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Millstone, Units 2 & 3, Proposed License Amendment Requests to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation
	ML15021A128
Person / Time
Site:	Millstone
Issue date:	01/15/2015
From:	Sartain M D; Dominion, Dominion Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-008-01, TSTF-523, Rev 2
	Download: ML15021A128 (71)
	v • d • e

Dominion Nuclear Connecticut, Inc. DAminionRope Ferry Rd., Waterford, CT 06385 DMailing Address:

P.O. Box 128Waterford, CT 06385dorn.conJAN 15 2015U. S. Nuclear Regulatory Commission Serial No.: 15-012Attention:

Document Control Desk NL&OS/WDC:

ROWashington, DC 20555-0001 Docket Nos.: 50-33650-423License Nos.: DPR-65NPF-49DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNITS 2 AND 3PROPOSED LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-523, REVISION2, GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) is submitting arequest for an amendment to the Technical Specifications (TS) for Millstone PowerStation Unit 2 (MPS2) and Millstone Power Station Unit 3 (MPS3). The proposedamendments would modify TS requirements to address Generic Letter 2008-01,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, andContainment Spray Systems,"

as described in Technical Specifications Task Force(TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

InDNC letter 09-790, dated January 14, 2010, DNC committed to evaluate the NuclearRegulatory Commission (NRC)-approved TSTF traveler for applicability to MPS2 andMPS3 and, if a license amendment was determined to be necessary, to submit alicense amendment within one year of NRC approval of the TSTF traveler.

Attachment 1 provides a description and assessment of the proposed change for MPS2.Attachments 2 and 3 provide the marked-up TS and TS Bases pages, respectively.

Themarked-up MPS2 TS Bases pages are provided for information only. The changes tothe affected MPS2 TS Bases pages will be incorporated in accordance with the TSBases control Program when this amendment is approved.

Attachment 4 provides a description and assessment of the proposed change for MPS3.Attachments 5 and 6 provide the marked-up TS and TS Bases pages, respectively.

Themarked-up MPS3 TS Bases pages are provided for information only. The changes tothe affected MPS3 TS Bases pages will be incorporated in accordance with the TSBases control Program when this amendment is approved.

The proposed amendments do not involve a Significant Hazards Consideration pursuant to the provisions of 10 CFR 50.92. The Facility Safety Review Committee hasreviewed and concurred with the determinations herein.

Serial No. 15-012Docket Nos. 50-336/423 Page 2 of 3Approval of the proposed amendments is requested by January 31, 2016. Onceapproved, the amendments shall be implemented within 90 days.In accordance with 10 CFR 50.91, a copy of this application, with attachments, is beingprovided to the State of Connecticut.

If you should have any questions regarding this submittal, please contact Wanda Craftat (804) 273-4687.

Sincerely, Mark D. SartainVice President

-Nuclear Engineering STATE OF CONNECTICUT

)COUNTY OF NEW LONDONThe foregoing document was acknowledged before me, in and for the County aforesaid, today by Mr.Mark D. Sartain, who is Vice President

-Nuclear Engineering, of Dominion Nuclear Connecticut.

He hasaffirmed before me that he is duly authorized to execute and file the foregoing document in behalf of thatcompany, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this .day of JA'V Ji', 2015.My Commission Expires:

rlee'?l'Aý

./6THOMAS CLEARY __-___"_-

_NOTARY PUBLIC Notary PublicMY COMMISSION EXPIRESFE BRUARY 28, 2016Commitments contained in this letter: NoneAttachments:

1. MPS2 Description and Assessment of Technical Specification Change2. MPS2 Marked-Up Technical Specifications Pages3. MPS2 Technical Specifications Bases Pages -For Information Only4. MPS3 Description and Assessment of Technical Specification Change5. MPS3 Marked-Up Technical Specifications Pages6. MPS3 Technical Specifications Bases Pages -For Information Only Serial No. 15-012Docket Nos. 50-336/423 Page 3 of 3cc: U.S. Nuclear Regulatory Commission Region I2100 Renaissance BlvdSuite 100King of Prussia, PA 19406-2713 Mohan C. ThadaniNRC Senior Project ManagerU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 B-111555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power StationDirectorBureau of Air Management Monitoring and Radiation DivisionDepartment of Environmental Protection 79 Elm StreetHartford, CT 06106-5127 Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 1DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATION CHANGEDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 Serial No. 15-012Docket Nos. 50-336/423 Attachment 1, Page 1 of 4DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements (SRs) to verify thatthe system locations susceptible to gas accumulation are sufficiently filled with waterand to provide allowances which permit performance of the verification to the Technical Specifications (TS). The changes are being made to address the concerns discussed inGeneric Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal, and Containment Spray Systems."

The proposed amendment isconsistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing GasAccumulation."

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Dominion Nuclear Connecticut, Inc. (DNC) has reviewed the model safety evaluation dated January 15, 2014 as part of the Federal Register Notice of Availability.

Thisreview included a review of the NRC staff's evaluation, as well as the information provided in TSTF-523.

As described in the subsequent paragraphs, DNC hasconcluded that the justifications presented in the TSTF-523 proposal and the modelsafety evaluation prepared by the NRC staff are applicable to Millstone Power StationUnit 2 (MPS2) and justify this amendment for the incorporation of the changes to theMPS2 TS.2.2 Optional Changes and Variations DNC is proposing deviations from the TS changes described in the TSTF-523, Revision

2. The deviations are as follows:1. The required frequency of the revised or proposed surveillances is not 31 days.The required frequencies will be consistent with the station's existing gasmanagement program.

Currently, the gas monitoring program requiresmonitoring on a quarterly frequency.

The existing surveillance frequency takesinto consideration the gradual nature of gas accumulation in the ECCS pipingand the procedural controls governing system operation.

Based on plantexperience, the existing surveillance frequency of at least once per 92 days hasbeen deemed acceptable per the gas monitoring program.

Serial No. 15-012Docket Nos. 50-336/423 Attachment 1, Page 2 of 42. The MPS2 TS use different numbering and titles than the Standard Technical Specifications (STS) on which TSTF-523 was based. Specifically, the following TS are numbered and titled differently:

MPS2 TS number and title STS TS number and title3.4.1.3, RCS -Hot Shutdown 3.4.6, RCS Loops -MODE 43.4.1.4, RCS -Cold Shutdown

-Loops 3.4.7, RCS Loops -MODE 5, LoopsFilled Filled3.4.1.5, RCS -Cold Shutdown

-Loops Not 3.4.8, RCS Loops -MODE 5, LoopsFilled Not Filled3.5.2, ECCS Subsystems

-Tavg >300°F 3.5.2, ECCS -Operating 3.5.3, ECCS Subsystems

-Tavg <300°F 3.5.3, ECCS -Shutdown3.6.2, Depressurization And Cooling 3.6.6A Containment Spray andSystems -Containment Spray And Cooling Systems (Atmospheric andCooling Systems Dual)3.9.8.1, Refueling Operations

-Shutdown 3.9.4, Shutdown Cooling (SDC) andCooling And Coolant Circulation

-High Coolant Circulation

-High WaterWater Level Level3.9.8.2, Refueling Operations

-Shutdown 3.9.5, Shutdown Cooling (SDC) andCooling And Coolant Circulation

-Low Coolant Circulation

-Low WaterWater Level LevelThese differences are administrative andTSTF-523 to the MPS2 TS.do not affect the applicability of3.0 REGULATORY ANALYSIS3.1 Applicable Regulatory Requirements The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR)Part 50 or similar plant-specific principal design criteria provide design requirements.

Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programsprovide operating requirements.

The traveler and model safety evaluation discusses the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General DesignCriteria (GDC). The Construction Permits for MPS2 were issued prior to May 21, 1971;consequently, MPS2 was not subject to current GDC requirements (SECY-92-223, dated September 18, 1992). Since February 20, 1971, MPS2 has attempted to complywith the intent of the newer GDC to the extent possible, recognizing previous designcommitments.

MPS2 FSAR Section 1.A "AEC General Design Criteria for "NuclearPower Plants,"

provides an assessment against the 10 CFR 50, Appendix A, GeneralDesign Criteria for Nuclear Power Plants".

A review has determined that the MPS2plant-specific requirements are sufficiently similar to the Appendix A, GDC as related tothe proposed change. Therefore, the proposed change is applicable to MPS2.

Serial No. 15-012Docket Nos. 50-336/423 Attachment 1, Page 3 of 43.2 No Significant Hazards Consideration Determination Dominion Nuclear Connecticut, Inc. (DNC) requests adoption of TSTF-523, Rev. 2,"Generic Letter 2008-01, Managing Gas Accumulation,"

which is an approved change tothe standard technical specifications (STS), into the Millstone Power Station Unit 2technical specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation aresufficiently filled with water and to provide allowances which permit performance of theverification.

DNC has evaluated whether or not a significant hazards consideration is involved withthe proposed amendment(s) by focusing on the three standards set forth in 10 CFR50.92, "Issuance of amendment,"

as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.The proposed change revises or adds Surveillance Requirement(s)

(SRs) thatrequire verification that the Emergency Core Cooling System (ECCS), ShutdownCooling (SDC) System, and the Containment Spray System are not renderedinoperable due to accumulated gas and to provide allowances which permitperformance of the revised verification.

Gas accumulation in the subject systems isnot an initiator of any accident previously evaluated.

As a result, the probability ofany accident previously evaluated is not significantly increased.

The proposed SRsensure that the subject systems continue to be capable to perform their assumedsafety function and are not rendered inoperable due to gas accumulation.

Thus, theconsequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

Response:

No.The proposed change revises or adds SRs that require verification that the ECCS,SDC and the Containment Spray Systems are not rendered inoperable due toaccumulated gas and provide allowances which permit performance of the revisedverification.

The proposed change does not involve a physical alteration of the plant(i.e., no new or different type of equipment will be installed) or a change in themethods governing normal plant operation.

In addition, the proposed change doesnot impose any new or different requirements that could initiate an accident.

The Serial No. 15-012Docket Nos. 50-336/423 Attachment 1, Page 4 of 4proposed change does not alter assumptions made in the safety analysis and isconsistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kindof accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change revises or adds SRs that require verification that the ECCS,SDC and the Containment Spray Systems are not rendered inoperable due toaccumulated gas and provide allowances which permit performance of the revisedverification.

The proposed change adds new requirements to manage gasaccumulation in order to ensure the subject systems are capable of performing theirassumed safety functions.

The proposed SRs are more comprehensive than thecurrent SRs and will ensure that the assumptions of the safety analysis areprotected.

The proposed change does not adversely affect any current plant safetymargins or the reliability of the equipment assumed in the safety analysis.

Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safetyas a result of the proposed change.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, DNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and,accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use ofa facility component located within the restricted area, as defined in 10 CFR 20, orwould change an inspection or surveillance requirement.

However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant changein the types or a significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

noenvironmental impact statement or environmental assessment need be prepared inconnection with the proposed change.

Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 2MARKED-UP TECHNICAL SPECIFICATION PAGESDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 June 28, 2006REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWNLIMITING CONDITION FOR OPERATION linformati 3.4.1.3 Two loops or trains consisting of any combination of reactor coolant loops orshutdown cooling trains shall be OPERABLE and one loop or train shall be in operation.

NOITlSAll reactor coolant pumps and shutdown cooling pumps may not be inoperation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. no operations are pennitted that would cause introduction ofcoolant into the RCS with boron concentration less than requiredto meet the SDM of LCO 3.1.1.1; andb. core outlet temperature is maintained at least 10°F belowsaturation temperature.

2. The following restrictions apply when starting the first reactor coolantpump and any RCS cold leg temperature is < 275°F. The first reactorcoolant pump shall not be started unless:a. pressurizer water level is < 43.7%;b. pressurizer pressure is < 340 psia; andc. secondary water temperature in each steam generator is < 507Fabove each RCS cold leg temperature.

