75.

(5)

The decommissioning trust agreement for MPS Unit No. 3 at the time the transfer of the unit to DNC is effected and thereafter is subject to the following:

(a)

The decommissioning trust agreement must be in a form acceptable to ttie NRC.

(b)

With respect to the decommissioning trust fund, investments in the securities or other obligations of Dominion Resources, Inc. or its affiliates or subsidiaries, successors, or assigns are prohibited.

Except for investments tied to market inde~es or other non-nuclear-sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.

(c).

The decommissioning trust agreement for MPS Unit No. 3 must provide that no disbursements or payments from the trust, other than for ordinary administrative expenses, shall be made by the trustee until the trustee has first given the Director of the Office of Nuclear Reactor Regulation 30 days prior written notice of payment. The decommissioning trust agreement shall further contain a provision that no disbursements or payments from the trust shall be made if the trustee receives prior written notice of objection from the NRC.

(d)

The decommissioning trust agreement must provide that the agreement cannot be amended in any material respect without 30 days prior written notification to the Director of the Office of Nuclear Reactor Regulation.

Renewed License No. NPF-49 Amendment No. 267

REACTOR COOLANT SYSTEM HOT SHUTDOWN.

LIMITING CONDITION FOR OPERATION (continued)

b.

With less than the above required reactor coolant Joops in operation and the Control Rod Drive System is capable of rod withdrawal, within l hour open the

• Reactor Trip System breakers.

c.

With no loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO 3.1.1.1.2 and immediately initiate corrective action to return the required loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump(s), if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying secondary side water level to be greater than or equal to 17% at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.3.3 The required loop(s) shall be verified in operation and circulating reactor coolant at the frequency specified in the SurveilJance Frequency Control Program.

- - - - NOTE - - -

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.

4.4.1.3.4 Locations susceptible to gas accumulation in the required RHR trains shall be verified to be suffic.iently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNIT 3 3/44A Amendment No. W, +9+, ~. ~

267

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION ACTION:

a.

With less than the required RHR loop(s) OPERABLE or with less than the required steam generator water level, immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status or restore the required steam generator water level as soon as possible.

h.

With no RHR loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SOM of LCO 3.1.1.1.2 and immediately initiate corre~tive action to return the required RHR loop to operation.

SURVEILLANCE REQUJREMENTS 4.4. 1.4.1.1 The secondary side water level of at least two steam generators when required si1all be determined to be within limits at the frequency specified in the Surveillance Frequency Control Program.

4.4. l.4. l.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at the.frequency specified in the Surveillance Frequency Control Program.

4.4.1.4.1.3 The required pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power availability.

4.4.1.4. l.4 Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNJT 3 Amendment No. +-5+,.J-9'.7, ~. m 267

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED SURVEILLANCE REQUIREMENTS 4.4.1.4.2.1 The required pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power availability.

4.4.1.4.2.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.4.2.3 Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

MILLSTONE - UNIT 3 3/4 4-6a Amendment No. Hf, 9+, ~

267

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2

a.

b.

Each ECCS subsystem shall be demonstrated OPERABLE:

At the frequency specified in the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position 3SIH*MV8806 RWST Supply to SI Pumps OPEN 3SIH*MV8802A SI Pump A to Hot Leg Injection CLOSED 3SIH*MV8802B SI Pump B to Hot Leg Injection CLOSED 3SIH*MV8835 SI Cold Leg Master Isolation OPEN 3SIH*MV8813 SI Pump Master Miniflow Isolation OPEN 3SIL *MV8840 RHR to Hot Leg Injection CLOSED 3SIL *MV8809A RHR Pump A to Cold Leg Injection OPEN 3SIL *MV8809B RHR Pump B to Cold Leg Injection OPEN At the frequency specified in the Surveillance Frequency Control Program by:

1)

Verifying that the ECCS piping locations susceptible to gas accumulation, except for the operating centrifugal charging pump(s) and associated piping, the RSS pump, the RSS heat exchanger and associated piping, are

. sufficiently filled with water, and

- NOTE - -

Not required to be met for system vent flow paths opened under administrative control.

2)

Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

c.

By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1)

For all accessible areas of the containment prior to establishing CONTAINMENT fNTEGRITY, and

2)

At least once dai1y of the areas affected (during each day) within containment by containment entry and during the final entry when CONTAINMENT rNTEGRITY is established.

d.

At the frequency specified in the Surveillance Frequency Control Program by:

l)

Verifying automatic interlock action of the RHR System from the Reactor Coolant System by ensuring that with a simulated signal greater than or equal to 412.5 psia the interlocks prevent the valves from being opened.

MILLSTONE - UNIT 3 3/4 5-4 Amendment No. &G, :/-9, w.B, ~. W,.

~.~.~267

REFUELING OPERATIONS 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is greater than or equal to 23 feet.

ACTION:

With no RHR loop OPERABLE or in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.l.l and suspend loading irradiated fuel assemblies in the core and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8. l. l At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2800 gpm at the frequency specified in the SurveiHance Frequency Control Program.

4.9.8. l.2 Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

• The RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period, provided no operations are permitted that could cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9. l. l.

MILLSTONE - UNIT 3 3/4 9-8 Amendment No...J:.W, BG,~ 267

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one RHR loop shall be in operation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.

ACTION:

a.

With less than the required RHR loops OPERABLE, immediately initiate corrective action to return the required RHR loops to OPERABLE status, or to establish greater than or equal to 23 feet of water above the reactor ves~el flange, as soon as possible.

b.

