View source for B17621, Application for Amend to License DPR-21,reflecting Permanently Defueled Condition of Unit 1,Tech Specs Administrative Controls Section as Allowed by Guidance Contained in NRC Administrative Ltr 95-06

{{Adams
| number = ML20205R267
| issue date = 04/19/1999
| title = Application for Amend to License DPR-21,reflecting Permanently Defueled Condition of Unit 1,Tech Specs Administrative Controls Section as Allowed by Guidance Contained in NRC Administrative Ltr 95-06
| author name = Necci R
| author affiliation = NORTHEAST NUCLEAR ENERGY CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000245
| license number = 
| contact person = 
| document report number = AL-95-06, AL-95-6, B17621, NUDOCS 9904220259
| package number = ML20205R270
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 95
| project = 
| stage = Request
}}

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Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128 (860) 447-1791 Fax (860) 444-4277 The Northeast Utilities System APR l 91999 Docket No. 50-245 B17621 Re:        10CFR50.36 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Millstone Nuclear Power Station, Unit No.1 Proposed Revision to Technical Specifications Permanently Defueled Technical Specifications On July 21,1998, Northeast Nuclear Energy Company (NNECO) informed the USNRC that Millstone Unit No.1 had permanently ceased operations and that the fuel had been permanently removed from the reactor vessel.* Pursuant to 10CFR50.82(a)(2), the certification in the letter modified the Millstone Unit No.1 license to permanently withdraw the authority to operate the unit. As a result, Millstone Unit No.1 is only authorized to possess special nuclear material and is prohibited from placing or retaining fuel in the reactor vessel.
Pursuant to 10CFR50.90, NNECO is submitting this proposed change to the Millstone Unit No.1 Technical Specifications to reflect the permanently defueled condition of the unit. Additionally, NNECO is submitting proposed changes to the Millstone Unit No.1 Technical Specifications " Administrative Controls" section as allowed by the guidance contained in NRC Administrative Letter 95-06,
      " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995. The Northeast Utilities Quality Assurance
                                                                                                                  /.
m Letter: B. D. Kenyon to USNRC: " Certification of Permanent Cessation of Power Operation and Permanent Removal of Fuel from the Reactor," B17388, dated                           -@j July 21,1998.
9904220259 990419 POR    ADOCK 05000245 P                    PDR

U. S. Nucirr Regul: tory Commission B17621%ttachment\Page 2 Program (NUQAP) Topical Report is NNECO's NRC-approved Quality Assurance Program which is controlled under 10CFR50.54(a)(3). The NUQAP revisions are not a reduction in commitment and will be included in the applicable submittal of changes to the NUQAP Topical Report. This application is being submitted assuming that the NRC will have approved a previous NNECO submittal to the administrative controls sections associated with the use of generic titles for management positions.*
A description of the proposed changes and the Significant Hazards Consideration are presented in Attachment 1. As discussed in the attachment, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident previously evaluated, or involve a significant reduction in the margin of safety. Based on our evaluation, we conclude there is reasonable assurance that Millstone Unit No.1 plant activities, consistent with the proposed Technical Specifications, will not impa::t the health and safety of the public.
A cross reference table correlating. the current MP1 operating Technical Specifications is included in Attachment 2. The retyped Permanently Defueled Technical Specifications (PDTS) in its entirety is included in Attachment 3. The retyped Bases for the PDTS is included in Attachment 4 for information only.
The proposed changes have ' been reviewed and approved by the Plant Operations Review Committee and the Station Operations Review Committee.
The Nuclear Safety Assessment Board has also reviewed the submittal. A representative of the State of Connecticut is being informed of this request by a copy of this letter.
We request this proposed change be issued at your earliest convenience, with the amendments effective as of the date of issuance, to be implemented within 90 days of issuance.
* Letter. M. L Bowling to USNRC, " Proposed revision to Technical Specifications, Administrative Controls," B17572, dated December 22,1998.

U. S. Nuclear Regulatory Commission
  - B17621\ Attachment \Page 3 o
There are no regulatory commitments contained within this letter.
I Very Truly Yours, 1
NORTHEAST NUCLEAR ENERGY COMPANY M
R. P. Necci Vice President - Nuclear Oversight and Regulatory Affairs Subscribed and sworn to before me this   a9      day of Q31                1999 MYhU DT n ORw
( Q Notary Public                                             l Date Commission Expires:       lo- h Q4 l
i Attachments (4) cc:    H. J. Miller, Region i Administrator L. L. Wheeler, NRC Project Manager, Millstone Unit No.1 Mr. Kevin T. A. McCarthy, Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

r --
Docket No. 50-245 B17621 l
j Attachment i l
Millstone Nuclear Power Station Unit No.1 Proposed Change to the Millstone Unit No.1 Technical Specifications          4 Permanentiv Defueled Technical Specifications l
I l
l l
i April 1999

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U. S. Nucle:r R:gul: tory Commission B17621%ttachment 1\Page 2                                                                    )
PROPOSED CHANGE TO THE MILLSTONE UNIT NO.1 TECHNICAL SPECIFICATIONS BACKGROUND On July 21,1998, Northeast Nuclear Energy Company (NNECO) Informed the USNRC that Millstone Unit No.1 (MP1) had permanently ceased operations and that the fuel had been permanently removed from the reactor vessel.")                        Pursuant to 10CFR50.82(a)(2), the certification in the letter modified the MP1 license to permanently withdraw the authority to operate the unit. As a result, MP1 is only authorized to possess special nuclear material and is prohibited from placing or retaining fuel in the reactor vessel. The purpose of this submittal is to revise the MP1 Technical Specihcations (MP1 TS) to reflect the defueled status of the unit.
Pursuant to 10CFR50.36(c)(6) " Decommissioning," NNECO is submitting the proposed change to Technical Specifications to reflect the permanently defueled condition of MP1.10CFR50.36 states that Technical Specifications involving safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis.
The current MP1 TS have been customized over the years to meet the specific needs of the unit. In the development of these proposed Permanently Defueled Technical Specifications (PDTS), NNECO reviewed the Technical Specifications of other units that have been termanently shutdown, primarily Maine Yankee, Connecticut Yankee, and Big Rock Point, and the improved Standard Technical Specifications (STS)                  ,
contained in NUREG-1433, " Standard Technical Specifications, General Electric Plants        I (BWR/4)." The STS were developed to meet the criteria set forth in the final Commission Policy Statement for Nuclear Power Reactors, dated July 22,1993.
Although the STS were developed for operating plants, the STS also contain the latest NRC approved guidance on Technical Specifications for a plant with irradiated fuel in the fuel pool. Since the safety function related to safe maintenance and storage of          1 irradiated fuel at an operating plant is similar to the corresponding function at a permanently defueled plant, the STS provide an appropriate standard for comparison.
In general, requirements in the current MP1 TS are either retained as is, retained with       ,
modifications, relocated to another controlled document, or deleted as no longer applicable to the defueled condition. Unless otherwise indicated, the MP1 TS requirements designated for relocation, will be relocated verbatim to the referenced controlled documents. Therefore, the cumulative effect of the requirements in the Quality Assurance Program, the Final Safety Analysis Report (FSAR), the Operating U)
Letter. B. D. Kenyon to USNRC: " Certification of Permanent Cessation of Power Operation and Permanent Removal of Fuel from the Reactor," B17388, dated July 21,1998.

U. S. Nucle:r Regul tory Commission B17621\ Attachment 1\Page 3 License, and the proposed PDTS and other regulations continue to ensure safe maintenance and storage of irradiated fuel.
The criteria set forth in the final Commission Policy Statement, which was used to develop the STS, have been codified in NRC Regulation 10CFR50.36(c)(2)(ii). These criteria were developed .for licenses authorizing operation and focused on instrumentation to detect degradation of the reactor coc! ant system pressure boundary and on equipment or process variables that affect the integrity of the fission products barriers during design basis accidents or transients. The fourth criterion refers to the use of operating experience and probabilistic risk assessment to identify and include in the Technical Specifications structures, systems, and components (SSCs) shown to be significant to public health and safety.        Nevertheless, these criteria, codified by 10CFR50.36, are the source of the Technical Specifications requirements for the safe storage of spent fuel. NNECO has given consideration to these criteria as they apply to a plant with a reactor which is permanently shutdown and defueled. A general discussion of these considerations is provided below.
10CFR50.36(c)(2)(ii)(A) Criterion 1 states that Technical Specification limiting conditions for operation must be established for " installed instrumentation used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." Since no fuel is present in the reactor at MP1, this criterion is not applicable.
10CFR50.36(c)(2)(ii)(B) Criterion 2 states that Technical Specification limiting conditions for operation must be established for " process variables that are initial conditions of a design basis accident (DBA) or transient analysis that assume the failure of or present a challenge to the integrity of a fission product barrier." The purpose of this criterion is to capture those process variables that have initial vdues assumed in the DBA and transient analyses and which are monitored and controlled during power operation. While this criterion was developed for operating reactors, there are some DBAs which continue to apply to a plant authorized only to possess, store, and handle nuclear fuel. The scope of DBA? applicable to a permanently defueled plant is significantly reduced from those postulated for an operating plant.
There are no transients which apply in the defueled condition. The scope of the DBAs applicable is discussed in more detail below.
10CFR50.36(c)(2)(ii)(C) Criterion 3 states that Technical Specification limiting conditions for operation must be established for SSCs that are part of the primary success path and which function or actuate to mitigate a DBA or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier. The intent of this criterion is to capture into Technical Specifications only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured in this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success I    path of a safety sequence analysis consist of the combination and sequences of equipment needed to operate (including consideration for single failure), so that the
~- -

U. S. Nuclerr Rigul tory Commission B17621\ Attachment 1\Page 4 plant response to DBAs and transients limits the consequences of the events to within the appropriate acceptance criteria. While there are no transients which continue to apply in the defueled condition, there are some DBAs which continue to apply to a plant authorized only to possess, store, and handle nuclear fuel. The scope of DBAs applicable to a permanently defueled plant is significantly reduced from those postulated for an operating plant. There are no transients which apply in the defueled condition. The scope of the DBAs applicable is discussed in more detail below.
10CFR50.36(c)(2)(ii)(D) Criterion 4 states that Technical Specification limiting conditions for operation must be established for SSCs which operating experience or probabilistic risk assessment has shown to be significant to the public health and safety. The intent of this criterion is that risk insights and operating experience be factored into the establishment of Technical Specifications limiting conditions for operation. This criterion was developed to cover those insights not fully recognized in the safety analysis report DBA or transient analyses. These insights are used to verify that none of the LCOs to be relocated or eliminated from Technical Specifications contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are commonly found to dominate risk. All of the accident sequences that previously dominated risk at MP1 are no longer applicable with the reactor in the permanently defueled condition. Experience from other defueled reactors has been factored in as applicable to the proposed Technical Specifications.
Section 15 of the MP1 FSAR described the DBA scenarios that were applicable during plant operations. However, as a result of the certification of permanent cessation of operations discussed above, most of the accident scenarios postulated in the FSAR are no longer applicable. NNECO revised Section 15 of the MP1 FSAR to reflect the current plant status. These postulated accidents are listed in the following table and discussed below.
Postulated Accident or Transient                         Current 15.2 Decrease in Reactor Coolant Temperature 15.2.1 Loss of Feedwater Heating                                  Not Applicable     1
                                                                                          ^
15.2.2 Feedwater Controller Failure - Maximum Demand          l   Not Applicable 15.2.3 Pressure Regulator Failure - Open                          Not    licable 15.3 Increase in Reactor Pressure 15.3.1 Steam Pressure Regulator Failure -Decreasing              Not Applicable Flow 15.3.2 Generator Load Rejection                              l   Not Applicable   l 15.3.3 Turbine Trip                                          l   Not Applicable   l 15.3.4 Main Steam Isolation Valve Closure                    l   Not Applicable   l 15.3.5 Loss of Condenser Vacuum                              l   Not Applicable   l 15.3.6 Loss of Feedwater Flow                                l   Not Applicable   l 15.3.7 Failure of the Isolation Condenser                    l   Not Applicable   l 15.3.8 Loss of Auxiliary Power                               l   Not Applicable   l

U. S. Nucirr Regulttory Commission B17621%ttachment 1\Page 5 Postulated Accident or Transient                           Current 15.4 Decrease in Reactor Coolant System Flow Rate 15.4.1 Recirculation Pump Trip                                   Not Applicable     i 15.4.2 Recirc Pump Controller Failure - Decreasing Flow       l  Not Applicable 15.4.3 Recirculation Pump Seizure                                Not      licable 15.5 Power Distribution and Anomalies 15.5.1 Rod Withdrawal                                            Not Applicable 15.5.2 Abnormal Start-up of idle Rectrculation Pump              Not Applicable 15.5.3 Recirc Pump Controller Failure - Increasing Flow          Not Apr'icable     J 15.5.4 Control Rod Drop                                          Not Applicable 15.6 Increase in Reactor Coolant Inventory                              Not      licable 15.7 Decrease in Reactor Coolant Inventory 15.7.1 inadvertent Safety / Relief Valve Opening                 Not Applicable 15.7.2 Pressure Regulator Failure - Open                      l  Not Applicable 15.7.3 Main Steam Line Break Outside of Containment           l  Not Applicable 15.7.4 Loss of Coolant Accident                               l  Not Applicable 15.7.5 Loss of Feedwater Flow                                 l  Not Applicable 15.7.6 Loss of Auxiliary Power                                l  Not Applicable 15.7.7 Other Line Breaks Outside Containment                  l  Not Applicable 15.8 Fuel Handling Accident                                          l    Applicable 15.9 Anticipated Transients Without Scram                            l  Not Applicable The most severe postulated accidents for nuclear power plants involve damage to the reactor core and the release of large quantities of fission products to the reactor coolant system. Many of the accident scenarios postulated in the FSAR involve failures or malfunctions in the systems that could affect the reactor core. With the termination of reactor operations at MP1 and the removal of authorization to operate the reactor or to place or retain fuel in the reactor, such accidents are no longer possible. The irradiated fuel is stored in the fuel pool and these systems serve no function related to storage of irradiated fuel in the fuel pool. Therefore, the postulated ,
accidents involving failure or malfunction of these systems are no longer applicable.      I These include FSAR Sections 15.2 through 15.7 and 15.9 as indicated on the table above.
Section 15.8 discusses the design basis fuel handling accident. Since MP1 is no longer authorized to operate or to place or retain fuel in the reactor, the limiting fuel handling accident (i.e., fuel assembly drop onto the top of the core during fuel handling operations) is no longer possible and is therefore, no longer part of the plant design basis. However, several fuel handling accidents in the fuel pool are still possible and are analyzed in the FSAR.
Analysis was performed to evaluate the consequences of dropping several components of differing weights on the irradiated fuel in the fuel pool. These components included:
a fuel pool gate, a new fuel assembly, an irradiated fuel assembly, and other items

U. S. Nucie r Rigul tory Commission B17621%ttachment 1\Page 6 such as boxes, containers, pumps, etc. The results of the analysis were that the worst case accident was the dropping of the fuel pool gate on the irradiated fuel assemblies, which resulted in a total of 54 fuel rods ruptured.
For conservatism, a bounding analysis
* was completed to calculate the release from a          ;
failure of four fuel assemblies (248 fuel rods). This analysis was performed with no secondary containment and no standby gas treatment resulting in an unfiltered ground level release. The results of this analysis demonstrate:
: 1. calculated doses at the exclusion area boundary and the low population zone are within 10CFR100 limits,
: 2. calculated doses to the Millstone control rooms are within the limits specified in GDC 19,*                                                                                   i l
: 3. results are significantly less than the previous limiting fuel handling accident in the reactor core.
In summary, most of the acc! dent scenarios described in FSAR Section 15 are no                !
longer possible due to the termination of reactor operations and the removal of fuel from the reactor vessel at the MP1. The remaining postulated DBA used in the development of the PDTS is a fuel handling accident in the fuel pool.
l
* Calculation No. XX-XXX-44RA, " Radiological Assessment of Fuel Handling Accident at MP-1," Revision 1, October 21,1998.
* Doses were not calculated for the MP3 controhoom since the atmospheric dispersion factor (X/Q) is approximately 50 times less than the X/Q to the MP2 control room.
Therefore, the dose to the MP3 control room is estimated to be approximately 50 times less than the calculated MP2 control room dose identified in FSARCR 98-MP1-15 and Calculation No. XX-XXX-44RA, " Radiological Assessment of Fuel Handling Accident at MP-1," Revision 1, October 21,1998.

U. S. Nucle:r Regul:tery Commission B17621%ttachment 1\Page 7 DESCRIPTION OF CHANGES NNECO reviewed each existing MP1 TS to determine if it should be retained in the PDTS in its present form, modified as appropriate for permanently defueled conditions, relocated to another controlled document, or deleted. The results of this evaluation are presented below on a section-by-section basis.
MP1 TS - Section 1.0 - Definitions Definitions are currently contained in the beginning of MP1 TS. The MP1 TS provides definitions for terminology that is unique to the Technical Specifications. The standard convention used in the STS, of indicating definitions throughout the text by showing the defined term in all capital letters, has been adopted in the PDTS. However, with the reduction in scope of the PDTS, most of these terms are no longer applicable. The following table shows a comparison of the existing MP1 TS definitions with those definitions contained in the STS and the proposed PDTS. The STS definitions that have not been retained in the proposed PDTS are discussed individually below. Those definitions listed as "Not Applicable" relate to operations that will no longer be conducted at MP1 (e.g., definitions related to power operation of MP1). Those             l definitions listed as "Not included" are definitions that are not in the STS and are therefore, not being retained in the proposed PDTS.
Current MP1 TS                    Improved STS            Proposed PDTS 1.0.A Deleted Previously                    Not Applicable           Not Applicable      j 1.0.B Core Alterations                  1.1 Definitions              Not Applicable 1.0.C Hot Standby                       Table 1.1-1 Definitions      Not Applicable 1.0.D Immediate                         1.3 Completion Times    1.3 Completion Times 1.0.E Instrument or Channel             1.1 Definitions              Not Applicable      ,
Calibration 1.0.F Instrument or Channel             1.1 Definitions              Not Applicable      )
Functional Test 1.0.G Instrument Check                  1.1 Definitions              Not Applicable 1.0.H Minimum Critical Power            1.1 Definitions              Not Applicable Ratio (MCPR) 1.0.1 Mode                              1.1 Definitions              Not Applicable 1.0.J Operable - Operability            1.1 Definitions              1.1 Definitions 1.0.K Operating                              Not included             Not included 1.0.L Operating Cycle                        Not included             Not included 1.0.M Fraction of Limiting Power        1.1 Definitions              Not Applicable Density 1.0.M Maximum Fraction of               1.1 Definitions              Not Applicable Limiting Power Density 1.0.N Primary Containment                    Not included             Not included Integrity

U. S. Nucle r Regul: tory Commissi:n B17621%ttachment 1\Page 8 Current MP1 TS                Improved STS           Proposed PDTS 1.0.0.1 Instrument Channel                Not included            Not included 1.0.0.2 Trip System                       Not included            Not included 1.0.O.3 Protective Action                 Not included            Not included 1.0.O.4 Protectivo Function               Not included            Not included 1.0.P Rated Neutron Flux                  Not included            Not included 1.0.Q Rated Thermal Power            1.1 Definitions             Not Applicable 1.0.R Reactor Power Operation        Table 1.1-1 Definitions     Not Applicable 1.0.R.1 Startup/ Hot Standby Mode    Table 1.1-1 Definitions     Not Applicable 1.0.R.2 Run Mode                     Table 1.1-1 Definitions     Not Applicable 1.0.S Reactor Vessel Pressure             Not included            Not included 1.0.T Refueling Outage                    Not included            Not included 1.0.U Secondary Containment               Not included            Not included Integrity 1.0.V Shutdown                       Table 1.1-1 Definitions     Not Applicable 1.0.V.1 Hot Shutdown                 Table 1.1-1 Definitions     Not Applicable 1.0.V.2 Cold Shutdown                Table 1.1-1                 Not Applicable Definitions 1.0.W Simulated Automatic                 Not included            Not included Actuation 1.0.X Surveillance                        Not included            Not included 1.0.Y Reportable Event                    Not included            Not included 1.0.AA Transition Boiling                 Not included            Not included 1.0.BB Emergency Power Sources            Not included            Not included 1.0.CC Staggered Test Basis          1.1 Definitions              Not included 1.0.DD Dose Equivalent 1-131         1.1 Definitions             Not Applicable 1.0.EE E-Average Disintegration           Not included            Not included Energy                                                                           l 1.0.FF Radioactive Waste                  Not included               Relocate Treatment System 1.0.GG REMODCM                       5.5 Programs and        5.7 Programs and    l Manuals                 Manuals 1.0.HH Purge - Purging                    Not included            Not included 1 . 0 .11 Venting                         Not included            Not included 1.0.JJ Member (s) of the Public           Not included            Not included 1.0.KK Site Boundary                 4.1 Site Location       4.1 Site Location   i 1.0.LL Source Check                       Not included            Not included 1.0.MM Unrestricted Area                  Not included            Not included -
1.0.NN Refuel Condition              Table 1.1-1                 Not Applicable Definitions                                  .
I 1.0.00 Supplemental Reload           1.1 Definitions (COLR)      Not Applicable Licensing Submittal 1.0.PP Average Planar Linear Heat    1.1 Definitions             Not Applicable Generation Rate (APLHGR)