APPLICABILITY:

MODE 4ACTION: a.With one reactor coolant loop AND two shutdown cooling trains inoperable:

Immediately initiate action to restore a second reactor coolant loop, or oneshutdown cooling train to OPERABLE status.b. With two reactor coolant loops AND one shutdown cooling train inoperable:

Immediately initiate action to restore a second shutdown cooling train, or onereactor coolant loop to OPERABLE status, and be in COLD SHUTDOWNwithin 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .c. With all reactor coolant loops AND shutdown cooling trains inoperable, ORno reactor coolant loop or shutdown cooling train in operation:

Immediately suspend operations that would cause introduction of coolant intothe RCS with boron concentration less than required to meet SDM of LCO3. 1.1 and immediately initiate action to restore one reactor coolant loop orone shutdown cooling train to OPERABLE status and operation.

MILLSTONE

-UNIT 23/4 4-1bAmendment No. 69, 2-19, 249, 293 September 14, 2000REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWNSURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump, if not in operation, shall be determined OPERABLE once per 7days by verifying correct breaker alignment and indicated power available.

-A,4.4.1.3.2 The required steam generator(s) shall be determined

OPERABLE, by verifying thesecondary side water level to be > 10% narrow range at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .4.4.1.3.3 One reactor coolant loop or shutdown cooling train shall be verified to be in operation at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .'4,NoteNot required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4...................................................................................................................

4.4.1.3.4 Locations susceptible to gas accumulation in the required shutdown coolingtrains shall be verified to be sufficiently filled with water at least once per 92 days.MILLSTONE

-UNIT 23/4 4-1cAmendment No. 69, 24-9 June 28, 2006REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN

-REACTOR COOLANT SYSTEM LOOPS FILLED Information yLIMITING CONDITION FOR OPERATION 3.4.1.4 One shutdown cooling train shall be OPERABLE and in operation, and either:a. One additional shutdown cooling train shall be OPERABLE; ORb. The secondary side water level of each steam generator shall be > 10% narrowrange.NOTESI The normal or emergency power source may be inoperable in MODE 5.2. All shutdown cooling pumps may not be in operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hourperiod provided:

a. no operations are permitted that would cause introduction of coolantinto the RCS with boron concentration less than required to meet theSDM of LCO 3.11. 1.; andb. core outlet temperature is maintained at least 10'F below saturation temperature.

3. The following restrictions apply when starting the first reactor coolant pump andany RCS cold leg temperature is < 275'F. The first reactor coolant pump shall notbe started unless:a. pressurizer water level is < 43.7%;b. pressurizer pressure is < 340 psia; andc. secondary water temperature in each steam generator is < 50'F aboveeach RCS cold leg temperature.

4. One required shutdown cooling train may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months forsurveillance testing provided the other shutdown cooling train is OPERABLE andin operation.

5. All shutdown cooling trains may not be in operation during planned heatup toMODE 4 when at least one reactor coolant loop is in operation.

MILLSTONE

-UNIT 23/4 4-1dAmendment No. 249, 293 Jul11.. 2--, 2v06REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN

-REACTOR COOLANT SYSTEM LOOPS FILLEDLIMITING CONDITION FOR OPERATION (continued)

APPLICABILITY:

MODE 5 with Reactor Coolant System loops filled.ACTION: a. With one shutdown cooling train inoperable and any steam generator secondary water level not within limits, immediately initiate action to eitherrestore a second shutdown cooling train to OPERABLE status or restore steamgenerator secondary water levels to within limit.b. With no shutdown cooling train OPERABLE or in operation, immediately suspend operations that would cause introduction of coolant into the RCS withboron concentration less than required to meet SDM of LCO 3.1.1.1 and /immediately initiate action to restore one shutdown cooling train toOPERABLE status and operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1 The required shutdown cooling pump, if not in operation, shall be determined OPERABLE once per 7 days by verifying correct breaker alignment and indicated poweravailable.

4.4.1.4.2 The required steam generators shall be determined

OPERABLE, by verifying thesecondary side water level to be _ 10% narrow range at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .4.4.1.4.3 One shutdown cooling train shall be verified to be in operation at least once per 12hours.4.4.1.4.4 Locations susceptible to gas accumulation in the required shutdown cooling,\-trains shall be verified to be sufficiently filled with Water at least once per 92 days.IMILLSTONE

-UNIT 23/4 4-1 eAmendment No. _249, June 28, 2006REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN

-REACTOR COOLANT SYSTEM LOOPS NOT FILLEDInformation onlyLIMITING CONDITION FOR OPERATION 3.4.1.5 Two shutdown cooling trains shall be OPERABLE and one shutdown cooling trainshall be in operation.

NOTES1. The normal or emergency power source may be inoperable in MODE 5.2. All shutdown cooling pumps may not be in operation for up to 15 minutes whenswitching from one train to another provided:

a. no operations are permitted that would cause introduction of coolant intothe RCS with boron concentration less than required to meet the SDM ofLCO 3.1.1.1;b. core outlet temperature is maintained at least 10F below saturation temperature; andc. no draining operations to further reduce Reactor Coolant System watervolume are permitted.

3. The following restrictions apply when starting the first reactor coolant pump andany RCS cold leg temperature is < 275°F. The first reactor coolant pump shall noibe started unless:a. pressurizer water level is < 43.7%;b. pressurizer pressure is < 340 psia; andc. secondary water temperature in each steam generator is < 50'F above eacaRCS cold leg temperature

4. One shutdown cooling train may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the other shutdown cooling train is OPERABLE and inoperation.

APPLICABILITY:

MODE 5 with Reactor Coolant System loops not filled.tACTION: a.With one shutdown cooling train inoperable, immediately initiate action torestore the required shutdown cooling train to OPERABLE status.b. With no shutdown cooling train OPERABLE or in operation, immediately suspend operations that would cause introduction of coolant into the RCS withboron concentration less than required to meet SDM of LCO 3.1 .1.1 andimmediately initiate action to restore one shutdown cooling train toOPERABLE status and operation.

MILLSTONE

-UNIT 23/4 4-1fAmendment No. 249, 293 Se-ptemb

-14, 2900REACTOR COOLANT SYSTEMCOOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN

-REACTOR COOLANT SYSTEM LOOPS NOT FILLEDSURVEILLANCE REQUIREMENTS 4.4.1.5.1 The required shutdown cooling pump, if not in operation, shall be determined OPERABLE once per 7 days by verifying correct breaker alignment and indicated poweravailable.

4.4.1.5.2 One shutdown cooling train shall be verified to be in operation at least once per 12hours.4.4.1.5.3 Locations susceptible to gas accumulation in the required shutdown coolingtrains shall be verified to be sufficiently filled with water at least once per 92 days.MILLSTONE

-UNIT 23/4 4-1-MAmendment No.--94-91 EMERGENCY CORE COOLING SYSTEMS -------------.....

NOTE ---------------

SURVILLNCE EQUIREMNTSNot required to be rnet for system vent flow pathsopne une administratve control.4 .5: t acsw t m hall be dem onstrated O PERA B LE :a, t least once per 31 days by verifying each Emergency Core Cooling Systemmanual, power operated, and automatic valve in the flow path servicing safetyrelated equipment, that is not locked, sealed, or otherwise secured in position, is inthe correct position.

b. At least once per 31 days by verifying that the following valves are in the indicated position with power to the valve operator removed:Valve Number Valve Function Valve Position2-SI-306 Shutdown Cooling Open*Flow Control2-SI-659 SRAS Recirc. Open**2-SI-660 SRAS Recirc. Open**Pinned and locked at preset throttle open position.

- To be closed prior to recirculation following LOCA.c. By verifying the developed head of each high pressure safety injection pump at theflow test point is greater than or equal to the required developed head when testedpursuant to Specification 4.0.5.d. By verifying the developed head of each low pressure safety injection pump at theflow test point is greater than or equal to the required developed head when testedpursuant to Specification 4.0.5.e. By verifying the delivered flow of each charging pump at the required discharge pressure is greater than or equal to the required flow when tested pursuant toSpecification 4.0.5.f. At least once per 18 months by verifying each Emergency Core Cooling Systemautomatic valve in the flow path that is not locked, sealed, or otherwise secured inposition, actuates to the correct position on an actual or simulated actuation signal.g. At least once per 18 months by verifying each high pressure safety injection pumpand low pressure safety injection pump starts automatically on an actual orsimulated actuation signal.MILLSTONE

-UNIT 2314 5-4Amendment No. &-2, 4-59, 2-36,-2-8 September 18, 2007EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS (Continued)

h. At least once per 18 months by verifying each low pressure safety injection pumpstops automatically on an actual or simulated actuation signal.i. By verifying the correct position of each electrical and/or mechanical position stopfor each injection valve in Table 4.5-1:1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after completion of valve operations.

2. At least once per 18 months.j. At least once per 18 months by verifying through visual inspection of thecontainment sump that each Emergency Core Cooling System subsystem suctioninlet is not restricted by debris and the suction inlet strainers show no evidence ofstructural distress or abnormal corrosion.

k. At least once per 18 months by verifying the Shutdown Cooling System openpermissive interlock prevents the Shutdown Cooling System inlet isolation valvesfrom being opened with an actual or simulated Reactor Coolant System pressuresignal of> 300 psia.1. At least once per 92 days by verifying that ECCS locations susceptible toN gas accumulation are sufficiently filled with water.MILLSTONE

-UNIT 23/4 5-5Amendment No. 7, 4-5, 52, 64-, 4-0-1,4--59, +-64-, 24-7, 244, 22-3-, 28-3,-30

-Sternki~-9-2OO4--

EMERGENCY CORE COOLING SYSTEMSECCS SUBSYSTEMS

-_Trk. < 300°FLIMITING CONDITION FOR OPERATION 3.5.3 One high pressure safety injection subsystem shall be OPERABLE.

NOTES -/----------------

I. The provisions of Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 4for the high pressure safety injection pump that is inoperable pursuant to Specification 3.4.9.3 provided the high pressure safety injection pump is restored to OPERABLE statuswithin I hour after entering MODE 4.2. In MODE 4, the requirement for OPERABLE safety injection and sump recirculation actuation signals is satisfied by use of the safety injection and sump recirculation trippushbuttons.

3. In MODE 4, the OPERABLE HPSI pump is not required to start automatically on a SIAS.Therefore, the pump control switch for this OPERABLE pump may be placed in the pull-to-lock position without affecting the OPERABILITY of this pump.APPLICABILITY:

MODES 3* and 4.ACTION:a. With no high pressure safety injection subsystem

OPERABLE, restore at least onehigh pressure safety injection subsystem to OPERABLE status within one hour orbe in COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .b. In the event the ECCS is actuated and injects water into the Reactor CoolantSystem, a Special Report shall be prepared and submitted to the Coimmalission pursuant to Specification 6.9.2 within 90 days describing the circumstances of theactuation and the total accumulated actuation cycles to date.SURVEILLANCE REQUIREMENTS 4.5.3.1 The high pressure safety injection subsystem shall be demonstrated OPERABLE perthe applicable portions of Surveillance Requirements 4.5.2.a, 4.5.2.b, 4.5.2.c, 4.5.21, 4.5.2.g,4.5.2. i, a4i 4.5.2.j/-qn ad4.5.2.1..

With pressurizer pressure

< 1750 psia.MILLSTONE

-UNIT 2 3/4 5-7 AmendmentNo.

3-9, , 24-6, 21-9,2 6-, .3-Marchi 16,2006-CONTAINMENT SYSTEMS3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMSCONTAINMENT SPRAY AND COOLING SYSTEMSLIMITING CONDITION FOR OPERATION 3.6.2.1.

Two containment spray trains and two containment cooling trains, with each coolingtrain consisting of two containment air recirculation and cooling units, shall be OPERABLE.

APPLICABILITY:

MODES 1, 2 and 3*.ACTION:Inoperable Equipment Required ACTIONa. One containment a.1 Restore the inoperable containment spray train tospray train OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to lessthan 1750 psia within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. One containment b.1 Restore the inoperable containment cooling train tocooling train OPERABLE status within 7 days or be in HOT SHUTDOWNwithin the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .c. One containment c.1 Restore the inoperable containment spray train or thespray train inoperable containment cooling train to OPERABLE statuswithin 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in HOT SHUTDOWN within the nextAND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .One containment cooling traind. Two containment d.1 Restore at least one inoperable containment cooling train tocooling trains OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in HOTSHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .e. All other e.1 Enter LCO 3.0.3 immediately.

combinations SURVEILLANCE REQUIREMENTS 4.6.2.1.1 Each containment spray train shall be demonstrated OPERABLE:

a. t least once per 31 days by verifying each containment spray manual, powerpperated, and automatic valve in the spray train flow path, that is not locked,aled, or otherwise secured in position, is in the correct position.

