Text

Issuance of Amendment Nos. 345 and 285 Regarding Adoption of Technical Specification Task Force-359, Increase Flexibility in Mode Restraints
	ML23058A454
Person / Time
Site:	Millstone ; (DPR-065, NPF-049)
Issue date:	03/16/2023
From:	Richard Guzman; NRC/NRR/DORL/LPL1
To:	Stoddard D; Dominion Energy Nuclear Connecticut
References
	EPID L-2022-LLA-0052
	Download: ML23058A454 (57)
	v • d • e

March 16, 2023 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Dominion Energy Nuclear Connecticut, Inc.

Millstone Power Station Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 ISSUANCE OF AMENDMENT NOS. 345 AND 285 REGARDING ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE-359, INCREASE FLEXIBILITY IN MODE RESTRAINTS (EPID L-2022-LLA-0052)

Dear Mr. Stoddard:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 345 to Renewed Facility Operating License No. DPR-65 and Amendment No. 285 to Renewed Facility Operating License No. NPF-49 for the Millstone Power Station, Unit Nos. 2 and 3, respectively.

The amendments are in response to your application dated April 6, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22096A221).

The amendments revise the technical specifications (TS) requirements for mode change limitations in Limiting Condition for Operation 3.0.4 and Surveillance Requirement 4.0.4 to adopt the provisions of Technical Specification Task Force Traveler-359, Revision 9 (TSTF-359),

Increase Flexibility in Mode Restraints. The availability of TSTF-359 for adoption by licensees was announced in the Federal Register on April 4, 2003 (68 FR 16579) as part of the Consolidated Improvement Process.

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

Sincerely,

/RA/

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

Enclosures:

1. Amendment No. 345 to DPR-65

2. Amendment No. 285 to NPF-49

3. 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. 345 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 6, 2022, 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 renewed 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. 345 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 its issuance and shall be implemented within 60 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Hipólito J. González, 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 16, 2023 Hipolito J.

Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2023.03.16 17:15:14 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 345 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 Page Insert Page 3

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

Remove Page Insert Page 3/4 0-1 3/4 0-1 3/4 0-1a 3/4 0-2 3/4 0-2 3/4 0-2a 3/4 4-13 3/4 4-13 3/4 4-21a 3/4 4-21a 3/4 4-21b 3/4 5-7 3/4 5-7 3/4 7-4 3/4 7-4 3/4 7-4a 3/4 7-4a 3/4 8-1 3/4 8-1 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. 345 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. 345

MILLSTONE - UNIT 2 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3./4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in LCO 3.0.6. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour ACTION shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time it is identified that a Limiting Condition for Operation is not met.

Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or Amendment Nos. 62, 151, 230, 249, 345 3/4 0-1

MILLSTONE - UNIT 2 APPLICABILITY:

LIMITING CONDITION FOR OPERATION (Continued) c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s),

subsystem(s), train(s), component(s) and device(s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , ACTION shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it, as applicable, in:

Amendment Nos. 62, 151, 230, 249, 345 3/4 0-1a

MILLSTONE - UNIT 2 APPLICABILITY:

LIMITING CONDITION FOR OPERATION (Continued) 1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and 3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This specification is not applicable in MODES 5 or 6.

3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance time interval.

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

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

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

4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOs Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

Amendment No. 62, 70, 161, 230, 271, 345 3/4 0-2

MILLSTONE - UNIT 2 APPLICABILITY:

SURVEILLANCE REQUIREMENTS (Continued)

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Amendment No. 62, 70, 161, 230, 271, 345 3/4 0-2a

MILLSTONE - UNIT 2 REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a.

0.5 µCi/gram DOSE EQUIVALENT I-131, and b.

550 µCi/gram DOSE EQUIVALENT XE-133.

APPLICABILITY:

MODES 1, 2, 3, 4.

ACTION:

a.

With the specific activity of the primary coolant > 0.5 µCi/gram DOSE EQUIVALENT I-131, verify DOSE EQUIVALENT I-131 30 µCi/gram once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b.

With the specific activity of the primary coolant > 0.5 µCi/gram DOSE EQUIVALENT I-131 but 30 µCi/gram, operation may continue for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months while efforts are made to restore DOSE EQUIVALENT I-131 to within the 0.5 µCi/gram limit. Specification 3.0.4.c is applicable.

c.

With the specific activity of the primary coolant > 0.5 µCi/gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval, or > 30 µCi/gram DOSE EQUIVALENT I-131, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

d.

With the specific activity of the primary coolant > 550 µCi/gram DOSE EQUIVALENT XE-133, operation may continue for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months while efforts are made to restore DOSE EQUIVALENT XE-133 to within the 550 µCi/gram limit. Specification 3.0.4.c is applicable.

e.

With the specific activity of the primary coolant > 550 µCi/gram DOSE EQUIVALENT XE-133 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Amendment No. 9, 111, 115, 151, 194, 228, 307, 340, 3/4 4-13 345

MILLSTONE - UNIT 2 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 A Low Temperature Overpressure Protection (LTOP) System, as specified below, shall be OPERABLE.

a.

MODE 4, and MODE 5 with all RCS cold leg temperature > 190°F:

1.

Maximum of two charging pumps and one HPSI pump may be capable of injecting into the RCS; and 2.

Two OPERABLE PORVs with a lift setpoint of 415 psia.

b.

MODE 5 with any RCS cold leg temperature 190 °F, and MODE 6 either:

1.

Maximum of one charging pump may be capable of injecting into the RCS; and 2.

Two OPERABLE PORVs with a lift setpoint of415 psia.

OR 3.

Maximum of two charging pumps and one HPSI pump may be capable of injecting into the RCS; and 4.

The RCS is depressurized and an RCS vent of 2.2 sq. inches.

APPLICABILITY:

MODE 4 when the temperature of any RCS cold leg is less than or equal to 275°F, MODE 5, and MODE 6 when the head is on the reactor vessel.

ACTION:

NOTE LCO 3.0.4.b is not applicable to PORVs when entering MODE 4 a.

With one required PORV inoperable in MODE 4, restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a 2.2 square inch vent within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

b.

With one required PORV inoperable in MODES 5 or 6, either restore inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or depressurize and vent the RCS through a 2.2 square inch vent within the next 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

c.

With both required PORVs inoperable, depressurize and vent the RCS through a 2.2 square inch vent within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

d.

With more than the maximum allowed pumps capable of injecting into the RCS, take immediate action to comply with 3.4.9.3.

Amendment No. 50, 151, 185, 218, 345 3/4 4-21a

MILLSTONE - UNIT 2 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued) e.

In the event either the PORVs or the RCS vent(s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days. The report shall describe the circumstances initiating the transient, the effect of the PORVs or RCS vent(s) on the transient, and any corrective action necessary to prevent recurrence.

SURVEILLANCE REQUIREMENTS 4.4.9.3.1 Each PORV shall be demonstrated OPERABLE by:

a.

Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required OPERABLE and at the frequency specified in the Surveillance Frequency Control Program thereafter when the PORV is required OPERABLE.

b.

Performance of a CHANNEL CALIBRATION on the PORV actuation channel at the frequency specified in the Surveillance Frequency Control Program.

c.

Verifying the PORV block valve is open at the frequency specified in the Surveillance Frequency Control Program when the PORV is being used for overpressure protection.

d.

Testing in accordance with the inservice test requirements of Specification 4.0.5.

4.4.9.3.2 Verify no more than the maximum allowed number of charging pumps are capable of injecting into the RCS at the frequency specified in the Surveillance Frequency Control Program.

4.4.9.3.3 Verify no more than the maximum allowed number of HPSI pumps are capable of injecting into the RCS at the frequency specified in the Surveillance Frequency Control Program.

4.4.9.3.4 Verify the required RCS vent is open at the frequency specified in the Surveillance Frequency Control Program when the vent pathway is provided by vent valve(s) that is(are) locked, sealed, or otherwise secured in the open position, otherwise, verify the vent pathway at the frequency specified in the Surveillance Frequency Control Program.

Amendment No. 50, 147, 185, 218, 227, 243, 324, 3/4 4-21b 345

MILLSTONE - UNIT 2 EMERGENCY CORE COOLING SYSTEM ECCS SUBSYSTEMS - Tavg < 300°F LIMITING CONDITION FOR OPERATION 3.5.3 One high pressure safety injection subsystem shall be OPERABLE.

1.

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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 start 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:

NOTE LCO 3.0.4.b is not applicable to ECCS high pressure safety injection subsystem when entering MODE 4 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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 4.5.3.1 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.l.

With pressurizer pressure < 1750 psia.

Amendment No. 39, 185, 216, 218, 227, 283, 325, 3/4 5-7 345

MILLSTONE - UNIT 2 PLANT SYSTEMS AUXILIARY FEEDWATER PUMPS LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three steam generator auxiliary feedwater pumps shall be OPERABLE with:

a.