I l U. S. Nucle:r Regul: tory Commission           "
B17621%ttachment 1\Page 9 l
Current MP1 TS                    Improved STS             Proposed PDTS 1.0.QQ Linear Heat Generation            1.1 Definitions                Not Applicable Rate 1.0.RR Limiting Control Rod                   Not included               Not included Pattern 1.0.SS Reactor Protection System         1.1 Definitions                Not Applicable (RPS) Logic Response Time STS Section 1.1, Definitions, contains the following additional definitions which have not been included in the proposed MP1 PDTS.
Emergency Core Cooling System (ECCS) Response Time - Not Applicable since 10CFR50.46(a)(1)(i) states that nuclear reactor power facilities which have submitted the certifications required under 10CFR50.82(a)(1) are not required to be provided with Emergency Core Cooling Systems.
End Of Cycle Recirculation Pump Trip System Response Time - Not Applicable since MP1 design does not include an end of cycle recirculation pump trip system.
Isolation System Response Time - Not Applicable since with existing plant conditions, no isolation systems are required.
L., Maximum Allowable Primary Containment Leakage Rate - Not Applicable since with existing plant conditions primary containment is no longer required.
Leakage - Leakage measurement inside the primary containment provides early detection of pipe cracking and the increased potential for a LOCA. Since a LOCA is no longer a credible accident at MP1, there is no reason to monitor leakage in primary containment. Therefore, the definition of leakage has not been included.
Physics Tests - Physics tests are tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. Since MP1 no longer has authority to place or retain fuel in the reactor vessel in accordance with 10CFR50.82(a)(2), physics test cannot be performed at MP1. Therefore, the definition of Physics tests has not been included.
Pressure and Temperature Limits Report - The              PTLR is the unit specific document which provides the reactor vessel pressure and temperature limits for the current fluence period, including heatup and cooldown rates. Since MP1 no longer has authority to place or retain fuel in the reactor vessel in accordance with 10CFR50.82(a)(2), the vessel will no longer be operated at pressure or temperature. Further, since the certifications required under 10CFR50.82(a)(1) have been submitted, MP1 is exempted from the requirements of 10CFR50, Appendix G, Fracture Toughness Requirements and Appendix H, Reactor Vessel

U. S. Nucie:r R:gul: tory Commission B17621%ttachment 1\Page 10 Material Surveillance Program Requirements.             Therefore, the definition of Pressure and Temperature Limits Report has not been included.
Shutdown Margin - SDM requirements are specified to ensure that the reactor can be made subcritical from all operating conditions, transients and Design Basis Events; that the reactivity transients associated with postulated accidents are controllable within acceptable limits and that the reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition.
Since MP1 no longer has authority to place or retain fuel in the reactor vessel in accordance with 10CFR50.82(a)(2), shutdown margin requirements no longer                )
apply. Therefore, the definition of Shutdown Margin has not been included.
Thermal Power - Thermal Power is a measure of the rate of transfer of total             l reactor core heat to the reactor coolant. Since MP1 ceased commercial                   '
operations and no longer has authority to place or retain fuel in the reactor vessel in accordance with 10CFR50.82(a)(2), thermal power will no longer be generated.
Therefore, the definition of Thermal Power has not been included.
Turbine Bypass System Response Time - The Main Turbine Bypass System is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, to prevent exceeding MCPR limits. Since MP1 has ceased power operations and no longer has authority to place or retain fuel in the reactor vessel in accordance with 10CFR50.82(a)(2), the events which require operation of the Turbine Bypass System cannot occur. Therefore, the requirement to maintain the Turbine Bypass System OPERABLE no longer applies. The definition of Turbine Bypass System response time has been deleted.
The following definitions have been added in the proposed MP1 PDTS:
ACTIONS - ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated conditions within the specified completion times.
CERTIFIED FUEL HANDLER - A CERTIFIED FUEL HANDLER is an individual who complies with the provisions of the CERTIFIED FUEL HANDLER training program required by Technical Specifications.
ACTIONS replaces ACTION STATEMENTS in the existing MP1 TS and has been added as a new definition to ensure consistent understanding and application.                )
CERTIFIED FUEL HANDLER has been added as a new definition to ensure consistent understanding and application. Further discussion regarding CERTIFIED FUEL HANDLERS is included in the Administrative Controls section of the PDTS.
The OPERABLE - OPERABILITY definition is in the STS and in the current MP1 TS and has been retained in the proposed MP1 PDTS.

U. S. Nucle:r Regul; tory Commission B17621\ Attachment 1\Page 11 MP1 TS Section 2.0 - Safety Limits and Limitina Safety System Settina Section 2.0 of the MP1 TS contains " safety limits" and " limiting safety system settings."
in accordance with 10CFR50.36(c)(1), safety limits are limiting parameters necessary to protect the physical barriers that guard against uncontrolled release of radioactivity from a nuclear reactor. If a parameter exceeds the specified safety limit, the reactor must be shutdown and operation may not resume until authorized by the Commission.
Limiting safety system settings are values of various parameters associated with the Nuclear Steam Supply System at which automatic protective action is needed during normal operations or anticipated transients to prevent exceeding a safety limit. MP1 Section 2.0 Technical Specifications are listed in the table below with the corresponding sections of the improved Standard Technical Specifications and the PDTS.
Current MP1 TS                    Improved STS                  Proposed PDTS 2.1.1 Safety Limit - Fuel       2.1.1 Reactor Core Safety Limit          Not Applicable Cladding Integrity 2.1.2 Limiting Safety System    3.2    Power Distribution Limits         Not Applicable Setting - Fuel Cladding Integrity 2.2.1 Safety Limit - Reactor    2.1.2 Reactor Coolant System             Not Applicable Coolant System                  Pressure Safety Limit 2.2.2 Limit Safety System       3.3.1.1 Reactor Protection               Not Applicable Setting - Reactor Coolant       System Instrumentation System                          3.4.3 RCS - Safety / Relief Valves The current MP1 TS contain two safety limits. MP1 TS 2.1 sets safety limits and limiting safety system settings that prevent damage to the fuel cladding during reactor operation that could result in the release of fission products to the reactor coolant system. MP1 TS 2.2 sets safety limits and limiting safety system settings that prevent potential damage to the reactor coolant system pressure boundary that could result in the release of fission products to the containment atmosphere. Pursuant to 10CFR50.82(a)(2), the facility operating license for MP1 no longer authorizes operation of the reactor or placement or retention of fuel in the reactor. Since the safety limits and limiting safety system settings apply to an operating reactor, they have no function in the permanently defueled condition. Therefore, the safety limits and limiting safety system settings have not been retained.

U. S. Nuclorr Regul:t:ry Commission B17621\ Attachment 1\Page 12 1
MP1 TS Section 3.0 Limitina Conditions for Operation Section 3.0 of the current MP1 TS contains the Limiting Conditions for Operation             I (LCO). In accordance with 10CFR50.36(c)(2), LCOs specify the lowest functional capability or performance levels of equipment required for safe operation of the facility.
The LCOs typically place restrictions on availability of safety equipment needed to prevent or mitigate a postulated DBA, or on process variables necessary to preserve the initial conditions assumed in the safety analyses of postulated DBAs.
10CFR50.36(c)(2)(ii) defines four criteria for establishing LCOs.            Associated surveillance requirements help to ensure that specified equipment and parameters are maintained within the limits specified in the LCOs.
As discussed previously, only one postulated DBA remains applicable to MP1 with the reactor in the permanently defueled state.        As a result, most of the LCOs and accompanying surveillance requirements contained in the MP1 TS were determined to be inappropriate for retention in the proposed PDTS. The following table contains a         '
comparison between the provisions of the current MP1 TS, the corresponding sections of the STS and the proposed PDTS.
Current MP1 TS                   Improved STS         l    Proposed PDTS 3.0 General                    LCO 3.0 Applicability of       LCO 3.0 Applicability of      j LCOs                           LCOs 3.1 Reactor Protection         LCO - 3.3.1.1                      Not Applicable System                         Instrumentation Reactor Protection System 3.2 Protective                 LCO 3.3.2.1 Control Rod            Not Applicable Instrumentation                Block Instrumentation LCO 3.3.5.1 Emergency Core Cooling System Instrumentation LCO 3 3.6.1 Primary Containment isolation Instrumentation 3.3 Reactivity Control         LCO 3.1 Reactivity Control         Not Applicable Systems 3.4 Standby Liquid Control     LCO 3.1.7 Standby Liquid           Not Applicable System                         Control System 3.5 Core and Containment       LCO 3.5 Emergency Core             Not Applicable Cooling Systems                Cooling Systems and Reactor Core isolation Cooling System 3.6 Primary System             LCO 3.4 Reactor Coolant            Not Applicable Boundary                       System

U. S. NucleCr Regulatory Commission B17621%ttachment 1\Page 13 Current MP1 TS          l         Improved STS          l     Proposed PDTS 3.7 Containment Systems          LCO 3.6 Containment          l      Not Applicable Systems                      i 3.8 Radioactive Materials        LCO 5.5.4 Radioactive        l Relocate to REMODCM      l Effluent Controls Program    l        and 5.6.1 3.9 Auxiliary Electrical         LCO 3.8 Electrical Power            Not Applicable    .
System        .                  Systems 3.10 Refueling and Spent         LCO 3.9 Refueling              LCO 3.1 Defueled         i Fuel Handling                    Operations                     Systems, LCO 3.2 Spent Fuel Handling
                                                                                       ]
j 3.11 Power Distribution          LCO 3.2 Power Distribution          Not Applicable      )
Limits                           Limits 3.13 Inservice Inspection      l          Not included              Relocate to TRM 3.14 Plant Systems            l LCO 3.7 Plant Systems         l      Not Applicable Each section of MP1 TS Section 3.0 is discussed in more detail below.
MP1 TS Section 3.0 - Limitino Conditions for Ooeration This section contains Specifications that have generic applicability to the LCOs and surveillance requirements. Due to the limited number of LCOs in the proposed PDTS, a number of the MP1 TS provisions in this section are no longer necessary or applicable to the MP1 facility as indicated in the following table. STS LCOs 3.0.1 and 3.0.2 have been included in the proposed PDTS. These LCOs have been modified to reflect the permanently defueled condition. The STS that have not been retained in the proposed PDTS are discussed individually below.
Current MP1 TS                    Improved STS                Proposed PDTS 3.0 General                 LCO 3.0.6 - Support Systems            Not Applicable Not Used           LCO 3.0.1 - Applicability       LCO 3.0.1 - Applicability Not Used           LCO 3.0.2 - Failure to meet LCO 3.0.2 - Failure to meet an LCO                          an LCO Not Used           LCO 3.0.3 - ltems not                   Not included covered by Technical Specifications Not Used           LCO 3.0.4 - Entry into a                Not included Mode when LCO not met Not Used           LCO 3.0.5 - Removlng                    Not included Equipment From Service Not Used           LCO 3.0.6 - Inoperability of            Not included Support Systems Not Used           . CO 3.0.7 - Special                    Not included Operations LCOs

U. S. Nucle:r Regul: tory Commission B17621%ttachment 1\Page 14 MP1 TS 3.0 discusses inoperability of a system, subsystem, Usin, component, or device due to the inoperability of its emergency power supply. Since there are no systems required for the permanently defueled condition that have emergency power supplies, this LCO is not applicable and is not retained.
STS LCO 3.0.3 discusses the requirements associated with conditions that are not covered by the Technical Specifications. This LCO is only applicable in Modes 1 through 3. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, this LCO is not applicable and is not included.
STS LCO 3.0.4 discusses entry into operating modes when the specified LCO is not met. - Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, mode definitions no longer apply and modo changes will no longer occur. Therefore, this LCO is not applicable and is not included.
STS LCO 3.0.5 permits equipment to be removed from service or declared inoperable to comply with action statements or to Se returned to service under administrative control to perform testing required to don'onstrate STS operability or operability of other equipment. The scope of the LC0s specified in the PDTS are sufficiently reduced to make this provision unnecessari.
STS LCO 3.0.6 allows that when an LCO is not met solely due to a support system LCO not being met, the conditions and required actions associated with this supported system are not required to be entered. Only the support system LCO actions are required to be entered. The scope of the LCOs specified in the PDTS are sufficiently reduced to make this provision unnecessary.
STS LCO 3.0.7 allows specified Technical Specification requirements to be changed to permit performance of special tests and operations. Since there are no special test exceptions specified in the PDTS, this provision is unnecessary and is not included.
MP1 TS Sectien 3.1 - Reactor Protection System This section contains the LCOs related to the instrumentation in the Reactor Protection System.
Current MP1 TS                    Improved STS                Proposed PDTS 3.1.A Reactor Protection            LCO 3.3.1.1 Reactor                Not Applicable      ,
System                              Protection System                                      j 3.1.B Not Used 3.1.C Reactor Protection            LCO 3.3.8.2 Reactor                Not Applicable System Power Monitoring             Protection System Electric Power Monitoring I

U. S. Nucle r Regul tory Commission B17621\ Attachment 1\Page 15 MP1 TS Section 3.1.A - The reactor protection system was designed to shutdown the reactor when parameters exceeded specified limits to prevent or mitigate the consequences of postulated accidents that could result in damage to the reactor fuel cladding or the reactor coolant system pressure boundary during power operations.
Since MP1 has permanently ceased operations and the fuel has been permanently removed from the reactor vessel, the postulated accident scenarios requiring actuation   1 of the reactor protection system are no longer possible. Therefore, these Specifications have not been retained.
MP1 TS Section 3.1.C - The reactor protection system power monitoring system was designed to ensure that electrical power was supplied to the reactor protection system.
As stated above, the reactor protection system is not required due to the cessation of operations at MP1, therefore; the reactor protection system power monitoring system is not required and this Specification is not retained.
MP1 TS Section 3.2 - Protective instrumentation i
This section contains the LCOs related to a variety of instrumentation. The following    ,
table lists the Specifications in this section.
J l
Current MP1 TS                     Improved STS          Proposed PDTS 3.2.A Primary Containment             LCO 3.3.6.1 Primary          Not Applicable        l Isolation Functions                   Containment Isolation instrumentation 3.2.B Emergency Core Cooling          LCO 3.3.5.1 Emergency        Not Applicable Subsystems Actuation                  Core Cooling System Instrumentation 3.2.C Control Rod Block               LCO 3.3.2.1 Control Rod      Not Applicable Actuation                             Block Instrumentation 3.2.D Air Ejector Of'-Gas                    Not included           Not included System 3.2.E Reactor Building                LCO 3.3.6.2 Secondary        Not Applicable Ventilation System, Steam             Containment Isolation Tunnel Ventilation isolation and      Instrumentation Standby Gas Treatment Initiation 3.2.F Loss of Normal Power            LCO 3.3.8.1 Loss of          Not Applicable        i instrumentation                       Power Instrumentation MP1 TS Section 3.2.A Primary Containment isolation Functions - This system was designed to prevent or mitigate the consequences of postulated accidents by isolating    i the primary containment and preventing the release of radioactive fission products to     l the atmosphere. Since MP1 has permanently ceased operations and the fuel has been         i permanently removed from the reactor vessel, the postulated accident scenarios requiring primary containment isolation are no longer possible and this Specification is not retained.

U. S. Nucle r Regulltory Commission B17621%ttachment 1\Page 16 MP1 TS Section 3.2.B Emergency Core Cooling Systems Actuation - This system was designed to initiate the emergency core cooling systems to provide cooling to the reactor in the event of the design basis LOCA. The system is designed to prevent or mitigate the consequences of postulated accidents that could result in damage to the reactor fuel or the reactor coolant pressure boundary. MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel. Therefore, the postulated accident scenarios requiring initiation of the emergency core cooling systems are no longer possible and this Specification is not retained.
MP1 TS Section 3.2.C Control Rod Block Actuation - This system was designed to maintain reactor thermal power within design limits by preventing the establishment of an abnormal rod pattern. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the control rod system is not required to be operational and control rod block actuation is not required. This Specification is not retained.
MP1 TS Section 3.2.D Air Ejector Off-Gas System - This system was designed to monitor off-gas radiation levels during power operation and indicate when limits for the release of radioactive materials to the environment were approached The off-gas radiation monitoring system affects appropriate control of off-gas flow so that the limits are not exceeded during plant operation. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the air ejector off-gas monitors are no longer required and this Specification is not retained.
MP1 TS Section 3.2.E Reactor Building Ventilation System, Steam Tunnel Ventilation Isolation and Standby Gas Treatment initiation - These systems were designed to monitor radiation levels from the Reactor Building exhaust duct, adjacent to the steam tunnel ventilation exhaust duct, and in the vicinity of the fuel pool. These systems were also designed to initiate isolation signals to the reactor building ventilation and the steam tunnel ventilation systems, and to initiate operation of the Standby Gas Treatment System (SGTS) when limits to the release of radioactive materials to the environment were approached. Fuel handling accidents in the spent fuel pool have been analyzed and the radiological consequences have been bounded by the failure of all fuel pins in four fuel assemblies. The radiological consequence
* were calculated assuming no credit either for secondary containment or the SGTS (i.e., an unfiltered ground release). Calculated doses at the exclusion area boundary and the low population zone were within 10CFR100 limits, and calculated doses to the Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19.           j Since MP1 accident analysis no longer relies on the secondary containment ventilation      j and steam tunnel ventilation radiation monitors or the SGTS for mitigation of              l t
radiological releases, these systems are no longer required to be OPERABLE nor are W Calculation No. XX-XXX-44RA," Radiological Assessment of Fuel Handling Accident at       i MP 1," Revision 1, October 21,1998.

i U. S. Nucle:r Regulitory Commissinn B17621\ Attachment 1\Page 17 they required to perform their safety functions. Therefore, this Specification is not retained.
MP1 TS Section 3.2.F Loss of Normal Power (LNP) Instrumentation - This system was designed to assure that adequate power was available to operate emergency safeguards equipment. The LNP instrumentation monitored safety division buses 14E and 14F, for safety buses S1 and S2 respectively. The fuel handling accident in the l    spent fuel storage pool has been analyzed as the remaining design basis accident.
Emergency safeguards equir> ment is not relied on to prevent the occurrence of a fuel l   handling accident, nor to mitigate the consequences of a fuel handling accident.
Further, since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is ,
no need for LNP instrumentation to ensure adequate power to the emergency                    i safeguards equipment. Therefore, this Specification is not retained.
MP1 TS Section 3.3 - Reactivity Control This section contains the LCOs related to reactivity control. The following table lists the Specifications in this section.
Current MP1 TS                    Improved STS              Proposed PDTS 3.3.A Reactivity Limitations        LCO 3.1.6 Rod Pattem              Not Applicable Control 3.3.B Control Rod Withdrawal        LCO 3.1.3 Control Rod             Not Applicable Operability 3.3.C Scram insertion Times         LCO 3.1.4 Control Rod             Not Applicable Scram Times 3.3.D Control Rod                   LCO 3.1.5 Control Rod             Not Applicable         !
Accumulators                        Scram Accumulators 3.3.E Reactivity Anomalies          LCO 3.1.2 Reactivity              Not Applicable Anomalies i
3.3.F Shutdown Requirements         Addressed in each                 Not Applicable individual Specification                                 l 3.3.G The mal Power Core            LCO 3.2 Power                     Not Applicable Flow                                Distribution Limits MP1 TS Section 3.3.A Reactivity Limitations - This LCO prevented the loading of excess reactivity that could prevent a reactor shutdown in the event of the worst case stuck control rod accident. Since MP1 will no longer place or retain fuel in the reactor vessel, reactivity limitations associated with fuel in the reactor no longer apply.
Therefore, this Specification is not retained.
MP1 TS Section 3.3.B Control Rod Withdrawal - This LCO established conditions to prevent the addition of excess reactivity due improper operation of the control rods or failure of the control rod system. Since MP1 is no longer authorized to place or retain

