ML20027B970

Issuance of Amendment No. 338 Regarding Adoption of TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using CLIIP

ML20027B970
Person / Time
Site:	Millstone
Issue date:	03/26/2020
From:	Jennifer Tobin Plant Licensing Branch 1
To:	Stoddard D Dominion Nuclear Connecticut
Tobin, NRR/DORL/LPLI,
References
EPID L-2019-LLA-0077, TSTF-522
Download: ML20027B970 (15)

Text

March 26, 2020 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 2 ISSUANCE OF AMENDMENT NO. 338 REGARDING ADOPTION OF TSTF-522, REVISION 0, REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2019-LLA-0077)

Dear Mr. Stoddard:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 338 to Renewed Facility Operating License No. DPR-65 for Millstone Power Station, Unit No. 2, in response to your application dated April 11, 2019.

The amendment revises the technical specification (TS) surveillance requirements (SRs), which currently require operating ventilation systems with charcoal filters for a 10-hour period at a frequency controlled in accordance with the TS surveillance frequency control program. The SRs are revised to require operation of the systems for 15 continuous minutes at a frequency controlled in accordance with the surveillance frequency control program. The amendment is consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month, as published in the Federal Register on September 20, 2012 (77 FR 58421).

The changes revise TS SR 4.6.5.1, Enclosure Building Filtration System, and remove the requirement in TS SR 4.6.5.1.a to run the flow test with the duct heaters energized, since the charcoal adsorption test is performed at 95 percent relative humidity.

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

If you have any questions please contact the Beaver Valley Project Manager, Jennifer Tobin, at 301-415-2328 or Jennifer.Tobin@nrc.gov.

Sincerely,

/RA/

Jennifer C. Tobin, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosures:

1. Amendment No. 338 to DPR-65

2. Safety Evaluation cc: Listserv

DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

DOCKET NO. 50-336 MILLSTONE POWER STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 338 Renewed License No. DPR-65

1.

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

A.

The application for amendment by Dominion Energy Nuclear Connecticut, Inc.

(the licensee) dated April 11, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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. 338 are hereby incorporated into 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 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: March 26, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 338 MILLSTONE POWER STATION, UNIT NO. 2 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 a marginal line indicating the area of change.

Remove Insert 3

3 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Insert 3/4 6-25 3/4 6-25 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 sources 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. 338 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. 338

MILLSTONE - UNIT 2 CONTAINMENT SYSTEMS 3/4.6.5 SECONDARY CONTAINMENT ENCLOSURE BUILDING FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.1 Two separate and independent Enclosure Building Filtration Trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

SURVEILLANCE REQUIREMENTS 4.6.5.1 Each Enclosure Building Filtration Train shall be demonstrated OPERABLE:

a.

At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 continuous minutes.

b.

At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, and (2) following painting, fire or chemical release in any ventilation zone communicating with the train by:

Inoperable Equipment Required ACTION a.

One Enclosure Building Filtration Train.

a.1 Restore the inoperable Enclosure Building Filtration Train to OPERABLE status within 7 days or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

b.

NOTE Not applicable when second Enclosure Building Filtration Train intentionally made inoperable.

Two Enclosure Building Filtration Trains.

b.1 Verify at least one train of containment spray is OPERABLE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND b.2 Restore at least one Enclosure Building Filtration Train to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

Amendment No. 208, 321, 324, 338 3/4 6-25

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 338 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-65 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION, UNIT NO. 2 DOCKET NO. 50-336

1.0 INTRODUCTION

By letter dated April 11, 2019 (Reference 1), Dominion Energy Nuclear Connecticut, Inc.

(Dominion or the licensee) submitted a license amendment request (LAR) for the Millstone Power Station, Unit No. 2 (Millstone Unit 2).

The LAR proposes to modify Technical Specification (TS) Surveillance Requirement (SR) 4.6.5.1 for the enclosure building filtration system (EBFS). Dominion proposes to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month (Reference 2), and decrease ventilation system flow test requirements from 10 continuous hours, at the frequency specified in the TS surveillance frequency control program (SFCP), to 15 continuous minutes at the frequency specified in the SFCP. Additionally, the licensee proposes that TS SR 4.6.5.1 be revised to remove the requirement to run the flow test with the duct heaters energized since the charcoal adsorption test is performed at 95 percent relative humidity.