With no RHR loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3. 9. !. I and immediately initiate corrective action to return the required RHR loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.9.8.2.1 At least one RHR loop shall be verified in operation and circulating reactor coolant at a flow rate of greater than or equal to 2800 gpm at the frequency specified in the Surveillance Frequency Control Program.

4.9.8.2.2 Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

• The RHR loop may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period, provided no operations are permitted that could cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.1.

MILLSTONE - UNIT 3 3/4 9-9 Amendment No.~' m, ~

267

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 325 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-65 AND AMENDMENT NO. 267 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

DOCKET NOS. 50-336 AND 50-423 MILLSTONE POWER STATION, UNIT NOS. 2 AND 3

1.0 INTRODUCTION

By application dated January 15, 2015 (Reference 1 ), as supplemented by letters dated April 15, July 16, July 30, November 2, and December 1, 2015 (References 2, 3, 4, 5, and 6, respectively), Dominion Nuclear Connecticut, Inc. (DNC, the licensee), submitted to the U.S. Nuclear Regulatory Commission (NRC, the Commission) a license amendment request (LAR) for changes to the Millstone Power Station, Unit 2*and 3 (MPS2 and MPS3). Specifically, the licensee requested to adopt NRG-approved Technical Specifications Task Force (TSTF)

Standard Technical Specifications (STS) Change Traveler TSTF-523, Revision 2, "Generic Letter [GL] 2008-01, Managing Gas Accumulation" (Reference 7). 1 The proposed change would revise surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS). The proposed change would also add new SRs related to gas accumulation for the shutdown cooling and containment spray (CS) systems (MPS2) and the residual heat removal (RHR) system (MPS3). The Technical Specification (TS) Bases changes associated with these SRs would also be made accordingly.

The January 15, 2015, application, as modified by the supplemental letter dated April 15, 2015, was noticed in the Federal Register on July 21, 2015 (80 FR 43126). The supplemental letters dated July 16, July 30, November 2, and December 1, 2015, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.

1 The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700) as part of the consolidated line item improvement process (CLllP).

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance which the NRC staff considered in assessing the proposed TS change are as follows:

The regulations in Appendix A to Title 1 O of the Code of Federal Regulations (1 O CFR) Part 50 or similar plant-specific principal design criteria provide design requirements.2 Appendix B to 1 O CFR Part 50, the TSs, and licensee quality assurance programs provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems inelude:

General Design Criterion (GDC) 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards.

GDC 34 requires a AHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs simultaneous with failure of specified electrical power systems.

GDCs 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements.

GDCs 38, 39, and 40 require a containment heat removal (CHA) system design that meets performance, inspection, and testing requirements.

Applicable quality assurance criteria provided in Appendix B to 1 O CFR Part 50 include:

Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions.

Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have peen satisfied.

Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

2 The Atomic Energy Commission (AEC) published the rule that added 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971, with the rule becoming effective on May 21, 1971. Appendix A was not applied to plants with construction permits issued prior to May 21, 1971. Such plants were licensed in accord with. principal design criteria that are generally similar to Appendix A requirements.

Additionally, th~ regulations in 1 O CFR 50.46 provide specified EGGS performance criteria.

The. NRC's regulatory requirements related.to the content of the TSs are contained in 1 O CFR 50.36(c). The regulations at 10 CFR 50.36 require that the TSs include items in the following categories: ( 1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility

. operation will be within safety limits, and that the LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33 identifies instructions for filling and venting the EGGS and decay heat removal (DHR) system, as well as for draining and refilling heat exchangers. STSs and most licensee TSs include SRs to verify that at least some of the subject systems' piping is filled with water.

The NRG staff model safety evaluation (SE) dated December 23, 2013 (Reference 8) for adoption of TSTF-523 changes was written for plants licensed to the GDC which are referenced in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (SAP). The NRG staff recognizes that the SAP is not the regulatory basis of the proposed TS changes, and the licensee is not required to confirm that the SAP guidance is applicable to MPS2 and MPS3. With respect to conformance with the GDC for MPS2, the licensee stated:

The construction permits for MPS2 were issued prior to May 21, 1971; consequently, MPS2 was not subject to current GDC requirements (SECY-92-223, dated September 18, 1992). Since February 20, 1971, MPS2 has attempted to comply with the intent of the newer GDC to the extent possible, recognizing previous design commitments. MPS2's [final safety analysis report]

FSAR Section 1.A "AEC General Design Criteria for "Nuclear Power Plants,"

• provides an assessment against the 1 O CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants". A review has determined that the MPS2 plant-specific requirements are sufficiently similar to the Appendix A, GDC as related to the proposed change. Therefore, the proposed change is applicable to MPS2.

With respect to conformance with the GDC for MPS3, the licensee stated its application dated January 15. 2015 (Reference 1 ):

MPS3 is not licensed to the current 10 CFR 50, Appendix A, GOG. MPS3's

[updated final safety analysis report] UFSAR, Section 3.1 "Design Of Structures, Components, Equipment, And Systems," provides an assessment against the 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants" as amended through 1978. A review has determined that the MPS3 plant-specific requirements are sufficiently similar to the Appendix A, GDC as related to the proposed change. Therefore, the proposed change is applicable to MPS3.

The NRC staff agrees with the licensee's assessment above. The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants," for MPS2 and NUREG-1431, "Standard Technical Specifications Westinghouse Plants" for MPS3.