1 U. S. Nuclerr Regul:. tory Commission B17621\ Attachment 1\Page 18 fuel in the reedor vessel, reactivity cannot be added by the control rods. Therefore, there is no need to place conditions for operation on the control rod system, and this        j Specification is not retained.
MP1 TS Section 3.3.C Scram insertion Times - This LCO established conditions to ensure that the control rods would insett to bring the reactor subcritical at a rate fast   -
enough to prevent fuel damage during the limiting power transient, a generator load reject coincident with failure of the turbine bypass system. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, the insertion of control rods cannot add negative reactivity. Therefore, there is no need to maintain conditions governing rate of control rod insertion, and this Specification is not retained.
MP1 TS Section 3.3.D Control Rod Accurnulators - This Specification established conditions to limit the number and location of control rod accumulators allowed to be inoperable to ensure that the reactor could be made subcritical. Since MP1 has                j permanently ceased power operations and is no longer authorized to place or retain            i fuel in the reactor vessel, control rods are no longer required. Therefore, there is no need to establish conditions governing accumulator operability. This Specification is not retained.
MP1 TS Section 3.3.E Reactivity Anomalies - This LCO established conditions to limit the difference to 1% delta K between the core reactivity of the critical rod pattern selected base state and the predicted rod inventory at that state. This limit ensured       i that the reactivity inserted into the core, in the worst case, would not lead to transients exceeding design condit!cns of the reactor system. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, reactivity anomalies are no longer applicable. This Specification is not retained.                                                                                   l MP1 TS Section 3.3.F Shutdown Requirements - This LCO established requirements to shutdown the reactor when required conditions of Specifications 3.3.A through 3.3.D could not be maintained. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel and since                  i Specifications 3.3.A through 3.3.D have not been retained, there is no need for             i shutdown requirements associated with these Specifications.                Therefore, this Specification is not retained.
MP1 TS Section 3.3.G Thermal Power Core Flow - This LCO established conditions to           l ensure that the reactor thermal power and the total core flow were maintained within          l the restrictions of the power to flow operating map curves. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, the power to flow operating map is no longer applicable. Therefore, this Specification is not retained.
l 1

l l
i U. S. Nuclear Regul-tory Commission                                                     i B17621%ttachment 1\Page 19 MP1 TS Section 3.4 - Standby Liould Control This section contains the LCO related to standby liquid control system. The following table lists the Specifications in this section.                                         I Current MP1 TS                     Improved STS           Proposed PDTS        {
3.4.A Normal Operation                LCO 3.1.7 Standby Liquid      Not Applicable Control System 3.4.8 Operation with inoperable LCO 3.1.7 Standby Liquid            Not Applicable Components                            Control System 3.4.C Boron Requirements              LCO 3.1.7 Standby Liquid      Not Applicable Control System MP1 TS Sections 3.4.A, 3.4.B, 3.4.C Standby Liquid Control System - These Specifications ensured that: 1) the standby liquid control system had the capability to shutdown the reactor from full power to a cold, xenon-free shutdown assuming none of the withdrawn control rods could be inserted; and 2) the standby liquid control system met the requirement of the ATWS rule,10CFR50.62. Since the ATWS rule no longer applies to MP1, and MP1 has permanently ceased power operations, there is no need for a standby liquid control system and these Specifications are not retained.
MP1 TS Section 3.5 - Core and Containment Coolina This section contains the LCO related to core and containment cooling systems. The following table lists the Specifications in this section.
Current MP1 TS                     Improved STS           Proposed PDTS 3.5.A Core Spray and LPCI             LCO 3.5.1 ECCS ~              Not Applicable Subsystems                            Operating 3.5.B Containment Cooling             LCO 3.6.3.2 Drywell           Not Applicable      i Subsystems                            Cooling System Fans 3.5.C FWCl Subsystem                  LCO 3.5.1 ECCS -              Not Applicable Operating 3.5.D Automatic Pressure              LCO 3.4.3 Safety / Relief     Not Applicable Relief Subsystems                     Valves                                             l 3.5.E isolation Condenser             LCO 3.5.3 RCIC System         Not Applicable      l 3.5.F Minimum Core and                Addressed in each             Not Applicable Containment Cooling System            individual Specification Availability 3.5.G Ultimate Heat Sink              LCO 3.7.2 Plant Service       Not Applicable Water and Ultimate Heat                            l Sink MP1 TS Section 3.5.A Core Spray and LPCI Subsystems - These subsystems were part of the emergency core cooling systems and were designed to provide adequate

U. S. Nuclerr Regulitory Commission B17621%ttachment 1\Page 20 emergency cooling capability to the reactor in the event of a loss of coolant accident (i.e., the design basis LOCA). These subsystems were designed to provide sufficient cooling to the core to dissipate the energy associated with the loss of coolant accident and to limit fuel clad temperature to well below the clad melting temperature to assure that core geometry remains intact and to limit any clad metal-water reaction to less than 1%. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, a design basis LOCA is no longer possible and the emergency core cooling systems are no longer needed. Therefore, this Specification is not retained.
MP1 TS Section 3.5.B Containment Cooling Subsystems - This subsystem was designed to remove heat energy from containment in the event of a loss of-coolant accident (LOCA). The heat removal capacity of one of the two cooling loops was adequate to prevent the torus water temperature from exceeding the equipment temperature capability which is specified to be 203 degrees F. One cooling loop also provided sufficient subcooling such that adequate net positive suction head (NPSH)          .
could be assured without reliance on containment pressure except during short               !
intervals during the postulated LOCA. Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, a design basis LOCA that requires initiation of the containment cooling subsystem is no longer possible. Therefore, this Specification is not retained.
MP1 TS Section 3.5.C FWCl Subsystem - This subsystem was a single train high pressure ECCS that used feedwater and condensate components to supply water from the condenser hotwell to the vessel for core cooling and was designed to reduce the probability of core uncovery during the lifetime of the plant.            Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, a design basis LOCA that requires initiation of the FWCl subsystem is no longer possible. Therefore, this Specification is not retained.
MP1 TS Section 3.5.D Automatic Pressure Relief (APR) Subsystems - This subsystem was a backup to the FWCl subsystem and enabled the Core Spray or LPCI systems to provide protection against the small pipe break in the event of FWCl failure, by depressurizing the reactor vessel rapidly enough to actuate the Core Spray and LPCI systems. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the postulated small pipe break accidents that would require initiation of the APR subsystems are no longer possible. Therefore, this Specification is not retained.
MP1 TS Section 3.5.E isolation Condenser System - This system was designed to provide a means of core decay heat removal following reactor isolation and scram.
Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, a reactor isolation (i.e., MSIV isolation) and reactor scram are no longer applicable. Therefore, this Specification is not retained.

I U. S. Nucle:r Regulatory Commission                                                          ]
B17621%ttacnment 1\Page 21                                                                     '
MP1 TS Section 3.5.F Minimum Core and Containment Cooling System Availability -
This LCO established requirements to assure a minimum of core cooling equipment was available (e.g., emergency power sources for ECCS) when required conditions of Specifications 3.5.A through 3.5.E could riot be maintained.              Since MP1 has permanently ceased power operations and is no longer authorized to place or retain fuel in the reactor vessel, core cooling equipment is no longer needed. Further, Specifications 3.5.A through 3.5.E have not been retained as described above.                 j Therefore, this Specification is not retained.
MP1 TS Section 3.5.G Ultimate Heat Sink - This LCO established limitations on the ultimate heat sink temperature to assure that sufficient cooling capacity was available to either 1) provide normal cooldown of the facility, or 2) mitigate the effects of accident conditions within acceptable limits. Since MP1 has permanently ceased power                  .
operations and is no longer authorized to operate the reactor or to place or retain fuel     I in the reactor vessel, the postulated accident conditions requiring cooling by the ultimate heat sink are no longer possible and this Specification is not retained.            ;
I MP1 TS Section 3.S - Primary System Boundary This section contains the LCOs related to reactor coolant system pressure boundary.
The following table lists the Specifications in this section.
Current MP1 TS                     Improved STS               Proposed PDTS i
3.6.A Thermal Limitations           LCO 3.4.10 RCS                     Not Applicable Pressure and Temperature Limits 3.6.B Pressurization                LCO 3.4.10 RCS                     Not Applicable Temperature                         Pressure and Temperature Limits 3.6.C Coolant Chemistry             LCO 3.4.7 RCS Specific             Not Applicable Activity 3.6.D Coolant Leakage               LCO 3.4.4 RCS                      Not Applicable Operational Leakage 3.6.E Safety and Relief Valves      LCO 3.4.3 Safety / Relief          Not Applicable Valves 3.6.F Structural Integrity                   Not included               Not included 3.6.G Jet Pumps                     LCO 3.4.2 Jet Pumps                Not Applicable 3.6.H Recirculation Pump Flow       LCO 3.4.1 Recirculation            Not Applicable Mismatch                            Loops Operating 3.6.1 Snubbers                              Not included               Not Applicable 3.6.J Condensate                            Not included               Not Applicable Demineralizers 3.6.K Mechanical Condenser                  Not included               Not Applicable Vacuum Pump

U. S. Nuclerr Regul: tory Commission B17621\ Attachment 1\Page 22 MP1 TS Section 3.6.A Thermal Limitations - This LCO established requirements for heatup and cooldown rates during plant operation in order to operate within the analyzed requirements for stress intensity and fatigue limits for the reactor vessel.
Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, heatup and cooldown rates are no longer needed to protect the reactor vessel and preserve the reactor coolant pressure boundary. Therefore, there is no need to establish thermal limits and this Specification is not retained.
MP1 TS Section 3.6.B Pressurization Temperature - This LCO established operating limits for reactor vessel pressure and temperature for the following:
a) normal heatup and cooldown with the reactor critical and the reactor not critical, and b) during inservice hydrostatic and leak testing.
These limits were designed to protect the integrity of the reactor pressure vessel and to mitigate the effects of a hypothetical LOCA during inservice hydrostatic and leak tests with an assumed active single failure. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is no need to establish operating limits for raactor vessel temperature and pressure. Therefore, this Specification is not retained.
MP1 TS Section 3.6.C Coolant Chemistry - Reactor Coolant System chemistry was monitored for specific activity with the reactor in the STARTUP/ HOT STANDBY or RUN modes and with the average reactor coolant temperature greater than 212 F to:
e   ensure that potential offsite doses due to postulated events which release reactor coolant directly to the environment would be acceptably low; and e   identify fuel leaks and fuel failure.
Limits also were established for Reactor Coolant System water chemistry at different steaming rates for conductivity, chlorides and pH to prevent stress corrosion cracking      i of the 304 stainless steel materials and damage to the Zircaloy fuel cladding. If those limits were not met, an orderly shutdown was required to be initiated. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is no need to monitor reactor coolant system chemistry. Water chemistry limits for the fuel storage pool are established in the proposed PDTS to minimize the potential effects of corrosion which could affect the safe storage of irradiated fuel. Therefore, this Specification is not retained.
MP1 TS Section 3.6.D Coolant Leakage - This LCO established " unidentified" and
" identified" primary system leakage limits to allow prompt identification and isolation of leaks before the integrity of the reactor coolant system pressure boundary was impaired. Since MP1 has permanently ceased power operations and is no longer

U. S. Nuclear Regulatory Commission                                                          l B17621\ Attachment 1\Page 23 authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is no need to carry an LCO to monitor primary system leakage. Therefore, this Specification is not retained.
MP1 TS Section 3.6.E Safety and Relief Valves - The safety and relief valves were designed to prevent overpressurization of, and damage to, the primary system boundary. The automatic pressure relief function is described earlier in this submittal in MP1 TS Section 3.5.D. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the reactor pressure vessel will never again be pressurized with fuel in the reector. Therefore, the safety and relief valves are not required and this Specification is not retained.
MP1 TS Section 3.6.F Structural Integrity - This LCO referred to the Inservice Inspection requiremer.ts of the primary system boundary components as specified in MP1 TS Section 3.13. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, inservice inspection requirements for primary system boundary components are no longer required. Therefore, this Specification is not retained.
MP1 TS Section 3.6.G Jet Pumps - This LCO established requirements for jet pump integrity which was designed to provide two-thirds of core height reflood capability in the aftermath of a design basis LOCA. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, a LOCA is no longer possible at MP1. Therefore, jet pump integrity is not required and this Specification is not retained.
MP1 TS Section 3.6.H Recirculation Pump Flow Mismatch - This Specification provided procedural limitations at power operation on the differences in reactor recirculation pump speed in order to minimize the probability that the wrong LPCI loop would be selected for injection following a LOCA. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, a LOCA cannot occur. Therefore, this Specification is not retained.
MP1 TS Section 3.6.1 Snubbers - The snubbers were designed to limit movement and prevent damage to primary system components during all modes of reactor operation, including heatups and cooldowns.          The MP1 snubber list was reviewed and no snubbers on the list are associated with the maintenance and storage of irradiated fuel in the fuel storage pool and its associated support systems. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the snubbers are not required and this Specification is not retained.
MP1 TS Section 3.6.J Condensate Demineralizers - The condensate demineralizers ensured that the feedwater to the reactor during power operation met the chemistry

U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 24 Specifications of MP1 TS Section 3.6.C.              As discussed above, since MP1 TS Specification 3.6.C " Coolant Chemistry" is not retained, the feedwater system and the condensate demineralizers are not required.            Therefore, this Specification is not retained.                                                                                   i l
MP1 TS Section 3.6.K Mechanical Condenser Vacuum Pump - The mechanical vacuum pump was designed to establish a vacuum in the condenser for main turbine operation and to limit the release of activity from the main condenser in the event of a control rod drop accident. This Specification prevented the release of fission products to the atmosphere from the main condenser by isolating the mechanical vacuum pump whenever the Main Steam Isolation valves were open and a signal of main steam line high-high radiation was present. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, a control rod drop accident cannot occur. Therefore, the mechanical vacuum pump is not required and this Specification is not retained.
MP1 TS Section 3.7 - Containment Systems This section contains the LCO related to containment systems. The following table lists the Specifications in this section.
Current MP1 TS                       Improved STS              Proposed PDTS 3.7. A Primary Containment           LCO 3.6.2.1 Suppression             Not Applicable     i 3.7.A.1 Suppression Chamber          Pool Average Temperature Water Level and Temperature          LCO 3.6.2.2 Suppression Pool Water Level 3.7.A.2 Drywell to Suppression        LCO 3.6.2.5 Drywell to             Not Applicable Chamber Differential Pressure         Suppression Chamber Differential Pressure 3.7.A.3 Primary Containment           LCO 3.6.1.1 Primary                Not Applicable Integrity                            Containment 3.7.A.4 Pressure Suppression          LCO 3.6.1.7 Reactor Building       Not Applicable     J Chamber - Reactor Building           to Suppression Chamber                                 i Vacuum Breakers                      Vacuum Breakers 3.7.A.5 Pressure Suppression          LCO 3.6.1.8 - Suppression          Not Applicable Chamber- Drywell Vacuum               Chamber to Drywel: Vacuum Breakers'                             Breakers 3.7.A.6 Oxygen Concentration          LCO 3.6.3.3 Primary                Not Applicable Containment Oxygen Concentration 3.7.A.7 Containment High              LCO 3.3.3.1 Post Accident          Not Applicable Range Radiation Monitors              Monitoring instrumentation 3.7.B Standby Gas Treatment           LCO 3.6.4.3 Standby Gas            Not Applicable System                               Treatment System 3.7.C Secondary Containment           LCO 3.6.4.1 Secondary              Not Applicable

U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 25 Current MP1 TS                      improved STS               Proposed PDTS Containment 3.7.D Primary Containment            LCO 3.6.1.3 Primary                Not Applicable isolation Valves                     Containment Isolation Valves MP1 TS Section 3.7.A.1 through 3.7.A.8 Primary Containment - These LCOs established primary containment integrity when the reactor was critical or when the reactor was in power operations or hot shutdown These limits ensured that primary containment integrity was maintained to prevent the release of fission products to the environment. Since MP1 has permanently ceased power operation and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, primary containment integrity requirements are no longer applicable.             Therefore, these Specifications are not retained.
MP1 TS Section 3.7.8 Standby Gas Treatment System - The standby gas treatment system was designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions. Current accident analysis is encompassed by the spectrum of fuel handling accidents in the spent fuel pool as described in Chapter 15 of the FSAR. Fuel handling accidents in the spent fuel pool were analyzed and the radiological consequences were bounded by the failure of all fuel pins in four fuel assemblies.* The radiological consequences were calculated assuming no credit either for secondary containment or the SGTG (i.e., an unfiltered ground release). Calculated doses at the exclusion area boundary and the low population zone were within 10CFR100 limits, and calculated doses to the Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19 and much less than the previous limiting fuel handling accident dose. Since MP1 accident analysis no longer relies on the secondary containment or the SGTS for mitigation of radiological releases, these systems are no longer required to be OPERABLE nor are they required to perform their safety functions. Therefore, the SGTS is not required and this Specification is not retained.
MP1 TS Section 3.7.C Secondary Containment - The secondary containment was designed to minimize any ground level release of radioactive materials which might result from a serious accident. Secondary containment integrity was required whenever primary containment integrity was required and whenever activities having the potential of significant fission products release, such as movement of the fuel cask, irradiated fuel, or other loads in containment were performed Analysis of a fuel cask drop over the fuel storage pool is not needed because engineered controls are established for the cask drop prevention system by LCOs 3.10.D - Crane Operability and 3.10.E - Crane Travel with a Spent Fuel Cask. Current accident analysis is encompassed by the spectrum of fuel handling accidents in the spent fuel pool as described in Chapter 15 of the FSAR. Fuel handling accidents irs the spent fuel pool
* Calculation No. XX-XXX-44RA," Radiological Assessment of Fuel Handling Accident at MP-1," Revision 1, October 21,1998.
i

U. S. Nuclear Regul: tory Commission B17621\ Attachment 1\Page 26 were analyzed and the radiological consequences were bounded by the failure of all fuel pins in four fuel assemblies. The radiological consequences were calculated assuming no credit either for secondary containment or the SGTS (i.e., an unfiltered ground release). Calculated doses at the exclusion area boundary and the low population zone were within 10CFR100 limits, and calculated doses to the Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19 and much less than the previous limiting fuel handling accident dose. Since MP1 accident analysis no longer relies on the secondary containment or the SGTS for mitigation of radiological releases, these systems are no longer required to be OPERABLE, nor are they required to perform their safety functions. Therefore, this Specification is not retained.
MP1 TS Section 3.7.D Primary Containment isolation Valves - The primary containment isolation valves were designed to isolate the containment in the event of a LOCA and prevent the release of fission products to the atmosphere to maintain the integrity of the pressure suppression system during reactor power operations. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is no need for primary containment isolation valves. Therefore, this Specification is not retained.
MP1 TS Section 3.8 - Radioactive Materials This section contains the LCO related to radioactive materials. The following table lists the Specifications in this section.
Current MP1 TS                     Improved STS               Proposed PDTS 3.8.A Radioactive Liquid                     Not included                REMODCM Effluent Instrumentation 3.8 B Radioactive Gaseous                    Not included                REMODCM           l Effluent Monitoring                                                                        l Instrumentation 3.8.C Radioactive Liquid            LCO 5.5.4 Radioactive                REMODCM           i Effluents                           Effluent Controls Program                              l 3.8.D Radioactive Gaseous           LCO 5.5.4 Radioactive                REMODCM Effluents                           Effluent Controls Program Radioactive liquid and gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid and gaseous effluents during actual or potential releases. MP1 TS Section 3.8.A thorough 3.8.D are being relocated to the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). The REMODCM general description is retained in the PDTS in the Administrative Controls under the Programs and Manuals - Section 5.6.1.

m U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 27 MP1 TS Section 3.9 - Auxiliary Electrical Power This section contains the LCOs related to AC and DC Electrical Systems.                The following table lists the Specifications in this section.
Current MP1 TS                       Improved STS             Proposed PDTS 3.9.A Electrical Sources             LCO 3.8.1 AC Sources -            Not Applicable Operating LCO 3.8.4 DC Sources -
Operating 3.9.B Electrical Sources             LCO 3.8.1 AC Sources -            Not Applicable Operating LCO 3.8.4 DC Sources -
Operating 3.9.C Diesel and Gas Turbine         LCO 3.8.3 Diesel Fuel Oil,        Not Applicable Fuel                                 Lube Oil, and Starting Air MP1 TS Section 3.9.A and 3.9.B - Electrical Sources - These LCOs specified the AC and DC electrical power requirements when the reactor was operating. These limits ensured that sufficient electrical power, including offsite power sources and onsite emergency power sources, was available to operate the emergency safeguards equipment. The design basis accidents that required power for the emergency safeguards equipment systems supplied by the auxiliary electrical system are no longer applicable. Analysis has shown that power to the systems that support storage and cooling of the irradiated fuel can be interrupted for several days before boiling occurs in the fuel pool." Fuel storage pool boiling would occur after approximately ten days without power assuming an initial fuel pool water temperature of 100 F and no Reactor Building openings. As a result, there is sufficient time to restore power to fuel storage   i pool cooling systems before fuel storage pool boiling would occur. Therefore, there is no need to the establish electrical requirements identified in these Specifications and these Specifications are not retained.
MP1 TS Section 3.9.C - Diesel and Gas Turbine Fuel - This LCO specified the minimum amount of fuel oil to be maintained onsite to support the diesel generator and the gas turbine. The design basis accidents that required power for the emergency safeguards equipment systems supplied by the auxiliary electrical system are no longer applicable. Further, because of the decay history of the irradiated fuel in the fuel storage pool, power to the systems that support storage and cooling of the irradiated       ;
fuel in the fuel storage pool can be interrupted for several days without any               '
consequences to the irradiated fuel. As previously described, studies have concluded that fuel storage pool boiling would occur after ten days without power to fuel pool cooling and Reactor Building HVAC. As a result of this study, there is sufficient time to restore power to fuel storage pool cooling systems before fuel storage pool boiling
* Calculation No. 99-ENG-01906-M1, Rev. O, " Transient & Steady State Temperature of MP1 SFP & RB Wdh No Active SFP Cooling."