The model safety evaluation on TSTF-522 (Reference 3) evaluated reducing the period of equipment operation required by SRs for various Standard Technical Specification (STS) ventilation systems, such as the control room emergency filtration system, from 10 continuous hours to 15 continuous minutes.

The licensee stated that the justification presented in the TSTF-522, Revision 0, proposal and the model safety evaluation prepared by the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff are applicable to Millstone Unit 2 and justifies this amendment for the incorporation of the changes to the Millstone Unit 2 TSs. The availability of this TS improvement was announced in the Federal Register on September 20, 2012 (77 FR 58421) as part of the consolidated line item improvement process.

2.0 REGULATORY EVALUATION

One of the reasons air filtration and adsorption systems are required at nuclear power plants is to lower the concentration of airborne radioactive material that may be released from the site to the environment due to a design-basis event. Lowering the concentration of airborne radioactive materials can mitigate doses to plant operators and members of the public in the event of a design-basis event. A typical system consists of ventilation ductwork, fans, dampers, valves, instrumentation, prefilters or demisters, high efficiency particulate air (HEPA) filters, heaters, and activated charcoal adsorbers. These systems are tested by operating the systems and monitoring the response of the overall system, as well as individual components.

Laboratory tests of charcoal adsorbers are also performed to ensure the charcoal adsorbs an acceptable amount of radioactive gasses.

Current testing requirements for the air filtration and adsorption systems state that the systems should be operated for at least 10 continuous hours with heaters operating at a frequency in accordance with the SFCP. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that has been superseded. Regulatory Guide 1.52, Revision 3, Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants (Reference 9), states that at least 15 continuous minutes of ventilation system operation with heaters operating in accordance with the licensees SFCP is acceptable for those plants that test ventilation system adsorption at a relative humidity of less than 95 percent. Plants that test ventilation system adsorption at a relative humidity of 95 percent do not require heaters for the ventilation system to perform its specified safety function, and the bracketed phrase with heaters operating is not included in the SRs.

2.1 Description of the Enclosure Building Filtration System (EBFS)

The functions of the EBFS are to collect and process potential containment leakage in order to minimize environmental activity levels resulting from sources of containment leakage following a loss-of-coolant accident. The EBFS is designed to establish and maintain a negative pressure of 0.25 inches water-gauge within the enclosure building filtration region immediately following a loss-of-coolant accident and to reduce airborne radioactive products to the environment by filtration prior to release of air through the Millstone stack. Although not credited in the fuel handling accident and cask drop analyses, EBFS is capable of being automatically or manually aligned to minimize the consequences of those accidents. The system has two redundant, independent subsystems, each fully capable of fulfilling the functional requirement. LAR, page 2, provides a table indicating that the EBFS correlates to the Shield Building Exhaust Air Cleanup System in the STSs.

2.2.

Licensees Proposed Changes For Millstone Unit 2, the licensee proposed revising TS SR 4.6.5.1 for the EBFS by deleting the stricken text and inserting the new text shown in bold below:

TS SR 4.6.5.1

a. At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 continuous minutes 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters on.

2.3 Regulatory Review The regulatory requirements for design and testing of these systems are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67 and Part 100, as well as 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, (GDC) 19, 41, 42, 43, and 61.

Regulatory Guide (RG) 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants (Reference 4), was published in March 1978 to provide guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR related to air filtration and adsorption systems.

Regulatory Position 4, Maintenance, item d of Revision 2 of RG 1.52 stated:

Each ESF [engineered safety feature] atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA filters.

The purpose of this position is to minimize the moisture content in the system and thereby enhance efficiency in the event the system is called upon to perform its design-basis function.

In NUREG-1432, Revision 4.0, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Specifications (STSs) (Reference 5), the following SRs required that operability be demonstrated by operating the heaters in the respective ventilation and filtering systems for at least 10 continuous hours every 31 days:

SR 3.6.8.1 in STS 3.6.8, Shield Building Exhaust Air Cleanup System (SBEACS)

(Dual);

SR 3.6.10.1 in STS 3.6.10, Iodine Cleanup System (ICS) (Atmospheric and Dual);

SR 3.7.11.1 in STS 3.7.11, Control Room Emergency Air Cleanup System (CREACS);

SR 3.7.13.1 in STS 3.7.13, Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS);

SR 3.7.14.1 in STS 3.7.14, Fuel Building Air Cleanup System (FBACS); and SR 3.7.15.1 in STS 3.7.15, Penetration Room Exhaust Air Cleanup System (PREACS).