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of the SRP.

Revision 3 of SRP, Section 6.2.2, "Containment Heat Removal Systems," dated March 2007 (Reference 14), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

Revision 3 of SRP, Section 6.3, "Emergency Core Cooling System," dated March 2007 (Reference 15), provides the procedures concerning the review of ECCS to help ensure compliance with GDC 35, 36, and 37.

Revision 5 of SRP, Section 5.4.7, "Residual Heat Removal (RHR) System," dated May 201 O (Reference 16), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system (RCS) during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

3.1 Background

Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in January 2008 to address the issue of gas accumulation in ECCS, OHR, and CS systems (Reference 9). The industry and NRC staff agreed that a change to the STS and plant-specific TS would be necessary to address some issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the MPS2 and MPS3 TSs using a plant-specific adoption of the TSTF-523 changes.

3.2 NRC Staff Review of the Proposed TS Changes 3.2.1 MPS2 TS Changes The licensee stated that it has reviewed the information contained in the model SE dated December 23, 2013 (Reference 8) and that the LAR is consistent with NRG-approved TSTF 523. Changes were proposed for SRs 4.5.2.a, 4.5.3.1, 4.6.2.1.a, 4.9.8.1 as well as the addition of new SRs 4.4.1.3.4, 4.4.1.4.4, 4.4.1.5.3, 4.5.2.1, 4.6.2.1.1.f, 4.9.8.1.2 and 4.9.8.2.3 to TS 3.4.1.3, "RCS Hot Shutdown," TS 3.4.1.4, "RCS - Cold Shutdown - Loops Filled,"

TS 3.4.1.5, "RCS - Cold Shutdown - Loops Not Filled," TS 3.5.2, "ECCS Subsystems - Tavg 2:300°F," TS 3.5.3, "EGGS Subsystems - Tavg<300°F," TS 3.6.2, "Depressurization and Cooling Systems - Containment Spray and Cooling Systems," TS 3.9.8.1, "Refueling Operations

- Shutdown Cooling and Coolant Circulation - High Water Level," and TS 3.9.8.2, "Refueling Operations - Shutdown Cooling and Coolant Circulation - Low Water Level," respectively.

In the LAA, the licensee proposed two deviations from the TS changes described in TSTF-523, Revision 2. In the first deviation, the licensee initially proposed a specific surveillance frequency of 92 days for the associated MPS2 SRs which is different from the 31-day surveillance frequency per the STS SRs added or modified by TSTF-523.

On October 29, 2015, the NRG issued License Amendment No. 324 for Millstone Power Station, Unit 2 ( Reference 17) approving MPS2 adoption of TSTF-425, Revision 3, "Relocate Surveillance Frequencies to a License Control - [Risk-Informed Technical Specification Task Force (RITSTF)] Initiative Sb." This approval allowed the licensee to relocate most periodic frequencies of TS surveillances to a licensee-controlled Surveillance Frequency Control Program (SFCP).

The licensee submitted a supplemental letter dated December 1, 2015 (Reference 6), to incorporate the MPS2 surveillance frequencies proposed in the January 15, 2015, LAA into the approved SFCP. Specifically, the licensee provided TS pages to replace the specific surveillance frequency wording for the MPS2 SRs "at least once per 92 days" with "at the frequency specified in the Surveillance Frequency Control Program." Consistent with TSTF-523, Revision 2, frequencies of the SRs related to management of gas accumulation are permitted to be in accordance with an SFCP. However, the NRG staff completed its review of the proposed deviation prior to the December 1, 2015, supplement, the evaluation of which is discussed in Section 3.3 of this SE.

Regarding the second deviation, the licensee proposed changes to the MPS2 TSs using different numbering and titles than the STS. TSTF-523 and the NRG staff model SE (Reference 8) were based on the STS. The licensee uses custom TSs for MPS2. The proposed deviations are considered administrative differences (i.e., number and title formatting) by the NRG staff and do not affect the applicability of TSTF-523 to the MPS2 TSs.

The proposed amendment adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants" by TSTF-523.

The NRG staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 1 O CFR 50.36(c). The licensee proposed the following TS changes for MPS2 in it's application dated December 1, 2015 (Reference 6):

( 1)

Add SR 4.4.1.3.4, which states:

Locations susceptible to gas accumulation in.the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

A note is also added that states Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.

(2)

Add SR 4.4.1.4.4, which states:

Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

(3)

Add SR 4.4.1.5.3, which states:

Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program."

(4)

Add a note to the requirement related to valve positions that each ECCS subsystem shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program. The note in SR 4.5.2.a, states:

Not required to be met for system vent flow paths opened under administrative control.

(5)

Add SR 4.5.2.1, which states:

At the frequency specified in the Surveillance Frequency Control Program by verifying that ECCS locations susceptible to gas accumulation are sufficiently filled with water.

As well as adding SR 4.5.2.1 to the list of SR's that must be met for SR 4.5.3.1.

{6)

Add a note to the requirement related to valve positions that each CS spray train shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program. The note in SR 4.6.2.1.1, states:

Not required to be met for system vent flow paths opened under administrative control.

{7)

Add SR 4.6.2.1.1.f, which states:

At the frequency specified in the Surveillance Frequency Control Program by verifying the Containment Spray System locations susceptible to gas accumulation are sufficiently filled with water.