U. S. Nuclear Regulatory Commission                                                           l l
B17621%ttachment 1\Page 28 would occur. Therefore, the electrical systems are no longer required, and there is no         I need to maintain the fuel oil onsite to support MP1. These Specifications are not retained.
MP1 TS Section 3.10 - Refuelina and Soent Fuel Handlina This section contains the LCOs related to Refueling and Spent Fuel Handling. The following table lists the Specifications in this section.
Current MP1 TS                    Improved STS                 Proposed PDTS           ;
3.10.A Refueling Interlocks      LCO 3.9.1 Refueling                    Not Applicable Equipment interlocks 3.10.8 Core Monitoring           LCO 3.3.1.2 Source Range               Not Applicable Monitor Instrumentation 3.10.C Fuel Storage Pool                  Not included            LCO 3.1.1 Fuel Storage Water Level                                                           Pool Water Level 3.10.D Crane Operability                  Not included               LCO 3.2.1 Reactor Building Crane Operability 3.10.E Crane Travel With A                 Not included              LCO 3.2.2 Reactor Spent Fuel Cask-                                                   Building Crane Travel With a Spent Fuel Cask MP1 TS Section 3.10.A - Refueling Interlocks - The refueling interlocks assured that inadvertent criticality would not occur during refueling operations. Since MP1 has permanently ceased power operations and is no longer authorized to operate the                l reactor or to place or retain fuel in the reactor vessel, refueling interlocks, including the requirement to place the reactor mode switch in REFUEL, are no longer required.
Therefore, this Specification is not retained.
MP1 TS Section 3.10.B - Core Monitoring - The core monitoring LCO required two OPERABLE source range monitors, one in and one adjacent to any core quadrant where fuel or control rods'were being moved, to assure adequate monitoring of that quadrant during Core Alterations. In certain cases, special movable dunking type detectors were allowed to be used for core monitoring during reloading of fuel assemblies into the central core region. However, since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the core monitoring system is no longer applicable.
Therefore, this Specification is not retained.
MP1 TS Section 3.10.C - Fuel Storage Pool Water Level - Fuel storage pool water level
  -is retained in the PDTS as LCO 3.1.1. This information has been reformatted to be consistent with the STS.                                                                      l MP1 TS Section 3.10.D - Crane Operability - This LCO is included in the proposed PDTS as LCO 3.2.1 and has been reformatted in the STS format.

U. S. Nuclear Regulatory Commission B17621%ttachment 1V' age 29 MP1 TS Section 3.10.E - Crane Travel with a Spent Fuel Cask - This LCO is included in the proposed PDTS as LCO 3.2.2 and has been reformatted in the STS format.
MP1 TS Section 3.11 - Power Distribution Limits This section contains the LCOs related to Power Distribution Limits. The following table lists the Specifications in this section.
Current MP1 TS                       Improved STS               Proposed PDTS 3.11.A Average Planar Linear        LCO 3.2.1 Average Planar             Not Applicable Heat Generation Rate                Linear Heat Generation Rate 3.11.B Linear Heat                  LCO 3.2.3 Linear Heat                Not Applicable Generation Rate                     Generation Rate 3.11.C Minimum Critical             LCO 3.2.2 Minimum Critical           Not Applicable Power Ratio                         Power Ratio 3.11.D APRM Setpoints               LCO 3.2.4 Average Power              Not Applicable Range Monitor Gain & Setpoints MP1 TS Section 3.11.A through 3.11.D - These Specifications defined the thermal limits associated with power operation of the reactor. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, these limits are no longer applicable and these Specifications are not retained.
MP1 TS Section 3.12 - No Title - was deleted in a previous amendment.
MP1 TS Section 3.13 - Inservice inspection This section contains the LCOs related to inservice inspection. The following table lists the Specifications in this section.
Current MP1 TS                       improved STS             Proposed PDTS 3.13 Inservice inspection                      Not included           Relocate to the TRM MP1 TS Section 3.13 - The Inservice Inspection requirements are not included in the STS, as it does not satisfy any of the four criteria identified in 10CFR50.36. Applicable ISI requirements will be relocated to the Technical Requirements Manual. This Specification is not retained in the proposed PDTS.

U. S. Nuclear Regulatory Commission B17621\ Attachment 1\Page 30 MP1 TS Section 3.14 - Plant Systems This section contains the LCOs related to Plant Systems. The following table lists the Specifications in this section.
Current MP1 TS                     improved STS               Proposed PDTS 3.14.A Turbine Bypass System LCO 3.7.7 Main Turbine                     Not Applicable Byoass System 3.14.B Reactor High Water           LCO 3.3.2.2 Feedwater and           Not Applicable Level Feedwater Pump Trip           Main Turbine High Water instrumentation                     Level Trip instrumentation MP1 TS Section 3.14.A - Turbine Bypass System - The turbine bypass system provided overpressure protection for the reactor in the event of a main turbine trip. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the turbine bypass system is no longer required and this Specification is not retained.                                        i MP1 TS Section 3.14.8 - Reactor High Water Level Feedwater Pump Trip Instrumentation - The reactor high water level feedwater pump trip provided protection for the main turbine in the event of a high reactor level which could cause moisture carryover to the main turbine. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, the reactor high water level feedwater pump trip is no longer required and this Specification is not retained.
MP1 TS Section 4.0 Surveillance Reauirements Section 4.0 of the current MP1 TS describes the surveillance requirements. In accordance with 10CFR50.36(c)(3), surveillance requirements are related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The surveillance requirements for the PDTS are provided for each             I LCO directly following that LCO in accordance with the STS.
Since there are no safety limits that apply to MP1 with the reactor shutdown and defueled, and since there are relatively few remaining LCOs, the number of surveillance requirements has been greatly reduced. The following table shows a comparison between the provisions of the current MP1 TS, the corresponding sections of the STS, and the proposed PDTS.
Current MP1 TS                 Improved STS                   Proposed PDTS 4.0 General                  SR 3.0 Surveillance              SR 3.0 Surveillance Requirements Applicability       Requirements Applicability 4.1 Reactor Protection      SR 3.3.1.1 Instrumentation              Not Applicable System                      Reactor Protection System

U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 31 Current MP1 TS         l          Improved STS           l      Proposed PDTS           l 4.2 Protective                SR 3.3.2.1 Control Rod Block           Not Applicable Instrumentation               Instrumentation SR 3.3.5.1 Emergency Core Cooling System Instrumentation SR 3.3.6.1 Primary Containment Isolation instrutnantation 4.3 Reactivity Control     l SR 3.1 Reactivity Control     ~l        Not Applicable        l 4.4 Standby Liquid         l SR 3.1.7 Standby Liquid                 Not Applicable        l Control System             l Control System                                                l 4.5 Core and                 SR 3.5 Emergency Core                   Not Applicable Containment Cooling          Cooling and Reactor Core Systems                      isolation Cooling Systems 4.6 Primary System            SR 3.4 Reactor Coolant                  Not Applicable Boundary                     S>stem 4.7 Containment               SR 3.6 Containment Systems l            Not Applicable Systems                                                      l 4.8 Radioactive               5.5.4 Radioactive Effluent         Relocate to REMODCM l Materials                     Controls Program                           and 5.6.1         l 4.9 Auxiliary Electrical      SR 3.8 Electrical Power                 Not Applicable System                        Systems 4.10 Refueling and            SR 3.9 Refueling Operations       SR 3.1.1 Fuel Storage Spent Fuel Handling                                             Pool Water Level SR 3.2.1 Reactor Building Crane Operability SR 3.2.2 Reactor Building Crane Travel with a Spent Fuel Cask 4.11 Power Distribution       SR 3.2 Power Distribution               Not Applicable Limits                        Limits 4.1                                     Not included                Relocated to TRM 4.14 Plant Systems         l SR 3.7 Plant Systems           l         Not Applicable      l MP1 TS Section 4.0 - General This section was intended to contain Specifications that had generic applicability to surveillance requirements. There are no requirements in the current MP1 TS. Three Specifications from the STS have been added to the proposed PDTS.                    These Specifications discuss Surveillance Applicability, Frequency, and Failure to Perform.

U. S. Nucie:r Regulttory Commission B17621%ttachment 1\Page 32 STS SR 3.0.4 discusses entry into other operating modes. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, MP1 cannot enter into other operating modes. This Specification is not applicable and is not retained.
MP1 TS Section 4.1 - Reactor Protection System This section specified the minimum frequency and type of surveillance to be applied to the reactor protection system.          These surveillance requirements applied to instrumentation and associated devices which initiated reactor scram during power operations.      Table 4.1.1 of MP1 TS 4.1 specified the testing and frequency requirements. As discussed in Section 3.1 above, the postulated accident scenarios requiring actuation of these systems are no longer possible at MP1 and these Specifications have not been retained in the PDTS. Therefore, the surveillance requirements of MP1 TS 4.1 and Table 4.1.1 have not been retained.
MP1 TS Section 4.2 - Protective Instrumentation This section specified the minimum frequency and type of surveillance to be applied to the protection instrumentation systems, which included the primary containment              i isolation, emergency core cooling actuation, control rod block actuation, air ejector off- )
gas, secondary containment integrity and loss of normal power systems. These surveillance requirements applied to instrumentation and associated devices required during power operation of the reactor. As discussed in Section 3.2.A through 3.2.D above, the postulated accident scenarios requiring actuation of these systems are no longer possible at MP1 and these Specifications have not been retained in the PDTS.
Additionally, as discussed in Sections 3.2.E and 3.2.F above, the surveillance requirements 4.2.E - Reactor Building Ventilation System, Steam Tunnel Ventilation isolation and Standby Gas Treatment Initiation and 4.2.F - Loss of Normal Power instrumentation are no longer required at MP1 because neither of the two Specifications is required or relied on to prevent the occurrence of a fuel handling accident in the fuel storage pool nor to mitigate the consequences of a fuel handling accident. Therefore, the surveillance requirements of Specification 4.2 have not been retained.
MP1 TS Section 4.3 - Reactivity Control This section specified the minimum frequency and type of surveillance to be applied to the reactivity limits and the control rod system to ensure operability of the reactivity control systems. These surveillance requirements applied to reactivity limitations and systems required during power operation of the reactor. As discussed in Section 3.3.A through 3.3.G above, since MP1 has permanently ceased power operation and is no             l longer authorized to place or retain fuel in the reactor vessel, these systems are no       j longer required at MP1 and these Specifications have not been retained in the PDTS.
Therefore, the surveillance requirements of Specification 4.3 have not been retained.

U. S. Nucle:r Regulatory Commission B17621%ttachment 1\Page 33 MP1 TS Section 4.4 - Standby Liouid Control System This section specified the minimum frequency and type of surveillance to be applied to the standby liquid control system. These surveillance requirements ensured that the standby liquid control system was OPERABLE during power operations to provide an emergency system to shutdown the reactor. As discussed in Section 3.4 above, since MP1 has permanently ceased power operation and is no longer authorized to place or retain fuel in the reactor vessel, this system is no longer required at MP1 and these Specifications have not been retained in the PDTS. Therefore, the surveillance requirements of Specification 4.4 have not been retained.
MP1 TS Section 4.5 - Core and Containment Coolina This section specdied the minimum frequency and type of surveillance to be applied to the core and containment cooling systems. These systems were designed to ensure the reactor core and the primary containment were cooled to prevent a breach of the reactor coolant system, or the primary containment which could have resulted in a release of fission products to the environment. As described in the MP1 TS Sections 3.5.A through 3.5.G above, since MP1 has permanently ceased power operation and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, the core cooling and containment cooling systems are no longer required and the surveillance requirements are not retained.
MP1 TS Section 4.6 - Primary System Boundary This section specified the minimum frequency and type of surveillance to be applied to the primary system boundary. These Specifications were designed to ensure the reactor coolant system was maintained within design stress limits to prevent a breach of the reactor coolant system which could have resulted in a release of fission products to the environment. These surveillance requirements included reactor coolant system        ,
pressure, temperature, and chemistry limits. As desc^>ed in the MP1 TS Sections            !
3.6.A through 3.6.K above, since MP1 has permanently ceased power operation and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, the core cooling and containment cooling systems are no longer required and the surveillance requirements are not retained.
MP1 TS Section 4.7 - Containment Systems The primary containment systems and the primary containment isolation valves (LCOs 3.7.A and 3.7.D) were designed to prevent the release of fission products to the environment after a design basis accident. These Specifications ensured the integrity of the primary containment. The surveillance requirements in these sections (4.7.A and 4.7.D) were required to meet primary containment systems integrity, and thus prevent the release of radioactive fission products to the environment.         As described in Sections 3.7.A and 3.7.D above, since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the li us I*

U. S. Nuclear Regul tory Commission B17621\ Attachment 1\Page 34 reactor vessel, primary containment integrity and primary containment isolation valves operability are no longer required.
The secondary containment and the SGTS (LCOs 3.7.B and 3.7.C) not only prevented or mitigated the release of fission products to the environment after a reactor-related     j accident, but also functioned to prevent the release of fission products to the environment in the event of a fuel handling accident in the fuel storage pool. As discussed in Sections 3.7.8 and 3.7.C above, NNECO recently analyzed the fuel handling accident in the fuel storage pool, reflecting the actual decay time on the irradiated fuel and assuming a ground level release without taking credit for the secondary containment or the SGTS. The radiological consequences at the exclusion area boundary and the low population zone were well within 10CFR Part 100 limits, and the calculated doses to the Millstone control roon operators were within the limits specified in 10CFR Part 50 GDC 19 and much les5 than the previous limiting fuel handling accident dose. Since MP1 no longer relies on secondary containment integrity or the SGTS to mitigate the radiological consequences of the fuel handling accident, these systems are no longer required to be OPERABLE nor are they required to perform their safety functions. Therefore, these Specifie9tions are not retained.
MP1 TS Section 4.8 - Radioactive Materials This section specified the minimum frequency and type of surveillance to be applied to the release of radioactive liquids and gases. These systems and Specifications tre designed to monitor radioactive releases to ensure that all releases are monitored and do not exceed the maximum release requirements. As described in the MP1 TS                  '
Sections 3.8.A through 3.8.D above, MP1 TS Section 3.8.A thorough 3.8.D are being relocated to the Radiological Effluent Monitoring and Offs' 3 Dose Calculation Manual (REMODCM).         The REMODCM description is retairied in the PDTS                 in the Administrative Controls under the Programs and Manuals - Section 5.6.1.
MP1 TS Section 4.9 - Auxiliary Electrical System This section specified the minimum frequency and type of surveillance to be applied to the AC and DC electrical power systems during power operations. As described in the MP1 TS Sections 3.9.A, 3.9.B and 3.9.C above, the design basis accidents that required power for the emergency safeguards equipment systems supplied by the auxiliary electrical system are no longer applicable. Further, because of the decay history of the irradiated fuel in the fuel storage pool, power to the systems that support storage and cooling of the irradiated fuel in the fuel storage pool can be interrupted for several days without any consequences to the irradiated fuel. As described in the MP1 TS Section 3.9 above, engineering calculations have concluded that the time to boil the MP1 fuel storage pool on a loss of power and cooling to the fuel pool is approximately ten days.* As a result, there is sufficient time to restore power to fuel pool cooling m Calculation No. 99-ENG-01906-M1, Rev. O," Transient & Steady State Temperature of MP1 SFP & RB With No Active SFP Cooling."

l U. S. Nuclear Reguttory Commission -
B17621%ttachment 1\Page 35 systems before boiling would occur. Therefore, the electrical systems Specifications are no longer required, and there is no need to maintain the fuel oil onsite to support MP1. These Specifications and the surveillance requirements are not retained.
MP1 TS Section 4.10 - Refuelina and Soent Fuel Handlina This section specified the minimum frequency and type of surveillance to be applied to the refueling and spent fuel handling systems. These Specifications were designed to ensure core taactivity is within the capability of the control rods, to prevent criticality during refueling and to assure the safe handling of spent fuel casks. Specifications 4.10.C - Fuel Pool Storage Level, 4.10.D - Crane Operability, and 4.10.E - Crane Travel with a Spent Fuel Cask are retained in the PDTS as SR 3.1.1, SR 3.2.1, and 3.2.2 and have been reformatted to be consistent with the STS. As described in the MP1 TS Sections 3.10.A and 3.10.B above, since MP1 has permanently ceased power operation and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, refueling interlocks and core monitoring systems are no longer required and the surveillance requirements are not retained.
MP1 TS Section 4.11 - Power Distribution Limits This section specified the minimum frequency and type of surveillance to be applied to the power distribution limits. As described in the MP1 TS Sections 3.11.A through 3.11.0 above, since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, power distribution limits are no longer applic.able and the surveillance requirements are not retained.
MP1 TS Section 4.12 - The section was deleted in a previous amendment.
MP1 TS Section 4.13 - Inservice Inspection This section specified the minimum frequency and type of surveillarce to be applied to the inservice inspection. As described in the MP1 TS Sections 3.13 above, inservice inspection requirements are not included in the STS, as they do r,ot satisfy any of the four criteria identified in 10CFR50.36. Applicable ISI surveillance requirements will be relocated. to the Technical Requirements Manual.            Therefore, the surveillance requirements are not retained in the proposed PDTS.
[WIP1 TS Section 4.14 - Plant Systems This section specified the minimum frequency and type of surveillance to be applied to the plant systems. These systems were designed to protect the reactor and turbine during power operations. As described in the MP1 TS Sections 3.14.A and 3.14.B above, since MP1 has permanently ceased power operation and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, the plant systems are no longer required and the surveillance requirements are not retained.

U. S. Nuclear Regul tory Commission B17621%ttachment 1\Page 36 MP1 TS Section 5.0 - Desian Features Section 5.0 of the current MP1 TS describes the desip,n features. In accordance with 10CFR50.36(c)(4), this section describes features of the facility such as materials of construction, or geometric arrangement that, if altered, would significantly affect safety and are not covered in other sections of the Technical Specifications. Consistent with the STS, the design features section is located in Section 4.0 of the PDTS. The current MP1 TS contain design features in six areas. These Specifications are listed in the table below with the corresponding sections of the STS and the PDTS.
Current MP1 TS                 Improved STS               Proposed PDTS 5.1 Site                           4.1 Site Location            4.1 Site Location 5.2 Reactor                        4.2 Reactor Core                   Not Applicable       j 5.3 Reactor Vessel                         Not included                Not included         l 5.4 Containment                            Not included                Not included         I 5.5 Fuel Storage                   4.3 Fuel Storage             4.2 Fuel Storage 5.6 Seismic Design                         Not included             Located in FSAR Of these sections, MP1 TS sections 5.1 Site and 5.5 Fuel Storage have been retained and modified as appropriate. These Specifications are now located in PDTS Section 4.0 Design Features in accordance with the numbering system in the STS (Section 4.1 Site Location and 4.2 Fuel Storage).
PDTS Section 4.1 - The description of the site contained in the current MP1 TS 5.1 Site is retained in PDTS. The information has been reformatted to be consistent with the STS.
PDTS Section 4.2 - The information and requirements contained in MP1 TS 5.5 Fuel Storage are retained in the PDTS. This information has been reformatted to be consistent with the STS.
MP1 TS Sections 5.2, 5.3, and 5.4 describe the design features of the reactor core, reactor vessel, and containment. These structures and systems serve to prevent or mitigate the consequences of postulated accidents involving the release of fission products. Pursuant to 10CFR50.82(a)(2), the facility operating license for MP1 no longer authorizes operation of the reactor or placement or retention of fuel in the reactor. Therefore, these design features are no longer required to protect the health and safety of the public. These sections have been deleted.
MP1 TS Section 5.6 Seismic Design is currently in the MP1 FSAR. This information is deleted in the Design Features section because the FSAR addresses storage of irradiated fuelin the fuel pool.

U. S. Nuclear Regulatory Commission                                                         l B17621%ttachment 1\Page 37 MP1 TS Section 6.0 - Administrative Controls Section 6.0 of the current MP1 TS describes the administrative controls. In accordance with 10CFR50.36(c)(5), administrative controls are the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Consistent with the STS, the administrative controls section is located in Section 5.0 of the PDTS.
The current MP1 TS administrative controls Specifications are listed in the table below with the corresponding sections of the STS and the PDTS.
Current MP1 TS                 Improved STS                   Proposed PDTS 6.1 Responsibility             5.1 Responsibility             5.1 Responsibility            l 6.2 Organization               5.2 Organization               5.2 Organization              !
6.3 Facility Staff             5.3 Unit Staff Qualifications  5.3 Unit Staff Qualificates Qualifications                                                                              j 6.4 Training                           Not included           5.4 Training                  {
6.5 Review and Audit                   Not included                Relocate to NUQAP 6.6 Reportable Event                   Not included                    Not included Action 6.7 Safety Limit Violation             Not included                   Not included 6.8 Procedures                 5.4 Procedures                 5.5 Procedures 6.9 Reporting                  5.6 Reporting                  5.7 Reporting Requirements                   Requirements                   Requirements 6.10 Record Retention                  Not included                Relocate to NUQAP 6.11 Radiation Protection              Not included                    Not included Program 6.12 High Radiation Area       5.7 High Radiation Area        5.8 High Radiation Area 6.13 Systems Integrity                 Not included                    Not included 6.14 lodine Monitoring                 Not included                    Not included 6.15 Radiological Effluent     5.5 Programs and Manuals       5.6.1 REMODCM Monitoring and Offsite Dose Calculation Manual                                                                     I (REMODCM) 6.16 Radioactive Waste         5.5 Programs and Manuals       5.5.1e. Procedures            1 Treatment 6.17 Post accident             5.5 Programs and Manuals               Not Applicable        1 Sampling / Sampling and Analysis of Plant Effluents MP1 TS Section 6.1 - Responsibility 4
This section defines the individual with overall responsibility for operation of MP1. This section is retained in the PDTS and modified to be consistent with the STS.