The Containi ent Spray System is not required to be OPERABLE in MODE 3 if pressurizer pressure is 1750 psia.MILLSTONE

-UN 2 3/4 6-12 Amendment No. 2-1-, 2-2-, -36,28---------------------------------

NOTE ----------------------------

"29-* required to be met for system vent flow paths*** " :opened under administrative control."

4-March 3, t7-2gCONTAINMENT SYSTEMSSURVEILLA,,.CE REQUIREMENTS (Continued)

b. By verifying the developed head of each containment spray pump at the flow testpoint is greater than or equal to the required developed head when tested pursuantto Specification 4.0.5.c. At least once per 18 months by verifying each automatic containment spray valvein the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.d. At least once per 18 months by verifying each containment spray pump startsautomatically on an actual or simulated actuation signal.e. By verifying each spray nozzle is unobstructed following activities that couldcause nozzle blockage.

4.6.2.1.

Each containment air recirculation and cooling unit shall be demonstrated OPE BLE:a. At least once per 31 days by operating each containment air recirculation andcooling unit in slow speed for> 15 minutes.b. At least once per 31 days by verifying each containment air recirculation andcooling unit cooling water flow rate is > 500 gpm.c. At least once per 18 months by verifying each containment air recirculation andcooling unit starts automatically on an actual or simulated actuation signal.f. At least once per 92 days by verifying the Containment Spray Systemlocations susceptible to gas accumulation are sufficiently filled with water.MILLSTONE

-UNIT 23/4 6-13Amendment No. 2-14, 2-83, 43-june -28,2&00&

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION

-HIGH WATER LEVELLIMITING CONDITION FOR OPERATION ACTION:With no shutdown cooling train OPERABLE or in operation, perform the following actions:a. Immediately suspend operations that would cause introduction of coolant into the RCSwith boron concentration less than required to meet the boron concentration of LCO 3.9.1and the loading of irradiated fuel assemblies in the core; andjb. Immediately initate action to restore one shutdown cooling train to OPERABLE statusand operation; andc. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months place the containment penetrations in the following status:1. Close the equipment door and secure with at least four bolts; and2. Close at least one personnel airlock door; and3. Each penetration providing direct access from the containment atmosphere to theoutside atmosphere shall be closed with a manual or automatic isolation valve,blind flange, or equivalent.

SURVEILLANCE REQUIREMENTS v7-'~14.9.8.1 One shutdown cooling train shall be verified to be in operation and circulating reactorcoolant at a flow rate greater than or equal to 1000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .\ 14.9.8.1.2.

Locations susceptible to gas accumulation in the required shutdown coolingtrttrains shall be verified to be sufficiently filled with water at least once per 92 days,MILLSTONE

-UNIT 23 /4 9-8a.Amendment No. 7-l-, 4-8-5, 2249, 28.4, iT.... 28, 2066REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION

-LOW WATER LEVELf1LIMITING CONDITION FOR OPERATION (continued)

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

SURVEILLANCE REQUIREMENTS 4.9.8.2.1 One shutdown cooling train shall be verified to be in operation and circulating reactorcoolant at a flow rate greater than or equal to 1000 gpm at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .4.9.8.2.2 The required shutdown cooling pump, if not in operation, shall be determined OPERABLE once per 7 days by verifying correct breaker alignment and indicated poweravailable.

_4.9.8.2.3 Locations susceptible to gas accumulation in the required shutdown coolingtrains shall be verified to be sufficiently filled with water at least once per 92 days.MILLSTONE

-UNIT 23/4 9-8cAmendment No. 293 --

Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 3MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGESFOR INFORMATION ONLYDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 3/4.4 REACTOR COOLANT SYSTEMBASES3/4.4.1 COOLANT LOOPS AND COOLANT CIRCULATION (continued) train must be in operation.

Any exceptions to these requirements are contained in the LCO Notes.An OPERABLE SDC train, for plant operation in MODES 4 and 5, includes a pump, heatexchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and todetermine RCS temperature.

In addition, sufficient portions of the Reactor Building ClosedCooling Water (RBCCW) and Service Water (SW) Systems shall be OPERABLE as required toprovide cooling to the SDC heat exchanger.

The flow path starts at the RCS hot leg and is returnedto the RCS cold legs. ýManagement of gas voids is important to SDC System OPERABILITY.

In MODE 4, an OPERABLE SDC train consists of the following equipment:

1. An OPERABLE SDC pump (low pressure safety injection pump);2. The associated SDC heat exchanger from the same facility as the SDC pump;3. The associated reactor building closed cooling water loop from the same facility asthe SDC pump;4. The associated service water loop from the same facility as the SDC pump; and5. All valves required to support SDC System operation are in the required positionor are capable of being placed in the required position.

In MODE 4, two OPERABLE SDC trains require 2 SDC pumps, 2 SDC heat exchangers, 2 RBCCW pumps, 2 RBCCW heat exchangers, and 2 SW pumps. In addition, 2 RBCCW headersand 2 SW headers are required to support the SDC heat exchangers, consistent with therequirements of Technical Specifications 3.7.3.1 and 3.7.4.1.In MODE 5, an OPERABLE SDC train consists of the following equipment:

1. An OPERABLE SDC pump (low pressure safety injection pump);2. The associated SDC heat exchanger from the same facility as the SDC pump;3. An RBCCW pump, powered from the same facility as the SDC pumrp, andRBCCW heat exchanger capable of cooling the associated SDC heat exchanger;

4. A SW pump, powered from the same facility as the SDC pump, capable ofsupplying cooling water to the associated RBCCW heat exchanger; and5, All valves required to support SDC System operation are in the required positionor are capable of being placed in the required positionMILLSTONE

-UNIT 2 B 3/4 4-1a aeiby- tri 6Amendment No. 50, 66, 69, 4-3-9, 2-4g,249, 3/4.4 REACTOR COOLANT SYSTEMBASES3/4.4.1 COOLANT LOOPS AND COOLANT CIRCULATION (continued)

In MODE 5, two OPERABLE SDC trains require 2 SDC pumps, 2 SDC heat exchangers, 2 RBCCW pumps, 2 RBCCW heat exchangers, and 2 SW pumps. In addition, 2 RBCCWheaders are required to provide cooling to the SDC heat exchangers, but only 1 SW header isrequired to support the SDC trains, The equipment specified is sufficient to address a singleactive failure of the SDC System and associated support systems.In addition, two.SDC trains can be considered

OPERABLE, with only one 125-vol.t D.C.bus train OPERABLE, in accordance with Limiting Condition for Operation (LCO) 3.8.2.4.

2-SI-306 and 2-SI-657 are both powered from the same 125-volt D.C. bus, on Facility

1. Should thesevalves reposition due to a loss of power, SDC would no longer be aligned to cool the RCS.However, a designated operator is assigned to reposition these valves as necessary in the event125-volt D.C. power is lost. Consistent with the bases for LCO 3.8.2.4, the 125-volt D.C. supportsystem operability requirements for both trains of SDC are satisfied in MODE 5 with at least one125-volt D.C. bus train OPERABLE and the 125-volt D.C. buses cross-tied.

The operation of one Reactor Coolant Pump or one shutdown cooling pumnp providesadequate flow to ensure mixing, prevent stratification and produce gradual reactivity changesduring boron concentration reductions in the Reactor Coolant System. The reactivity change rateassociated with boron reductions will, therefore, be within the capability of operator recognition and control..Flnsert A I-The restrictions on starting a Reactor Coolant Pump in MODE 4 with one or more RCScold legs < 275°F and in MODE 5 are provided to prevent RCS pressure transients, caused byenergy additions from the secondary system, which could exceed the limits of Appendix G to10 CFR Part 50. The RCS will be protected against overpressure transients and will not exceedthe limits of Appendix G by:1. Restricting pressurizer water volume to ensure sufficient steam volume is available toaccomnodate the insurge;2. Restricting pressurizer pressure to establish an initial pressure that will ensure systempressure does not exceed the limit; and3. Restricting primary to secondary system delta-T to reduce the energy addition from thesecondary system.If these restrictions are met, the steam bubble in the pressurizer is sufficient to ensure theAppendix G limits will not be exceeded.

No credit has been taken for PORV actuation to limitRCS pressure in the analysis of the energy addition transient.

MILLSTONE

-UNIT 2 B 3/4 4-lb Amendment No. =-50, 66, 69, 4-9, 24-8, 248,249, MPS2 Insert A, Bases -RCS Loops Modes 4 and 5 loops filled or unfilledSDC System piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation is necessary forproper operation of the required SDC train(s) and may also prevent water hammer, pumpcavitation, and pumping of noncondensible gas into the reactor vessel.Selection of SDC System locations susceptible to gas accumulation is based on a review ofsystem design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

The design review is supplemented by systemwalk downs to validate the system high points, and to confirm the location and orientation ofimportant components that can become sources of gas, or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The SDC System is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the SDC System is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be -declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.Surveillance Requirements 4.4.1.3.4, 4.4.1.4.4, and 4.4.1.5.3 are performed for SDC Systemlocations susceptible to gas accumulation and, if gas is found, the gas volume is compared tothe acceptance criteria for the location.

Susceptible locations in the same system flow pathwhich are subject to the same gas intrusion mechanisms may be verified by monitoring arepresentative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, orpersonnel safety. For these locations, alternative methods (e.g., operating parameters, remotemonitoring) may be used to monitor the susceptible location.

Monitoring is not required forsusceptible locations where the maximum potential accumulated gas void volume has beenevaluated and determined to not challenge system OPERABILITY.

The accuracy of the methodused for monitoring the susceptible locations and trending of the results should be sufficient toassure system OPERABILITY during the Surveillance interval.

The operating SDC pump andassociated piping are exempted from this surveillance requirement, in that the operating train isself venting/flushing.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation inthe SDC piping and the procedural controls governing system operation.

Based on plantexperience, the Surveillance Frequency of at least once per 92 days is acceptable.

SR 4.4.1.3.4 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapidshutdown, there may be insufficient time to verify all susceptible locations prior to enteringMODE 4.

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)BASES3/4.5.1 SAFETY INJECTION TANKS (continued) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and pressurizer pressure reduced to < 1750 psia within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowedcompletion times are reasonable, based on operating experience, to reach the required plantcondition from full power conditions in an orderly manner and without challenging plant systems.If more than one SIT is inoperable, the unit is in a condition outside the accident analyses.

Therefore, LCO 3.0.3 must be entered immediately.

LCO 3.5. L.a requires that each reactor coolant system safety injection tank shall be OPERABLEwith the isolation valve open and the power to the valve operator removed.This is to ensure that the valve is open and cannot be inadvertently closed. To meet LCO 3.5.1 .arequirements, the valve operator is considered to be the valve motor and not the motor controlcircuit.

Removing the closing coil while maintaining the breaker closed meets the intent of theTechnical Specification by ensuring that the valve cannot be inadvertently closed.Removing the closing coil and verifying that the closing coil is removed (Per SR 4.5.1 .e) meetsthe Technical Specification because it prevents energizing the valve operator to position the valvein the close direction.

Opening the breaker, in lieu of removing the closing coil, to remove power to the valve operator isnot a viable option since:1. Millstone Unit 2 Safety Evaluation Report (SER) Docket No. 50-336, dated May 10,1974, requires two independent means of position indication.

2. Surveillance Requirement 4.5.1 .a requires the control/indication circuit to be energized, toverify that the valve is open.3. Technical Specification 3/4,3.2, Engineered Safety Feature Actuation System.Instrumentation, requires these valves to open on a SIAS signal.Opening the breaker would eliminate the ability to satisfy the above three items.3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the event of a LOCA assuming the loss ofone subsystem through any single failure consideration.