(8)

Renumber SR 4.9.8.1 to 4.9.8.1.1 and add SR 4.9.8.1.2, which states:

Locations susceptible to gas accumulation in the required shutdown cooling trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

(9)

Add SR 4.9.8.2.3, which states:

Locations susceptible to gas accumulation in the required shutdown cooling)rains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (Reference 18). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function.3 Therefore the phrase, "sufficiently filled with water was recommended for the proposed TS changes. In the TS, "sufficiently filled with water is understood to mean "sufficiently filled with water to support Operability." The regulation at 1 O CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language is acceptable since this language.will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4 is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules, the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

• The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR.

Therefore, these notes are acceptable.

The NRC staff determined that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds that the proposed changes to MPS2 TSs are acceptable.

3 Operability determination process and functionality assessments for conditions adverse to quality and safety are described in NRG Inspection Manual Chapter 0326 (Reference 12).

3.2.2 MPS3 TS Changes As discussed above for MPS2, the licensee stated that it has reviewed the information contained in the model SE dated December 23, 2013 (Reference 8) and* that the LAA is consistent with NRG-approved TSTF 523. Changes were proposed for SRs 4.5.2.b.1, 4.5.2.b.2, as well as the addition of new SRs 4.4.1.3.4, 4.4.1.4.1.4, 4.4.1.4.2.3, 4.9.8.1 ;2 and 4.9.8.2.2 to TS 3.4.1.3, "RCS - Hot Shutdown," TS 3.4.1.4.1, "RCS - Cold Shutdown-Loops Filled," TS 3.4.1.4.2, "RCS - Cold Shutdown, Loops Not Filled," TS 3.5.2, "ECCS Subsystems - Tavg Greater Than Or Equal To 350°F," TS 3.5.3, "ECCS Subsystems - Tavg Less Than 350°F,"

TS 3.9.8.1, "Residual Heat Removal and Coolant Circulation - High Water Level," and TS 3.9.8.2, "Residual Heat Removal and Coolant Circulation - Low Water Level," respectively.

The proposed amendment adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1431, "Standard Technical Specifications Westinghouse Plants" by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36(c). The licensee proposed the following TS changes for MPS3 in its application dated January 15, 2015 (Reference 1 ):

(1)

Add SR 4.4.1.3.4, which states:

Locations susceptible to gas accumulation in the required AHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

A note is also added that states Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4.

(2)

Add SR 4.4.1.4.1.4, which states:

Locations susceptible to gas accumulation in the required AHR trains

, shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

(3)

Add SR 4.4.1.4.2.3, which states:

Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program."

(4)

Revise the language for SR 4.5.2.b.1 to state:

Verifying that the ECCS piping locations susceptible to gas accumulation, except for the operating centrifugal charging pump(s) and associated piping, the ASS pump, the RSS heat exchanger and associated piping, are sufficiently filled with water; and (5)

Add a note to SR 4.5.2.b.2, which states:

Not required to be met for system vent flow paths opened under administrative control.

(6)

Renumber SR 4.9.8.1 to 4.9.8.1.1 and add SR 4.9.8.1.2, which states:

Locations.susceptible to gas accumulation in the required. RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.

(7)

Renumber SR 4.9.8.2 to 4.9.8.2.1 and add SR 4.9.8.2.2, which states:

Locations susceptible to gas accumulation in the required RHR trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program."

The licensee deviated from the TSTF-523 approved changes by not proposing new SRs for the containment quench spray system (QSS) and the recirculation spray system (RSS). The NRG staff review of this deviation is discussed in Section 3.3 of this SE.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRG discussion contained in TIA 2008-03. The staff's assessment of the proposed TS changes as a result of licensee responses to the GL *and the TIA conclusion is discussed in Section 3.2.1 of this SE. The regulation at 1 O CFR 50.36(c){3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4 is acceptable because the note provides a limited time to perform the Surveillance after entering the Applicability of the LCO; however, under the STS usage rules the requirement to manage gas accumulation is not affected. Licensees must have confidence that the SR can be met or the LCO must be declared not met.

The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual.action to close the system vent flow path in order to maintain system operability during system venting and performance of the proposed gas accumulation SR.

Therefore, these notes are acceptable.

Similar to the proposed changes for MPS2, the licensee also proposed a deviation to the MPS3 TSs using different numbering and titles than the STS. TSTF-523 and the NRG staff model SE (Reference 8) were based on the STS. The licensee uses custom TSs for MPS3. The proposed deviations are considered administrative differences (i.e., number and title formatting) by the NRG staff and do not affect the applicability of TSTF-523 to the MPS3 TSs.

The NRC staff determined that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds that the proposed changes to MPS3 TSs are acceptable.

3.3 NRC Staff Technical Review The principal technical areas that the NRC staff reviewed are (1) the proposed MPS2 SR frequency of 92 days versus the TSTF-523 specified SR frequency of 31 days, and (2) the omission of the MPS3 Containment QSS, RSS, and aspects of the centrifugal charging pump (CCP) system from the SRs proposed in TSTF-523.

3.3.1 Assessment of MPS2 92-day Surveillance Frequency As stated above, DNC initially proposed an existing surveillance frequency of 92 days as opposed to adopting the 31 days described in TSTF-523 Revision 2 (Reference 7). DNC qualified the frequency by stating that the surveillance frequency of an affected location is increased in the event of discovery of a gas intrusion mechanism or a failed surveillance, and returned to 92 days upon resolution of the issue. Approximately 24 (92-day) surveillances at 27 locations have been performed on each train and approximately 108 follow-up surveillances have been conducted.