NUREG-1432, Revision 4.0, Standard Technical Specifications Combustion Engineering Plants, Volume 2, Bases (Reference 6), explains that operation of heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for Combustion Engineering plants would eliminate moisture on the charcoal adsorbers and HEPA filters in the description of each SR listed above.

Subsequently, the NRC staff was informed that 10 continuous hours of system operation would dry out the charcoal adsorber for a brief period of time, but following heater deenergization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level. The NRC staff found this information persuasive and subsequently issued NRC Generic Letter (GL) 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, and Errata (Reference 7 and Reference 8, respectively). GL 99-02 requests that licensees confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability. GL 99-02 also requests that licensees account for the effects of moisture accumulation in adsorbers.

Therefore, the NRC staff updated RG 1.52 to include this new information (Reference 9).

RG 1.52, Revision 3, Regulatory Position 6.1, states:

Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components.

One of the reasons for the previous 10-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorbers ability to capture gaseous activity. However, these effects would already be accounted for in existing Millstone TS SR 4.6.5.1, which requires testing charcoal adsorbers in a manner to account for the effect of moisture on the adsorbers ability to capture gaseous activity. RG 1.52, Revision 3, Regulatory Position 4.9, states:

Systems with humidity control can perform laboratory testing of representative samples of activated carbon at a relative humidity of 70%, and systems without humidity control should perform laboratory testing of representative samples of activated carbon at a relative humidity of 95%....

For Millstone Unit 2, the footnote to TS SR 4.6.5.1.c requires testing of charcoal adsorbers in these systems at a relative humidity of 95 percent. As noted in RG 1.52, Position 4.9, and footnote (4) to Table 1, Laboratory Tests for Activated Carbon, in RG 1.52, Revision 3, heaters are an allowed means to control relative humidity at less than or equal to 70 percent relative humidity.

The NRCs regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36. The regulations in 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 (LCOs); (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.

The NRCs guidance for the format and content of Combustion Engineering plant TSs can be found in NUREG-1432, Revision 4.0. The current NRC guidance relevant to the proposed amendment are those STSs as modified by TSTF-522.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensees proposed changes against the applicable regulatory guidance in RG 1.52, Revision 3 (Reference 9), guidance in the STSs as modified by TSTF-522, and the regulatory requirements of 10 CFR 50.36.

The proposed change would require at least 15 continuous minutes of system operation. The NRC staff found that the proposed change is consistent with guidance in RG 1.52, Revision 3.

The NRC staff evaluated the licensees proposed change against the applicable regulatory guidance in the STSs, as modified by TSTF-522. Because Millstone Unit 2 has custom TSs and does not follow the STSs, the proposed change does not adopt the format and content changes made to the STSs for Combustion Engineering plants by TSTF-522. As a minor variation, the licensee modified the TS inserts provided in TSTF-522 to fit the content and format of the Millstone Unit 2 TSs. The licensee explained these differences in Section 2.2 of the LAR. Thus, where the current SR specifies 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, the SR is being revised to specify 15 continuous minutes.

As discussed in Section 2.2 of the LAR, the Millstone Unit 2 TSs use different numbering and titles than the STSs in NUREG-1432. The TSTF-522 markups for Combustion Engineering plants are based on NUREG-1432. The differences do not affect the applicability of TSTF-522 to the Millstone Unit 2 TSs because while differences in formatting, nomenclature, and numbering exist, the requirements are the same. Further, some of the NUREG-1432 STS sections are not contained in the Millstone Unit 2 TSs. The corresponding markups included in TSTF-522 for these surveillances are not identical to Millstone Unit 2. RG 1.52 is applicable to the Millstone Unit 2 EBFS because the EBFS is a post-accident engineered safety feature (ESF) atmosphere cleanup system containing air filtration and adsorption units. The NRC staff reviewed Section 2.2 of the LAR and finds that this minor deviation from TSTF-522 does not impact the applicability of the conclusion in the NRC staffs model safety evaluation.

Additionally, Millstone Unit 2 does not include STS 5.5.11, Ventilation Filter Testing Program (VFTP). The requirements for laboratory test of a charcoal sample, HEPA filter bypass testing, and charcoal filter bypass testing found in the VFTP are performed as directed in TS SRs 4.6.5.1.b, 4.6.5.1.c, 4.6.5.1.d, and 4.6.5.1.e.