Two feedwater pumps capable of being powered from separate OPERABLE emergency busses, and b.

One feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY:

MODES 1, 2 and 3.

NOTE LCO 3.0.4.b is not applicable Amendment No. 63, 76, 90, 151, 236, 283, 297, 3/4 7-4 345

MILLSTONE - UNIT 2 PLANT SYSTEMS AUXILIARY FEEDWATER PUMPS LIMITING CONDITION FOR OPERATION (Continued)

ACTION:

Inoperable Equipment Required ACTION a.

Turbine-driven auxiliary feedwater pump due to one steam supply being inoperable.

a.

Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

NOTE Only applicable if MODE 2 has not been entered following REFUELING.

One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING.

b. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in at least HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c.

One auxiliary feedwater pump in MODE 1, 2, or 3 for reasons other than a. or b. above.

c.

Restore the auxiliary feedwater pump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If these ACTIONS are not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. Two auxiliary feedwater pumps in MODE 1, 2, or 3.

d. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Amendment No. 63, 76, 90, 151, 236, 283, 297, 3/4 7-4a 345

MILLSTONE - UNIT 2 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and b.

Two separate and independent diesel generators each with a separate fuel oil supply tank containing a minimum of 12,000 gallons of fuel.

APPLICABILITY:

MODES 1, 2, 3 and 4.

NOTE LCO 3.0.4.b is not applicable to diesel generators ACTION:

Inoperable Equipment Required ACTION a.

One offsite circuit a.1 Perform Surveillance Requirement 4.8.1.1.1 for remaining offsite circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to or after entering this condition, and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

AND a.2 Restore the inoperable offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (within 10 days* if Required ACTION a.3 is met) or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

AND Amendment No. 45, 177, 192, 231, 251, 261, 291, 339, 3/4 8-1 345

DOMINION ENERGY NUCLEAR CONNECTICUT, INC., ET AL DOCKET NO. 50-423 MILLSTONE POWER STATION, UNIT NO. 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 285 Renewed License No. NPF-49

1.

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

A.

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

(DENC, the licensee), dated April 6, 2022, 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. NPF-49 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 285 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. DENC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Hipólito J. González, 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 16, 2023 Hipolito J.

Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2023.03.16 17:15:46 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 285 MILLSTONE POWER STATION, UNIT NO. 3 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 a marginal line indicating the area of change.

Remove Page Insert Page 4

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

Remove Page Insert Page 3/4 0-1 3/4 0-1 3/4 0-1a 3/4 0-2 3/4 0-2 3/4 3-53 3/4 3-53 3/4 3-59a 3/4 3-59a 3/4 4-12 3/4 4-12 3/4 4-28 3/4 4-28 3/4 4-38 3/4 4-38 3/4 4-38a 3/4 4-38a 3/4 5-7 3/4 5-7 3/4 6-5 3/4 6-5 3/4 7-4 3/4 7-4 3/4 7-9a 3/4 7-9a 3/4 8-1 3/4 8-1 3/4 8-1a

(2)

Technical Specifications The Technical Specifications contained in Appendix A, revised through Amendment No. 285 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated into the license. DENC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

DENC shall not take any action that would cause Dominion Energy, Inc.

or its parent companies to void, cancel, or diminish DENC'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 DNC*, 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 the NRC.

(b)

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

Except for investments tied to market indexes 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.

On May 12, 2017, the name Dominion Nuclear Connecticut, Inc. changed to Dominion Energy Nuclear Connecticut, Inc.

Renewed License No. NPF-49 Amendment No. 270-283, 285

MILLSTONE - UNIT 3 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in Specification 3.0.5.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals, except as provided in Specification 3.0.5. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , b.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and c.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the action may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODE 5 or 6.

3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Amendment 54, 57, 179, 213, 285 3/4 0-1

MILLSTONE - UNIT 3 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION (Continued) 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to Specifications 3.0.1 and 3.0.2 for the system returned to service under administrative controls to perform the testing required to demonstrate OPERABILITY.

4.0.1 Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Condition for Operation except as provided in Specification 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

Amendment 54, 57, 179, 213, 285 3/4 0-1a

MILLSTONE - UNIT 3 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

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

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

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

4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCOs Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

4.0.5 Surveillance Requirements for inservice testing of ASME Code Class 1, 2, and 3 components shall be performed in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) as follows:

a.

Deleted.

b.

Surveillance intervals specified in the ASME OM Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

Amendment No. 54, 57, 138, 179, 213,

241, 3/4 0-2 285

MILLSTONE - UNIT 3 INSTRUMENTATION REMOTE SHUTDOWN INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.5 The Remote Shutdown Instrumentation transfer switches, power, controls and monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTION:

a.

With the number of OPERABLE remote shutdown monitoring channels less than the Minimum Channels OPERABLE as required by Table 3.3-9, restore the inoperable channel(s) to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

With one or more Remote Shutdown Instrumentation transfer switches, power, or control circuits inoperable, restore the inoperable switch(s)/circuit(s) to OPERABLE status within 7 days, or be in HOT STANDBY within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS 4.3.3.5.1 Each required remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6.

4.3.3.5.2 Each Remote Shutdown Instrumentation transfer switch, power and control circuit including the actuated components, shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program.

Amendment No. 57, 79, 100, 258, 285 3/4 3-53

MILLSTONE - UNIT 3 LIMITING CONDITION FOR OPERATION (Continued) action taken, the cause of the inoperability, and the plans and schedule for restoring the channel to OPERABLE status.

f.

With the number of OPERABLE channels for the reactor vessel water level monitor less than the minimum channels OPERABLE requirements of Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if repairs are feasible without shutting down or:

1.

Initiate an alternate method of monitoring the reactor vessel inventory; 2.

Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the channel(s) to OPERABLE status; and 3.

Restore the channel(s) to OPERABLE status at the next scheduled refueling.

SURVEILLANCE REQUIREMENTS 4.3.3.6.1 Each required accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION at the frequencies shown in Table 4.3-7.

4.3.3.6.2 Deleted Amendment No. 47, 57, 76, 142, 224,

258, 3/4 3-59a 285

MILLSTONE - UNIT 3 REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4.

Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTION:

a.

With one or both PORV(s) inoperable because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s); otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

With one PORV inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c.

With both PORVs inoperable due to causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close its associated block valve and remove power from the block valve and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d.

With one or both block valve(s) inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve(s) to OPERABLE status, or place its associated PORV(s) control switch to CLOSE. Restore at least one block valve to OPERABLE status within the next hour if both block valves are inoperable; restore any remaining inoperable block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Amendment No. 57, 88, 161, 229, 285 3/4 4-12

MILLSTONE - UNIT 3 REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the reactor coolant shall be limited to:

a.

Less than or equal to 1 microCurie per gram DOSE EQUIVALENT I-131, and b.

Less than or equal to 81.2 microCuries per gram DOSE EQUIVALENT XE-133.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

a.

With the specific activity of the reactor coolant greater than 1.0 microCurie per gram DOSE EQUIVALENT I-131, verify DOSE EQUIVALENT I-131 less than or equal to 60 microCuries per gram once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b.

With the specific activity of the reactor coolant greater than 1.0 microCurie per gram DOSE EQUIVALENT I-131 but less than or equal to 60 microCuries per gram, operation may continue for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months while efforts are made to restore DOSE EQUIVALENT I-131 to within the 1.0 microCurie per gram limit.

Specification 3.0.4.c is applicable.

c.

With the specific activity of the reactor coolant greater than 1.0 microCurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval, or greater than 60 microCuries per gram DOSE EQUIVALENT I-131, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

d.

With the specific activity of the reactor coolant greater than 81.2 microCuries per gram DOSE EQUIVALENT XE-133, operation may continue for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months while efforts are made to restore DOSE EQUIVALENT XE-133 to within the 81.2 microCuries per gram limit. Specification 3.0.4.c is applicable.

e.

With the specific activity of the reactor coolant greater than 81.2 microCuries per gram DOSE EQUIVALENT XE-133 for more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during one continuous time interval, be in HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Amendment No. 246, 285 3/4 4-28

MILLSTONE - UNIT 3 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 Cold Overpressure Protection shall be OPERABLE with a maximum of one centrifugal charging pump* and no Safety Injection pumps capable of injecting into the Reactor Coolant System (RCS) and one of the following pressure relief capabilities:

1.

One power operated relief valve (PORV) with a nominal lift setting established in Figure 3.4-4a and one PORV with a nominal lift setting established in Figure 3.4-4b with no more than one isolated RCS loop, or 2.

Two residual heat removal (RHR) suction relief valves with setpoints 426.8 psig and 453.2 psig, or 3.