U. S. Nucle:r Regul: tory Commission B17821\ Attachment 1\Page 38 The shift manager onsite has been designated with responsibility for the command function. The STS require that the command function be maintained in the control room. This requirement is based on the centralized nature of controls for an operating reactor and the rapid response necessary to command those controls in an abnormal or accident situation. With MP1 permanently shutdown and defueled and irradiated fuel stored in the fuel pool, the number of relevant controls located in the control room and the gradual nature of abnormal or accident situations does not warrant that this command function remain in the control room. Capability is provided to maintain ready communications between the control room and the shift manager at all times. This ready-communications capability includes: pagers, radios, and/or plant paging system.
The individual qualified to stand watch in the control room will be provided with the training necessary to take appropriate initial response as described in procedures.        )
l MP1 TS Section 6.2 - Oraanization This section defines the general organizational requirements for MP1. This section is retained in the PDTS. Previous submittals associated with staffing and training
* and associated with generic management titles
* have modified this section to be consistent with the STS and the defueled condition of MP1.                                            l MP1 TS Section 6.3 - Facility Staff Qualifications This section defines the qualification requirements for MP1 staff. This section is retained in the PDTS. As discussed in MP1 TS Section 6.2, a previous change was            l submitted to address staffing and training. This submittal modified this section to be consistent with the STS and the defueled condition of MP1.
MP1 TS Section 6.4 - Trainina This section defines the training requirements for MP1 Certified Fuel Handlers. This       !
section is retained in the PDTS As discussed in MP1 TS Section 6.2, two previous submittals were sent to the NRC to address staffing and training and generic management titles. This submittal modified this section to be consistent with the         '
defueled condition of MP1.
1 MP1 TS Section 6.5 - Review and Audit                                                     l l
This section defines the review and audit requirements for MP1. The following table lists the present contents of this section. All subsections of the MP1 TS Section 6.5 are to be relocated to the NUQAP as permitted by NRC Administrative Letter 95-06,
 " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."       The NUQAP Topical Report is NNECO's NRC-approved Quality                )
i
* Letter M. L. Bowling to USNRC, " Proposed revision to Technical Specifications, Administrative Control:," B17546, dated December 4,1998.                              "
* Letter. M. L. Bowling to USNRC, " Proposed revision to Technical Specifications, Administrative Controls," B17572, dated December 22,1998.

U. S. Nuclear Regulatory Commission                                                   {
B17621%ttachment 1\Page 39 Assurance Program which is controlled under 10CFR50.54(a)(3). These revisions are not e reduction in commitment and will be included in the annual submittal of changes to Revision 20 of the NUQAP Topical Report Current MP1 TS                improved STS           P oposed PDTS 6.5.1 Plant Operations Review           Not included    Relocated to NUQAP Committee (PORC)                                          7 6.5.2 Site Operations Review            Not included    Relocated to NUQAP Committee (SORC) 6.5.3 Nuclear Safety                    Not included    Relocated to NUQAP Assessment Board (NSAB) 6.5.4 Station Qualified Review          Not included    Relocated to NUQAP Program The STS does not include a Review and Audits section equivalent to the MP1 TS Section 6.5. The STS relocated this information to the NUQAP. These sections will be relocated to the NUQAP and were previously modified to replace specific NNECO titles  ,
with generic titles as discussed in Section 6.2 above.
MP1 TS Section 6.6 - Reportable Event Action This section covers the requirements for events that are reportable pursuant to 10CFR50.73. Consistent with the content of the STS, these provisions are not included in the PDTS. The requirements for reporting of events are specified in the applicable regulations and additional detail is not necessary.                                   l MP1 TS Section 6.7 - Safety Limit Violation This section specifies the actions to be taken if a safety limit specified in MP1 TS Section 2.0 is violated. As noted in the discussion of MP1 TS Section 2.0 above, the safety limits are no longer applicable and have not been retained in the PDTS.
Therefore, the provisions of MP1 TS Section 6.7 are unnecessary and have not been retained.
MP1 TS Section 6.8 - Procedures                                                       l This section defines the requirements for control and use of procedures. This section is retained in the PDTS. This section has been modified to be consistent with the STS and the defueled condition of MP1. A previous submittal, discussed in MP1 TS Section 6.2 above, replaced specific NNECO titles with generic management titles.
MP1 TS Section 6.9 - Reportina Reauirements This section defines the requirements for submitting various reports. This section is retained in the PDTS with appropriate modifications as PDTS Section 5.7. Annual Reports Sections 6.9.1.4 through 6.9.1.5 are retained as PDTS Section 5.7.1, Annual

I I
U. S. Nucle:r Regul: tory Commission B17621%ttachment 1\Page 40 Radiological Environmental Operating Report Section 6.9.1.7 is retained as PDTS Section 5.7.2, and Annual Radioactive Effluent Report Section 6.9.1.8 is retained as PDTS Section 5.7.3. The introductory paragraph, Routine Reports, Section 6.9.1, has been retained and identified in the PDTS Section 5.7 introduction by its source requirement,10CFR50.4. The wording is consistent with the STS to the extent consistent with the permanently shutdown and detueled status of the reactor. Several    .
reports listed in MP1 TS Section 6.9 are no longer applicable for a permanently         i defueled reactor. These inapplicable reports are not retained in the PDTS and include:
Startup Report Sections 6.9.1.1 through 6.9.1.3 Annual Reports Section 6.9.1.5(b)
Monthly Operating Report - 6.9.1.6 Supplemental Reload Licensing Submittal - 6.9.1.9 Special Reports - 6.9.2 MP1 TS requires special reports for:
: a. Inservice Inspection Results - MP1 TS Section 4.6.F
: b. Primary Containment Leak Rate Test Results - MP1 TS Section 4.7.A.3
: c. Materials Radiation Surveillance Specimen Examination and Results -
MP1 TS Section 4.6.B.3
: d. Radiological Effluent Reports - MP1 TS Section 3.8.C.2,3.8.D.2,3.8.D.3, and 3.8.D.4
: e. High Range Stack Monitor inoperability - MP1 TS Section 3.8.D.7
: f. Containment High Range Radiation Monitors - MP1 TS Section 3.7.A.7 Special Reports a, b, c, e, and f are not retained in the PDTS. The Specifications requiring these reports are no longer required as discussed above, therefore, the special reports are not required. Special Report d will be relocated to the REMODCM.
MP1 TS Section 6.10 - Record Retention This section contains requirements for the retention of various types of records. These requirements will be reloca.ed to the NUQAP where they will be maintained pursuant to 10CFR50.54(a). This relocation is consistent with the STS, therefore, this section is not retained.
MP1 TS Section 6.11 - Radiation Protection Proaram This section requires that the radiation protection program be maintained pursuant to 10CFR Part 20. Consistent with the content of the STS, these provisions are not included in the PDTS. The requirements for radiation protection are specified in the applicable regulations and additional detail is not necessary.
1

U. S. Nuctorr Regulatory Commission B17621\ Attachment 1\Page 41 MP1 TS Section 6.12 - Hioh Radiation Area This section defines the requirements for control of high radiation areas. This section is retained in the PDTS. This section has been modified to be consistent with the STS and the defueled condition of MP1.
MP1 TS Section 6.13 - Systems Intearity This section contains requirements necessary to minimize leakage from systems outside the containment. In the permanently defueled condition, these systems are no longer required, therefore, thia Specification is not retained.
MP1 TS Section 6.14 - lodine Monitorina This section discusses iodine monitoring. lodine is generated during operation of the     ,
reactor at power. MP1 is no longer authorized to operate the reactor, therefore, iodine  l monitoring is not required and this Specification is not retained. Since MP1 has been shutdowri since November,1995, the irradiated fuel does not have sufficient iodine to warrant a monitoring program.
MP1 TS Section 6.15 - Radioloaical Effluent Monitorina and Offsite Dose Calculation Manual (REMODCM)
This section - discusses the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). This section is retained in the PDTS in Section 5.6 Programs and Manuals, specifically as Section 5.6.1 Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).
MP1 TS Section 6.16 - Radioactive Waste Treatment This section discusses the procedures for control of radioactive effluents. This section is retained in the PDTS in Section 5.5 Procedures, specifically as Section 5.5.ie. The   ,
Section 6.16 note about the Process Control Program is not retained because the          l requirements of this program are identified in 10CFR and are not contained in the STS.
MP1 TS Section 6.17 - Post Accident Samolina/Samolina and Analysis of Plant              ;
Effluents This section discusses the program for performing post accident sarnpling and analysis of plant effluents. Since.MP1 has permanently ceased power operations and is no longer authorized to operate the reactor, the postulated accidents that would require post accident sampling are no longer applicable and this Specification is not retained.

U. S. Nuclear Regul; tory Ccmmission B17621%ttachment 1\Page 42 Summary of Specifications included in the PDTS Three LCOs and associated Surveillance Requirements are contained in the PDTS.
The first Specification, PDTS 3.1.1, was determined to be necessary to meet                  ,
10CFR50.36(c)(2)(ii)(B), Criterion 2 in that it addresses limits that are initial conditions
; for design basis accidents.. The other two Specifications, PDTS 3.2.1 and 3.2.2,             ]
l addresses 10CFR50.36(c)(2)(ii)(C), Criterion 3 because they establish LCOs for SSCs          I (i.e., Reactor Building crane) that are part of the primary success path and which function to prevent an accident (i.e., a drop of a spent fuel cask over irradiated fuel assemblies) that either assumes the failure of, or presents a challenge to, the integrity of the fuel cladding of the irradiated fuel in the fuel storage pool.
PDTS 3.1.1 Fuel Storaos Pool Water Level This Specification requires that the fuel pool water level be maintained and requires verification of compliance at a frequency of 24 hours. The actions associated with this LCO are to immediately suspend fuel handling operations and restore level to within          l limits.                                                                                      I PDTS 3.2.1 Reactor Buildina Crane Operability This Specification requires that the Reactor Building crane be maintained OPERABLE while handling spent fuel casks. The actions associated with this LCO are to immediately suspend all spent fuel cask handling and to place the load in a safe condition. A visual inspection, no-load mechanical and electrical tests, and a load test are conducted on the Reactor Building crane within 4 days prior to spent fuel cask handling operations and every 4 days thereafter during spent fuel cask handling.
PDTS 3.2.2 Reactor Buildina Crane Travel with a Soent Fuel Cask This Specification requires that the Reactor Building crane interlocks and limit switches which prevent crane travel over irradiated fuel assemblies in the fuel storage pool function when the Reactor Building crane is used for handling of a spent fuel cask.
Crane interlocks and limit switches are required to be tested within 7 days prior to spent fuel cask handling operations and every 7 days thereafter during spent fuel cask handling.
SIGNIFICANT HAZARDS CONSIDERATION A review of the proposed changes has determined that there is no Unreviewed Safety Question. The proposed changes to the Technical Specifications have been evaluated against the standards of 10CFR50.92 and have been determined to not involve a significant hazards consideration. An evaluation against these standards is provided below for each of the specific proposed changes.

U. S. Nuclear Regulotory Commission B17621%ttachment 1\Page 43 MP1 TS Section 1 - Definitions Definitions are provided in the MP1 TS for terminology unique to the Technical Specifications. With the reduction in scope of the PDTS as discussed in the evaluation of the remaining MP1 TS sections, most of these unique terms are no longer applicable. For example, the definition of REACTOR POWER OPERATION is based on conditions of the reactor and are no longer used in the defueled condition. The definition of ACTION from the STS has been adopted and a new definition CERTIFIED FUEL HANDLER has been added in Section 1.0 of the PDTS. The basis for the definition of a CERTIFIED FUEL HANDLER was provided to the NRC in a previous submittal." The defiriition of OPERABLE - OPERABILITY was retained in Section 1.0 of the PDTS. Section 1.0 is expanded to include information from the STS on the use of logical connectors, interpretation of completion times and interpretation of surveillance frequencies. The defined terms are indicated throughout the text of the PDTS by showing the terms in all capital letters. This expanded information is consistent with the STS and has been modified to the reduced scope of the PDTS.
The proposed change to MP1 TS Section 1 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The removal of the defined terms that no longer appear in the body of the PDTS has no impact on SSCs or in methods of operation of these SSCs. In addition, the explanatory information that has been added to this section is consistent with the STS and is administrative in nature in that it adds to the clarity and ease of use of the PDTS. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The removal of the defined terms that no longer appear in the body of the PDTS has no impact on SSCs or in methods of operation of these SSCs. In addition, the explanatory information that has been added to this section is consistent with the STS and is administrative in nature in that it adds to the clarity and ease of use of the PDTS. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
* Letter: M. L. Bowling to USNRC, " Proposed revision to Technical Specifications, Administrative Controls," B17572, dated December 22,1998.

U. S. Nuctorr Regulitory Commission B17621\ Attachment 1\Page 44 i
The removal of the defined terms that no longer appear in the body of the PDTS has no impact on SSCs or in methods of operation of these SSCs. In addition, the explanatory information that has been added to this section is consistent with the STS and is administrative in nature in that it adds to the clarity and ease of use of the PDTS. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 2 - Safety Limits and Limitino Safety System Settinos Section 2 of the MP1 TS contains Safety Limits and Limiting Safety System Settings. In accordance with 10CFR50.36(c)(1), safety limits are limiting parameters necessary to protect the physical barriers that guard against uncontrolled release of radioactivity from a nuclear reactor. N a parameter exceeds the specified safety limit, the reactor must be shutdown and operation may not resume until authorized by the Commission.
Limiting safety system settings are values of various parameters associated with the Nuclear Steam Supply System at which automatic protective action is needed during normal operations or anticipated transients to prevent exceeding a safety limit.
The current MP1 TS contain two safety limits. MP1 TS 2.1.1 sets limits on the combination of reactor pressure, core flow, and minimum critical power ratio. These limits prevent damage to the fuel cladding during reactor power operation which could lead to the release of fission products to the reactor coolant system. MP1 TS 2.2.1 sets limits on reactor coolant system pressure. This limitation is intended to prevent damage to the reactor coolant system pressure boundary that could result in the release of fission products in the reactor coolant system to the containment atmosphere.
There are two Specifications which address limiting safety system settings, each            i corresponding to one of the safety limits. MP1 TS 2.1.2 defines the process variables at which automatic protective action is initiated to prevent the fuel cladding safety limit (MP1 TS 2.1.1) from being exceeded. Examples of the automatic protective actions include APRM Flux Scram Trip and APRM Rod Block Trip. MP1 TS 2.2.2 defines the process variables at which automatic protective action is initiated to prevent the reactor coolant system safety limit (MP1 TS 2.2.1) from being exceeded. Examples of the automatic protective actions include Reactor Coolant High Pressure Scram Trip
.and Safety / Relief Valve settings.
Pursuant to 10CFR50.82(a)(2), the facility operating license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor. Since MP1 has permanently ceased power operation and the license no longer authorizes operation, the safety limits and limiting safety systems settings are no longer applicable, and these Specifications are deleted.
The proposed change to MP1 TS Section 2 does not:

U. S. Nucle:r Regulatory C:mmission                                                        '
B17621%ttachment 1\Page 45
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.                                                                  I The provisions of this section are solely related to power operation of the nuclear      ,
reactor. The postulated DBAs involving power operation of the reactor are no            I longer possible due to the permanently shutdown and defueled status of MP1. The DBA that remains applicable to MP1 is not affected by these provisions. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in       l the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident           l previously evaluated.
The provisions of this section are solely related to power operation of the nuclear reactor. The postulated DBAs involving power operation of the reactor are no longer possible due to the permanently shutdown and defueled status of MP1. The DBA that remains applicable to MP1 is not affected by these provisions. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The provisions of this section are solely related to power operation of the nuclear reactor. The postulated DBAs involving power operation of the reactor are no longer possible due to the permanently shutdown and defueled status of MP1. The DBA that remains applicable to MP1 is not affected by these provisions. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3 Ilmitina Conditions for Operation Section 3 of the current MP1 TS describes the Limiting Conditions for Operation (LCOs). In accordance with 10CFR50.36(c)(2), LCOs specify the lowest functional capability or performance levels of equipment required for safe operation of the facility.   ;
The LCOs typically place restrictions on availability of safety equipment needed to          l prevent or mitigate a postulated DBA or on process variables necessary to preserve the initial conditions assumed in the safety analyses of postulated DBAs.
10CFR50.36(c)(2)(ii) define four criteria for establishing LCOs.              Associated surveillance requirements help to ensure that the specified equipment and parameters are maintained within the limits specified in the LCOs. Each section of MP1 TS Section 3 is evaluated below.

U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 46 MP1 TS Section 3.0 - General MP1 TS 3.0 permits the LCO action statements associated with individual systems, subsystems, trains, components, or devices to be consistent with the LCO action statements of the associated electrical power source (normal or emergency power supply). Due to the limited number of LCOs remaining in the proposed PDTS, and since there are no systems required for the permanently defueled condition that have an associated electrical power source, this LCO is not applicable and is not retained.
Although MP1 TS do not contain these LCOs, STS LCO 3.0.1 and LCO 3.0.2 are being placed in the PDTS.        These LCOs discuss applicability and failure to meet the requirements of an LCO.
The proposed change to MP1 TS Section 3.0 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on SSCs or the methods of operation of the SSCs. Similarly, the generic actions from the STS (LCOs 3.0.1 and 3.0.2) added to the MP1 PDTS have no impact on SSCs or the methods of operation of the SSCs.
Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on SSCs or the methods of operation of the SSCs. Similarly, the generic actions from the STS (LCOs 3.0.1 and 3.0.2) added to the MP1 PDTS have no impact on SSCs or the methods of operation of the SSCs.
Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously    l evaluated.
l
: 3. Involve a significant reduction in a margin of safety.
The generic actions that are no longer applicable due to the reduction in scope of the proposed PDTS have no impact on SSCs or the methods of operation of the SSCs. Similarly, the generic actions from the STS (LCOs 3.0.1 and 3.0.2) added to  1 the MP1 PDTS have no impact on SSCs or the methods of operation of the SSCs.
Therefore, the proposed changes to this sec* ion of the MP1 TS do not involve any reduction in a margin of safety.

l 1
U. S. Nuclear Regulatory Commission B17621\ Attachment 1\Page 47 MP1 TS Section 3.1 - Reactor Protection System The reactor protection system was designed to shutdown the reactor when parameters exceeded specified limits to prevent or mitigate the consequences of postulated            l accidents that could result in damage to the reactor fuel cladding or the reactor coolant  '
pressure boundary. The LCOs in this section must be satisfied for the reactor protection system to be considered OPERABLE. Since Millstone Unit No.1 has permanently ceased operations and the fuel has been permanently removed from the reactor vessel, the postulated accident scenarios requiring actuation of the reactor protection system are no longer possible. Therefore, these Specifications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications uset none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.1 does not:
: 1. Involve a significant increase in the probability or consequences of an accident        ;
previously evaluated.
The only remaining DBA postulated in the FSAR is the fuel handling accident in the fuel storage pool. The reactor protection system, as described above, was found not necessary for the safe storage of irradiated fuel. Additionally, the reactor protection system LCO does not satisfy any of the four criteria stated in 10CFR50.36 for inclusion within the Technical Specifications.       Specifically, this instrumentation is rot necessary to monitor any potential degradation on the integrity of the fuel pool and does not prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation effecting the safe storage of irradiated fuel in the fuel pool or analysis of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.