Either subsystem operating inconjunction with the safety injection tanks is capable of supplying sufficient core cooling to limitthe peak cladding temperatures within acceptable limits for all postulated break sizes rangingfrom the double ended break of the largest RCS cold leg pipe downward.

MILLSTONE

-UNIT 2 B 3/4 5-2 Amendment No. 6+/-, 42, 4-49, 2-7,2220, Management of gas voids is important to ECCS OPERABILITY.-

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)BASES3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (continued)

Surveillance Requirement 4.5.2,a verifies the correct alignment for manual, power operated, andautomatic valves in the ECCS flow paths to provide assurance that the proper flow paths will existfor ECCS operation.

This surveillance does not apply to valves that are locked, sealed, orotherwise secured in position, since these valves were verified to be hi the correct position prior tolocking,

sealing, or securing.

A valve that receives an actuation signal is allowed to be in anonaccident position provided the valve automatically repositions within the proper stroke time.This surveillance does not require any testing or valve manipulation.

Rather, it involvesverification that those valves capable of being mispositioned are in the correct position.

The 31day frequency is appropriate because the valves are operated under procedural control and animproper valve position would only affect a single train. This frequency has been shown to beacceptable through operating experience.

-nsertSurveillance Requirement 4.5.2.b verifies proper valve position to ensure that the flow path fromthe ECCS pumps to the RCS is maintained.

Misalignment of these valves could render bothECCS trains inoperable.

Securing these valves in position by removing power to the valveoperator ensures that the valves cannot be inadvertently misaligned or change position as theresult of an active failure.

A 31 day frequency is considered reasonable in view of otheradministrative controls ensuring that a rnispositioned valve is an unlikely possibility.

Surveillance Requirements 4.5.2.c and 4.5.2.d, which address periodic surveillance testing of theECCS pumps (high pressure and low pressure safety injection pumps) to detect gross degradation caused by impeller structural damage or other hydraulic component

problems, is required by theASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OMI Code). Thistype of testing may be accomplished by measuring the pump developed head at only one point ofthe pump characteristic curve. This verifies both that the measured performance is within anacceptable tolerance of the original pump baseline performance and that the performance at thetest flow is greater than or equal to the performance assumned in the umit safety analysis.

Thesurveillance requirements are specified in the Inservice Testing Program.

The ASME OM Codeprovides the activities and frequencies necessary to satisfy the requirements.

Surveillance Requirement 4.5.2.e, which addresses periodic surveillance testing of the chargingpumps to detect gross degradation caused by hydraulic component

problems, is required by theASME OM Code. For positive displacement pumps, this type of testing may be accomplished bycomparing the measured pump flow, discharge pressure and vibration to their respective acceptance criteria.

Acceptance criteria are verified to bound the assumptions utilized in accidentanalyses.

This verifies both that the measured performance is within an acceptable tolerance ofthe original pump baseline performance and that the performance at the test point is greater thanor equal to the performance assumed for mitigation of the beyond design basis events. Thesurveillance requirements are specified in the Inservice Testing Program.

The ASME OM Codeprovides the activities and frequencies necessary to satisfy the requirements.

MILLSTONE

-UNIT 2 B 3/4 5-2b Amendment No. 4-, 64, -42, 4-49, 4--5,2445, 2-144, 24q, 2-0, 2-247, 224-,

-Sep 4 er919 04--3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)BASES3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (continued)

Surveillance Requirements 4.5,2.f, 45.2.g, and 4.5.2.h demonstrate that each automatic ECCSflow path valve actuates to the required position on an actual or simulated actuation signal (SIASor SRAS), that each ECCS pump starts on receipt of an actual or simulated actuation signal(SIAS), and that the LPSI pumps stop on receipt of an actual or simulated actuation signal(SRAS). This surveillance is not required for valves that are locked, sealed, or otherwise securedin the requiied position under administrative controls.

The 18 month frequency is based on theneed to perform these surveillances under the conditions that apply during a plant outage, and thepotential for unplanned transients if the surveillances were performed with the reactor at power.The 18 month frequency is also acceptable based on consideration of the design reliability (andconfirming operating experience) of the equipment.

The actuation logic is tested as part of theEngineered Safety Feature Actuation System (ESFAS) testing, and equipment performance ismonitored as part of the Inservice Testing Program.Surveillance Requirement 4.5.2.i verifies the high and low pressure safety injection valves listedin Table 4.5-1 will align to the required positions on an SIAS for proper ECCS performance.

Thesafety injection valves have stops to position them properly so that flow is restricted to a rupturedcold leg, ensuring that the other cold legs receive at least the required minimum flow. The 18month frequency is based on the need to perform these surveillances under the conditions thatapply during a plant outage and the potential for unplanned transients if the surveillances wereperformed with the reactor at power. The 18 mnonth frequency is also acceptable based onconsideration of the design reliability (and confirming operating experience) of the equipment.

Surveillance Requirement

'4.5.2.j addresses periodic inspection of the contaimnent sump toensure that it is unrestricted and stays in proper operating condition.

The 18 month frequency isbased on the need to perform this surveillance under the conditions that apply during an outage,and the need to have access to the location.

This frequency is sufficient to detect abnormaldegradation and is confirmed by operating experience.

Surveillance Requirement 4.5.2.k verifies that the Shutdown Cooling (SDC) System openpermissive interlock is OPERABLE to ensure the SDC suction isolation valves are prevented from being remotely opened when RCS pressure is at or above the SDC suction design pressureof 300 psia. The suction piping of the SDC pumps (low pressure safety injection puinps) is theSDC component with the limiting design pressure rating. The interlock provides assurance thatdouble isolation of the SDC System firom the RCS is preserved whenever RCS pressure is at orabove the design pressure.

The 18 month frequency is based on the need to perfornr this.surveillance under the conditions that apply during an outage. The 18 month frequency is alsoacceptable based on consideration of the design reliability (and confimxing operating experience) of the equipment.

<-- lnse-rt C IMILLSTONE1

-UNIT 2 B 3/4 5-2c Amendment No. 45,, 4-8-5, 24-4,2-,22-0 2-- 236, 2-83-/

MPS2 Insert B -ECCS Subsystems Surveillance requirement 4.5.2.a is modified to exempt system vent flow paths opened underadministrative control.

The administrative controls are proceduralized and include stationing.

adedicated individual at the system vent flow path who is in continuous communication with theoperators in the control room. This individual will have a method to rapidly close the systemvent flow path if directed.

MPS2 Insert C -ECCS Subsystems ECCS piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for properoperation of the ECCS and may also prevent water hammer, pump cavitation, and pumping ofnoncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vesselSurveillance requirement 4.5.2.1 verifies that the locations susceptible to gas accumulation in theECCS are sufficiently full of water. Selection of ECCS locations

'susceptible to gasaccumulation is based on a review of system design information, including piping andinstrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

The design review is supplemented by system walk downs to validate the system high pointsand to confirm the location and orientation of important components that can become sources ofgas or could otherwise cause gas to be trapped or difficult to remove during systemmaintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e.,the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gasvolume is compared to the acceptance criteria for the location.

Susceptible locations in thesame system flow path which are subject to the same gas intrusion mechanisms may beverified by monitoring a representative sub-set of susceptible locations.

Monitoring may not bepractical for locations that are inaccessible due to radiological or environmental conditions, theplant configuration, or personnel safety. For these locations, alternative methods (e.g.,operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of theresults should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation inthe ECCS piping and the procedural controls governing system operation.

Based on plantexperience, the Surveillance Frequency of at least once per 92 days is acceptable.

+/-BDC 04-vli2-01 CONTAINMENT SYSTEMSBASES3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMSThe OPERABILITY of the containment spray system ensures that containment depressurization and cooling capability will be available in the event of a LOCA. The pressurereduction and resultant lower containment leakage rate are consistent with the assumptions usedin the accident analyses.

The OPERABILITY of the containmnent cooling system ensures that 1) the contairnent air temperature will be maintained within limits during normal operation, and 2) adequate heatremoval capacity is available when operated in conjunction with the containment spray systemduring post-LOCA conditions.

Management of gas voids is important to Containment Spray System OPERABILITY.

To be OPERABLE, the two trains of the contaimnent spray system shall be capable oftaking a suction from the refueling water storage tank on a containmnent spray actuation signal andautomatically transferring suction to the containment sump on a sump recirculation actuation signal. Each containment spray train flow path from the containment surnp shall be via anOPERABLE shutdown cooling heat exchanger.

The containment cooling system consists of two containment cooling trains. Eachcontainmrent cooling train has two containmnent air recirculationi and cooling units. For thepurpose of applying the appropriate ACTION statement, the loss of a single contaimnent airrecirculation and cooling unit will make the respective containment cooling train inoperable.

Either the containment spray system or the containment cooling system is sufficient tomitigate a loss of coolant accident.

The contaimnent spray system is more effective than thecontainment cooling system in reducing the temperature of superheated steam inside containment following a main steam line break. Because of this, the contaimient spray system is required tomitigate a main steam line break accident inside containment.

In addition, the contaimnent spraysystem provides a mechanism for removing iodine from the containient atmosphere.

Therefore, at least one train of containment spray is required to be OPERABLE when pressurizer pressure is> 1750 psia, and the allowed outage time for one train of spray reflects the dualfumction of containment spray for heat removal and iodine removal.Surveillance Requirement 4.6.2.1.1

.a verifies the correct aligniment for manual, poweroperated, and automatic valves in the Contaimnent Spray System flow paths to provide assurance that the proper flow paths Wvill exist for containment spray operation.

This surveillance does notapply to valves that are locked, sealed, or otherwise secured in position, since these valves wereverified to be in the correct position prior to locking,

sealing, or securing.

A valve that receives anactuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper stroke time. This surveillance does not require any testing or valvemaniapulation.

Rather, it involves verification that those valves capable of being mispositioned arein the correct position.

he 31 day frequency is appropriate because the valves are operated underprocedural control andj i improper valve position would only affect a single train. Thisfrequency has been s , to be acceptable through operating experience.

MILLSTONE

-UNIT 2 B 3/4 6-3 Amendment No. ?2L, 6+-, 24-0, 24--5) 2-22Insert D ] 1G+&ge4-by4NR lI,112~6,~'2S,'O3

-t-B B R-D ý1-21-CONTAINMENT SYSTEMSBASES3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (Continued)

Surveillance Requirement 4.6.2.1.

Lb, which addresses periodic surveillance testing of thecontainment spray pumps to detect gross degradation caused by impeller structural damage orother hydraulic component

problems, is required by the ASME 0M Code. This type of testingmay be accomplished by measuring the pump developed head at only one point of the pumpcharacteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow isgreater than or equal to the performance assumed in the unit safety analysis.

The surveillance requirements are specified in the Inservice Testing Program.

The ASME OM Code provides theactivities and frequencies necessary to satisfy the requirements.

Surveillance Requirements 4.6.2.1.

L.c and 4.6,2.1.1

.d demonstrate that each automatic containment spray valve actuates to the required position on an actual or simulated actuation signal (CSAS or SRAS), and that each containment spray pump starts on receipt of an actual orsimulated actuation signal (CSAS). This surveillance is not required for valves that are locked,sealed, or otherwise secured in the required position under administrative controls.

The 18 monthfrequency is based on the need to perform these surveillances under the conditions that applyduring a plant outage and the potential for unplanned transients if the surveillances wereperformed with the reactor at power. The 18 month frequency is also acceptable based onconsideration of the design reliability (and confirming operating experience) of the equipment.

The actuation logic is tested as part of the Engineered Safety Feature Actuation System (ESFAS)testing, and equipment performance is monitored as part of the inservice Testing Program.Surveillance Requirement 4.6.2.1.l.e requires verification that each spray nozzle isunobstructed following maintenance that could cause nozzle blockage.

Normal plant operation and maintenance activities are not expected to trigger performance of this surveillance requirement.

However, activities, such as an inadvertent spray actuation that causes fluid flowthrough the nozzles, a major configuration change, or a loss of foreign material control whenworking within the respective system boundary may require surveillance perfonnance.

Anevaluation, based on the specific situation, will determine the appropriate method (e.g., visualinspection, air or smoke flow test) to verify no nozzle obstruction.