One PORV with a nominal lift setting established in Figure 3.4-4a or Figure 3.4-4b with no more than one isolated RCS loop and one RHR suction relief valve with a setpoint 426.8 psig and 453.2 psig, or 4.

RCS depressurized with an RCS vent of 2.0 square inches.

APPLICABILITY:

MODE 4 when any RCS cold leg temperature is 226F, MODE 5, and MODE 6 when the head is on the reactor vessel.

ACTION:

NOTE LCO 3.0.4.b is not applicable when entering MODE 4 a.

With two or more centrifugal charging pumps capable of injecting into the RCS, immediately initiate action to establish that a maximum of one centrifugal charging pump is capable of injecting into the RCS.

b.

With any Safety Injection pump capable of injecting into the RCS, immediately initiate action to establish that no Safety Injection pumps are capable of injecting into the RCS.

c.

With one required relief valve inoperable in MODE 4, restore the required relief valve to OPERABLE status within 7 days, or depressurize and vent the RCS through at least a 2.0 square inch vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Two centrifugal charging pumps may be capable of injecting into the RCS for less than one hour, during pump swap operations. However, at no time will two charging pumps be simultaneously out of pull-to-lock during pump swap operations.

Amendment No. 18, 57, 80, 143, 157,

197, 3/4 4-38 285

MILLSTONE - UNIT 3 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION d.

With one required relief valve inoperable in MODE 5 or 6, restore the required relief valve to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or depressurize the RCS and establish an RCS vent of 2.0 square inches within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

e.

With two required relief valves inoperable, depressurize the RCS and establish an RCS vent of 2.0 square inches within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

f.

In the event the PORVs, the RHR suction relief valves, or the RCS vent are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days. The report shall describe the circumstances initiating the transient, the effect of the PORVs, the RHR suction relief valves, or RCS vent on the transient, and any corrective action necessary to prevent recurrence.

Amendment No. 18, 57, 80, 143, 157,

197, 3/4 4-38a 285

MILLSTONE - UNIT 3 EMERGENCY CORE COOLING SYSTEMS 3/4.5.3 ECCS SUBSYSTEMS - Tavg LESS THAN 350F LIMITING CONDITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem comprised of the following shall be OPERABLE:

a.

One OPERABLE centrifugal charging pump, b.

One OPERABLE RHR heat exchanger, c.

One OPERABLE RHR pump, d.

One OPERABLE containment recirculation heat exchanger, e.

One OPERABLE containment recirculation pump, and f.

An OPERABLE flow path which, with manual realignment of valves, is capable of discharging to the RCS, taking suction from the refueling water storage tank, and transferring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY:

MODE 4.

ACTION:

NOTE LCO 3.0.4.b is not applicable to ECCS high pressure safety injection subsystem a.

With no ECCS subsystem OPERABLE because of the inoperability of the centrifugal charging pump, the containment recirculation pump, the containment recirculation heat exchanger, the flow path from the refueling water storage tank, or the flow path capable of taking suction from the containment sump, restore at least one ECCS subsystem to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in COLD SHUTDOWN within the next 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months .

b.

With no ECCS subsystem OPERABLE because of the inoperability of either the residual heat removal heat exchanger or RHR pump, restore at least one ECCS subsystem to OPERABLE status or maintain the Reactor Coolant System Tavg less than 350°F by use of alternate heat removal methods.

c.

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. The current value of the usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

Amendment No. 157, 3/4 5-7 285

MILLSTONE - UNIT 3 CONTAINMENT SYSTEMS CONTAINMENT AIR LOCKS LIMITING CONDITION FOR OPERATION 3.6.1.3 The containment air lock shall be OPERABLE with:

a.

Both doors closed except when the air lock is being used for normal transit entry and exit through the containment, then at least one air lock door shall be closed, and b.

An overall air lock leakage rate in accordance with the Containment Leakage Rate Testing Program.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

a.

With only one containment air lock door inoperable:

1.

Verify the OPERABLE air lock door is closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and either restore the inoperable air lock door to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or lock the OPERABLE air lock door closed, 2.

Operation may then continue provided that the OPERABLE air lock door is verified to be locked closed at least once per 31 days, 3.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

With only the containment air lock interlock mechanism inoperable, verify an OPERABLE air lock door is closed within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and lock an OPERABLE air lock door closed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Verify an OPERABLE air lock door is locked closed at least once per 31 days thereafter. Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . (Entry into and exit from containment is permissible under the control of a dedicated individual).

NOTE Entry and exit through the containment air lock doors is permitted to perform repairs on the affected air lock components.

Amendment No. 57, 59, 154, 186, 205, 3/4 6-5 285

MILLSTONE - UNIT 3 PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:

a.

Two motor-driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and b.

One steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY:

MODES 1, 2, and 3.

ACTION:

NOTE LCO 3.0.4.b is not applicable Inoperable Equipment Required ACTION a.

Turbine-driven auxiliary feedwater pump due to one of the two required steam supplies being inoperable.

a.

Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

NOTE Only applicable if MODE 2 has not been entered following REFUELING.

One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING.

b. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in at least HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c.

One auxiliary feedwater pump in MODE 1, 2, or 3 for reasons other than a. or b. above.

c.

Restore the auxiliary feedwater pump to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If these ACTIONS are not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. Two auxiliary feedwater pumps in MODE 1, 2, or 3.

d. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Amendment No. 57, 100, 235, 3/4 7-4 285

MILLSTONE - UNIT 3 PLANT SYSTEMS STEAM GENERATOR ATMOSPHERIC RELIEF BYPASS LINES LIMITING CONDITION FOR OPERATION 3.7.1.6 Each steam generator atmospheric relief bypass valve (SGARBV) line shall be OPERABLE, with the associated main steam atmospheric relief isolation (block) valve in the open position.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS:

a.

With one required SGARBV line inoperable, restore required SGARBV line to OPERABLE status within 7 days or be in at least MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in MODE 4 without reliance upon steam generator for heat removal within the next 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

b.

With two or more required SGARBV lines inoperable, restore all but one required SGARBV line to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in at least MODE 3 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in MODE 4 without reliance upon steam generator for heat removal within the next 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

SURVEILLANCE REQUIREMENTS 4.7.1.6.1 Verify one complete cycle of each SGARBV at the frequency specified in the Surveillance Frequency Control Program.

4.7.1.6.2 Verify one complete cycle of each main steam atmospheric relief isolation (block) valve at the frequency specified in the Surveillance Frequency Control Program.

Amendment No. 151, 258, 3/4 7-9a 285

MILLSTONE - UNIT 3 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a.

Two physically independent circuits between the offsite transmission network and the onsite Class 1E Distribution System, and b.

Two separate and independent diesel generators, each with:

1.

A separate day tank containing a minimum volume of 278 gallons of fuel, 2.

A separate Fuel Storage System containing a minimum volume of 32,760 gallons of fuel, 3.

A separate fuel transfer pump, 4.

Lubricating oil storage containing a minimum total volume of 280 gallons of lubricating oil, and 5.

Capability to transfer lubricating oil from storage to the diesel generator unit.

APPLICABILITY:

MODES 1, 2, 3, and 4.

NOTE LCO 3.0.4.b is not applicable to diesel generators Amendment No. 64, 97, 112, 210, 229, 3/4 8-1 285

MILLSTONE - UNIT 3 OPERATING LIMITING CONDITION FOR OPERATION (Continued)

ACTION:

Inoperable Equipment Required ACTION a.

One offsite circuit a.1 Perform Surveillance Requirement 4.8.1.1.1.a for remaining offsite circuit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to or after entering this condition, and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

AND a.2 Restore the inoperable offsite circuit to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b.

One diesel generator b.1 Perform Surveillance Requirement 4.8.1.1.1.a for the offsite circuits within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to or after entering this condition, and at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

AND b.2 Demonstrate OPERABLE diesel generator is not inoperable due to common cause failure within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or perform Surveillance Requirement 4.8.1.1.2.a.5 for the OPERABLE diesel generator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

AND Amendment No. 64, 97, 112, 210, 229, 3/4 8-1a 285

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 345 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-65 AND AMENDMENT NO. 285 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-49 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

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

1.0 INTRODUCTION

By letter dated April 6, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22096A221), Dominion Energy Nuclear Connecticut, Inc. (DENC, the licensee), requested changes to the technical specifications (TS) for Millstone Power Station (Millstone), Unit Nos. 2 (MPS2) and 3 (MPS3). The proposed changes would modify TS requirements for mode change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 4.0.4 to adopt the provisions of Technical Specification Task Force Traveler 359, Revision 9 (TSTF-359), Increase Flexibility in Mode Restraints. The availability of TSTF-359 for adoption by licensees was announced in the Federal Register on April 4, 2003 (68 FR 16579) as part of the Consolidated Improvement Process (CLIIP).