[
U. S. Nuclear Regul: tory Commission B17621\ Attachment 1\Page 48 MP1 TS Section 3.2 - Protective instrumentation The protective instrumentation consisted of primary containment isolation, emergency core cooling systems actuation, control rod block actuation, air ejector off-gas monitoring, secondary containment systems initiation, and loss of normal power             i instrumentation systems. These systems, with the exception of secondary containment systems initiation, were designed to prevent or mitigate the consequences of postulated reactor related accidents by monitoring, actuating, or isolating appropriate systems and components to prevent damage to the fuel cladding, reactor coolant system, or the containment and thus prevented or mitigated the release of radioactive fission products to the environment. Since reactor related accidents are no longer possible at MP1, the associated systems are not required to mitigate these accidents and the Specifications (i.e., LCO 3.2.A, 3.2.B, 3.2.C, 3.2.D, and 3.2.F) are not retained.
The secondary containment systems, which include the standby gas treatment system (SGTS) initiation, Steam Tunnel Ventilation isolation, and Reactor Building ventilation system isolation from high radiation levels at various locations, also function to prevent or mitigate the release of fission products to the environment in the event of a fuel handling accident. Fuel handling accidents in the spent fuel pool have been analyzed and the radiological consequences have been bounded by the failure of all fuel pins in four fuel assemblies ~. The radiological consequences were calculated assuming no credit either for secondary containment or the SGTS (i.e., an unfiltered ground release). Calculated doses at the exclusion area boundary and the low population zone were within 10CFR100 limits, and calculated doses to the Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19. Since MP1               '
accident analysis no longer relies on the secondary containment ventilation and steam tunnel ventilation radiation monitors or the SGTS for mitigation of radiological releases, these systems are no longer required to be OPERABLE nor are they required to perform their safety functions. Therefore, Specification 3.2.E is not retained.
The proposed change to MP1 TS Section 3.2 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The protective instrumentation system, with the exception of the secondary containment systems initiation, does not prevent or mitigate the consequences of fuel handling accidents for the irradiated fuel in the fuel storage pool. Therefore, removing all protective instrumentation except for secondary containment systems initiation does not involve any increase in the probability or consequences of any accident previously evaluated.
The secondary containment systems, which include isolation signals from the Reactor Building ventilation and Steam Tunnel ventilation radiation monitors, and

U. S. Nuclerr Regul: tory Ccmmission B17621\ Attachment 1\Pcge 49 initiation from the SGTS radiation monitors, limit the release of fission prodacts to the environment in the event of a fuel handling accident. Recent bounding analysis was performed of the fuel handling accident in the fuel storage pool, and it was concluded that 10CFR Part 100 limits were not exceeded even without taking credit for the SGTS and the secondary containment systems. Since the remaining accident analysis does not take credit for secondary containment and SGTS mitigation, the probability or consequences of accidents previously evaluated are not increased by this change.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the r:maining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
MP1 TS 3.2.E includes the radiatior, monitors for the secondary containment systems, which are composed of the Reactor Building ventilation and Steam Tunnel ventilation radiation monitors for system isolation and the SGTS radiation monitors for system initiation. The current analysis of the fuel handling accidents in the fuel storage pool does not rely on these radiation monitors for prevention or mitigation.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.3 - Reactivity Control                                                     >
The reactivity control Specifications assured: 1) the operability of the control rod system, 2) that reactor power responded as expected, 3) the capability for rapid shutdown via a scram, and 4) that the control rod system was able to control reactor power. The LCOs in this section must be satisfied for the reactivity control systems to be considered OPERABLE. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, there is no need for reactivity control systems.
Therefore, these Specifications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.3 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

U. S. Nucterr Regul: tory Commission B17621\ Attachment 1\Page 50 i
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, j     are no longer possible due to the permanently defueled condition of the reactor.
2     The reactivity control system was reviewed as discussed above and found not j     necessary for the safe storage of irradiated fuel in the fuel storage pool. Since MP1
;     is no longer authorized to operate the reactor or to place or retain fuel in the reactor, reactivity control systems have no active function for fuel handling           !
accidents in the fuel storage pool. Therefore, the proposed changes to this section     1 of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.               1
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.4 - Standby Liauid Control System The standby liquid control system provided an emergency means of shutting down the reactor in the event that the normal reactivity control systems did not function as designed. The LCOs in this section must be satisfied for the standby liquid control system to be considered OPERABLE. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, the standby liquid control system no longer has any active safety function. Therefore, these Specifications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.4 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The standby liquid control system was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. Therefore,
\

1 U. S. Nucirr Regul: tory Commission B17621%ttachment 1\Page 51 the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.              ,
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.                                                         l MP1 TS Section 3.5 - Core and Containment Coolina Systems The core and containment cooling systems were designed to ensure that the reactor core and the containment were cooled to prevent possible damage to the fuel cladding, reactor coolant pressure boundary, or the containment in the event of a design basis LOCA. The LCOs in this section must be satisfied for the core and containment cooling systems to be considered OPERABLE. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, core and containment cooling systems no longer have any active safety function. Therefore, these Specifications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.5 does not:
: 1. Involve a significant increase in the probability or consequences of an accident          l previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The core and containment cooling systems were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage      i pool. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

U. S. Nucle:r R!gul tory Commission B17621%ttachment 1\Page 52 The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Srocifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.6 - Primary System Boundary These Specifications were designed to maintain the integrity of the reactor coolant system pressure boundary to prevent release of fission products to the containment.
The Specifications included temperature, pressure, chemistry, and structural requirements to ensure that the reactor coolant pressure boundary was not degraded.
Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor, primary system boundary limits are no longer required. Therefore, these Specifications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.6 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The reactor coolant system pressure boundary was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Thereforc, the

U. S. Nuctorr Regul: tory Commission B17621%ttachment 1\Page 53 proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.7 - Containment Systems The primary containment and primary containment isolation valve systems (LCOs 3.7.A       ,
and 3.7.D) were designed to: 1) establish primary containment integrity with the reactor critical or when the reactor was in power operations or hot shutdown, and 2) isolate the  ;
containment in the event of a LOCA and prevent the release of fission products to the      '
environment. The Specifications ensure the operability of the primary containment.
The LCOs in this section must be satisfied for the primary containment systems to be considered OPERABLE. Since MP1 is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, there is no need for primary containment and primary containment isolation valve systems. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The Standby Gas Treatment System (SGTS) and the secondary containment systems (LCOs 3.7.B and 3.7.C) were designed to: 1) filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions, and 2) minimize any ground level release of radioactive materials which might result from a serious accident. The secondary containment and the SGTS were also specifically designed to prevent the release of fission products to the environment in the event of a fuel handling accident in the fuel storage pool. Fuel handling accidents in the spent fuel pool were analyzed and the radiological consequences were bounded by the failure of all fuel pins in four fuel assemblies. The radiological consequences were calculated assuming no credit either for secondary containment or the SGTS (i.e., an      l unfiltered ground release). Calculated doses at the exclusion area boundary and the       I low population zone were within 10CFR100 limits, and calculated doses to the              I Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19 and much less than the previous limiting fuel handling accident dose. Since MP1 accident analysis no longer relies on the secondary containment or the SGTS for mitigation of radiological releases, these systems are no longer required to be OPERABLE nor are they required to perform their safety functions. Therefore, these Specifications are not retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.

U. S. Nucirr Regulatory Commissi:n B17621%ttachment 1\Page 64 The proposed change to MP1 TS Section 3.7 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.                                                                  J All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanentiv defueled condition of the reactor.
The primary and secondary containments were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.
Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a senificant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
MP1 TS 3.7.B/4.7.B and 3.7.C/4.7.C include the operability and surveillance requirements for the SGTS and the secondary containment systems. The current analysis of the fuel handling accidents in the fuel storage pool does not rely on the SGTS nor on the secondary containment systems for prevention or mitigation.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.8 - Radioactive Materials The information in this section is being relocated to the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). These Specifications provide the limits on release of radioactive liquids and gases and the instrumentation required to monitor those releases. This information will be maintained in the REMODCM.
However, this information is not required to be located in Technical Specifications as defined by the criteria of 10CFR50.36(c)(2)(ii). The REMODCM is addressed in the proposed PDTS in Section 5.6 Programs and Manuals, specifically Section 5.6.1              1 Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).

U. S. Nucle r Regul2 tory Commission B17621%ttachment 1\Page 55                                                             j l
The proposed change to MP1 TS Section 3.8 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The provisions of this section are being relocated to REMODCM. The REMODCM is a program as defined in the PDTS Section 5.0 Administrative Controls, Subsection 5.6 Programs and Manuals. Relocating this information is consistent with the STS and is not required to be located in the Technical Specifications pursuant to 10CFR50.36. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The provisions of this section are being relocated to REMODCM. The REMODCM is a program as defined in the PDTS Section 5.0 Administrative Controls, Subsection 5.6 Programs and Manuals. Relocating this information is consistent with the STS and is not required to be located in the Technical Specifications pursuant to 10CFR50.36. Therefore, the proposed changes to this section of the      :
MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
l
: 3. Involve a significant reduction in a margin of safety.
The provisions of this section are being relocated to REMODCM. The REMODCM is a program as defined in the PDTS Section 5.0 Administrative Controls, Subsection 5.6 Programs and Manuals. Relocating this information is consistent with the STS and is not required to be located in the Technical Specifications pursuant to 10CFR50.36. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.9 - Auxiliary Electrical System LCOs 3.9.A and 3.9.B specified the AC and DC electrical power requirements when the reactor was operating. These limits ensured that sufficient electrical power, including offsite power sources and onsite emergency power sources, was available to operate emergency safeguards equipment. LCO 3.9.C specified the minimum amount of fuel oil to be maintained onsite to support the diesel generator and the gas turbine. The DBAs that required power for the emergency safeguards equipment supplied by the auxiliary electrical power system and the onsite emergency power sources are no longer applicable. Further, because of the decay history of the irradiated fuel in the fuel storage pool, power to the systems that support storage and cooling of the irradiated fuel in the fuel storage pool can be interrupted for several days without any consequences to the irradiated fuel. As previously described, studies have concluded 1

U. S. Nucisar Rigulitory Commission B17621\ Attachment 1\Page 56 that fuel storage pool boiling would occur after ten days without power to fuel pool cooling and Reactor Building HVAC."" Therefore, there is sufficient time to restore power to fuel storage pool cooling systems before fuel storage pool boiling would occur. The electrical systems Specifications are no longer required, and the auxiliary electrical systems are no longer relied on to prevent or mitigate a fuel handling accident. Therefore, these Specifications are not retained.
The proposed change to MP1 TS Section 3.9 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The auxiliary electrical cystem was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.10 - Refuelina and Soent Fuel Pool Handlina The Refueling Interlocks and Core Monitoring Systems (LCOs 3.10.A and 3.10.B) assured that inadvertent criticality would not occur during refueling operations and that two source range monitors, one in and one adjacent to any core quadrant where fuel or control rods were being moved, were OPERABLE to assure adequate monitoring of power. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, l
@ Calculation No. 99-ENG-01906-M1, Rev. O, iransient & Steady State Temperature of MP1 SFP & RB With No Active SFP Cooling."

U. S. Nucint Rcgulitory Commission B17621%ttachment . ' age 57 refuelirig interlocks, including the requirement to place the reactor mode switch in refuel, and core monitoring systems are no longer required. Therefore, Specifications 3.10.A Refueling interlocks and 3.10.8 Core Monitoring are not retained. Specification 3.10.C Fuel Storage Pool Level,3.10.D Reactor Building Crane Operability, and 3.10.E Crane Travel with a Spent Fuel Cask are being retained in the PDTS as LCOs 3.1.1, 3.2.1, and 3.2.2 respectively. With the reactor in the permanently shutdown and defueled condition, removed Specifications 3.10 A and 3.10.B meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.10 does not:
I
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool,  i are no longer possible due to the permanently defueled condition of the reactor.
The refueling interlocks and the core monitoring system were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.                                                                i l
The fuel storage pool level, Reactor Building crane operability, and Reactor          I l
Building crane travel with a spent fuel cask Specifications are being retained in the PDTS. Therefore, in total, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.                                                                 !
l The deletion and relocation of these Specifications do not involve any change to the  i structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1.  ,
The fuel storage pool level, Reactor Building crane operability, and Reactor          l Building crane travel with a spent fuel cask Specifications are being retained in the .
PDTS. Therefore, the proposed changes to this section of the MP1 TS would not         I create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion and relocation of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA              l applicable to MP1. The fuel storage pool level, Reactor Building crane operability, and Reactor Building crane travel with a spent fuel cask Specifications are being retained in the PDTS. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
t

l l
U. S. Nuclear R:gulttory Commission B17621%ttachment 1\Page 58 MP1 TS Section 3.11 - Power Distribution Limits These Specifications defined the thermal limits associated with power operation of the reactor. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, these limits are no longer required and these Specifications have not been retainod. With the reactor in the permanently shutdown and defueled condition, these Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.11 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The power distribution limits were reviewed and discussed above and found not          i necessary for the safe storage of irradiated fuel in the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of these Specifications does not involve any change to the structures     l or equipment or methods of operation affecting the safe storage of irradiated fuelin the fuel pool or analysis of remaining DBA applicable to MP1. Therefore, t '
proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.            ;
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
1 I
MP1 TS Section 3.12 - This section was deleted in a previous amendment - No                 ,
evaluation necessary.
MP1 TS Section 3.13 - Inservice inspection The Inservice inspection requirements are not included in the STS, as they do not meet any of the requirements for incorporation into Technical Specifications identified in l
l l
L

U. S. Nucircr Regul: tory Commission B17621\ Attachment 1\Page 59 10CFR50.36(c)(2)(ii) criteria and therefore are not retained in the PDTS. Applicable ISI requirements will be relocated to the Technical Requirements Manual.
The proposed change to MP1 TS Section 3.13 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The inservice inspection requirements were reviewed and discussed above and the        ;
applicable ISI requirements will be relocated to the Technical Requirements            J Manual. Therefore, the proposed changes to this section of the MP1 TS do not           I involve any increase in the probability or consequences of the fuel handling accidents previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.                                                                  J The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel :n the fuel pool or analysis of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
i The deletion of these provisions from the Technical Specifications does not impact      j the assumptions or methodology used in the analyses of remaining DBA applicable         !
to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 3.14 - Plant Systems The plant system Specifications were designed to protect the reactor vessel from            ,
overpressure, and the turbine from moisture carryover. These Specifications were associated with an operating nuclear reactor. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor, the plant systems Specifications are no longer required.
Therefore, these Spec!'ications have not been retained. With the reactor in the permanently shutdown and defueled condition, these Specifications meet ncne of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 3.14 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

=
U. S. Nucirr Regulitory Commission B17621%ttachment 1\Page 60 All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The plant systems were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or         ,
different kind of accident from any accident previously evaluated.                         !
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.0 - Surveillance Reouirements Section 4.0 of the current MP1 TS describes the surveillance requirements. In accordance with 10CFR50.36(c)(3), surveillance requirements are related to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. The surveillance requirements for the PDTS are provided for each LCO directly following that LCO in accordance with the STS. Since there are no safety limits that apply to MP1 with the reactor shutdown and defueled, and since there are relatively few remaining LCOs, the number of surveillance requirements have been greatly reduced. Each section of MP1 TS Section 4 is evaluated below.
MP1 TS Section 4.0 - General This section normally contains Specifications that have generic applicability to surveillance requirements. There are no surveillance requirements in the current MP1 TS. Three Specifications from the STS have been added to the PDTS. These Specifications discuss Surveillance Applicability, Frequency, and Failure to Perform.
The Specification contained in the STS prohibiting entry into an operating mode or other specific condition has not been included since the reactor at MP1 is permanently shutdown and defueled and there will no longer be any changes in operating mode.
l i
1 4
                                                                                                )

U. S. Nuclerr R:gulitory Commission                                                    l B17621%ttachment 1\Page 61 The proposed change to MP1 TS Section 4.0 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The Specifications that are being added are administrative in that they provide direction for applicability, frequency and failure to perform the required surveillances. These requirements have no impact on SSCs, or on the methods of operating SSCs. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The Specifications that are being added are administrative in that they provide direction for applicability, frequency and failure to perform the required surveillances. These requirements have no impact on SSCs, or on the methods of operating SSCs. Therefoia, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The Specifications that are being added are administrative in that they provide direction for applicability, frequency and failure to perform the required surveillances. These requirements have no impact on SSCs, or on the methods of operating SSCs. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.1 - Reactor Protection System This section specified the minimum frequency and type of surveillance to be applied to the reactor protection system.          These surveillance requirements applied to instrumentation and associated devices which initiated reactor scram during power operations. Table 4.1.1 of MP1 TS 4.1 specified the testing and frequency requirements. As discussed in Section 3.1 above, the postulated accident scenarios requiring actuation of thesa systems are no longer possible at MP1 and these Specifications have not been retained in the PDTS. Therefore, the surveillance requirements of MP1 TS 4.1 and Table 4.1.1 have not been retained. With the reactor in the permanently shutdown and defueled condition, the reactor protection system Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
1 i
i i
l 1

U. S. Nucirr Rsgulatory Commission B17621\ Attachment 1\Page 62 The proposed change to MP1 TS Section 4.1 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The reactor protection system was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.
Specifically, this instrumentation is not necessary to monitor any potential degradation on the integrity of the fuel pool and is not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.                                                                  l The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the           I proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.2 - Protective Instrumentation This section specified the minimum frequency and type of surveillance to be applied to the protection instrumentation systems, which include primary containment isolation, emergency core cooling actuation, control rod block actuation, air ejector off-gas, secondary containment integrity and loss of normal power. These surveillance requirements applied to instrumentation and associated devices required during power operation of the reactor. As discussed in Section 3.2.A through 3.2.D above, the postulated accident scenarios requiring actuation of these systems are no longer possible at MP1. and these Specifications have not been retained in the PDTS.
Additionally, as discussed in Sections 3.2.E and 3.2.F above, the surveillance requirements 4.2.E Reactor Building Ventilation System, Steam Tunnel Ventilation isolation and Standby Gas Treatment initiation and 4.2.F - Loss of Normal Power Instrumentation are no longer required or relied on to prevent the occurrence of a fuel handling accident in the fuel storage pool nor to mitigate the consequences of a fuel 1

U. S. Nucle:r RegulItory Commission B17621%ttachment 1\Page 63 I
handling accident. Therefore, the surveillance requirements of Specification 4.2 have not been retained and with the reactor in the permanently shutdown and defueled             {
condition, the protective instrumentation Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 4.2 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possib'a due to the permanently defueled condition of the reactor.
The protective instrumentation was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.
Specifically, this instrumentation is not necessary to monitor any potential degradation on the integrity of the fuel pool and is not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of these Specifications does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significart reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the remaining DBA applicable to MP1. MP1 surveillance requirement 4.2.E includes the radiation monitors for the secondary containment systems, which are composed of the Reactor Building ventilation and Steam Tunnel ventilation radiation monitors for system isolation and the SGTS radiation monitors for system initiation. The current analysis of the fuel handling accidents in the fuel storage pool does not rely on these radiation monitors for prevention or mitigation. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.3 - Reactivity Control This section specified the minimum frequency and type of surveillance to be applied to the reactivity limits and the control rod system to ensure operability of the reactivity l

U. S. Nucirr Rigulitory Commission B17621%ttachment 1\Page 64 control systems. These surveillance requirements applied to reactivity limitations and systems required during power operation of the reactor. As discussed in Section 3.3 above, since MP1 has permanently ceased power operation and is no longer authorized to place or retain fuel in the reactor vessel, these systems are no longer required at MP1 and these Specifications have not been retained in the PDTS.
Therefore, the surveillance requirements of Specification 4.3 have not been retained and with the reactor in the permanently shutdown and defueled condition, the reactivity control Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 4.3 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The reactivity control systems were reviewed and discussed above and found not          i necessary for the ' safe storage of irradiated fuel in the fuel storage pool.
Specifically, these systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.4 - Standby Liauid Control System This section specified the minimum frequency and type of surveillance to be applied to the standby liquid centrol system. These surveillance requirements ensured that the standby liquid control system was OPERABLE during power operations to provide an emergency system to shutdown the reactor. As discussed in Section 3.4 above, since

l U. S. Nucle r RsgulItory Commission B17621\ Attachment 1\Page 65 MP1 has permanently ceased power operation and is no longer authorized to place or retain fuel in the reactor vessel, these systems are no longer required at MP1 and these Specifications have not been retained in the PDTS. Therefore, the surveillance requirements of Specification 4.4 have not been retained and with the reactor in the permanently shutdown and defueled condition, the standby liquid control system Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 4.4 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The standby liquid control system was reviewed and discussed above and found not          I necessary for the safe storage of irradiated fuel in the fuel storage pool.
Specifically, this system is not necessary to monitor any potential degradation on the integrity of the fuel pool and is not needed to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed              i changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
I The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1 Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.5 - Core and Containment Coolina Systems This section specified the minimum frequency and type of surveillance to be applied to the core and containment cooling systems. These surveillance requirements ensured that adequate emergency cooling capability for heat removal was available in the event of a loss of coolant accident or isolation from the normal reactor heat sink.           As discussed in Section 3.5, the Section 3.5 Specifications have not been retained in the PDTS based on the fact that core and containment cooling systems no longer have any l
_ l

U. S. Nucle:r Regul: tory Commission B17621\ Attachment 1\Page 66 active safety function since a design basis LOCA is no longer possible. Therefore, the surveillance requirements of Specification 4.5 have not been retained and with the         i reactor in the permanentiy shutdown and defueled condition, the core and containment cooling systems Specifications meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 4.5 does not:
: 1. Involve a significant increase in the probability or consequences of an accident        {
previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The core and containment cooling systems were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage    '
pool. These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.                                   .
I
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.6 - Primary System Boundary This section specified the minimum frequency and type of surveillance to be applied to the reactor coolant system pressure boundary. These Specifications were designed to ensure the reactor coolant system was maintained within design stress limits to prevent degradation of the reactor coolant system which could have resulted in a release of fission products to the atmosphere. These surveillance requirements included reactor coolant system pressure, temperature, and chemistry limits. As discussed in Section 3.6 above, the primary system boundary limits specified in this section no longer serve any active safety function and these Specifications have not been retained in the PDTS. Therefore, the surveillance requirements of Specification 4.6 have not been

U. S. Nucle r Rsgul t:ry Ccmmission B17621\ Attachment 1\Page 67 retained and with the reactor in the permanently shutdown and defueled condition, the primary system boundary limits meet none of the 10CFR50.36(c)(2)(ii) criteria.
The proposed change to MP1 TS Section 4.6 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The primary system boundary Specifications were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage
   ' pool. These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of these Specifications do not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.7 - Containment Systems The primary containment systems and primary containment isc5 tion valves (LCOs 3.7.A and 3.7.D) were designed to prevent the release of fission products to the environment after a design basis accident. These Specifications ensured the integrity of the primary containment. The surveillance requirements in these sections (4.7.A and 4.7.D) must be satisfied for the primary containment systems integrity, and thus prevent the release of radioactive fission products to the environment. As described in Section 3.7 above, since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel, primary containment integrity and primary containment isolation valves operability are no longer required and these LCOs meet none of the 10CFR50.36(c)(2)(ii) criteria.