MPS2 surveillances where voids were discovered have been summarized from DNC information in the following table. The as-left conditions are water-solid unless otherwise identified. If not listed, then the surveillance did not identify a void.

Date Void Void I Allowable, Location Surveillance Comments No.

ff1 03/09/10 1

0.341/2.57 CS discharqe, Point 26 92 day Outgassing alter shutdown cooling 03/16/10 2

0.022 / 0.128 LPSI discharqe, Point 20 termination following refueling outage 3

0.046 I 0.244 LPSI discharQe, Point 21 (RFO) 4 0.042 I 0.129 LPSI discharQe, Point 22 5

0.011 / 0.147 LPSI discharqe, Point 23 06/08/10 6

0.024 /0.128 LPSI discharQe, Point 20 7

0.012 I 0.244 LPSI discharqe, Point 21 06/22110 8

0.123/2.57 CS discharQe, Point 26 08/17/10 9

0.088 /2.57 CS discharQe, Point 26 08/31/10 10 0.005/0.129 LPSI discharqe, Point 22 11 0.005 I 0.147 LPSI discharge, Point 23 12/20/10 12 0.013 / 0.128 LPSI discharge, Point 20 13 0.060 I 0.244 LPSI discharge, Point 21 14 0.011 I 0.147 LPSI discharqe, Point 23 02/15/11 15 0.026/0.128 LPSI discharae, Point 20 01/03/12 16 0.059 /0.207 HPSI discharge, Point Improper fill and vent after maintenance 11 01/18/12 17 0.037 /0.129 LPSI discharge, Point 22 Degassinq 12/18/12 18 0.049 /0.334 HPSI suction, Point 5 Improper fill and vent alter maintenance 02/26113 19 0.341 /2.57 CS discharqe, Point 26 Deqassina 05/21/13 20 6.557 I 2.57 CS discharae, Point 26 Accumulator leakaqe 05/22/13 21 0.088 0.161 /

CS discharge, Point 26 See Surveillance due to accumulator thru 2.57 comments monitoring daily first week, weekly for 03131/14 next 46 weeks. Corrected in next RFO.

08/13/13 22 0.161 /2.57 CS discharge, Poii;it 26 92 days Per Reference 5, source was safety injection tank back leakage across multiple valves in the B train CS Date Void Void I Allowable, Location Surveillance Comments No.

ff discharge header (void information was originally submitted by licensee as part of 5122/13 thru 3/31/14 groupinal.

05/16/14 23 0.006 / 0.128 LPSI discharge, Point 20 92 days Outgassing after shutdown cooling 24 0.025 I 0.244 LPSI discharge, Point 21 termination following RFO.

24 0.027 /0.129 LPSI discharge, Point 22 26 0.042 I 0.147 LPSI discharge, Point 23 27 0.343/ 2.57 CS discharqe, Point 25 Improper fill and vent after RFO.

28 5.286 I 2.57 CS dischame, Point 27 05/17/14 29 0.031 /2.57 CS discharge, Point 25 See Follow-up surveillance of other train comments after 05/16/14 improper fill and vent after RFO.

07/28/14 30 0.036/0.128 LPSI discharae, Point 20 92 days Outgassing after shutdown cooling 31 0.122 /0.129 LPSI discharoe, Point 22 termination following RFO.

32 0.015/0.147 LPSI discharge, Point 23 10/23/14 33 0.013/0.128 LPSI discharge, Point 20 Outgassing after shutdown cooling 34 0.069 I 0.244 LPSI discharge, Point 21 termination following AFO.

35 0.048 I 0.129 LPSI discharge, Point 22 36 0.025 I 0.147 LPSI discharge, Point 23 10/31/14 37 0.010/0.128 LPSI discharge, Point 20 Outgassing after shutdown cooling 38 0.006 / 0.129 LPSI discharge, Point 22 termination following RFO.

39 0.025 / 0.147 LPSI discharge, Point 23 01/16/15 40 0.007 I 0.244 LPSI discharge, Point 21 Outgassing after shutdown cooling termination following RFO.

04/06/15 41 0.026 / 0.128 LPSI discharge, Point 20 Outgassing after shutdown cooling 42 0.037 I 0.129 LPSI discharge, Point 22 termination following RFO.

43 0.030 I 0.147 LPSI discharge, Point 23 05/16/14 44 CS discharge, Point 27 See Part of piping can't be vented due to Comments pipe slope. Improper fill and vent identified.

05/19/14 45 0.071 - 0.161 I 2.57 CS discharge, Point 27 See Outgassing after shutdown cooling through comments termination following RFO.

06/15/15 Surveillances daily then bi-weekly in

(

response to 05/16/14.

06/29/15 46 0.017 /0.128 LPSI discharqe, Point 20 92 days Outgassing after shutdown cooling 47 0.002 /0.244 LPSI discharqe, Point 21 termination following RFO.

48 0.020 /0.147 LPSI discharoe, Point 23 49 0.025 I 2.57 CS discharge, Point 27

• OL.itgassing after shutdown cooling termination following RFO. Part of piping can't be vented due to pipe slope.