TSTF-359 was one of the industrys initiatives implemented under the risk-informed TS program. These initiatives were intended to maintain or improve safety while reducing unnecessary burden and to make TS requirements consistent with the U.S. Nuclear Regulatory Commissions (NRCs or Commissions) other risk-informed regulatory requirements, in particular, the Maintenance Rule.

Prior to the approval of TSTF-359, the Standard Technical Specifications (STS, NUREG-1430 through 1434) specified that a nuclear power plant could not go to higher modes of operation (i.e., move toward power operation) unless all TS systems, normally required for the higher mode, were operable. This limitation was typically included in LCO 3.0.4 and SR 3.0.4 for each plant. LCO 3.0.4 and SR 3.0.4 in the STS stated, in part, that when an LCO or SR is not met, entry into a MODE or other specified condition in the applicability shall not be made except when the associated actions to be entered permit continued operation in the MODE or other specified condition in the applicability for an unlimited period of time. In TSTF-359, the industry stated that this requirement was unnecessarily restrictive and could unduly delay plant startup while considerable resources were used to resolve startup issues that were risk insignificant or low risk. A maintenance activity that takes longer than planned could delay a mode change and adversely impact a utilitys orderly plant startup and return to power operation. The objective of TSTF-359 is to provide additional operational flexibility without compromising plant safety.

MPS2 is a Combustion Engineering design nuclear plant and MPS3 is a Westinghouse design nuclear plant. MPS2 and MPS3 have not adopted the STS. The MPS2 and MPS3 plant-specific equivalents to the STS LCO 3.0.4 and SR 3.0.4 are LCO 3.0.4 and SR 4.0.4. The proposed changes in the LAR to LCO 3.0.4 and SR 4.0.4 would allow mode changes into a TS condition that has a specific required action and completion time. The licensee will utilize the LCO 3.0.4 and SR 3.0.4 allowances only when they determine that there is a high likelihood that the LCO will be satisfied within the LCO completion time (CT), after the mode change. In addition, the LCO 3.0.4 and SR 4.0.4 allowances can be applied to values and parameters in specifications when explicitly stated in the TS (non-system/component TS such as: reactor coolant system specific activity). These changes are in addition to the current mode change allowance when a required action has an indefinite completion time. The LCO 3.0.4 and SR 4.0.4 mode change allowances are not permitted for the systems and components (termed higher risk) listed in section 3.1.1, Identification of Risk-Important TS Systems and Components, for the modes specified. Two examples are: (1) Westinghouse plants cannot transition from Mode 5 to Mode 4 without a high head safety injection system train operable; and (2) Westinghouse and Combustion Engineering plants cannot transition up into any mode with an inoperable required emergency diesel generator.

2.0 REGULATORY EVALUATION

2.1 Description of Changes 2.1.1 Proposed Change to MPS2 and MPS3 TS LCO 3.0.4 and SR 3.0.4 Currently, LCO 3.0.4 for MPS2 and MPS3 does not allow entrance into a higher mode (or other specified condition) in the applicability when an LCO is not met, except when the associated Actions to be entered permit continued operation in that mode or condition indefinitely, or a specific exception is granted. Similarly, when an LCOs surveillances have not been met within their specified frequency, entry into a higher mode (or other specified condition) is not allowed by SR 4.0.4.

The current MPS2 and MPS3 TS LCO 3.0.4 reads:

Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for the Limiting Condition for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when conformance to them permits continued operation of the facility for an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

In addition, LCO 3.0.4 for MPS3 also states that Exceptions to these requirements are stated in the individual specifications.

The licensees proposed revision to both the MPS2 and MPS3 LCO 3.0.4 reads:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The current SR 4.0.4 for MPS2 and MPS3 reads:

Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

The licensee proposed a revision to SR 4.0.4 for both units that will conform to the proposed changes to LCO 3.0.4 and read:

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The proposed TS LCO 3.0.4.a retains the current allowance for when the required actions allow indefinite operation. The proposed TS LCO 3.0.4.b allows entering modes or other specified conditions in the applicability except when higher-risk systems and components, for the mode being entered, are inoperable. When applying TS LCO 3.0.4.b, the decision for entering a higher mode or condition in the Applicability of the LCO will be made by plant management after the required risk assessment has been performed and requisite risk management actions established, through the program established to implement Title 10 of the Code of Federal Regulations 10 CFR 50.65(a)(4). Entry into the modes or other specified conditions in the Applicability of the TS shall be for no more than the duration of the applicable required actions completion time, or until the LCO is met. The licensee has proposed to remove current notes in individual specifications that prohibit mode changes which are now encompassed by LCO 3.0.4.b. Similarly, the licensee has proposed to add notes that prohibit mode changes under LCO 3.0.4.b for higher-risk systems and components. The proposed LCO 3.0.4.b allowance can involve multiple components in a single LCO or in multiple LCOs; however, use of the LCO 3.0.4.b provisions is always contingent upon completion of a 10 CFR, Part 50, section 65(a)(4)-based risk assessment.

LCO 3.0.4 allowances related to values and parameters of TS are not typically addressed by LCO 3.0.4.b risk assessments and are therefore addressed by a new LCO 3.0.4.c. LCO 3.0.4.c refers to allowances already in the TS and annotated in the individual TS. LCO 3.0.4.c also allows for entry into the modes or other specified conditions in the Applicability for TS for no more than the duration of the applicable required actions completion time or until the LCO is met or the unit is not within the applicability of the TS.

Existing LCO 3.0.4 exceptions are removed with this change consistent with TSTF-359-A.

2.1.2 Additional Proposed Changes to MPS2 TS The licensee proposed to make the following additional changes to the TSs for MPS2, consistent with TSTF-359-A:

Technical Specification No.

Description of Change LCO 3.4.8 Actions b and d are revised to state that LCO 3.0.4.c is applicable to Dose Equivalent I-131 and Xe-133.

LCO 3.4.9.3 Action f that provides an exception to LCO 3.0.4 is deleted. A new note is added to the Actions that states that LCO 3.0.4.b is not applicable when entering Mode 4. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.5.3 A new note is added to the Actions that states that LCO 3.0.4.b is not applicable to the high pressure safety injection subsystem.

LCO 3.7.1.2 A new note is added to the Actions that states that LCO 3.0.4.b is not applicable.

LCO 3.8.1.1 A new note is added to the Actions that states that LCO 3.0.4.b is not applicable to diesel generators.

Bases for LCO 3.0.4 The existing MPS2 Bases for LCO 3.0.4 are replaced with TSTF-359 bases for Improved Technical Specifications (ITS) LCO 3.0.4.

Bases for SR 4.0.4 The existing MPS2 Bases for SR 4.0.4 are replaced with TSTF-359 bases for ITS SR 3.0.4.

Bases for LCO 3.4.8 The bases are revised to reflect LCO 3.0.4.c allowance consistent with TSTF-359.

Bases for LCO 3.4.9.3 The Bases are revised to reflect deletion of the paragraph in Action f that provided an exception to LCO 3.0.4. Discussion is added to address the application of LCO 3.0.4.b.

Technical Specification No.

Description of Change Bases for LCO 3.5.3 Discussion is added to address the inapplicability of LCO 3.0.4.b.

Bases for LCO 3.7.1.2 Discussion is added to address the inapplicability of LCO 3.0.4.b.

Bases for LCO 3.8.1.1 Discussion is added to address the inapplicability of LCO 3.0.4.b.

2.1.3 Additional Proposed Changes to MPS3 TS The licensee proposed to make the following additional changes to the TS for MPS3, consistent with TSTF-359:

Technical Specification No.

Description of Change LCO 3.3.3.5 Delete Action c, which permits entry into an Operational Mode while subject to the Action requirements.

LCO 3.3.3.6 Delete Action g, which permits entry into an Operational Mode while subject to the Action requirements.

LCO 3.4.4 Delete Action e, which permits entry into an Operational Mode while subject to the Action requirements.

LCO 3.4.8 Revise Actions to indicate that LCO 3.0.4.c is applicable to Dose Equivalent 1-131 and Xe-133, consistent with TSTF-359.

LCO 3.4.9.3 Add new note that LCO 3.0.4.b is not applicable when entering Mode 4, consistent with TSTF-359. Delete Action g, which permits entry into an Operational Mode while subject to the Action requirements. TSTF-359 removes existing LCO 3.0.4 exceptions.

LCO 3.5.3 Add a new note that LCO 3.0.4.b is not applicable to high pressure safety injection subsystem, consistent with TSTF-359.

LCO 3.6.1.3 Delete Action a.4, which permits entry into an Operational Mode while subject to the Action requirements.

LCO 3.7.1.2 Add a new note that LCO 3.0.4.b is not applicable, consistent with TSTF-359.

LCO 3.7.1.6 Delete the last sentence in Action a, which provides an exception to LCO 3.0.4.