F Surveillance Requirement 4.6.2.1.2.a demonstrates that each containment air recirculation and cooling unit can be operated in slow speed for > 15 minutes to ensure OPERABILITY andthat all associated controls are functioning properly.

It also ensures fani or motor failure can bedetected and corrective action taken. The 31 day frequency considers the known reliability of thefan units and controls, the two train redundancy available, and the low probability of a significant degradation of the containment air recirculation and cooling unit occurring between surveillances.

This frequency has been shown to be acceptable through operating experience.

MILLSTONE

-UNIT 2 B 3/4 6-3a Amendment No. 244, 24, 23-6, 2-7, Insert D -Containment Spray SystemSurveillance requirement 4.6.2.1.1.a is modified to exempt system vent flow paths opened underadministrative control.

The administrative controls are proceduralized and include stationing adedicated individual at the system vent flow path who is in continuous communication with theoperators in the control room. This individual will have a method to rapidly close the system vent flowpath if directed.

Insert E -Spray SystemsContainment Spray System piping and components have the potential to develop voids and pocketsof entrained gases. Preventing and managing gas intrusion and accumulation is necessary for properoperation of the required containment spray trains and may also prevent water hammer and pumpcavitation.

Surveillance requirement 4.6.2.1.1.f verifies that the locations susceptible to gas accumulation in theContainment Spray System are sufficiently full of water. Selection of Containment Spray Systemlocations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, andcalculations.

The design review is supplemented by system walk downs to validate the system highpoints and to confirm the location and orientation of important components that can become sourcesof gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance orrestoration.

Susceptible locations depend on plant and system configuration, such as stand-by versusoperating conditions.

The Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations.

If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volurne ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the Containment Spray System is not rendered inoperable by theaccumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declaredmet. Accumulated gas should be eliminated or brought within the acceptance criteria limits.Containment Spray System locations susceptible to gas accumulation are monitored and, if gas isfound, the gas volume is compared to the acceptance criteria for the location.

Susceptible locations inthe same system flow path which are subject to the same gas intrusion mechanisms may be verifiedby monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical forlocations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remotemonitoring) may be used to monitor the susceptible location.

Monitoring is not required forsusceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

-The accuracy of the method used formonitoring the susceptible locations and trending of the results should be sufficient to assure systemOPERABILITY during the Surveillance interval.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation in theContainment Spray System piping and the procedural controls governing system operation.

Based onplant experience, the Surveillance Frequency of at least once per 92 days is acceptable.

REFUELING OPERATIONS BASES3/4.9.6 DELETED3/4.9.7 DELETED3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION In MODE 6 the shutdown cooling trains are the primary means of heat removal.

OneSDC train provides sufficient heat removal capability.

However, to provide redundant paths forheat removal either two SDC trains are required to be OPERABLE and one SDC train must be inoperation, or one SDC train is required to be OPERABLE and in operation with the refueling cavity water level : 23 feet above the reactor vessel flange. This volume of water in the refueling cavity will provide a large heat sink in the event of a failure of the operating SDC train. Anyexception to these requirements are contained in the LCO Notes.An OPERABLE SDC train, for plant operation in MODE 6, includes a pump, heatexchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and todetennine RCS temperature.

In addition, sufficient portions of the Reactor Building ClosedCooling Water (RBCCW) and Service Water (SW) Systems shall be OPERABLE as required toprovide cooling to the SDC heat exchanger.

The flow path starts at the RCS hot leg and isreturned to the RCS cold legs. OPERABLE SDC train consists of the following equipment:

~M anagerment of-gas vo-ids is im--portan to SD Sys--tem

-O--'R' BILT .1. An OPERABLE SDC pump (low pressure sa ery mjection pump);2. The associated SDC heat exchanger from the same facility as the SDC pump;3. An RBCCW pump, powered from the same facility as the SDC pump, and RBCCW heatexchanger capable of cooling the associated SDC heat exchanger;

4. A SW pump, powered flom the same facility, as the SDC pump, capable of supplying cooling water to the associated RBCCW heat exchanger; and5. All valves required to support SDC System operation are in the required position or arecapable of being placed in the required position.

In MODE 6, two OPERABLE SDC trains require 2 SDC pumps, 2 SDC heat exchangers, 2 RBCCW pumps, 2 RBCCW heat exchangers, and 2 SW pumps. In addition, 2 RBCCWheaders are required to' provide cooling to the SDC heat exchangers, but only 1 SW header isrequired to support the SDC trains. The equipment specified is sufficient to address a singleactive failure of the SDC System and associated support systems.MILLSTONE

-UNIT 2 B 3/4 9-2 Amendment No. 69,-74, 44-7, 4-8-5, 40,24-55, 2a49-,

-BerP, 9&44P-280(0 REFUELING OPERATIONS BASES3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION (Continued'l In addition, two SDC trains can be considered

OPERABLE, with only one 125-volt D.C.bus train OPERABLE, in accordance with Limiting Condition for Operation (LCO) 3.8.2.4.2-SI-306 and 2-SI-657 are both powered from the same 125-volt D.C. bus, on Facility

1. Shouldthese valves reposition due to a loss of power, SDC would no longer be aligned to cool the RCS.However, a designated operator is assigned to reposition these valves as necessary in the event125-volt D.C. power is lost. Consistent with the bases for LCO 3.8.2.4, the 125-volt D.C. supportsystem operability requirements for both trains of SDC aye satisfied in MODE 6 with at least one125-volt D.C. bus train OPERABLE and the 125-volt D.C. buses cross-tied.

Either SDC pump may be aligned to the refueling water storage tank (RWST) to supportfilling the fueling cavity or for performance of required testing.

A SDC pump may also be used totransfer water from the refueling cavity to the RWST. In addition, either SDC pump may bealigned to draw a suction on the spent fuel pool (SFP) through 2-RW-1I and 2-SI-442 instead ofthe normal SDC suction flow path, provided the SFP transfer canal gate valve 2-RW-280 is openunder administrative control (e.g., caution tagged).

When using this alternate SDC flow path, itwill be necessary to secure the SFP cooling pumps, and limit SDC flow as specified in theappropriate procedure, to prevent vortexing in the suction piping. The evaluation of this alternate SDC flow path assumed that this flow path will not be used during a refueling outage until afterthe completion of the fuel shuffle such that approximately one third of the reactor core willcontain new fuel. By waiting until the completion of the fuel shuffle, sufficient time (at least 14days from reactor shutdownf) will have elapsed to ensure the limited SDC flow rate specified forthis alternate lineup will be adequate for decay heat removal fiom the reactor core and the spentfuel pool. In addition, CORE ALTERATIONS shall be suspended when using this alternate flowpath, and this flow path should only be used for short time periods, approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . If thealternate flow path is expected to be used for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or the decay heat load will notbe bounded as previously discussed, further evaluation is required to ensure that this alternate flow path is acceptable.

These'alternate lineups do not affect the OPERABILITY of the SDC train. In addition, these alternate lineups will satisfy the requirement for a SDC train to be in operation if theminimum required SDC flow tlrough the reactor core is maintained.

In MODE 6, with the refueling cavity filled to >_ 23 feet above the reactor vessel flange,both SDC trains may not be in operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in each 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, provided nooperations are permitted that would dilute the RCS boron concentration by introduction of coolantinto the RCS with boron concentration less than required to meet the minimum boronconcentration of LCO 3.9.1. Boron concentration reduction with coolant at boron concentrations less than required to assure the RCS boron concentration is maintained is prohibited becauseMAILLSTONE

-UNIT 2 B 3/4 9-2a Amendment No. 69, q-, fl-7, 4-8, , 24G.,24-, 249, 2-4, 29-3,.L- RC JulyX~k 5U., 2007 MPS2 Insert F -SDC Trains Refueling Insert F, Bases Refueling Operations

-SDC and Coolant Circulation SDC System piping and components have the potential to develop voids and pockets ofentrained gases. Preventing and managing gas intrusion and accumulation is necessary forproper operation of the required SDC loop(s) and may also prevent water hammer, pumpcavitation, and pumping of noncondensible gas into the reactor vessel.Surveillance Requirement 4.9.8.1.2 and 4.9.8.2.3 are performed for SDC System locations susceptible to gas accumulation and, if gas is found, the gas volurne is compared to theacceptance criteria for the location.

Susceptible locations in the same system flow path whichare subject to the same gas intrusion mechanisms may be verified by monitoring arepresentative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, orpersonnel safety. For these locations alternative methods (e.g., operating parameters, remotemonitoring) may be used to monitor the susceptible location.

Monitoring is not required forsusceptible locations where the maximum potential accumulated gas void volume has beenevaluated and determined to not challenge system OPERABILITY.

The accuracy of the methodused for monitoring the susceptible locations and trending of the results should be sufficient toassure system OPERABILITY during the Surveillance interval.

The monitoring frequency takes into consideration the gradual nature of gas accumulation in theSDC System piping and the procedural controls governing system operation.

Based on plantexperience, the Surveillance Frequency of at least once per 92 days is acceptable.

Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 4DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATION CHANGEDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 Serial No. 15-012Docket Nos. 50-336/423 Attachment 4, Page 1 of 5DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Technical Specifications (TS) Surveillance Requirements (SRs) to verify system locations susceptible to gas accumulation aresufficiently filled with water and to provide allowances which permit performance of theverification to the TS. The changes are being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling,Decay Heat Removal, and Containment Spray Systems."

The proposed amendment isconsistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing GasAccumulation."

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Dominion Nuclear Connecticut, Inc. (DNC) has reviewed the model safety evaluation dated January 15, 2014 as part of the Federal Register Notice of Availability.

Thisreview included a review of the NRC staffs evaluation, as well as the information provided in TSTF-523.

As described in the subsequent paragraphs, DNC hasconcluded that the justifications presented in the TSTF-523 proposal and the modelsafety evaluation prepared by the NRC staff are applicable to Millstone Power StationUnit 3 (MPS3) and justify this amendment for the incorporation of the changes to theMPS3 TS.2.2 Optional Changes and Variations DNC is proposing deviations from the TS changes described in the TSTF-523, Revision

2. The deviations are as follows:1. Consistent with the MPS3 response to Generic Letter 2008-01, as discussed inDominion Letter Serial No. 08-0013C, dated October 14, 2008 (ML082890266),

DNC is only proposing SRs for those systems that are susceptible to gasaccumulation.

SRs will not be incorporated for the following systems:* 3/4.6.2.1, Containment Quench Spray System (Standard Technical Specification (STS) 3.6.6D)The Quench Spray System (QSS) is maintained full from the RWST to anequivalent level in the piping headers located inside containment, theremainder of the vertical headers and the spray rings are maintained dry.The quarterly pump operability surveillances ensure adequate water volumeis pumped through suction and discharge piping at a velocity to adequately sweep any gas from the water filled system piping outside of containment.

Serial No. 15-012Docket Nos. 50-336/423 Attachment 4, Page 2 of 5There are no identified gas intrusion mechanisms for this system. Therefore, the QSS piping is free of potential gas voids and a routine surveillance toverify the QSS piping locations susceptible to gas accumulation aresufficiently filled with water is unnecessary.

3/4.6.2.2, Recirculation Spray System (STS 3.6.6E)The Recirculation Spray System (RSS) piping is not maintained water filled bydesign, excluding the ECCS cross connect piping, which is included with theECCS piping that is susceptible to gas accumulations.

The pump and pipingfill and self-vent during the course of a loss-of-coolant event and the initialsystem operation.

The RSS will only actuate based on specific actuation signals which will ensure there is adequate water available to meet NPSHrequirements.

The RSS is maintained dry and designed to fill and self vent.Since there is no identified gas intrusion mechanism, a routine surveillance toverify the RSS piping locations are sufficiently filled with water isunnecessary.