U. S. Nucl2cr R gulttory Commission B17621\ Attachment 1\Page 68 The secondary containment and the SGTS (LCOs 3.7.C and 3.7.B) not only prevent or mitigate the release of fission products to the environment after a reactor-related accident, but also function to prevent the release of fission products to the environment in the event of a fuel handling accident in the fuel storage pool. As discussed in Section 3.7 above, NNECO recently analyzed the fuel handling accident in the fuel storage pool, considering the actual decay time on the irradiated fuel and assuming a ground level release without taking credit for the secondary containment or the SGTS. The radiological consequences at the exclusion area boundary and the low population zone were well within 10CFR Part 100 limits, and the calculated doses to the Millstone control room operators were within the limits specified in 10CFR Part 50 GDC 19. Since MP1 no longer relies on secondary containment integrity or the SGTS to mitigate the radiological consequences of the fuel handling accident, these systems are no longer required and these Specifications are not retained.                          j The proposed change to MP1 TS Section 4.7 does not:
: 1. Involve a signnicant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The primary and secondary containments were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.
The primary and secondary containments are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the fuel handling accidents in the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS do         l not involve any increase in the probability or consequences of any accident            '
previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The provisions of this section are related to power operation of the nuclear reactor and to the handling of irradiated fuel. The postulated design basis accidents involving power operation of the reactor are no longer possible due to the permanently shutdown and defueled status of MP1. The design basis accidents that remain applicable to MP1 are the fuel handling accidents in the fuel storage pool.
These accidents have been reanalyzed to reflect the actual decay time of the irradiated fuel, and the radiological consequences were such that there was no need for the secondary containment and the SGTS to mitigate the consequences.
Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.

U. S. Nucle r Reguilt:ry Commission B17621%ttachment 1\Page 69
: 3. Involve a significant reduction in a margin of safety.
The provisions of this section are related to power operation of the nuclear reactor and to the handling'of irradiated fuel. The postulated design basis accidents involving power operation of the reactor are no longte possible due to the permanently shutdown and defueled status of MP1. The d6 sign basis accidents that remain applicable to MP1 are the fuel handling accidents in the fuel storage pool. The current analysis of the fuel handling accidents in the fuel storage pool does not rely on the SGTS nor on the secondary containment systems for mitigation or prevention. The deletion of the provisions in Specification 4.7 does not impact the assumptions or methodology used in the remaining DBA analysis. Tnerefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.8 - Radioactive Materials The information in this section is being relocated to the Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). These Specifications provide the limits on release of radioactive liquids and gases and the instrumentation required to monitor those releases. This information will be maintained in the REMODCM. The REMODCM is addressed in the proposed PDTS in Section 5.6 Programs and Manuals, specifically Section 5.6.1 Radiological Effluent Monitoring and Offsite Dose Calculation   ,
Manual (REMODCM). The radioactive materials Specifications do not satisfy any of the four criteria stated in 10CFR50.36(c)(2)(ii) for inclusion within the Technical Specifications.
The proposed change to MP1 TS Section 4.8 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The radioactive materials systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needeo to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1.
These Specifications are being relocated to the REMODCM and are addressed in proposed PDTS Section 5.6.1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of these Specifications does not involve any change to the structures or oquipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or the analysis of the remaining DBA applicable to MP1. Therefore,

U. S. NucleIr Regulatory Commission B17621\ Attachment 1\Page 70 the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.                                   ,
1 The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.9 - Auxiliary Electrical System This section specified the minimum frequency and type of surveillance to be applied to the AC and DC electrical power systems. These Specifications were designed to ensure adequate electrical power during power operations. As discussed in Section 3.9 above, the DBAs that required power for the emergency safeguards equipment supplied by the auxiliary power system are no longer applicable. Further, because of the decay history of the irradiated fuel in the fuel storage pool, power to the systems that support storage and cooling of the irradiated fuel in the fuel storage pool can be interrupted for several days without any consequences tu the irradiated fuel. As described in Section 3.9 above, engineering calculations have concluded that the time to boil the MP1 fuel storage pool on a loss of power and cooling to the fuel pool is approximately ten days."') There is sufficient time to restore power to fuel pool cooling systems before boiling would occur. Therefore, the electrical systems are no longer required to perform a safety function. The auxiliary electrical system Specifications do    ,
not satisfy any of the four criteria stated in 10 CFR 50.36(c)(2)(ii) for inclusion within the Technical Specifications. The surveillance requirements of Specification 4.9 have      i not been retained.
The proposed change to MP1 TS Section 4.9 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The auxiliary electrical power system was reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. These systems are not necessary to monitor any potential degradation on the integrity of     '
the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
02> Calculation No. 99-ENG-01906-M1, Rev. O, " Transient & Steady State Temperature of MP1 SFP & RB With No Active SFP Cooling."

U. S. Nucle:r Regulitory C mmission B17621\ Attachment 1\Page 71
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affacting the safe storage of irradiated fuel in the l fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.10 - Refuelina and Spent Fuel Handlina This section specified the minimum frequency and type of surveillance to be applied to the refueling and spent fuel handling systems. These Specifications were designed to ensure that core reactivity is within the capability of the control rods, to prevent criticality during refueling, and to assure the safe handling of spent fuel casks. MP1 TS Specifications 4.10.C Fuel Storage Pool Level, 4.10.D Crane Operability, and 4.10.E Crane Travel with a Spent Fuel Cask are retained in the PDTS as SR 3.1.1, 3.2.1, and 3.2.2 respectively. As described in Section 3.10 abovo, Specifications 4.10.A Refueling Interlocks and 4.10.B Core Monitoring Sysicms we not being retain 6d since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor or to place or retain fuel in the reactor vessel. Therefore, the refueling interlocks and the core monitoring system are no longer required and these Specifications are not retained. The refueling interlocks and core monitoring system Specifications do not satisfy any of the four criteria stated in 10CFR50.36(c)(2)(ii) for inclusion within the Technical Specifications.
The proposed change to MP1 TS Section 4.10 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The refueling interlocks and the core monitoring system were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1.          1

U S. Nucle r Rsgul: tory Commission B17621\ Attachment 1\Page 72 The fuel storage pool level, crane operability, and crane travel with a spent fuel j     cask Specifications are being retained in the proposed PDTS Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
l     The deletion and relocation of these Specifications do not invcive any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of remaining DBA applicable to MP1. The fuel storage pool level, crane operability, and crane travel with a spent fuel cask Specifications are being retained in the PDTS. Therefore, the proposed changes l     to this section of the MP1 TS would not create the possibility of a new or different i     kind of accident from any accident previously evaluated.
l 3. Involve a significant reduction in a margin of safety.
The deletion and relocation of these provisions from the Technical Specifications j     does not impact the assumptions or methodology used in the analyses of remaining i     DBA applicable to MP1. The fuel storage pool level, crane operability, and crane l
travel with a spent fuel cask Specifications are being retained in the PDTS.
Therefore, the proposed changes to this section of the MP1 TS do not involve a l     significant reduction in a margin of safety.
l l MP1 TS Section 4.11 - Power Distribution Limits l
l This section specified the minimum frequency and type of surveillance to be applied to ensure that the critical power ratio and heat generation limits were not exceeded.              '
These surveillance requirements applied to limitations and systems required during power operation of the reactor. As discussed in Section 3.11 above, since MP1 has l permanently ceased power operations and is no longer authorized to operate the                 ;
l reactor or to place or retain fuel in the reactor, power distribution limits are no longer l required and these Specifications have not been retained in the PDTS. Power l distribution limits do not satisfy any of the four criteria stated in 10CFR50.36(c)(2)(ii) for l inclusion within the Technical Specifications. Therefore, the surveillance requirements l of Specification 4.11 have not been retained.
The proposed change to MP1 TS Section 4.11 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.

i U. S. Nucirr Regulitory Commission B17621%ttachment 1\Page 73 The power distribution limits were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability   l or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the  i fuel pool or analysis of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.12 - This section was deleted in a previous amendment - No evaluation necessary.
MP1 TS Section 4.13 - Inservice Inspection This section specified the minimum frequency and type of surveillance to be applied to the inservice inspection. As described in the MP1 TS Sections 3.13 above, inservice inspection requirements are not included in the STS, as they do not satisfy any of the four criteria identified in 10CFR50.36(c)(2)(ii).       Applicable Inservice inspection surveillance requirements have been relocated to the Technical Requirements Manual.
The proposed change to MP1 TS Section 4.13 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The inservice inspection requirements were reviewed tend discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool.
These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the DBA remaining applicable to MP1. Therefore, the proposed

U. S. Nucle:r Rtgulitory Commission B17621%ttachment 1\Page 74 changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The relocation of these surveillance requirements does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of remaining DBA applicable to MP1.
Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The relocation of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 4.14 - Plant Systems This section specified the minimum frequency and type of surveillance to be applied to the plant systems. These systems were designed to protect the reactor and turbine during power operations. As described in the MP1 TS Section 3.14 above, since MP1 has permanently ceased power operations and is no longer authorized operate the reactor or to place or retain fuel in the reactor, the plant systems are no longer required and the surveillance requirements are not retained. Plant systems Specifications do not satisfy any of the four criteria stated in 10CFR50.36(c)(2)(ii) for inclusion within the Technical Specifications for a permanently defueled plant.
The proposed change to MP1 TS Section 4.14 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The plant systems were reviewed and discussed above and found not necessary for the safe storage of irradiated fuel in the fuel storage pool. These systems are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.

7.--
U. S. Nucle r Rcgul tory Commissi n B17621%ttachment 1\Page 75
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion of this Specification does not involve any change to the structures or equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 5.0 Desian Features Section 5.0 of the current MP1 TS describes the design features. In accordance with 10CFR50.36(c)(4), this section describes features of the facility such as materials of construction, or geometric arrangement that, if altered, would significantly affect safety and are not covered in other sections of the Technical Specifications. The current MP1 TS contain design features in six areas. Consistent with the STS, the design features are located in Section 4.0 of the PDTS. These Specifications are listed in the table below with the corresponding sections of the STS and the PDTS.
Current MP1 TS                   Improved STS              Proposed PDTS 5.1 Site                            4.1 Site Location           4.1 Site Location 5.2 Reactor                         4.2 Reactor Core                 Not Applicable 5.3 Reactor Vessel                         Not included               Not included 5.4 Containment                            Not included               Not included 5.5 Fuel Storage                    4.3 Fuel Storage            4.2 Fuel Storage 5.6 Seismic Design                         Not included              in MP1 FSAR Of these sections, MP1 TS sections 5.1 Site and 5.5 Fuel Storage have been retained ar.d modified as appropriate. These Specifications are now located in PDTS Section 4.0 Design Features in accordance with the numbering system in the STS (Section 4.1 Site Location and 4.2 Fuel Storage).
PDTS Section 4.1 The description of the site contained in the current MP1 TS 5.1 Site are retained in PDTS. The information has been reformatted to be consistent with the STS.

U. S. Nucle:r Regul tory Ccmmission B17621\ Attachment 1\Page 76 PDTS Section 4.2 The information and requirements contained in MP1 TS 5.5 Fuel Storage are retained in the PDTS. This information has been reformatted to be consistent with the STS.
MP1 TS Sections 5.2, 5.3, and 5.4 describe the design features of the reactor core, reactor vessel, and containment. These structures and systems serve to prevent or mitigate the consequences of postulated accidents involving the release of fission products. Pursuant to 10CFR50.82(a)(2), the facility operating license for MP1 no longer authorizes operation of the reactor or placement or retention of fuel in the reactor. Therefore, these design features are no longer required to protect the health and safety of the public. These sections have been deleted.
MP1 TS Section 5.6 Seismic Design is currently in the MP1 FSAR. This information is included in the MP1 FSAR and addresses storage of irradiated fuel pool.
The proposed change to MP1 TS Section 5 does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.                                                                 l l
All DBAs, with the exception of the fuel handling accident in the fuel storage pool, are no longer possible due to the permanently defueled condition of the reactor.
The design features were reviewed and discussed and, except for those Specifications which are being retained, were found not necessary for the safe storage of irradiated fuel in the fuel storage pool. The deleted design features are not necessary to monitor any potential degradation on the integrity of the fuel pool and are not needed to function to prevent or mitigate the consequences of any of the DBA remaining applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The deletion or relocation of these provisions from the Specification does not involve any change to the structures or. equipment or methods of operation affecting the safe storage of irradiated fuel in the fuel pool or analysis of the remaining applicable DBA to MP1. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Involve a significant reduction in a margin of safety.
The deletion or relocation of these provisions from the Technical Specifications does not impact the assumptions or methodology used in the analyses of the i

U. S. Nuclear Regul: tory Commission B17621%ttachment 1\Page 77 remaining DBA applicable to MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
MP1 TS Section 6 - Administrative Controls Consistent with the STS, the administrative controls are located in Section 5.0 of the PDTS. Where practicable, the individual Specifications in the PDTS have been patterned after those contained in the STS. Soms deviations in the PDTS have been included as appropriate for MP1 plant specific items. The scope of activities, and consequently the size of the staff at MP1, ata greally reduced from those at an operating plant. Also, as previously discussed in 'his cubmittal, the potential impact on the health and safety of the public due to postulaiou accidents is much lower than for an operating plant. Therefore, some of the administrative controls have been reduced as appropriate. The specific provisions of the MP1 TS are discussed separately below.
Current MP1 TS                      improved STS               Proposed PDTS 6.1 Responsibility               5.1 Responsibility            5.1 Responsibility 6.2 Organization                 5.2 Organization              5.2 Organization 6.3 Facility Staff               5.3 Unit Staff Qualifications 5.3 Unit Staff Qualifications                                                 Qualifications 6.4 Training                                Not included       5.4 Training 6.5 Review and Audit                        Not included       Relocate to NUQAP 6.6 Reportable Event Action                 Not included                Not included 6.7 Safety Limit Violation                  Not included                Not included 6.8 Procedures                   5.4 Procedures                5.5 Procedures 6.9 Reporting Requirements       5.6 Reporting Requirements    5.7 Reporting Requirements 6.10 Record Retention                       Not included           Relocate to NUQAP 6.11 Radiation Protection                   Not included                Not included Program 6.12 High Radiation Area         5.7 High Radiation Area       5.8 H95 Radiation Area 6.13 Systems integrity                      Not included                Not incicded 6.14 lodine Monitoring                      Not included                Not included 6.15 Radiological Effluent       5.5 Programs and Manuals      5.6.1 REMODCM Monitoring and Offsite Dose                                    Programs and Manuals Calculation Manual (REMODCM) 6.16 Radioactive Waste           5.5 Programs and Manuals      5.5.1e. Procedures Treatment 6.17 Post Accident Sampling /    5.5 Programs and Manuals              Not Applicable Sampling and Analysis of Plant Effluents
                                                                                   - _ __A

U. S. Nucle:r R gulitory Commission B17621%ttachment 1\Page 78 MP1 TS Section 6.1 - Responsibility This section defines the individual with overall responsibility for operation of MP1 This section is retained in the PDTS and modified to be consistent with the STS. The shift manager onsite has been designated with responsibility for the command function. The STS require that the command function be maintained in the control room. This requirement is based on the centralized nature of controls for an operating reactor and the rapid response necessary to command those controls in an abnormal or accident situation. With MP1 permanently shutdown and defueled and irradiated fuel stored in the fuel pool, the number of relevant controls located in the control roum and the gradual nature of abnormal or accident situations do not warrant that the command function remain in the control room. Capability is provided to maintain ready communications between the control room and the chift manager at all times. This ready communications capability includes: pagers, radios, and/or plant paging systam.
The individual qualified to stand watch in the control room will be provided with the training necessary to take appropriate initial response as described in procedures.
MP1 TS Section 6.2 - Oraanization This section defines the general organizatiorial requiremer:ts for MP1. This section is retained in the PDTS. Previous submittals associated with staffing and training and associated with generic managemer,t titles have modified this section to be consistent with the STS and the defueled condition of MP1.
MP1 TS Section 6.3 - Facility Staff Qualifications This section defines the qualification requirements for MP1 staff. This section is retained in the PDTS. As discussed in MP1 TS Section 6.2, a previous change was submitted to address staffing and training. This submittal modified the section to be consistent with the STS and the defueled condition of MP1.
MP1 TS Section 6.4 - Trainina This section defines the training requirements for MP1 Certified Fuel Handlers. This section is retained in the PDTS. As discussed in MP1 TS Section 6.2, two previous submittals were sent to the NRC to address staffing and training and generic management titia changes. These submittals modified the section to be consistent with the defueled condition of MP1.
MP1 TS Section 6.5 - Review and Audit - This section defines the review and audit requirements for MP1. The STS does not include a Review and Audits section equivalent to MP1 TS Section 6.5. The STS relocated this information to the Quality Assurance Topical Report. Sections 6.5.1, 6.5.2, 6.5.3, and 6.5.4 will be relocated to the NUQAP. These sections were previously modified to replace specific NNECO titles with generic titles as discussed in Section 6.2 above. All subsections of the MP1 TS Section 6.5 are to be relocated to the NUQAP as permittod by NRC Administrative

U. S. Nuclear R:gulatory Commission B17621%ttachment 1\Page 79 Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
MP1 TS Section 6.6 - Reportable Event Action This section covers the requirements for events that are reportable pursuant to 10CFR50.73. Consistent with the content of the STS, these provisions are not included in the PDTS. The requirements for reporting of events are specified in the applicable regulations and additional detail is not necessary.
MP1 TS Section 6.7 - Safety Limit Violation This section specifies the actions to be taken if a safety limit specified in MP1 TS Section 2 is violated. As noted in the discussion of MP1 TS Section 2 above, the safety limits are no longer applicable and have not been retained in the PDTS.
Therefore, the provisions of MP1 TS Section 6.7 are unnecessary and have not been retained.
MP1 TS Section 6.8 - Procedures This section defines the requirements for control and use of procedures. This section is retained in the PDTS. This section has been modified to be consistent with the STS and the defueled condition of MP1. A previous submittal, discussed in MP1 TS Section 6.2 above, replaced specific NNECO title with generic manLgement titles.
MP1 TS Section 6.9 - Reportino Reauirements This section defines the requirements for submitting various reports. This section is retained in the PDTS with appropriate modifications as PDTS Section 5.7. Annual Reports Sections 6.9.1.4 through 6.9.1.5 are retained as PDTS Section 5.7.1, Annual Radiological Environmental Operating Report Section 6.9.1.7 is retained as PDTS Section 5.7.2, and Annual Radioactive Effluent Report Section 6.9.1.8 is retained as PDTS Section 5.7.3. The wording is consistent with the STS to the extent consistent with the permanently shutdown and defueled status of the reactor. The introductory paragraph, Routine Reports, Section 6.9.1, is also retained and identified in the PDTS by its source requirement in 10CFR50.4. Several reports listed in MP1 TS Section 6.9 are no longer applicable for a permanently defueled reactor.
These reports are not retained in the PDTS and include:
Startup Report - 6.9.1.1 through 6.9.1.3 Annual Reports - 6.9.1.5(b)
Monthly Operating Report - 6.9.1.6 Supplemental Reload Licensing Submittal - 6.9.1.9 Special Reports - 6.9.2 l

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U. S. Nucle:r Regulatory Commission B17621%ttachment 1\ Pat,a 80 MP1 TS requires special reports for:
: a. Inservice inspection Results - MP1 TS Section 4.6.F
: b. Primary Containment Leak Rate Test Results - MP1 TS Section 4.7.A.3
: c. Materials Radiation Surveillance Specimen Examination and Results -
MP1 TS Section 4.6.B.3
: d. Radiological Effluent Reports - MP1 TS Section 3.8.C.2,3.8.D.2, 3.8.D.3, and 3.8.D.4
: e. High Range Stack Monitor inoperability - MP1 TS Section 3.8.D.7
: f. Containment High Range Radiation Monitors - MP1 TS Section 3.7.A.7 Special Reports a, b, c, e, and f are not retained in the PDTS. The Specifications requiring these reports are no longer required as discussed above, therefore, the special reports are not required. Special report d will be relocated to the REMODCM.
MP1 TS Section 6.10 - Record Retention This section contains requirements for the retention of various types of records. These requirements will be relocated to the NUQAP where they will be maintained pursuant to 10CFR50.54(a). This relocation is consistent with the STS, therefore, this section is not retained.
MP1 TS Section 6.11 - Radiation Protection Proaram                                       l This section requires that the radiation protection program be maintained pursuant to 10CFR Part 20. Consistent with the content of the STS, these provisions are not included in the PDTS. The requirements for radiation protection are specified in the applicable regulations and additional detail is not necessary.
MP1 TS Section 6.12 - Hiah Radiation Area This section defines the requirements for control of high radiation areas. This section is retained in the PDTS. This section has been modified to be consistent with the STS, current health physics practices, and the defueled condition of MP1.
MP1 TS Section 6.13 - Systems inteority This section contains requirements necessary to minimize leakage from systems outside the containment. In the permanently defueled condition, these systems are no longer required, therefore, this Specification is not retained.
MP1 TS Section 6.14 - lodine Monitorina This section discusses iodine monitoring. lodine is generated during operation of the reactor at power. MP1 is no longer authorized to operate the reactor, therefore, iodine monitoring is not required and this Specification is not retained. Since MP1 has been