LCO 3.8.1.1 Add a new note that LCO 3.0.4.b is not applicable to diesel generators, consistent with TSTF-359.

Bases for LCO 3.0.4 The existing MPS3 Bases for LCO 3.0.4 are replaced with TSTF-359 bases for ITS LCO 3.0.4.

Bases for SR 4.0.4 The existing MPS3 Bases for SR 4.0.4 are replaced with TSTF-359 bases for ITS SR 3.0.4.

Bases for LCO 3.4.8 Revise bases to reflect LCO 3.0.4.c allowance consistent with TSTF-359.

Bases for LCO 3.4.9.3 Discussion is added to address the application of LCO 3.0.4.b.

Bases for LCO 3.5.3 Discussion is added to address the application of LCO 3.0.4.b.

Technical Specification No.

Description of Change Bases for LCO 3.7.1.2 Discussion is added to address the application of LCO 3.0.4.b.

Bases for LCO 3.8.1.1 Discussion is added to address the application of LCO 3.0.4.b.

2.1.4 Variations from TSTF-359 proposed for MPS2 and MPS3 The licensee proposed the following variations from the TS changes described in the modified TSTF-359, Revision 9 (ML031190607), and the NRC staffs model safety evaluation published in the Federal Register on April 4, 2003 (68 FR 16579). Specifically, the licensee stated:

1. The MPS2 and MPS3 TS utilize different numbering and titles than NUREG 1432, Standard Technical Specifications, Combustion Engineering Plants, [for MPS2] and NUREG-1431, "Standard Technical Specifications, Westinghouse Plants, [for MPS3] on which TSTF-359 was based. Additionally, the MPS2/3 TS do not contain all of the TS that were revised by TSTF-359.

These differences are administrative and do not affect the applicability of TSTF-359 to MPS2/3 TS.

2. MPS2 and MPS3 have not converted to the STS from NUREG-1432, and NUREG-1431, respectively. As a result, the MPS2/3 individual SRs do not stipulate the specific time frames and conditions necessary for meeting the SRs to allow entry into the mode or condition of applicability without having performed the SR. Consequently, the existing exceptions to SR 4.0.4 are proposed to be retained in the MPS2/3 TS, and the proposed Bases for SR 4.0.4 will not include the paragraph below that is included in TSTF-359 for the Bases equivalent to STS SR 3.0.4.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveillance that could not be performed until after entering the LCO's Applicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note, as not required (to be met or performed) until a particular event, condition, or time has been reached. Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

3. TSTF-359 and the model safety evaluation refer to Regulatory Guide (RG) 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. However, RG 1.182 was withdrawn in November 2012 because it was redundant to the inclusion of its information in RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants [ML18220B281].

Therefore, the proposed Bases for MPS2/3 LCO 3.0.4 refer to RG 1.182. This is an administrative variation that does not affect the applicability of TSTF-359 to the MPS2/3 TSs.

4. One minor readability change to the TS has been included with insertion of the word or between LCO 3.0.4.a and 3.0.4.b to highlight the mutual exclusivity of these elements. This "or" connector was contained in the NRC Notice of Availability published April 4, 2003 (68 FR 16585).

2.2 Regulatory Review In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) surveillance requirements (SR); (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plants TS. As stated in 10 CFR 50.36(c)(2)(i), the Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications By convention, the LCOs are contained in Sections 3.1 through 3.10 of the STS. For MPS2 and MPS3, this equates to Sections 3/4.1 through 3/4.12 in their plant TS. TS Section 3/4.0, on LCO and SR Applicability, provides details or ground rules for complying with the LCOs.

LCO 3.0.4 and SR 4.0.4 address requirements for LCO compliance when transitioning between modes.

The TSs have taken advantage of risk technology as experience and capability have increased. Since the mid-1980s, the NRC has been reviewing and granting improvements to TSs that are based, in part, on probabilistic risk assessment (PRA) insights. In its final policy statement on TS improvements of July 22, 1993, the Commission stated that it expects that licensees will utilize any plant-specific PRA or risk survey in preparing their TS-related submittals. In evaluating these submittals, the NRC staff applies the guidance in RG 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, (ML17317A256) and in RG 1.177, Revision 2, An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications (ML20164A034). The NRC staff has appropriately adapted this guidance to assess the acceptability of upward mode changes with equipment inoperable. This review had the following objectives:

To ensure that the plant risk does not increase unacceptably during the actual implementation of the proposed change (e.g., when the plant enters a higher operational condition while an LCO is not met). This risk increase is referred to as temporary.

To compare and assess the risk impact of the proposed change to the acceptance guidelines of the Commissions Safety Goal Policy Statement, as documented in RG 1.174. The risk impact, which is measured by the average yearly risk increase associated with the change, aims at minimizing the cumulative risk associated with the proposed change so that the plants average baseline risk is maintained within a minimal range.

To assess the licensees ability to identify risk-significant configurations resulting from maintenance or other operational activities and take appropriate compensatory measures to avoid such configurations.

The NRC staff reviewed licensee reliance on 10 CFR 50.65(a)(4) for the non-higher-risk systems and components, and related guidance to assess and manage the risk of upward mode changes. The Commission has found that compliance with the industry guidance for implementation of 10 CFR 50.65(a)(4), as endorsed by RG 1.160, and mandated by LCO 3.0.4, SR 4.0.4, and SR 4.0.3, satisfies the configuration risk management objectives of RG 1.177 for TS surveillance interval and completion time extensions. The licensees reliance on 10 CFR 50.65(a)(4) processes that are consistent with the provisions of the NRC-endorsed industry guidance was also found to be adequate for managing the risk of missed surveillances as described in the Federal Register on September 28, 2001 (66 FR 49714).

The NRC staff review also had the objective of ensuring that existing NRC inspection programs have the necessary controls in place to allow the NRC staff to oversee the implementation of the proposed change, reliance on 10 CFR 50.65(a)(4) processes or programs, and the ability to adequately assess the licensees performance associated with risk assessments. The review encompassed inspection procedures (i.e., NRC Inspection Procedure 62709 dated 12/28/00, Configuration Risk Assessment and Risk Management Process, and NRC Inspection Procedure 71111.13 dated 01/17/02, Maintenance Risk Assessments and Emergent Work Control), the significance determination process (SDP)

(i.e., Maintenance Risk Assessment and Risk Management Significance Determination Process), enforcement guidance (i.e., Enforcement Manual Section 7.11, Actions Involving the Maintenance Rule), and the associated reactor oversight process (ROP).

3.0 TECHNICAL EVALUATION

During the development of the current STS, improvements were made to LCO 3.0.4, such as clarifying its applicability with respect to plant shutdowns, cold shutdown mode and refueling mode. In addition, during the STS development, almost all the LCO with completion times greater than or equal to 30 days, and many LCOs with completion times greater than or equal to 7 days were given individual LCO 3.0.4 exceptions. During some conversions to the STS, individual plants provided acceptable justifications for other LCO 3.0.4 exceptions. All of these specific LCO 3.0.4 exceptions allow entry into a mode or other specified condition in the TS applicability while relying on the TS required actions and associated completion times. The changes proposed by MPS2 and MPS3, would provide standardization and consistency to the use and application of LCO 3.0.4, both internal to and between each of the specifications, as well as with the STS. This proposed change will also ensure consistency through the utilization of appropriate levels of risk assessment of plant configurations for application of LCO 3.0.4.

However, nothing in this safety evaluation should be interpreted as encouraging upward mode transition with inoperable equipment. Good practice should dictate that such transitions should normally be initiated only when all required equipment is operable and that mode transition with inoperable equipment should be the exception rather than the rule.

The current LCO 3.0.4.a allowances are retained in the proposal and do not represent a change in risk from the current situation. The LCO 3.0.4.b allowances apply to systems and components and require a risk assessment prior to utilization to ensure an acceptable level of safety is maintained. The LCO 3.0.4.c allowances apply to parameters and values which have been previously approved by the NRC in a plants specific TSs. The licensee provided in the TS Bases, a discussion and list of each NRC-approved LCO 3.0.4.c specific value and parameter allowance. The TS Bases of LCO 3.0.4 are revised to explain the new allowances and their utilization.

In its review of TSTF-359, the NRC staff did a generic qualitative assessment of the risk impact of the proposed change in LCO 3.0.4.b allowances by evaluating how licensee implementation of the proposed risk-informed approach is expected to meet the requirements of the applicable RGs. The NRC staff referred to the guidance provided in RG 1.174 and in RG 1.177. RG 1.177 provides the NRC staffs recommendations on using risk information to assess the impact of proposed changes to nuclear power plant TSs on the risk associated with plant operation.

Although RG 1.177 does not specifically address the type of generic change in this proposal, the NRC staff considered the approach documented in RG 1.177 in evaluating the risk information provided in support the proposed changes in TS LCO 3.0.4.