Of 49 void discovery entries, 34 occurred at the four-six-inch cold leg low pressure safety injection (LPSI) discharge header lines at ultrasonic testing points 20 through 23 just before joining with the high pressure safety injection (HPSI) lines outside containment and 12 occurred in the CS pump discharge headers just prior to the containment penetrations. The one pump suction side void that was reported was significantly smaller than the void size that was reported to. cause a loss of operability (0.049 ft3 versus 0.334 ft3, respectively).

Two 92-day surveillances identified voids that exceeded operational acceptance criteria and one was close. These were as follows:

Date Void I Allowable, ft3 Location Comments 05/21/13 6.557 I 2.57 CS discharge, Point 26 Accumulator leakage 05/16/14 5.286 I 2.57 CS discharge, Point 27 Improper fill and vent after RFO.

07/28/14 0.122 I :0.129 LPSI discharge, Point 22 See following discussion The scenario that resulted in the May 21, 2013, void actually was identifie.d on November 11, 2012, when daily safety injection tank (SIT) level monitoring identified a decreasing tank level.

Ultrasonic testing of HPSI and LPSI lines at the containment penetrations did not reveal a problem. Leakage through three closed valves in series into the CS discharge header was not considered credible and the licensee concluded the leakage was going to the refueling water storage tank (RWST). It was not until the next 92-day scheduled surveillance on May 21, 2013, that the CS void was identified. This was considered to be a missed opportunity to recognize the leakage path and the SIT monitoring procedure has been revised to require ultrasonic testing at the containment penetrations for the CS discharge headers.

DNC concluded that a portion of the total void on July 28, 2014, was due to a residual air void that migrated to this high point over time by itself or was aided during the quarterly LPSI pump run. As a result of lessons learned from the May 16, 2014, and July 28, 2014, void discoveries,*

a gas accumulation surveillance procedure is required to be performed quarterly and prior to plant heat up from a refueling out.age or if any portion of the ECCS is drained for maintenance during a forced outage.

The only large void volumes that occurred were three occurrences in discharge pipes. Such voids are of less concern than suction pipe voids since discharge pipe voids do not typically cause a loss of function. Further, DNC modified its procedures as a result of lessons learned from these void discoveries. For these reasons, the NRC staff finds the DNC 92-day surveillance frequency, as originally proposed, to be acceptable.

As discussed, in Section 3.2.1 of this SE, DNC submitted a supplement dated December 1, 2015 (Reference 6), to incorporate the surveillance frequencies originally proposed in the LAR into the SFCP, which was approved by NRC License Amendment No. 324 for MPS2 (Reference 17). The NRC staff determined that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and* that the LCO will be met. Therefore, the NRC staff finds that the proposed changes to MPS2 TSs are acceptable.

3.3.2 Assessment of 12 Hour Stipulation Notes were added to selected TSs that stated that locations susceptible to gas accumulation in specified systems did not have to be verified to be sufficiently filled with water in accordance with surveillance requirements until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4. This is in recognition of conditions that may exist during a rapid shutdown where performing the surveillance in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> could delay and exacerbate operator response to the transient. Therefore, the NRC staff finds the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> stipulation to be acceptable.

3.3.3 Assessment of Open Vent Path Certain operability requirements may not be met if vent valves are open. Addition of a note that states "Not required to be met for system vent flow paths opened under administrative control" is provided in recognition of the conduct of surveillances that would otherwise violate operability requirements. The qualifications provided in the bases that "the administrative controls are proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators in the control room" and "This individual will have a method to rapidly close the system vent flow path if directed" will result in restoration of system integrity consistent with operability requirements. Therefore, the NRC staff finds this is acceptable.

3.4 Other Considerations Applicable to the LAR 3.4.1 Froude Number Froude number is defined as:

where:

u NFR=-

fii5 u =water velocity based on pipe diameter, fVsec g = gravitational constant = 32.2 fVsec2 D =pipe diameter, ft In Reference 11, the NRC staff stated that use oJ dynamic venting is an effective means to remove gas from local high points and traps in piping when correctly based on the dynamic flow rate, void volume, Froude number, and the system water volume. Froude numbers that are consistent with the NRC acceptance criteria were provided in the following table:

NFR Effect

> 0.54 Gas will move toward the downstream end of a horizontal pipe that has no local high points. Some bubbles may move downward in a vertical pipe.

< 0.8 Dynamic venting is not effective.

0.8 < NFR < 2.0 Time to clear gas is a function of flow rate and piping geometry.

Timing is not well characterized.

1 Gas will be removed from an inverted "U" tube heat exchanger for steady state flow lasting several minutes. This criterion is not applicable at the bottom of vertical pipe that connects to a horizontal pipe.

2.0 All gas will be removed from a pipe but localized gas pockets may remain where full flow conditions may not exist such as in the vicinity of valves or orifices.

The DNC response to GL 2008-01 states that a Froude number> 0.70 will remove gas from piping. The DNC qualified the inconsistency with the above table by stating that, at the time of the GL responses, NFR was based on a 1998 Creare Inc. report. This is no longer the case.

Locations where dynamic*venting is credited have NFR > 0.8, most are ;;;: 1.0 and some are

2.0. A comprehensive list identified 0.94 :5 NFR ::::; 12.22 with.flush times that are judged acceptable in conjunction with the surveillance requirements and pipe orientations that are consistent with the NRC staff criteria. Therefore, the staff finds the licensee's use of NFR is acceptable.

3.4.2 Exclusions of MPS3 equipment from SRs The staff finds that the DNC approach to excluding the ass, aspects of the RSS, and aspects*

of the CCP system are consistent with the MPS3 response to GL 2008-01 (Reference 10).