The NRC staff compared the proposed change to the existing SR, as well as the regulatory requirements of 10 CFR 50.36. Existing Millstone Unit 2 TS SR 4.6.5.1 provides assurance that the necessary quality of ventilation systems and components will be maintained and that the LCOs will be met. The proposed change reduces the amount of required system operational time from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 continuous minutes. The 10-hour operational requirement for heaters was based on using the SRs to eliminate moisture in the adsorbers and thus ensure the adsorbers would capture gaseous activity. The effects of moisture on the adsorbers ability to capture gaseous activity are accounted for in the licensees TS SR 4.6.5.1, which requires testing at a specific temperature and relative humidity value to account for the effects of moisture. Specifically, TS SR 4.6.5.1 requires testing of charcoal adsorbers in these systems at a relative humidity of 95 percent. The

• footnote to SR 4.6.5.1.b.2 and 4.6.5.1.c states:

ASTM D3803-89 shall be used in place of ANS N509-1976 as referenced in table 2 of Regulatory Guide 1.52. The laboratory test of charcoal should be conducted at a temperature of 30°C and a relative humidity of 95% within the tolerances specified by ASTM D3803-89.

Additionally, the charcoal sample shall have a removal efficiency of 95%.

TSTF-522 identifies a regulatory position indicating that plants that test ventilation system adsorption at a higher humidity do not require heaters for the ventilation system to perform its specified safety function systems, and that reference to the heaters can be removed from the TSs. Specifically, TSTF-522, Section 4.0, Technical Analysis, states:

Plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function consistent with [RG 1.52, Revision 3] Regulatory Position 4.9, given above. These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases. These plants may also subsequently pursue elimination of the heaters from the plant design under 10 CFR 50.59.

The NRC staff finds, based on justification provided in TSTF-522, that the proposed SR for EBFS is acceptable to remove the requirement to complete the ventilation system test with the duct heaters energized since the adsorption test is performed at 95 percent relative humidity.

The NRC staff finds that the TS change reducing the required minimum system operation time to 15 continuous minutes is consistent with RG 1.52, Revision 3, and is sufficient to demonstrate operability of the EBFS system and all its components. The NRC staff also finds that proposed TS SR 4.6.5.1 meets the regulatory requirements of 10 CFR 50.36, because it provides assurance that the necessary quality of ventilation system and components will be maintained and that the LCO 3.6.5.1 will be met. Therefore, the NRC staff finds the proposed TS change acceptable.

The regulation in 10 CFR 50.36 states, A summary statement of the bases or reasons for such specifications... shall also be included in the application but shall not become part of the technical specifications.

The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with TS 6.23, Technical Specifications (TS) Bases Control Program.

Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes (Attachment 3 to the LAR) corresponding to the proposed TS changes. The NRC staff determined that the TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Connecticut State official was notified of the proposed issuance of the amendment on January 27, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 or changes SRs.

The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on this finding (June 4, 2019; 83 FR 25834). Accordingly, the amendment meets 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 prepared in connection with the issuance of the amendment.

6.0 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1.

Letter from Dominion Energy Nuclear Connecticut, Inc., to U.S. Nuclear Regulatory Commission, Millstone Power Station Units 2 and 3, Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month, dated April 11, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19109A100).

2.

Technical Specifications Task Force (TSTF) Traveler TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month, dated March 30, 2010 (ADAMS Accession No. ML100890316).

3.

Model Safety Evaluation for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month, Using the Consolidated Line Item Improvement Process, dated September 30, 2012 (ADAMS Accession No. ML12158A464).

4.

Regulatory Guide 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, dated March 1978 (ADAMS Accession No. ML003740139).

5.

NUREG-1432, Revision 4, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Specifications, dated April 2012 (ADAMS Accession No. ML12102A165).

6.

NUREG-1432, Revision 4, Standard Technical Specifications, Combustion Engineering Plants, Volume 2, Bases, dated April 2012 (ADAMS Accession No. ML12102A169).

7.

NRC Generic Letter 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, dated June 3, 1999 (ADAMS Accession No. ML082350935).

8.

NRC Generic Letter 99-02 (ERRATA), Laboratory Testing of Nuclear-Grade Activated Charcoal, dated August 23, 1999 (ADAMS Accession No. ML031110094).

9.

Regulatory Guide 1.52, Revision 3, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants, dated June 2001 (ADAMS Accession No. ML011710176).

Principal Contributor: L. Wheeler Date: March 26, 2020

ML20027B970

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