The NRC staffs evaluation of how the implementation of the proposed risk-informed approach, used to justify LCO 3.0.4.b allowances, agrees with the objectives of the guidance outlined in RG 1.177 is discussed in section 3.1. Oversight of the risk-informed approach associated with the LCO 3.0.4.b allowances is discussed in section 3.2 of this safety evaluation.

3.1 Evaluation of Risk Management Both the temporary and cumulative risk of the proposed change is adequately limited. The temporary risk is limited by the exclusion of higher-risk systems and components, and completion time limits contained in the TSs (section 3.1.1 of this safety evaluation). The cumulative risk is limited by the temporary risk limitations and by the expected low frequency of the proposed operational condition changes with inoperable equipment (section 3.1.2 of this safety evaluation). Adequate NRC oversight of the licensees ability to use the LCO 3.0.4.b provisions under appropriate circumstances (i.e., to identify risk-significant configurations when entering a higher mode or condition in the applicability of an LCO (section 3.1.3 of this safety evaluation)) is provided by NRC inspection of the licensees implementation of 10 CFR 50.65(a)(4) as applied to the proposed change.

3.1.1 Temporary Risk Increases The RG 1.177 proposes the incremental conditional core damage probability (ICCDP) and the incremental conditional large early release probability (ICLERP) as appropriate measures of the increase in probability of core damage and large early release, respectively, during the period of implementation of a proposed TS change. In addition, RG 1.177 stresses the need to preclude potentially high-risk configurations introduced by the proposed change. The ICCDP associated with any specified plant condition, such as the condition introduced by entering a higher mode with plant equipment inoperable, is expressed by the following equation:

ICCDP = R d = (R1 - R0) d (1) where:

R = the conditional risk increase, in terms of core damage frequency (CDF), caused by the specified condition d = the duration of the specified plant condition R1 = the plant CDF with the specified condition permanently present R0 = the plant CDF without the specified condition The same expression can be used for ICLERP by substituting the measure of risk (i.e., large early release frequency (LERF) for CDF). The magnitude of the ICCDP and ICLERP values associated with plant conditions applicable to LCO 3.0.4.b allowances can be managed by the duration, d, of such conditions. The following sections discuss how the key elements of the proposed risk-informed approach, used to justify LCO 3.0.4. and, thus, prevent any significant temporary risk increases.

3.1.2 Identification of Risk-Important TS Systems and Components A major element that limits the risk of the proposed mode change flexibility is the exclusion of certain systems and associated LCO for the mode change allowance. TSs allow operation in Mode 1 (Power Operation) with specified levels of inoperability for specified times. This provides a benchmark of currently acceptable risk against which to measure any incremental risk inherent in the proposed LCO 3.0.4.b. If a system inoperability accrues risk at a higher rate in one or more of the transition operational conditions than it would in Mode 1, then an upward transition into that mode should not be allowed without demonstration of a high degree of experience and sophistication in risk management. However, the risk management process evaluated in section 3.1.3 (of this safety evaluation), is adequate if higher-risk systems/components are excluded from the scope of LCO 3.0.4.b.

The importance of most TS systems in mitigating accidents increases as power increases.

However, some TS systems are relatively more important during lower power and shutdown operations, because:

Certain events are peculiar to modes of plant operation other than power operation, Certain events are more probable at modes of plant operation other than power operation, and Some modes of plant operation have less mitigation system capability than power operation.

The risk information submitted in support of the proposed changes to TS LCO 3.0.4 and SR 3.0.4 in TSTF-359 included qualitative risk assessments performed by each owners group to identify higher-risk systems and components at the various modes of operation, including transitions between modes, as the plant moves upward from the refueling mode of operation toward power operation. The owners groups generic qualitative risk assessments are included as attachments to TSTF-359, Revision 9 (ML031190607). Each of the owners groups generic qualitative risk assessments discuss the technical approach used and the systems/components subsequently determined to be of higher risk significance; the systems/components not to be granted the TS LCO 3.0.4 allowances for the various operational conditions are listed.

The owners groups generic qualitative risk assessments applicable to this LAR are:

Westinghouse Owners Group, Qualitative Risk Assessment Supporting Increased Flexibility in MODE Restraints, Combustion Engineering Owners Group, Qualitative Risk Assessment for Relaxation of Mode Entry Restraints, CE Nuclear Power LLC, CE NPSD-1207, Rev 0.

Following interactions with the NRC staff, all owners groups used the same systematic approach in their qualitative risk assessments to identify the higher-risk systems in the STS, consisting of the following steps:

Identification of plant conditions (i.e., plant parameters and availability of key mitigation systems) associated with changes in plant modes while returning to power, Identification of key activities that have the potential to impact risk and which are in progress during transitions between modes while the plant is returning to

power, Identification of applicable accident initiating events for each mode or other specified condition in the applicability, and Identification of the higher-risk systems and components by combining the information in the first three steps (qualitative risk assessment).

The risk assessments properly used the results and insights from previous deterministic and probabilistic studies to systematically search for plant conditions in which certain key plant components are more important in mitigating accidents than during operation at power (MODE 1). This search was systematic, taking the following factors into account for the various stages of returning the plant to power:

The status of accident mitigation and normally operating systems, The status of key plant parameters such as reactor coolant system pressure, The key activities that are in progress during transitions between modes which have the potential to impact risk (e.g., the transfer from auxiliary to main feedwater at some PWR plants when Mode 1 is entered),

The applicable accident initiating events for each mode of plant operation, and Design and operational differences among plants or groups of plants.

The following systems and components applicable to this LAR were identified as higher-risk systems and components when the plant is entering a new mode.

Westinghouse Owners Group Plants System Entering Mode Emergency Diesel Generators 4, 3, 2, 1 Auxiliary Feedwater (AFW) System (for plants depending on AFW for startup) 4, 3, 2, 1 High Head Safety Injection 4

Low-Temperature Overpressure Protection (LTOP) System 4

Combustion Engineering Owners Group Plants System Entering Mode Emergency Diesel Generators 5, 4, 3, 2, 1 Auxiliary Feedwater /Emergency Feedwater (AFW/EFW) System 4, 3, 2, 1 High Pressure Safety Injection (HPSI) System 4, 3 (below 1700 psia)

LTOP/PORVs (when used for Low-Temperature Overpressure Protection (LTOP))

5, 4 (below set temperature)

Shutdown Cooling System (Low Pressure Safety Injection (LPSI) pumps) 5 If a licensee identifies a higher-risk system for only some of the modes of applicability, the TSs for that system would be modified by a note that reads, for example, "LCO 3.0.4(b) is not applicable when entering MODE 1 from MODE 2." Systems identified as higher risk for Mode 4 and 5 for boiling water reactors (BWRs), are also excluded from transitioning up to the mode of higher risk, and as previously discussed, notes for those transitions are superfluous. In addition, operational condition transitions for Modes 5 and 6 for PWRs, will be addressed by administrative controls.

The NRC staffs review of the owners groups qualitative risk assessments finds that they are of adequate quality to support the application (i.e., they identify the higher-risk systems and components) associated with entering higher modes of plant operation with equipment inoperable while returning to power.

The licensee has adopted the TSTF-359 wording for MPS2 and MPS3 TS LCO 3.0.4 and SR 4.0.4. Existing exceptions LCO 3.0.4 have been deleted from various TS LCOs as described in TSTF-359, and the supporting documentation. LCO 3.0.4.c has been referenced appropriately for the TS defining limits on parameters and values. The licensee has, consistent with the above tables, added notes to the appropriate TS to state that the revised TS LCO 3.0.4.b, allowing mode changes with inoperable equipment, is not applicable for the previously mentioned higher-risk systems.

Limited Time in TS Required Actions Any temporary risk increase will be limited by, among other factors, duration constraints imposed by the TS completion times of the inoperable systems. For the systems and components that are not higher risk, any temporary risk increase associated with the proposed allowance will be smaller than what is considered acceptable when the same systems and components are inoperable at power. This is due to the fact that completion times associated with the majority of TS systems and components were developed for power operation and pose a smaller plant risk for action statement entries initiated or occurring at lower modes of operation as compared to power operation.

The TS LCO 3.0.4.b allowance will be used only when the licensee determines that there is a high likelihood that the LCO will be satisfied following the mode change. This will minimize the likelihood of additional temporary risk increases associated with the need to exit a mode due to failure to restore the unavailable equipment within the completion time (CT). In most cases, licensees will enter into a higher mode with the intent to move up to Mode 1 (power operation).