The MPS3 ass is excluded from SRs because there are no identified gas intrusion mechanisms, piping is gravity filled from the RWST to an equivalent level in the piping headers located inside containment, the remainder of the vertical headers and the spray rings are

• maintained dry, and pipe slopes are self-venting to the RWST or to the ass pump. Once filled, the pump on each train is run with pipe Froude numbers of 1.60 and 2.00. Pump tests are repeated quarterly. Therefore, the ass piping is free of potential gas voids and a routine surveillance to verify the ass piping locations susceptible to gas accumulation are sufficiently filled with water is unnecessary.

The MPS3 operating CCPs, associated pump piping, the RSS pump, the RSS heat exchanger, and associated RSS piping are generally excluded from SRs because the RSS suction piping and the containment emergency sump are maintained dry, the pumps are self-venting to the discharge piping, and the discharge piping, which includes the coolers, is maintained dry and will self-vent through the CS header nozzles following pump start. Some lines associated with the CCPs that are not operating have the potential to collect gas. These are vented every 31 days. DNC also noted that an orifice design modification was incorporated into the bypass lines in circa 2001 that was shown to eliminate gas accumulation.

Therefore, the NRG staff finds the licensee's justification for excluding these systems from MPS2 SRs as discussed above are acceptable.

3.4.3 Monitoring Between Surveillance Intervals Accumulator and SIT levels4 are monitored daily and, if level decreases, vulnerable ECCS and CS piping locations are inspected. The response and monitoring frequency for off gassing due to RCS leakage or due to a malfunction associated with the chemical sampling system is not pre-defined. As stated by the licensee in its November 2, 2015, letter (Reference 5), the licensee's response to exceeding RCS leakage requirements may involve ultrasonic testing for gas accumulation monitoring to determine the leakage path and a gas monitoring frequency would then be developed for problem areas until.the condition is corrected." With respect to the chemical sampling system, DNC identified connections where the system connected to other piping and discussed dynamic sweeping and surveillance monitoring of the piping.

With respect to other equipment, malfunctions would be documented in a corrective action response and any gas voiding or accumulation would result in further investigation and resolution by the licensee.

DNC's daily monitoring of the SIT level and other monitoring of system parameters, such as those associated with RCS leakage, are considered by the NRG staff as acceptable to prevent void issues that would not otherwise be potentially identified by solely relying on a 92-day 4 "SIT" (safety injection tank) is used in MPS2 documentation; "accumulator" is used in conjunction with MPS3.

surveillance interval. Therefore, the NRC staff finds the licensee's detection, monitoring, trending, and procedural controls associated with the monitoring of system parameters for potential sources of gas accumulation in between surveillance intervals as described_ in its LAA and supplements are acceptable.

3.5 NRC Staff Conclusion

The NRC staff reviewed the proposed TS changes for MPS2 and MPS3 and determined that the proposed SRs meet the regulatory requirements of 1 O CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds the proposed TS changes are acceptable.

The NRC staff reviewed two principal technical issues: (1) the MPS2 specification of a 92-day SR frequency versus the TSTF-523 specified SR frequency of 31 days, and (2) the MPS3 omission of the ass and ASS from the SRs proposed in TSTF-523. The NRC staff finds the proposed MPS2 92-day SR frequency acceptable based on the surveillance history, application of lessons learned, and equipment monitoring as discussed above. Additionally, the staff finds the proposed omission of the MPS3 ass and ASS from the SRs proposed in TSTF-523 acceptable because the ASS suction piping and the containment emergency sump are" maintained dry, the pumps are self-venting to the discharge piping, and the discharge piping, which includes the coolers, is maintained dry and will self-vent through the CS header nozzles following pump start as discussed above.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Connecticut State official was notified of the proposed issuance of the amendments. The State official provided comments via e-mail on January 11, 2016. In brief, the State official's comments concerned an October 4, 2015, event at MPS2 that involved the licensee's identification and assessment of air voids in the shutdown cooling system, which the State official believed may not have been considered by the NRC staff in its review of the associated licensee RAI response. The State official also inquired whether the plant operators' practice of using a vacuum pump to remove entrained air from a plant system was applicable to the staff's review of the proposed license amendment request. The comments and questions from the State official were considered in the NRC staff's review. The NRC staff found the licensee's response adequately addressed the staff's RAls regarding void occurrences at MPS2. The NRC staff also determined that both matters raised by the State official are procedurally controlled in the licensee's plant procedures and do not impact the proposed Technical Specification surveillance requirements which were reviewed and determined to be acceptable by the NRC staff. Specifically, the licensee's procedures for the identification and removal of gas voids in piping/plant systems are not a Technical Specification requirement and are monitored and assessed through the NRC's reactor oversight process (ROP) inspections which, in part, would confirm that the scope of the licensee's plant procedures and administrative controls are adequate to control safety related operations within applicable regulatory requirements. Additionally, the NRC staff confirmed that the licensee has appropriately entered the issue as a performance deficiency into its corrective action program.

For the reasons stated above, the NRC staff finds that the concerns identified by the State official do not impa<:;t the staff's safety conclusions for the proposed license amendment; that is, there is reasonable assurance that the activities proposed in the LAR can be conducted without endangering the health and safety of the public and will be conducted in compliance with the Commission's regulations. The NRC staff's complete response to the State official's comments can be viewed in ADAMS at Accession No. ML16027A260 (Reference 18).