U. S. Nucle:r Regul: tory Cammissi:n                                                         j B17621%ttachment 1\Page 81                                                                   l shutdown since November,1995, the irradiated fuel in the fuel storage pool does not have sumcient iodine to warrant a monitoring program.
MP1 TS Section 6.15 - Radioloaical Effluent Monitorina and Offsite Dose Calculation Manual (REMODCM)
This section discusses the Radiological Emuent Monitoring and Offsite Dose Calculation Manual (REMODCM). This section is retained in the PDTS in Section 5.6 Programs and Manuals, specifically as Section 5.6.1 Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).
MP1 TS Section 6.16 - Radioactive Waste Treatman_t This section discusses the procedures for control of radioactive emuents. This section is retained in the PDTS in Section 5.5 Procedures, specifically as Section 5.5.1e. The Section 6.16 note about the Process Control Program is no retained because the requirements of this program are identified in 10CFR and are not contained in the STS.
MP1 TS Section 6.17 - Post Accident Samolina/Samolina and Analysis of Plant Emuents This section discusses the program for performing post accident sampling and analysis of plant emuents. Since MP1 has permanently ceased power operations and is no longer authorized to operate the reactor, the postulated accidents that would require post accident sampling are no longer applicable and this Specification is not retained.
The proposed change to MP1 TS Section 6 does not:                                            j
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
This section of the MP1 TS provides for administrative controls over facility activities and does not directly affect the design of structures or equipment necessary for the safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the fuel pool. The proposed changes to this section delete provisions that are no longer applicable and modify the controls as appropriate for the reduced scope of activities due to the permanently shutdown and defueled condition of MP1.
The safety significant aspects of the organization, facility staffing, qualification and training will coretinue to be maintained. Programs, procedures, and reports that are     i applicable to the safe storage of irradiated fuel are included in the PDTS. The administrative controls for reviews and audits are being relocated to the NUQAP.
The retention of records is being relocated to the NUQAP. These changes are administrative in nature and do not affect any accidents applicable to the safe storage of irradiated fuel or the permanently shutdown and defueled condition of MP1. Therefore, the proposed changes to this section of the MP1 TS do not involve

U. S. Nuclear Regulatory Commission B17621%ttachment 1\Page 82 any increase in the probability or consequences of any accident previously evaluated
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The revised administrative controls do not alter the design of stru'ctures or equipment needed for safe storage of irradiated fuel or the methods of fuel handling and storage in the fuel pool. The proposed PDTS continue to provide for safety significant administrative controls and activities. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.                              ,
l l    3. Involve a significant reduction in a margin of safety.
l The proposed changes have no impact on the analyses of the postulated DBA             i remaining applicable to MP1. Therefore, the proposed changes to this section of       I the MP1 TS do not involve any reduction in a margin of safety,                        ;
Summary of Sionificant Hazards Evaluation                                                 !
The following is a summary compilation of the above significar.t hazards evaluations.
The proposed change does not:
: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
This proposed change is consistent with the STS. The relocation of requirements from the MP1 TS to the licensee controlled documents is consistent with the criteria set forth in 10CFR50.36 for the content of Technical Specifications. The removal of definitions, generic LCO actions and generic surveillance requirements has no impact on facility SSCs or the methods of operation of such SSCs. The deletion of design features and safety limits not applicable to the permanently shutdown and defueled status of MP1 has no impact on the remaining DBA, the fuel handling accidents in the fuel storage pool.       The removal of LCOs and surveillance requirements which are related only to the operation of the nuclear reactor or only to the prevention, diagnosis or mitigation of reactor-related transients or accidents do not effect the applicable DBA previously evaluated. The critical safety functions involving core reactivity control, reactor heat removal, reactor coolant system inventory control and containment integrity are no longer necessary at MP1. The proposed accidents involving damage to the reactor coolant system, main steam lines, reactor core, and the subsequent release of radioactive material are no longer i possible at MP1. Fuel pool cooling and makeup related equipment and support equipment (e.g., electrical power systems) are not required to be continuously available since recent analysis demonstrated that there is up to ten days before fuel I
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U. S. Nucirr RigulItory Commission B17621%ttachment 1\Page 83 storage pool boiling to effect repairs, establish alternate sources of make up flow, or establish steady state natural air circulation cooling of the Reactor Building atmosphere and fuel storage pool water in the event of a loss of cooling and makeup flow to the fuel pool. The radioactive decay of the irradiated fuel since shutdown of the reactor in November,1995 has reduced the consequences of the fuel handling accident to levels well below those previously analyzed. The relevant parameter (water level) associated with the fuel pool provides an initial condition for the fuel handling accident analyses and is included in the PDTS. The Reactor Building crane LCOs are retained to preserve the engineered controls which preclude a spent fuel cask drop from occurring over the fuel storage pool. The deletion and modification of provisions of the administrative controls do not directly affect the design of SSCs necessary for safe storage of irradiated fuel or the methods used for handling and storage of such fuel in the fuel pool. The relocation of administrative controls related to quality assurance to the Northeast Utilities Quality Assurance Program is also consistent with the guidance provided in NRC Administrative Letter AL 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995.
The changes to the administrative controls are administrative in nature and do not affect any accidents applicab's to the safe storage of irradiated fuel or the permanently shutdown and defueled condition of the reactor. Therefore, the proposed changes to the MP1 TS do not involve any increase in the probability or consequences of any accident previously evaluated.
: 2. Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes havo no impact on facility SSCs affecting the safe storage of irradiated fuel or on the methods of operation of such SSCs, or handling and storage of such fuel. lhe:.e changes are consistent with the STS and add to the clarity and ease of use of the proposed PDTS. The removal of Technical Specifications which are related only to the operation of the nuclear reactor or only to the prevention, diagnosis, or mitigation of reactor-related transients or accidents cannot result in different or more adverse failure modes or accidents than previously evaluated because the reactor is permanently shutdown and defueled and MP1 is no longer authorized to operate the plant. The proposed deletion of provisions of the MP1 TS do not affect systems credited in the accident analyses for the fuel         !
handling accident in the fuel storage pool at MP1. The proposed PDTS continue to require proper control and monitoring of safety significant parameters and activities.
The proposed restriction on the fuel pool level is fulfilled by normal operating conditions and preserves initial conditions assumed in the analyses of the postulated DBA. Reactor Building crane LCOs are retained from current Technical Specifications to preclude the possibility of a spent fuel cask drop over the fuel storage pool. Therefore, the proposed changes to this section of the MP1 TS would not create the possibility of a new or different kind of accident from any accident previously evaluated.

U. S. Nucleir Rsgulitory Commission                                                          I B17621%ttachment 1\Page 84
: 3. Involve a significant reduction in a margin of safety.
The deletion of provisions of the MP1 TS, which are not related to the storage of irradiated fuel or which are inconsistent with the scope of the STS, will not affect the analyses of the remaining DBA applicable to MP1. The postulated DBAs involving the reactor are no longer possible due to the permanently shutdovn and defueled condition of the reactor. The requirements for SSCs which have b9en deleted from the MP1 TS are not credited in the existing accident andyses for the remaining applicable postulated accidents and therefore, do not contricute to the margin of safety associated with the accident analysis. Therefore, the proposed changes to this section of the MP1 TS do not involve any reduction in a margin of safety.
Conclusion NNECO has concluded that the proposed change to the MP1 Technical Specifications does not involve a significant hazards consideration as defined by 10CFR50.92.
ENVIRONMENTAL IMPACT DETERMINATION This amendment request meets the criteria of 10CFR51.22(c)(9) for categorical exclusion or otherwise not requiring environmental review. Specific criteria contained in this section are discussed below.
: 1. The amendment involves no significant hazards consideration. As demonstrated            I above, this requested amendment does not involve any significant hazards considerations.                                                                        l
: 2. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The requested license amendment
                                                                                             ]
proposes to modify the facility operating license to reflect the permanently            j shutdown and defueled condition of the reactor. Administrative controls on plant        I effluents that may be released offsite are met. Thus, no anticipated plant activities   I as a result of the issuance of this amendment should result in a significant change in the types or amounts of any effluents that may be released offsite.
: 3. There is no significant increase in individual or cumulative occupational radiation worker exposure. The proposed amendment will provide relief from certain                  '
operational requirements that are inappropriate for a permanently shutdown and defueled reactor.        These operational requirements (surveillance testing, inspections, etc.) in some cases, result in the accrual of occupational radiation exposure of MP1 workers. As the requirements for conducting these cetivities are reduced, many of these activities may be eliminated. The elimination of these            j unnecessary activities is expected to result in a decrease in the cumulative radiation    !
exposure. In addition, administrative controls shall remain in place to ensure that       ,
individual occupational radiation exposure is maintained below applicable regulatory requirements.
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I U. S. Nuclerr RIgul: tory Commission B17621%ttachment 1\Page 85 l   4. On the basis of the preceding discussion, it has been concluded that the proposed amendment is acceptable and meets the eligibility criteria for categorical exclusion
'      set forth in 10CFR51.22(c)(9), and thus, no environmental impact statement or environmental assessment needs to be prepared in mnnection with the issuance of this amendment.
SCHEDULE CONSIDERATION We request NRC approval and issuance of this proposed change at your earliest convenience, with the amendments effective as of the date of issuance. Our proposed schedule for implementing these amendments is within 90 days of issuance.
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Attechment 2 Millstone Nuclear Power Station Unit No.1 Technical Specifications Cross-Reference Table l                                                                   I
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April 1999

U. S. Nucbir Regul tory Commission B17621%ttachment 2\Page 2 OPERATING TECHNICAL SPECIFICATIONS TO DEFUELED TECHNICAL SPECIFICATIONS CROSS-REFERENCE Operating                                Defueled 1.0    Definitions                      1.1 Definitions - Most Deleted 1.2 Logical Connectors 1.3 Completion Times 1.4 Frequency 2.0    Safety Limits & Limiting Safety  Not Applicable System Settings 3.0    LCO General                      LCO 3.0 Limiting Condition for Operation Applicability LCO 3.01 Applicability & LCO 3.02 Failure to Meet an LCO 4.0    Surveillance Requirement         SR 3.0 Surveillance Requirement General "Not Applicable"              Applicability 3.1    Reactor Protection System        Not Applicable
                                                                             )
4.1    Reactor Protection System        Not Applicable                     l 3.2.A Primary Containment isolation     Not Applicable                     l Functions                                                          ~
3.2.8 ECCS Actuation                    Not Applicable 4.2.A Functional Tests                  Not Applicable 3.2.C Control Rod Block Actuation       Not Applicable 4.2.B Control Rod Blocks                Not Applicable 3.2.D Air Ejector Off Gas System        Not Applicable 3.2.E Reactor Building Ventilation      Not Applicable Isolation, Steam Tunnel Ventilation isolation, & Standby Gas Treatment initiation 3.2.F Loss of Normal Power              Not Applicable Instrumentation 4.2.F Loss of Normal Power              Not Applicable Instrumentation 3.3.A Reactivity Limitations            Not Applicable                    I s 4.3.A Reactivity Limitations            Not Applicable 3.3.B Control Rod Withdrawal            Not Applicable 4.3.B Control Rod Withdrawal            Not Applicable 3.3.C Scram insertion Times             Not Applicable 4.3.C Scram insertion Times             Not Applicable 3.3.D Control Rod Accumulators          Not Applicable

U. S. Nuclear Regulatory Commission
' B17621%ttachment 2\Page 3 -
Operating                           Defueled 4.3.D Control Rod Accumulators      Not Applicable 3.3.E Reactivity Anomalies          Not Applicable 4.3.E Reactivity Anomalies          Not Applicable 3.3.F Shutdown Requirements         Not Applicable 3.3.G Thermal Power Core Flow       Not Applicable 3.4.A SLC - Normal Operation        Not Applicable 4.4.A SLC - Normal Operation        Not Applicable 3.4.B SLC - Operation with          Not Applicable Inoperable Components 3.4.C - SLC - Boron Requirements    Not Applicable 4.4.C SLC - Boron Requirements      Not Applicable 3.4.D SLC'- Shutdown Requirements   Not Applicable 3.5.A Core Spray & LPCI             Not Applicable 4.5.A Core Spray & LPCI             Not Applicable 3.5.B - Containment Cooling         Not Applicable 4.5.B Containment Cooling           Not Applicable 3.5.C F W Cl                        Not Applicable 4.5.C FWCl                          Not Applicable          j 3.5.D Automatic Pressure Relief     Not Applicable 4.5.D Automatic Pressure Relief     Not Applicable 3.5.E lsolation Condenser           Not Applicable 4.5.E isolation Condenser           Not Applicable 3.5.F Minimum Core & Containment    Not Applicable Cooling System Availability 4.5.F Normal Operation              Not Applicable 3.5.G Ultimate Heat Sink            Not Applicable 4.5.G Ultimate Heat Sink            Not Applicable 3.6.A Thermal Limitations           Not Applicable 4.6.A Thermal Limitations           Not Applicable 3.6.B Pressurization Temperature    Not Applicable 4.6.B Pressurization Temperature    Not Applicable 3.6.C - Coolant Chemistry           Not Applicable 4.6 C Coolant Chemistry             Not Applicable 3.6.D Coolant Leakage               Not Applicable          ;
4.6.D Coolant Leakage               Not Applicable          j 3.6.E Safety and Relief Valves      Not Applicable          i 4.6.E Safety and Relief Valves      Not Applicable 3.6.F StructuralIntegrity           Not Applicable 4.6.F Structuralintegrity           Not Applicable 3.6.G Jet Pumps                     Not Applicable l
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U. S. Nuclear Regul: tory Commission B17621%ttachment 2\Page 4 Operating                            Defueled 4.6.G Jet Pumps                      Not Applicable 3.6.H Recirc Pump Flow Mismatch      Not Applicable 4.6.H Recire Pump Flow Mismatch      Not Applicable 3.6.1  Snubbers                      Not Applicable 4.6.1  Snubbers                      Not Applicable 3.6.J Condensate Demineralizers      Not Applicable 4.6.J Condensate Demineralizers      Not Applicable 3.6.K Mechanical Condenser Vacuum    Not Applicable Pump 4.6.K Mechanical Condenser Vacuum    Not Applicable Pump                                                            1 3.7.A Primary Containment            Not Applicable                    1 4.7.A Primary Containment            Not Applicable 3.7.B Standby Gas Treatment System   Not Applicable 4.7.B Standby Gas Treatment System   Not Applicable 3.7.C Secondary Containment          Not Applicable                    ;
4.7.C Secondary Containment          Not Applicable                    l 3.7 D Primary Containment isolation  Not Applicable Valves 4.7.D Primary Containment isolation  Not Applicable Valves                                                          }
3.8.A Radioactive Liquid Effluent    Relocate to the REMODCM and 5.6.1 Instrumentation 4.8.A Radioactive Liquid Effluent    Relocate to the REMODCM and 5.6.1 Instrumentation 3.8.B Radioactive Gaseous Effluent   Ralocate to the REMODCM and 5.6.1 Monitoring Instrumentation 4.8.B Radioactive Gaseous Effluent   Relocate to the REMODCM and 5.6.1 Instrumentation 3.8.C Radioactive Liquid Effluents   Relocate to the REMODCM and 5.6.1 4.8.C Radioactive Liquid Effluents   Relocate to the REMODCM and 5.6.1 .
3.8.D Radioactive Gaseous Effluents  Relocate to the REMODCM and 5.6.1 4.8.D Radioactive Gcseous Effluents  Relocate to the REMODCM and 5.6.1 3.9.A Auxiliary Electrical Power -   Not Applicable Reactor Critical 4.9.A Emergency Power Sources        Not Applicable 3.9.B Auxiliary Electrical Power -   Not Applicable Mode Switch in Run 4.9.B Batteries                      Not Applicable 3.9.C Diesel and Gas Turbine Fuel    Not Applicable 4.9.C Diesel and Gas Turbine Fuel    Not Applicable i

U. S. Nucl cr Regul: tory Commission B17621%ttachment 2\Page 5                                                I i
Operating                             Defueled            ;
3.10.A Refueling interlocks           Not Applicable 4.10.A Refueling Interlocks           Not Applicable 3.10.8 Core Monitoring                Not Applicable 4.10.B Core Monitoring                Not Applicable 3.10.C Fuel Storage Pool Water Level  LCO 3.1.1 Fuel Storage Pool Water Level 4.10.C Fuel Storage Pool Water Level  SR 3.1.1 Fuel Storage Pool Water Level 3.10.D Crane Operability              LCO 3.2.1 Reactor Building Crane Operability 4.10.D Crane Operability              SR 3.2.1 Reactor Building Crane Operability 3.10.E Crane Travel with a Spent Fuel LCO 3.2.2 Reactor Building Crane Cask                               Travel with a Spent Fuel Cask 4.10.E Crane Interlocks and Switches  SR 3.2.2 Reactor Building Crane Travel with a Spent Fuel Cask 3.11 A Average Planar Linear Heat     Not Applicable Generation Rate 4.11.A Average Planar Linear Heat     Not Applicable                     ,
Generation Rate                                                  !
3.11.8 Linear Heat Generation Rate    Not Applicable 4.11.B Linear Heat Generation Rate    Not Applicable 3.11.C Minimum Critical Power Ratio   Not Applicable 4.11.C Minimum Critical Power Ratio   Not Applicable                     I 3.11.D APRM Setpoints                 Not Applicable 4.11.D APRM Setpoints                 Not Applicable 3.13.A Inservice inspection           Relocate to the TRM 4.13.A Inspections                    Relocate to the TRM                l 4.13.B Testing                        Relocate to the TRM 3.14.A Turbine Bypass System          Not Applicable 4.14.A Turbine Bypass System          Not Applicable 3.14.8 Reactor High Water Level       Not Applicable Feedwater Pump Trip instrumentation 4.14.B Reactor High Water Level       Not Applicable Feedwater Pump Trip Instrumentation 5.1    Site                           4.1 Site Location 5.2    Reactor                        Not Applicable 5.3    Reactor Vessel                 Not Applicable 5.4    Containment                    Not Applicable

U. S. Nucle:r Regul: tory Commission B17621%ttachment 2\Page 6 Operating                               Defueled 5.5     Fuel Storage                    4.2 Fuel Storage 5.6    Seismic Design                   Currently in MP-1 FSAR 6.1    Responsibility                   5.1    Responsibility 6.2    Organization                     5.2    Organization 6.3    Facility Staff Qualifications    5.3    Facility Staff Qualifications 6.4    Training                         5.4    Training 6.5.1 PORC                              Relocate to NUQAP 6.5.2 SORC                              Relocate to NUQAP 6.5.3 NSAB                              Relocate to NUQAP 6.5.4 Station Qualified Reviewer        Relocate to NUQAP Program 6.6     Reportable Event Action         Not Retained 6.7    Safety Limit Violation           Not Applicable 6.8    Procedures                       5.5   Procedures 6.9.1 Routine Reports                   5.7 Annual Reports (introductory paragraph) 6.9.1.1 through 6.9.1.3 Startup Reports Not Applicable 6.3.1.4 through 6.9.1.5 Annual Reports 5.7.1 Occupational Radiation Exposure Report 6.9.1.5(b) Not Applicable 6.9.1.6 Monthly Operating Report        Not Applicable 6.9.1.7 Annual Radiological             5.7.2 Annual Radiological Environmental Operating Report         Environmental Operating Report 6.9.1.8 Annual Radioactive Effluent     5.7.3 Annual Radioactive Effluent Report                                 Release Report 6.9.1.9 Supplemental Reload Licensing Not Applicable Submittal 6.9.2a inservice Inspection Results -   Relocate to TRM                          l 6.9.2b Primary Containment Leak         Not Applicable                           I Rate Test Results                                                         !
6.9.2c Materials Radiation              Not Applicable                           l Surveillance Specimen                                                     i Examination and Results                                                   l 6.9.2d Radiological Effluent Reports    Relocated to the REMODCM                 l 6.9.2e High Rangs Stack Monitor         Not Applicable Inoperability 6.9.2f Containment High Range           Not Applicable Radiation Monitors 6.10 Record Retention                   Relocated to NUQAP 6.11 Radiation Protection Program       Not included (part of 10CFR20)           l 6.12 High Radiation Area                5.8 High Radiation Area 6.13 Systems Integrity                  Not Applicable                           j

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l U. S. Nuclerr Regulatory Commission                                       '
B17621\ Attachment 2\Page 7 Operating                             Defueled 6.14 lodine Monitoring                Not Applicable 6.15 REMODCM                          5.6.1 REMODCM 6.16 Radioactive Waste Treatment      5.5.1 e. Procedures 6.17   Post Accident                  Not Applicable                      j Sampling / Sampling and Analysis of Plant Effluents
! None - included in STS                5.6.2 Technical Specifications (TS)
Bases Control Program None - included in NUREG-1625,        5.6.3 Fuel Storage Pool Water Proposed Standard Technical          Chemistry Program Specifications for Permanently Defueled Westinghouse Plants l
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i Docket No. 50-245 B17621 i
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Attachment 3 Millstone Nuclear Power Station Unit No.1 Retvoed Paoes for Permanently Defueled Technical Specifications
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