As discussed in section 3.2 (of this safety evaluation), the revised ROP monitors unplanned power changes as a performance indicator. The ROP, thus, discourages licensees from entering a mode or other specified condition in the applicability of an LCO, and moving up in power, when there is a likelihood that the mode would have to be subsequently exited due to failure to restore the unavailable equipment within the CT. Another disincentive for licensees to enter a higher mode when an LCO is not met is related to reporting requirements. As clearly stated in 10 CFR 50.72 and 50.73, a report is required when a nuclear plant shutdown or mode change is required by TSs. The NRCs oversight program will provide the framework for inspectors and other staff to follow the history at a specific plant of entering higher modes while an LCO is not met and use such information in assessing the licensees actions and performance.

3.1.3 Cumulative Risk Increases The cumulative risk impact of the change to allow the plant to enter a higher operational condition of operation with one or more safety-related components unavailable (as proposed here), is measured by the average yearly risk increase associated with the change. In general, this cumulative risk increase is assessed in terms of both CDF and LERF (i.e., CDF and LERF, respectively). The increase in CDF due to the proposed change is expressed by the following equation, which integrates the risk impact from all expected specified conditions (i.e.,

all expected plant conditions caused by mode changes with various TS systems and components unavailable).

CDF = (CDFi) = ICCDPi fi (2)

Where CDFi = the CDF increase due to specified condition i ICCDPi = the ICCDP associated with specified condition i fi = the average yearly frequency of occurrence of specified condition i A similar expression can be used for LERF by substituting the measure of risk (i.e., LERF for CDF). The magnitude of the CDF and LERF values associated with plant conditions applicable to LCO 3.0.4.b allowances can be managed by controlling the temporary risk increases, in terms of both CDF and LERF (i.e., ICCDP and ICLERP), and the frequency (f), of each of such conditions. In addition to the points made in the previous section regarding temporary risk increases, the following points put into perspective how the key elements of the proposed risk-informed approach, used to justify an LCO 3.0.4.b allowance, are expected to prevent significant cumulative risk increases by limiting the frequency of its use:

The frequency of risk-significant conditions will be limited by not providing the LCO 3.0.4.b allowances to the higher-risk systems and components.

The frequency of risk-significant conditions will be limited by the requirement to assess the likelihood that the LCO will be satisfied following the mode change.

The frequency of risk-significant conditions is limited by the fact that such conditions can occur only when the plant is returning to power following shutdown, i.e., during a small fraction of time per year (data over the past five years indicate that the plants are averaging 2.1 startups per year).

The addition of the proposed TS LCO 3.0.4.b allowances to the plant maintenance activities is not expected to change the plants average (cumulative) risk significantly.

3.1.4 Risk Assessment and Risk Management of Mode Changes With all safety systems and components operable, a plant can transition up in operational condition to power operation. With one or more system(s) or component(s) inoperable, this change permits a plant to transition up in mode to power operation if the inoperable system(s) or component(s) are not in the pre-analyzed higher risk category, a 10 CFR 50.65(a)(4) based risk assessment is performed prior to the mode transition, and the requisite risk management actions are taken. The proposed TS Bases state, LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed.

It should be noted that the risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable TS equipment regardless of whether the equipment is included in the licensees normal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by RG 1.160. The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability statement, and any corresponding risk management actions.

A risk assessment and establishment of risk management actions, as appropriate, are required for determination of acceptable risk for entering MODE or other specified conditions in the Applicability when an LCO is not met. Elements of acceptable risk assessment and risk management actions are included in section 11 of NUMARC 93-01, Assessment of Risk Resulting from Performance of Maintenance Activities (ML11116A198), as endorsed by RG 1.160, which addresses general guidance for conduct of the risk assessment, gives quantitative and qualitative guidelines for establishing risk management actions, and provides example risk management actions. These risk management actions include actions to plan and conduct other activities in a manner that controls overall risk, actions to increase risk awareness by shift and management personnel, actions to reduce the duration of the conditions, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed Mode change is acceptable.

NUMARC 93-01 states that a licensees risk assessment process should be sufficiently robust and comprehensive to assess risk associated with maintenance activities during power operation, low power, and shutdown conditions (all modes of operation), including changes in plant conditions. NUMARC 93-01 also states that the risk assessment should include consideration of: the degree of redundancy available for performance of the safety function(s) served by the out-of-service equipment; the duration of the out-of-service condition; component and system dependencies that are affected; the risk impact of performing the maintenance during shutdown versus at power; and, the impact of mode transition risk. For power operation, key plant safety functions are those that ensure the integrity of the reactor coolant pressure boundary, ensure the capability to shut down and maintain the reactor in safe shutdown condition, and ensure the capability to prevent or mitigate the consequences of accidents that could result in potentially significant offsite exposures.

While the inoperabilities permitted by the completion times of TS required actions take into consideration the safety significance and redundancy of the system or components within the scope of an LCO, the completion times generally do not address or consider concurrent system or component inoperabilities in multiple LCOs. Therefore, the performance of the 10 CFR 50.65(a)(4) risk assessment which looks at the entire plant configuration is essential (and required) prior to changing the mode. The 10 CFR 50.65(a)(4)-based risk assessment will be used to confirm (or reject) the appropriateness of transitioning up in mode given the actual status of plant safety equipment.

The risk impact on the plant condition of invoking a TS LCO 3.0.4.b allowance will be assessed and managed through the program established to implement 10 CFR 50.65(a)(4). This program is consistent with RG 1.177 and RG 1.174 in its approach. The implementation guidance for paragraph (a)(4) of the Maintenance Rule addresses controlling temporary risk increases resulting from maintenance activities. This guidance, consistent with guidance in RG 1.177, establishes action thresholds based on qualitative and quantitative considerations and risk management actions. Significant temporary risk increases following a TS LCO 3.0.4.b allowance are unlikely to occur unless:

High-risk configurations are allowed (e.g., certain combinations of multiple component outages) or Risk management of plant operation activities is inadequate.

The requirements associated with the proposed change are established to ensure that such conditions will not occur.

The thresholds of the cumulative (aggregate) risk impacts, assessed pursuant to 10 CFR 50.65(a)(4) and the associated implementation guidance, are based on the permanent change guidelines in NRC RG 1.174. Therefore, licensees will manage the risk exercising TS LCO 3.0.4 in conjunction with the risk from other concurrent plant activities to ensure that any increase, in terms of CDF and LERF will be small and consistent with the Commissions Safety Goal Policy Statement.

3.2 Oversight The ROP provides a means for assessing the licensees performance in the application of the proposed mode change flexibility. The adequacy of the licensees assessment and management of maintenance-related risk is addressed by existing inspection programs and guidance for 10 CFR 50.65(a)(4). Although the current versions of that guidance do not specifically address application of the licensees (a)(4) program to support risk-informed TSs, it is expected that, in most cases, risk assessment and management associated with risk-informed TSs would be required by (a)(4), because maintenance activities will be involved.

Adoption of the proposed change will make failure to assess and manage the risk of an upward mode change with inoperable equipment covered by TSs, prior to commencing such a mode change, a violation of TSs. Further, as explained above in general, under most foreseeable circumstances, such a change in configuration would also require a risk assessment under 10 CFR 50.65(a)(4). Inoperable systems or components will necessitate maintenance to restore them to operability, and hence a 10 CFR 50.65(a)(4) risk assessment would be performed prior to the performance of those maintenance actions (except for immediate plant stabilization and restoration actions if necessary). Further, before altering the plants configuration, including plant configuration changes associated with mode changes, the licensee must update the existing (a)(4) risk assessment to reflect those changes.

The Federal Register notice issuing a revision to the Maintenance Rule, 10 CFR 50.65 (64 FR 38553, dated July 19, 1999), along with NRC Inspection Procedure 71111.13, and section 11, dated February 22, 2000, Assessment of Risk Resulting from Performance of Maintenance Activities," of NUMARC 93-01, all indicate that to determine the safety impact of a change in plant conditions during maintenance, a risk assessment must be performed before changing plant conditions. The bases for the proposed TS change mandate that the risk assessment and management of upward mode changes will be conducted under the licensees program and process for meeting 10 CFR 50.65(a)(4). Oversight of licensee performance in assessing and managing the risk of plant maintenance activities is conducted principally by inspection in accordance with ROP Baseline Inspection Procedure (IP) 71111.13, Maintenance Risk Assessment and Emergent Work Control. Supplemental IP 62709, Configuration Risk Assessment and Risk Management Process, is utilized to evaluate the licensees process, when necessary.

The ROP is described in overview in NUREG-1649, Rev. 6, Reactor Oversight Process (ML16214A274), and in detail in the NRC Inspection Manual. IP 71111.13 requires verification of performance of risk assessments when they are required by 10 CFR 50.65(a)(4) and in accordance with licensee procedures. The procedure also requires verification of the adequacy of those risk assessments and verification of effective implementation of licensee-prescribed risk management actions. The rule itself requires such assessment and management of risk prior to maintenance activities, including preventive maintenance, surveillance, and testing (and promptly for emergent work) during all modes of plant operation.