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register (FR) on July 21, 2015 (80 FR 43126), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22{b), no environmental impact statement or environmental assessment need be prepar.ed in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and {3) the issuance of the amendment will not be inimic(11 to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1.

Sartain, M. D., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Proposed License Amendment Requests to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation," dated January 15, 2015 {Agencywide Documents Access and Management System (ADAMS) Accession No. 'ML15021A128).

2.

Daugherty, J. R., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Supplement to License

• Amendment Request to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation," dated April 15, 2015 (ADAMS Accession No. ML15111A449).

3.

Sartain, M. D., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation (TAC No. MF5715 &

MF5716)," dated July 16, 2015 (ADAMS Accession No.. ML15202A125).

4.

Sartain, M. D., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation (TAC No. MF5715 &

MF5716)," dated July 30, 2015 (ADAMS Accession No. 'ML15216A365).

5.

Sartain, M. D., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Response to Second Request for Additional Information Regarding License Amendment Request to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation (TAC No: MF5715 &

MF5716)," dated November 2, 2015 (ADAMS Accession No. 'ML15313A024).

6.

Clark, G. C., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Unit 2, Supplement to License Amendment Request to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation," dated December 1, 2015 (ADAMS Accession No. 'ML15342A028}.

7.

Technical Specifications Task Force (TSTF) to NRG, "Standard Technical Specifications Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation,"" dated February 21, 2013 (ADAMS Accession No. ML13053A075).

8.

NRG Staff Safety Evaluation, "Model Safety Evaluation for Plant Specific Adoption of Technical Specifications Task Force Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," using the Consolidated Line Item Improvement Process," dated December 23, 2013 (ADAMS Accession No. ML13255A169).

9.

NRG Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008 (ADAMS Accession No. ML072910759).

10.

Price, J. A., Dominion Nuclear Connecticut, Inc., letter to U.S. Nuclear Regulatory Commission, "Millstone Power Station Units 2 and 3, Nine-Month Response to NRG Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated October 14, 2008 (ADAMS Accession No. ML082890266).

11.

NEl-09-10, "Guidelines for Effective Prevention and Management of System Gas Accumulation," Rev 1a-A, April 2013 (ADAMS Accession No. ML13136A129).

12.

NRG Inspection Manual Chapter 0326, "Operability Determinations & Functionality Assessment~ for Conditions Adverse to Quality or Safety," dated January 31, 2014 (ADAMS Accession No. ML13274A578).

13.

Sanders, C. J., NRG letter to Heacock, D. A., Dominion Nuclear Connecticut, Inc.,

"Millstone Power Station Unit Nos. 2 and 3 - Closeout of Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal and Containment Spray Systems (TAC Nos, MD7845 and MD7846)," dated March 2, 2011 (ADAMS Accession No. ML110540393).

-*18 -

14.

NRC Standard Review Plan, Revision 3, Section 6.2.2, "Containment Heat Removal Systems, dated March 2007 (ADAMS Accession No. ML070160661 ).

15.

NRC Standard Review Plan, Revision, Section 6.3, "Emergency Core Cooling System,"

dated March 2007 (ADAMS Accession No. ML070550068).

16.

NRC Standard Review Plan, Revision 5, Section 5.4.7, "Residual Heat Removal (RHR)

System," dated May 2010 (ADAMS Accession No. ML100680577).

17.

Guzman, R., NRC letter to Heacock, D. A., Dominion Nuclear Connecticut, Inc.,

"Millstone Power Station Unit No. 2 - Issuance of Amendment Re: Risk-Informed Justification for the Relocation o Specific Surveillance Frequency Requirements to a Licensee Controlled Program, Adoption of TSTF-425, Revision 3," in Emergency Core Cooling Decay Heat Removal and Containment Spray Systems (TAC NO. MF5096),"

dated October 29, 2015 (ADAMS Accession No. ML15280A242).

18.

Wert, L. D. Jr., Memo to Blount, T. B. "Task Interface Agreement - Emergency Core Cooling System (ECCS) Voiding Relative to Compliance with Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1 (TIA 2008-03), (ADAMS Accession No. ML082560209).

19.

E-mail from R. Guzman to J. Semancik, January 27, 2016 (ADAMS Accession No. ML16027A260).

Principal Contributors: W. Lyon M. Hamm Date: January 29, 2016

Mr. David A. Heacock President and Chief Nuclear Officer Dominion Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 January 29, 2016

SUBJECT:

MILLSTONE POWER STATION UNITS 2 AND 3 - ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)-

523, REVISION 2, GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION (CAC NOS. MF5715 AND MF5716)

Dear Mr. Heacock:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 325 to Renewed Facility Operating License No. DPR-65 and Amendment No. 267 to Renewed Facility Operating License No. NPF-49 for Millstone Power Station, Unit Nos. 2 and 3 (MPS2 and MPS3), in response to your application dated January 15, 2015, as supplemented by letters dated April 15, July 16, July 30, November 2, and December 1, 2015.

The amendments modify the Technical Specifications (TSs) to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The changes are consistent with NRG-approved Technical Specification Task Force-523, Revis.ion 2, "Generic Letter 2008-01, Managing Gas Accumulation."

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-336 and 50-423

Enclosures:

1. Amendment No. 325 to DPR-65

2. Amendment No. 267 to NPF-49

3. Safety Evaluation cc w/encls: Distribution via ListServ DISTRIBUTION:

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