2. The MPS3 TS use different numbering and titles than the Standard Technical Specifications on which TSTF-523 was based. Specifically, the following TS arenumbered and titled differently:

MPS3 TS number and title STS TS number and title3.4.1.3, RCS -Hot Shutdown 3.4.6, RCS Loops -MODE 43.4.1.4 1, RCS -Cold Shutdown

-3.4.7, RCS Loops -MODE 5, LoopsLoops Filled Filled3.4.1.4.2, RCS Cold Shutdown

-Loops 3.4.8, RCS Loops -MODE 5, LoopsNot Filled Not Filled3.5.2, ECCS Subsystems

-Tavg 3.5.2, ECCS -Operating Greater Than Or Equal To 350°F3.5.3, ECCS Subsystems

-Tavg Less 3.5.3, ECCS -ShutdownThan 350'F3.9.8.1, Residual Heat Removal and 3.9.5, Residual Heat Removal (RHR)Coolant Circulation

-High Water Level and Coolant Circulation

-High WaterLevel3.9.8.2, Residual Heat Removal and 3.9.6, Residual Heat Removal (RHR)3.9..2,ResiualHea Remvaland and Goolant Girculation

-Low WaterCoolant Circulation

-low water level LevelLevelThese differences are administrative TSTF-523 to the MPS3 TS.and do not affect the applicability of Serial No. 15-012Docket Nos. 50-336/423 Attachment 4, Page 3 of 53.0 REGULATORY ANALYSIS3.1 Applicable Regulatory Requirements The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR)Part 50 or similar plant-specific principal design criteria provide design requirements.

Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programsprovide operating requirements.

The regulatory requirements of 10 CFR Part 50,Appendix A, that are applicable to gas management in the subject systems include:General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40.The traveler and model safety evaluation discusses the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General DesignCriteria (GDC). MPS3 is not licensed to the current 10 CFR 50, Appendix A, GDC.MPS3's UFSAR, Section 3.1 "Design Of Structures, Components, Equipment, AndSystems,"

provides an assessment against the 10 CFR 50, Appendix A, "GeneralDesign Criteria for Nuclear Power Plants" as amended through 1978. A review hasdetermined that the MPS3 plant-specific requirements are sufficiently similar to theAppendix A, GDC as related to the proposed change. Therefore, the proposed changeis applicable to MPS3.3.2 No Significant Hazards Consideration Determination Dominion Nuclear Connecticut, Inc. (DNC) requests adoption of TSTF-523, Rev. 2,"Generic Letter 2008-01, Managing Gas Accumulation,"

which is an approved change tothe standard technical specifications (STS), into the Millstone Power Station Unit 3technical specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation aresufficiently filled with water, and to provide allowances which permit performance of theverification.

DNC has evaluated whether or not a significant hazards consideration is involved withthe proposed amendment(s) by focusing on the three standards set forth in 10 CFR50.92, "Issuance of amendment,"

as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.The proposed change revises or adds Surveillance Requirement(s)

(SRs) thatrequire verification that the Emergency Core Cooling System (ECCS) and theResidual Heat Removal (RHR) System are not rendered inoperable due toaccumulated gas and to provide allowances which permit performance of the revisedverification.

Gas accumulation in the subject systems is not an initiator of any Serial No. 15-012Docket Nos. 50-336/423 Attachment 4, Page 4 of 5accident previously evaluated.

As a result, the probability of any accident previously evaluated is not significantly increased.

The proposed or revised SRs ensure thatthe subject systems continue to be capable to perform their assumed safety functionand are not rendered inoperable due to gas accumulation.

Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind ofaccident from any accident previously evaluated?

Response:

No.The proposed change revises or adds SRs that require verification that the ECCSand the RHR Systems are not rendered inoperable due to accumulated gas and toprovide allowances which permit performance of the revised verification.

Theproposed change does not involve a physical alteration of the plant (i.e., no new ordifferent type of equipment will be installed) or a change in the methods governing normal plant operation.

In addition, the proposed change does not impose any newor different requirements that could initiate an accident.

The proposed change doesnot alter assumptions made in the safety analysis and is consistent with the safetyanalysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kindof accident from any accident previously evaluated.

3 Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change revises or adds SRs that require verification that the ECCSand the RHR Systems, are not rendered inoperable due to accumulated gas and toprovide allowances which permit performance of the revised verification.

Theproposed change adds new requirements to manage gas accumulation in order toensure the subject systems are capable of performing their assumed safetyfunctions.

The proposed or revised SRs are more comprehensive than the currentSRs and will ensure that the assumptions of the safety analysis are protected.

Theproposed change does not adversely affect any current plant safety margins or thereliability of the equipment assumed in the safety analysis.

Therefore, there are nochanges being made to any safety analysis assumptions, safety limits or limitingsafety system settings that would adversely affect plant safety as a result of theproposed change.

Serial No. 15-012Docket Nos. 50-336/423 Attachment 4, Page 5 of 5Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, DNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and,accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use ofa facility component located within the restricted area, as defined in 10 CFR 20, orwould change an inspection or surveillance requirement.

However, the proposedchange does not involve (i) a significant hazards consideration, (ii) a significant changein the types or a significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b),

noenvironmental impact statement or environmental assessment need be prepared inconnection with the proposed change.

Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 5MARKED-UP TECHNICAL SPECIFICATION PAGESDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 06/28/06REACTOR COOLANT SYSTEMHOT SHUTDOWN Information onlyLIMITING CONDITION FOR OPERATION 3.4.1.3 Either: *, **a. With the Control Rod Drive System capable of rod withdrawal, at least two RCSloops shall be OPERABLE and in operation, orb. With the Control Rod Drive System not capable of rod withdrawal, at least twoloops consisting of any combination of RCS loops.and residual heat removal(RHR) loops shall be OPERABLE, and at least one of these loops shall be inoperation.

For RCS loop(s) to be OPERABLE, at least one reactor coolant pump(RCP) shall be in operation.

APPLICABILITY:

MODE 4.ACTION:a. With less than the above required loops OPERABLE, inmmediately initiatecorrective action to return the required loops to OPERABLE status as soon aspossible; if the remaining OPERABLE loop is an RHR loop, be in COLDSHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .All reactor coolant pumps and RHR pumps may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

(1)no operations are permitted that would cause introduction of coolant into the RCS with boronconcentration less than required to meet the SDM of LCO 3.1.1.1.2, and (2) core outlettemperature is maintained at least 10°F below saturation temperature.

The first reactor coolant pump shall not be started when any RCS loop wide range cold legtemperature is _< 226'F unless:a. Two pressurizer PORVs are in service to meet the cold overpressure protection requirements of Technical Specification 3,4.9.3 and the secondary side watertemperature of each steam generator is < 50'F above each RCS cold legtemperature; ORb. The secondary side water temperature of each steam generator is at or below eachRCS cold leg temperature.

This restriction only applies to RCS loops and associated components that are n ot isolatedfrom the reactor vessel.MILLSTONE

-UNIT 33/4 4-3Amendment No. 7-, 4-57-, 19-4, 230 REACTOR COOLANT SYSTEMHOT SHUTDOWNLIMITING CONDITION FOR OPERATION (continued)

b. With less than the above required reactor coolant loops in operation and theControl Rod Drive System is capable of rod withdrawal, within I hour open theReactor Trip System breakers.

c. With no loop in operation, suspend operations that would cause introduction ofcoolant into the RCS with boron concentration less than required to meet SDM ofLCO 3.1.1.1.2 and ininediately initiate corrective action to return the requiredloop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump(s),

if not in operation, shall be determined OPERABLE at thefrequency specified in the Surveillance Frequency Control Program by verifying correct breaker /alignments and indicated power availability.

4.4.1.3.2 The required steam generator(s) shall be determined OPERABLE by verifying secondary side water level to be greater than or equal to 17% at the frequency specified in theSurveillance Frequency Control Program.4.4.1.3.3 The required loop(s) shall be verified in operation and circulating reactor coolant atthe frequency specified in the Suirveillance Frequency Control Program.

'NoteNot required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 44.4.1.3.4 Locations susceptible to gas accumulation in the required.

RHR trains shallbe verified to be sufficiently filled with water at the frequency specified in theSurveillance Frequency Control Program...

MTLLSTONE

-UNIT 33/4 4-4Amendment No. 4-4-5, 4-9-7-, 2-3-0, 2-5 06/28/06REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS FILLED Information onlyLIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and inoperation*,

and either:a. One additional RHR loop shall be OPERABLE**,

orb. The secondary side water level of at least two steam generators shall be greaterthan 17%.APPLICABILITY:

MODE 5 with at least two reactor coolant loops filled"**

-*a. The RHR pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

(1) no operations are pernitted that would cause introduction of coolant into the RCS with boron concentration less thanrequired to meet the SDM of LCO 3.1.1.1.2, and (2) core outlet temperature is maintained atleast 1 OF below saturation temperature.

b. All RHIR loops may be removed fiom operation.

during a planned heatup to MODE 4 whenat least one RCS loop is OPERABLE and in operation and when two additional steamgenerators are OPERABLE as required by LCO 3.4.1.4.1.b.

- One RHR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the otherRHR loop is OPERABLE and in operation.

The first reactor coolant pump shall not be started when:a. Any RCS loop wide range cold leg temperature is > 150'F unless:1. Two pressurizer PORVs are in service to meet the cold overpressure protection requirements of Teclhical Specification 3.4.9.3 and the secondary side watertemperature of each steam generator is < 50°F above each RCS cold leg temperature; OR2. The secondaiy side water temperature of each steam generator is at or below eachRCS cold leg temperature.

b. All RCS loop wide range cold leg temperatures are < 150'F unless the secondary sidewater temperature of each steam generator is < 50'F above each RCS cold legtemperature.

This restriction only applies to RCS loops and associated components that are not isolatedfrom the reactor vessel.MILLSTONE

-UNIT 33/4 4-5Amendment No. 47-7, 4-9-7, 230 REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS FILLEDLIMITING CONDITION FOR OPERATION ACTION:a. With less than the required RHR loop(s) OPERABLE or with less than therequired steam generator water level, immediately initiate corrective action toreturn the inoperable RHR loop to OPERABLE status or restore the requiredsteam generator water level as soon as possible.

b. With no R:HR loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDMof LCO 3,1.1.1.2 and inmmediately initiate corrective action to return the requiredRHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shallbe detern-ined to be within limits at the frequency specified in the Surveillance Frequency ControlProgram.4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating reactorcoolant at the frequency specified in the Surveillance Frequency Control Program.4.4.1.4.1.3 The required pump, if not in operation, shall be determined OPERABLE at thefrequency specified in the Surveillance Frequency Control Program by verifying correct breakeralignment and indicated power availability.

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

-UNIT 33/4 4-5aAmendment No. 4-7-, 4-92-0, 2-5 06/28/06REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS NOT FILLED linformation only ILIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE*

and at least one RHRloop shall be in operation.**

APPLICABILITY:

MODE 5 with less than two reactor coolant loops filled***.

ACTION:a. With less than the above required RHR loops OPERABLE, immediately initiatecorrective action to return the required RHR loops to OPERABLE status as soonas possible.

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

One RIR loop may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing provided the otherRHR loop is OPERABLE and in operation.

The RHR pump may be deenergized for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months provided:

(1) no operations are pernmitted that would cause introduction of coolant into the RCS with boron concentration less thanrequired to meet the SDM of LCO 3.1.1.1.2, and (2) core outlet temperatuLre is maintained atleast 10°F below saturation temperature.

*

The first reactor coolant pump shall not be started when:a. Any RCS loop wide range cold leg temperature is> 150'F unless:1. Two pressurizer PORVs are in service to meet the cold overpressure protection requirements of Technical Specification 3.4ý9.3 and the secondary side watertemperature of each steam generator is < 50°F above each RCS cold legtemperature; OR2. The secondary side water temperature of each steam generator is at or below eachRCS cold leg temperature.

b. All RCS loop wide range cold leg temperatures are 150'F unless the secondary sidewater temperature of each steam generator is < 50'F above each RCS cold legtemperature.

This restriction onily applies to RCS loops and associated components that are not isolated fromthe reactor vessel.MILLSTONE

-UNIT 33/4 4-6Amendment No. 60, 99, 4-5f, 4,--7, 230 REACTOR COOLANT SYSTEMCOLD SHUTDOWN

-LOOPS NOT FILLEDSURVEILLANCE REQUIREMENTS 4.4.1.4,2.1 The required pump, if not in operation, shall be determined OPERABLE at thefrequency specified in the Surveillance Frequency Control Program by verifying correct breakeraligmnent and indicated power availability.