The guidance documents for both industry implementation of section 50.65(a)(4) of 10 CFR and NRC oversight of that implementation indicate that changes in plant configuration (which would include mode changes) in support of maintenance activities must be taken into account in the risk assessment and management process. Revisions to NRC inspection guidance and licensee implementation procedures will be needed to address oversight of risk assessment and management required by TSs in support of mode changes that are not already required under the circumstances by 10 CFR 50.65(a)(4). This consideration provides performance-based regulatory oversight of the use of the proposed flexibility, and a disincentive to use the flexibility without the requisite care in planning.

In addition, the NRC staff developed the SDP guidance for use in assessing inspection findings related to 10 CFR 50.65(a)(4). This guidance was issued in draft for comment and became final during August 2008. The ROP considers inspection findings and performance indicators in evaluating licensee ability to operate safely. The SDP is used to determine the significance of inspection findings related to licensee assessment and management of the risk associated with performing maintenance activities under all plant operating or shutdown conditions. Unplanned reactor scrams and unplanned power changes are two of the Reactor Safety Performance Indicators that the ROP utilizes to assess licensee performance and inform the public. The ROP will provide a disincentive to entering into power operation (Mode 1) when there is a significant likelihood that the mode would have to be subsequently exited due to failure to restore the unavailable equipment within the completion time.

3.3 Evaluation of Proposed Variations As stated in section 2.1.4 above, the licensee proposed four variations from the approved TSTF-359. The staff evaluated the proposed variations and concluded the following:

The staff found that MPS2 and MPS3 TSs having different numbering and titles than the STS used for TSTF-359 is an administrative difference and has no technical bearing on the acceptability of the proposed LAR. In addition, the staff found that MPS2 and MPS3 TSs not containing all of the TSs that were revised by TSTF-359 also has no technical bearing on the acceptability of the LAR. TSTF-359 defines the conditions under which it is acceptable to make a mode change with inoperable equipment and the technical basis for the staffs approval of TSTF-359 is not tied to specific TS systems or components. The mode change is acceptable if the licensee meets one of the three criteria in the revised LCO 3.0.4. Therefore, this variation is acceptable. The staff also found that the addition of the word "or" between LCO 3.0.4.a and 3.0.4.b for readability is an administrative change since the licensee would use the 3.0.4 option that is applicable to their plant condition at the time of the mode change.

The staff also evaluated the licensees proposal to reference RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (ML18220B281). In lieu to references in TSTF-359 to RG 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. This change is acceptable because RG 1.182 was withdrawn in November 2012 after the staff determined it to be redundant due to the inclusion of its information in RG 1.160. Accordingly, referencing RG 1.160 in the proposed TS Bases for MPS2 and MPS3 LCO 3.0.4 is an appropriate administrative change and is acceptable.

The final variation proposed by the licensee is necessary because MPS2 and MPS3 have not converted to the STS. One of the improvements in the STS is to provide a specific time frame or conditions for conducting SRs to allow entry into the mode or condition of applicability when entry into the mode of applicability is necessary to achieve the conditions required to conduct the SR. For example, the SR in the Westinghouse STS for comparing the results of the plant calorimetric heat balance calculation to power range channel output is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is >15 % rated thermal power. This allows the plant to enter Mode 1 without having performed the SR in order to achieve the conditions necessary to perform the SR. Since the MPS2 and MPS3 do not include this feature of the STS, the MPS2 and MPS3 include exceptions to SR 4.0.4 that allow them to enter the mode of applicability when necessary to accomplish the SR. Accordingly the licensee proposed retaining their existing exceptions to SR 4.0.4 in the MPS2 and MPS3 TS. The staff evaluated the licensees proposal and found that the revised SR 4.0.4 does not impact the existing exceptions and therefore the licensee will retain the ability to perform the SR under the appropriate conditions. In addition, retaining the existing exceptions does not affect the applicability of TSTF-359 to MPS2 and MPS3 because the requirement for SRs (without exceptions) to be current prior to changing modes is retained. When an LCO is not met due to a surveillance not being met, then entry into the mode of applicability is controlled by LCO 3.0.4 consistent with TSTF-359. Therefore, this variation is acceptable.

3.4 Summary The licensee submitted proposed TS changes to allow entry into a higher mode of operation, or other specified condition in the TS Applicability, while relying on the TS conditions, and associated required actions and completion times, provided a risk assessment is performed to confirm the acceptability of that action. The proposal revises MPS2 and MPS3 TS LCO 3.0.4 and SR 4.0, and their application to the TSs. New paragraphs a, b, and c are proposed for TS LCO 3.0.4.

The proposed TS LCO 3.0.4.a retains the current allowance, permitting the mode change when the TS required actions allow indefinite operation.

Proposed TS LCO 3.0.4.b is the change to allow entry into a higher mode of operation, or other specified condition in the TS Applicability, while relying on the TS conditions and associated required actions and completion times, provided a risk assessment is performed to confirm the acceptability of that action for the existing plant configuration. The NRC staff review finds that the process proposed by the licensee for assessing and managing risk during the implementation of the proposed TS LCO 3.0.4.b allowances meets Commission guidance for TS changes. Key elements of this process are listed below.

A risk assessment shall be performed before any TS LCO 3.0.4.b allowance is invoked.

The risk impact on the plant condition when invoking an LCO 3.0.4.b allowance will be assessed and managed through the program established to implement 10 CFR 50.65(a)(4) and the associated guidance in RG 1.160. Allowing entry into a higher mode or condition in the Applicability of an LCO after a 10 CFR 50.65(a)(4) based risk assessment and appropriate risk management actions are taken for the existing plant configuration will ensure that plant safety is maintained.

The LCO 3.0.4.b allowance will be used only when the licensee determines that there is a high likelihood that the LCO will be satisfied within the required actions completion time.

TS systems and components which may be of higher risk during mode changes have been identified generically by each owners group for each plant operational mode or condition. Licensees will identify such plant-specific systems and components in the individual plant TSs. The proposed LCO 3.0.4.b allowance does not apply to these systems and components for the mode or condition in the applicability of an LCO at which they are of higher risk.

In adopting LCO 3.0.4.b, the licensee will ensure that plant procedures in place to implement 10 CFR 50.65(a)(4) address the situation where entering a mode or other specified condition in the applicability is contemplated with plant equipment inoperable.

Such plant procedures will follow the guidance endorsed by NRC RG 1.160.

The NRCs ROP provides the framework for inspectors and other NRC staff to oversee the implementation of 10 CFR 50.65(a)(4) requirements at a specific plant and assess the licensees actions and performance.

The LCO 3.0.4.b allowance does not apply to values and parameters of the TSs that have their own respective LCO (e.g., Reactor Coolant System Specific Activity), but instead those values and parameters are addressed by LCO 3.0.4.c. The TS values and parameters for which mode transition allowances apply, have a note that states LCO 3.0.4.c is applicable.

The objective of the proposed change is to provide additional operational flexibility without compromising plant safety.

Both MPS2 and MPS3 have a Bases control program in section 6 of the respective TSs which is consistent with the bases control program described in the STS for Combustion Engineering plants, NUREG-1432, Revision 5 and Westinghouse Plants, NUREG-1431, Revision 5. The licensee will make conforming changes to the TS Bases for TS LCO 3.0.4 and SR 4.0.4 concurrent with the license amendment. The NRC staff agrees that the TS Bases Control Program is the appropriate process for updating the affected TS Bases pages.

The licensee's proposed changes are acceptable because the adopted key elements requires the licensee to assess and manage risk, and they are consistent with NRC-approved TSTF-359 and the Commission's regulations.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Connecticut State official was notified of the proposed issuance of the amendment on February 7, 2023. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes surveillance requirements. 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 such finding published in the Federal Register on July 15, 2022 (87 FR 42508).

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.

Principal Contributor: R. Elliott, NRR Date: March 16, 2023

ML23058A454 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME RGuzman KEntz VCusumano DATE 02/28/2023 3/3/2023 01/09/2023 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzález RGuzman DATE 03/15/2023 03/16/2023

v t e Letter Sequence Approval
EPID:L-2022-LLA-0052, TSTF-359 (Approved, Closed)
Initiation Acceptance Administration Questions Answers Results Approval, Approval Other:
MONTHYEAR2023-03-16 [Table View]

Person / Time
ML23058A454
Site:	Millstone (DPR-065, NPF-049)
Issue date:	03/16/2023
From:	Richard Guzman NRC/NRR/DORL/LPL1
To:	Stoddard D Dominion Energy Nuclear Connecticut
References
EPID L-2022-LLA-0052
Download: ML23058A454 (57)
v • d • e

ML23058A454

Text

SUBJECT:

Dear Mr. Stoddard:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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