4.4.1.4.2.2 At least one RHR loop shall be determined to be in operation and circulating reactorcoolant at the frequency specified in the Surveillance Frequency Control Program.4S.44.1.4.2.3 Locations susceptible to gas accumulation in the required RHR trainsshall be verified to be sufficiently filled with water at the frequency specified in theSurveillance Frequency Control Program.MILLSTONE

-UNTIT 33/4 4-6aAmendment No. 4-54, +97,-2-F87 February 9, 1995EMERGENCY CORE COOLING SYSTEMS For Information 13/4.5.2 ECCS SUBSYSTEMS

-Ta GREATER THAN OR EQUAL TO 350°FLIMITING CONDITION FOR OPERATION 3.5.2 Two independent Emergency Core Cooling System (ECCS) subsystems shall beOPERABLE with each subsystem comprised of:a. One OPERABLE centrifugal charging pump,b. One OPERABLE Safety Injection pump,c. One OPERABLE RHR heat exchanger,*

d. One OPERABLE RHR pump,*e. One OPERABLE containment recirculation heat exchanger,

f. One OPERABLE containment recirculation pump, andg. An OPERABLE flow path capable of taking suction from the refueling waterstorage tank on a Safety Injection signal and capable of automatically stopping theRER pump and being manually realigned to transfer suction to the containmuent sump during the recirculation phase of operation.

APPLICABILITY:

MODES 1, 2, and 3.ACTION:a. With one ECCS subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s* or be in at least HOT STANDBYwithin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .b. In the event the ECCS is actuated and injects water into the Reactor CoolantSystem, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of theactuation and the total accumulated actuation cycles to date. The current value ofthe usage factor for each affected Safety Injection nozzle shall be provided in thisSpecial Report whenever its value exceeds 0.70.The allowable outage time for each RHR pump/RHR heat exchanger may be extended to120 hours for the purpose of pump modification to change mechanical seal and other relatedmodifications.

This exception may only be used one time per RHR pump/RHR heatexchanger and is not valid after April 30, 1995.MILLSTONE

-UNIT 33/4 5-3Amendment No. 103 EMERGENCY CORE COOLING SYSTEMSSURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Program by yverifying that the following valves are in the indicated positions with power to thevalve operators removed:Valve Number Valve Function Valve Position3SIH*MV8806 RWST Supply to SI Pumps OPEN3SIH*MV8802A SI Pump A to Hot Leg Injection CLOSED3SIH*MV8802B SI Pump B to Hot Leg Injection CLOSED3SIH*MV8835 SI Cold Leg Master Isolation OPEN3SIH*MV8813 SI Pump Master Miniflow OPENIsolation 3SIL*MV8840 RHR to I-lot Leg Injection CLOSED3SIL*MV8809A RHR Pump A to Cold Leg OPENInjection 3SIL*MV8809B RHR Pump B to Cold Leg OPENInjection r locailons susceptible to gas accumulation

b. At the frequency specified in the Surveillnce Frequency Control Program by:1) Verifying that the ECCS piping, except for the operating centrifugal charging pump(s) and associated piping, the RSS pump, the RSS heatexchanger and associated piping, v mtdpa andare sufficiently tilled with water2) Verifying that each valve (manual, power-operated, or automatic n theflow path that is not locked, sealed, or otherwise secured in position, is inits correct position.

C. By) visual inspection which verifies that no loose debris (rags, trash, clothing, etc) is present in the containment which could be transported to the contaimnent su ip and cause restriction of the pump suctions during LOCA conditions.

Thisvi ual. inspection shall be performed:

1 For all accessible areas of the contaimnent prior to establishing CONTAINMENT INTEGRITY, andAt least once daily of the areas affected (during each day) withincontainment by containmuent entry and during the final entry whenCONTAINMENT INTEGRITY is established.

d. At the frequency specified in the Surveillance Frequency Control Program by:1) Verifying automatic interlock action of the RHR System from the ReactorCoolant System by ensuring that with a simulated signal greater than orequal to 412.5 psia the interlocks prevent the valves from being opened.MILLSTO -UNIT 3 3/4 5-4 Amendment No. 60,Q79, 4-00, 4-24, -- -------.

--.. -.--------

NOTE ---------------------------------

4-56, 2 , a0 "6 5{-Not required to be met for system vent flow pathsopened under administrative control.

REFUELING OPERATIONS 3/4.9,8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION HIGH WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.1 At least one residual heat removal (RHR) loop shall be OPERABLE and inoperation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange isgreater than or equal to 23 feet.ACTION:With no RHR loop OPERABLE or in operation, suspend operations that would causeintroduction of coolant into the RCS with boron concentration less than required to meet theboron concentration of LCO 3.9.1.1 and suspend loading irradiated fuel assemblies in the coreand immediately initiate corrective action to return the required RHR loop to OPERABLE andoperating status as soon as possible.

Close all containment penetrations providing direct accessfiom the containmrent atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .SURVEILLANCE REQUIREMENTS 4.9.8. ! least one RHR loop shall be verified in operation and circulating reactor coolant ata flow rate of greater than or equal to 2800 gpm at the frequency specified in the Surveillance Frequency Control Program.4.9.8.1.2 Locations susceptible to gas accumulation in the required RHRtrains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.The RHR loop may be removed from operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period, providedno operations are permitted that could cause introduction of coolant into the RCS with boronconcentration less than required to meet the boron concentration of LCO 3.9.1 .1.MILLSTONE

-UNIT 33/4 9-8Amendment No. 4--7, 2 , G.-2-5-8 REFUELING OPERATIONS LOW WATER LEVELLIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and atleast one R-SR loop shall be in operation.*

APPLICABILITY:

MODE 6, when the water level above the top of the reactor vessel flange isless than 23 feet.ACTION:a. With less than the required R-HR loops OPERABLE, immediately initiatecorrective action to return the required RER loops to OPERABLE status, or toestablish greater than or equal to 23 feet of water above the reactor vessel flange,as soon as possible.

b. With no RPR loop in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet theboron concentration of LCO 3.9.1 .1 and immediately initiate corrective action toreturn the required RPHR loop to operation.

Close all containment penetrations providing direct access from the containment atmosphere to the outsideatmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one RHR loop shall be verified in operation and circulating reactor coolant ata flow rate of greater than or equal to 2800 gpin at the frequency specified in the Surveillance Frequency Control Program.4.9.8.2.2 Locations susceptible to gas accumulation in the required RHR-trains shall be verified to be sufficiently filled with water at the frequency specified in the Surveillance Frequency Control Program.* The RHR loop may be removed from operation for up to- I hour per 8-hour period, providedno operations are permitted that could cause introduction of coolant into the RCS with boronconcentration less than required to meet the boron concentration of LCO 3.9.1.1.MILLSTONE

-UNIT 33/4 9-9Amendment No. 4-0-7, 23-0, 2-5-&

Serial No. 15-012Docket Nos. 50-336/423 ATTACHMENT 6MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGESFOR INFORMATION ONLYDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3

-L-BDCR-N-ot0'M fP3 @&;ia'.25, 2p6-3/4.4 REACTOR COOLANT SYSTEMBASES3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION The purpose of Specification 3.4. 1 is to require adequate forced flow rate for core heatremoval in MODES 1 and 2 during all normal operations and anticipated transients.

Flow isrepresented by the number of reactor coolant pumps in operation for removal of heat by the steamgenerators.

To meet safety analysis acceptance criteria for DNB, four reactor coolant pumps arerequired at rated power. An OPERABLE reactor coolant loop consists of an OPERABLE reactorcoolant pump in operation providing forced flow for heat transport and an OPERABLE steamgenerator.

With less than the required reactor coolant loops in operation this specification requires that the plant be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .In MODE 3, three reactor coolant loops, and in MODE 4, two reactor coolant loopsprovide sufficient heat removal capability for removing core decay heat even in the event of abank withdrawal accident;

however, in MODE 3 a single reactor coolant loop provides sufficient heat removal capacity if a banc withdrawal accident can be prevented, i.e., the Control Rod DriveSystem is not capable of rod withdrawal.

In MODE 4, if a bank withdrawal accident can be prevented, a single reactor coolant loopor RHR loop provides sufficient heat removal capability for removing decay heat; but singlefailure considerations require that at least two loops (any combination of RHR or RCS) beOPERABLE.

In MODE 5, with reactor coolant loops filled, a single RHR loop provides sufficient heat-removal capability for removing decay heat; but single failure considerations require that at leasttwo RH-R loops or at least one RHR loop and two steam generators be OPERABLE.

In MODE 5 with reactor coolant loops not filled, a single RHR loop provides sufficient heat removal capability for removing decay heat; but single failure considerations, and theunavailability of the steam generators as a heat removing comiponent, require that at least twoRHR loops be OPERABLE.

In MODE 5, during a planned heatup to MODE 4 with all RHR loops removed fromoperation, an RCS loop, OPERABLE and in operation, meets the requirements of an OPERABLEand operating RHR loop to circulate reactor coolant.

During the heatup there is no requirement forheat removal capability so the OPERABLE and operating RCS loop meets all of the requiredfunctions for the heatup condition.

Since failure of the RCS loop, which is OPERABLE andoperating, could also cause the associated steam generator to be inoperable, the associated steamgenerator cannot be used as one of the steam generators used to meet the requirement of LCO3.4.1.4.1.b.

VInnsert A-MILLSTONE

-TJNIT'3B 3/4 4-1Amendment No. 60, G, 99, 4--, 4-)4, 24--,

3/4.4 REACTOR COOLANT SYSTEMBASES (Continued)

The operation of one reactor coolant pump (RCP) or one RHR pump provides adequateflow to ensure mixing, prevent stratification and produce gradual reactivity changes during boronconcentration reductions in the Reactor Coolant System. The reactivity change rate associated with boron reduction will, therefore, be within the capability of operator recognition and control.The restrictions on starting the first RCP in MODE 4 below the cold overpressure protection enable temperature (226°F),

and in MODE 5 are provided to prevent RCS pressuretransients.

These transients, energy additions due to the differential temperature between thesteam generator secondary side and the RCS, can result in pressure excursions which couldchallenge the P/T limits. The RCS will be protected against overpressure transients and will notexceed the reactor vessel isothermal beltline P/T linmt by restricting RCP starts based on thedifferential water temperature between the secondary side of each steam generator and the RCScold legs. The restrictions on starting the first RCP only apply to RCPs in RCS loops that are not" isolated.

The restoration of isolated RCS loops is normally accomplished with all RCPs secured.If an isolated RCS loop is to be restored when an RCP is operating, the appropriate temperature

differential limit between the secondary side of the isolated loop steam generator and the inservice RCS cold legs is applicable, and shall be met prior to opening the loop isolation valves.The temperature differential limit between the secondary side of the steam generators andthe RCS cold legs is based on the equipment providing cold overpressure protection as requiredby Technical Specification 3.4.9.3.

If the pressurizer PORVs are providing cold overpressure protection, the steam generator secondary to RCS cold leg water temperature differential islimited to a maximum of 50'F. If any RI-R relief valve is providing cold overpressure protection and RCS cold leg temperature is above 150'F, the steam generator secondary water temperature must be at or below RCS cold leg water temperature.

If any RR relief valve is providing coldoverpressure protection and RCS cold leg temperature is at or below 150'F, the steamn- generator secondary to RCS cold leg water temperature differential is li-mited to a maximum of 50°F.Specification 3.4.1.5The reactor coolant loops are equipped with loop stop valves that permit any loop to beisolated from the reactor vessel. One valve is installed on each hot leg and one on each cold leg.The loop stop valves are used to perform maintenance on an isolated loop. Operation in MODES1-4 with a RCS loop stop valve closed is not permitted except for the mitigation of emergency orabnormal events. If a loop stop valve is closed for any reason, the required ACTIONS of thisspecification must be completed.

To ensure that inadvertent closure of a loop stop valve does notoccur, thevalves must be open with power to the valve operators removed in MODES 1, 2, 3 and4.MNLLSTONE

-UNIT 3 .B 3/44-la AmendmentNo.

gO, ,P-, 4-, --202,2-7,

,j' C-H--N-0705-.~i 3/4.4 REACTOR COOLANT SYSTEMBASES (Continued)

Specification 3.4.1.6 Specifications 3.4.1.4.1 and 2The re rement to maintain the isolated loop stop valves shut with power removedensures tha o reactivity addition to the core could occur due to the startup of an isolated loop.Verifica' n of the boron concentration in an isolated loop prior to opening the first stop valve,pro es a reassurance of the- adequacy of the boron concentration in. the isolated loopCS Loops Filled/Not Filled:In MODE 5, any RHR train with only one cold leg injection path is sufficient to provideadequate core cooling anid prevent stratification of boron in the Reactor Coolant System.The definition of OPERABILITY states that the system or subsystem must be capable ofperforming its specified function(s).

The reason for the operation of one reactor coolant pump(RCP) or one RHIR pump is to:Provide sufficient decay heat removal capability Provide adequate flow to ensure mixing to:o Prevent stratification Produce gradual reactivity changes due to boron concentration changes in theRCSThe definition of "Reactor coolant loops filled" includes a loop that is filled, swept, andvented, and capable of supporting natural circulation heat transfer.

This allows the non-operating RHR loop to be removed from service while filling and unisolating loops as long as steamgenerators on the OPERABLE reactor coolant loops are available to support decay heat removal.Any loop being unisolated is not OPERABLE until the loop has been swept and vented. Theprocess of sweep and vent will make the previously OPERABLE loops inoperable and therequirements of LCO 3.4.1.4.2, "Reactor Coolant System, COLD SHUTDOWN

-Loops NotFilled,"

are applicable.

When the RCS has been filled, swept and vented using an appro.edprocedure, all unisolated loops may be declared OPERABLE.

The definition of "Reactor coolant loops filled" also includes a loop that has been vacuuim ifilled and capable of supporting natural circulation heat transfer.

Any isolated loop that has beenvacuum filled is OPERABLE as soon as the loop is unisolated.

One cold leg injection isolation valve on an RHR train may be closed without conisidering the train to be inoperable, as long as the following conditions exist:° CCP temperature is at or below 957Fo Initial RHR temperature is below 184'FMILLSTONE

-UNIT 3 B 3/4 4-1ic Amendment No. 24-,-Aeknwl dgly+R&f+/-e Vaed041 /'

LBDCRNo.

08-MP3-014 October 21, 20083/4.4 REACTOR COOLANT SYSTEMBASES (Continued) o The single RHR cold leg injection flow path is not utilized until a minimum of 48hours after reactor shutdown" CCP flow is at least 6,600 gpm° RHR flow is at least 2,000 gpmIn the above system lineup, total flow to the core is decreased compared to the flow whentwo cold legs are in service.

This is acceptable due to the substantial margin between the flowrequired for cooling and the flow available, even tlrough a slightly restricted RHR train.The review concerning boron stratification with the utilization of the single injection pointline, indicates there will not be a significant change in the flow rate or distribution through thecore, so there is not an increased concern due to stratification.

Flow velocity, which is high, is not a concern from a flow erosion or pipe loadingstandpoint.

There are no loads imposed on the piping system which would exceed thoseexperienced in a seismic event. The temperature of the fluid is low and is not significant fr'om aflow erosion standpoint.

The boron dilution accident

analysis, for Millstone Unit 3 in MODE 5, assumes a fullRIHR System flow of approximately 4,000 gpm. Westinghouse

analysis, Reference (1), for RHRflows down to 1,000 gpm, determined adequate mixing results.

As the configuration will result ina RHR flow rate only slightly less then 4,000 gpm there is no concern in regards to a borondilution accident.

The basis for the requirement of two RCS loops OPERABLE is to provide naturalcirculation heat sink in the event the operating RHR loop is lost. If the RPIR loop were lost, withtwo loops filled and two loops air bound, natural circulation would be established in the two filled,-loops.Natural circulation would not be established in the air bound loops. Since there would beno circulation in the air bound loops, there would be no mechanism for the air in those loops to becarried to the vessel, and subsequently into the filled loops rendering them inoperable for heatsink requirements.

The LCO is met as long as at least two reactor coolant loops are OPERABLE and thefollowing conditions are satisfied:

o One RHR loop is OPERABLE and in operation, with exceptions as allowed inTechnical Specifications; andMILLSTONE

-UNIT 3B 3/4 4-1dAmendment No. 24-7, Insert A, Bases -RCS Loops Mode 4During any mode where RHR is required for decay heat removal, management of gas voids isimportant to RHR System OPERABILITY.

RHR System piping and components have thepotential to develop voids and pockets of entrained gases. Preventing and managing gasintrusion and accumulation is necessary for proper operation of the required RHR loop(s) andmay also prevent water hammer, pump cavitation, and pumping of noncondensible gas into thereactor vessel.Insert B, Bases -RCS Loops Modes 4 and 5 loops filled or unfilledThe RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas(i.e., the system is sufficiently filled with water), the Surveillance may be declared met.Accumulated gas should be eliminated or brought within the acceptance criteria limits.Selection of RHR System locations susceptible to gas accumulation is based on a review ofsystem design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations.

The design review is supplemented by systemwalk downs to validate the system high points and to confirm the location and orientation ofimportant components that can become sources of gas or could otherwise cause gas to betrapped or difficult to remove during system maintenance or restoration.

Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

Surveillance Requirements 4.4.1.3.4, 4.4.1.4.1.4, and 4.4.1.4.2.3 are performed for RHRSystem locations susceptible to gas accumulation and, if gas is found, the gas volume iscompared to the acceptance criteria for the location.

Susceptible locations in the same systemflow path which are subject to the same gas intrusion mechanisms may be verified bymonitoring a representative sub-set of susceptible locations.

Monitoring may not be practical forlocations that are inaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring isnot required for susceptible locations where the maximum potential accumulated gas void.volume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

Theoperating RHR pump and associated piping are exempted from this surveillance requirement, inthat the operating train is self venting/flushing.

The monitoring frequency of the locations that are susceptible to gas accumulation takes intoconsideration the gradual nature of gas accumulation in the RHR System piping and theprocedural controls governing system operation.

The frequency is controlled by the Surveillance Frequency Control Program.

The surveillance frequency may vary by each location's susceptibility to gas accumulation.

SR 4.4.1.3.4 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapidshutdown, there may be insufficient time to verify all susceptible locations prior to enteringMODE 4.

3/4.5 EMERGENCY CORE COOLING SYSTEMSBASES3/4,5.1 ACCUMULATORS The OPERABILITY of each Reactor Coolant System (RCS) accumulator ensures that a sufficient volume of borated water will be immediately forced into the reactor core through each of the coldlegs in the event the RCS pressure falls below the pressure of the accumulators, This initial surgeof water into the core provides the initial cooling mechanism during large RCS pipe ruptures.

The limits on accumulator volume, boron concentration and pressure ensure that the assumptions used for accumulator injection in the safety analysis are met.The accumulator power operated isolation valves are required to meet the guidance of "operating bypasses" in the context of IEEE Std. 279-1971, which requires that bypasses of a protective function be removed automatically whenever permissive conditions are not met. The "operating bypass" designed for the isolation valves is applicable to MODES 1, 2, and 3 with Pressurizer pressure above P-1 I setpoint.

In addition, as these accumulator isolation valves fail to meet singlefailure criteria, removal of power to the valves is required.

The limits for operation with an accumulator inoperable for any reason except an isolation valveclosed minimizes the time exposure of the plant to a LOCA event occurring concurrent withfailure of an additional accumulator which may result in unacceptable pealk claddingtemperatures.

If a closed isolation valve cannot be immediately opened, the full capability of oneaccumulator is not available and prompt action is required to place the reactor in a mode wherethis capability is not required.

I Management of gas voids is important to ECCS OPERABILITY.

3/4.5.2 AND 3/4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two independent ECCS subsystems ensures that su 'cient emergency core cooling capability will be available in the event of a LOCA assuming the Ths of onesubsystem through any single failure consideration.

Either subsystem operating ihncnjunction with the accumulators is capable of supplying sufficient core cooling to limit the peal lIaddingtemperatures within acceptable limits for all postulated break sizes ranging from the doub'l endedbreak of the largest RCS cold leg pipe downward.

In addition, each ECCS subsystem provi1a.long-term core cooling capability in the recirculation mode during the accident recovery perioc'ýý With the RCS temperature below 3507F, one OPERABLE ECCS subsystem is acceptable withoutsingle failure consideration and with some valves out of normal injection lineup, on the basis ofthe stable reactivity condition of the reactor and the limited core cooling requirements.

The Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation System isrequired to be available to support charging pump operation.

The Charging Pump/Reactor PlantComponent Cooling Water Pump Ventilation System consists of two redundant trains, eachcapable of providing 100% of the required flow. Each train has a two position, "Off' and "Auto,"remote control switch. With the remote control switches for each train in the "Auto" position, thesystem is capable of automatically transferring operation to the redundant train in the event of alow flow condition in the operating train. The associated fans do not receive any safety relatedautomatic start signals (e.g., Safety Injection Signal).MILLSTONE

-UNIT 3B 3/4 5-1AmendmentNo.

4-5-7,

-4a, %5 2 6-EMERGENCY CORE COOLING SYSTEMSBASESECCS SUBSYSTEMS (Continued)

Placing the remote control switch for a Charging Pump/Reactor Plant Component Cooling WaterPump Ventilation Train in the "Off' position to start the redundant train or to perform postmaintenance testing to verify availability of the redundant train will not affect the availability ofthat train, provided appropriate administrative controls have been established to ensure the remotecontrol switch is immediately returned to the "Auto" position after the completion of the specified activities or in response to plant conditions.

These administrative controls include the use of anapproved procedure and a designated individual at the control switch for the respective ChargingPump/Reactor Plant Component Cooling Water Pump Ventilation Train who can rapidly respondto instructions from procedures, or control room personnel, based on plant conditions.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensuresthat at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained.

Surveillance Requirements for throttle valve position stopsprovide assurance that proper ECCS flows will be maintained in the event of a LOCA. /1Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when thesystem is in its minimum resistance conifiguration, (2) provide the proper flow split betweeninjection points in accordance with the assumptions used in the ECCS-LOCA

analyses, and(3) provide an acceptable level of total ECCS flow to all injection points equal to or above thatassumed in the ECCS-LOCA analyses.

sufficiently Ilnsert C ->- ... ..." 'Any time the OPERABILITY of an ECCS throttle valve or an ECCS subsyst im has been affectedby repair, maintenance, modification, or replacement activity that alter flow ,nharacteristics, postmaintenance testing in accordance with SR 4.0.1 is required to demonstrate OPERABILITY.

\--sufficiently Surveillance Requirement 4.5.2.b.

1 requires verifyingthat the ECCS piping is full of water. TheECCS pumps are normally in a standby, nonoperating mode, with the exception.

of the operating centrifugal charging pump(s).

As such, the ECCS flow path piping has the potential to developvoids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS,,full of water ensures that the system will perform properly wteql-iFed-tc mjzt-hnto tho KCS.This will also prevent water hammer, degraded performance, taon, and gas binding ofECCSpumps, and reduce to the greatest extent practical the pumping of no-condensible gases (e.g., an,1 nitrogen, or hydrogen) into the reactor vessel following an SI signal or N img shutdown cooling.[]!n~sert D /This Surveillance Requirement is met by: injecting its full capacity into the RCS upon demandVENTING the ECCS pump casings and VENTING or Ultrasonic Test (UT) of theaccessible suction and discharge piping high points including the ECCS pump suctioncrossover piping (i.e., downstream of valves 3RSS*MV8837A/B and3RSS*MV8838A/B to safety injection and charging pump suction).

VENTING of theMILLSTONE

-UNIT 3B 3/4 5-2Amendment No. 4-N0, 7, 447, EMERGENCY CORE COOLING SYSTEMSBASESECCS SUBSYSTEMS (Continued) ilnsert E flush upon heat exchanger return to service and procedural compliance is relied upon toensure that gas is not present within the heat exchanger u-tubes.Surveillance Requirement 4.5.2.C.2 requires that the visual inspection of the containment beperformed at least once daily if the containment has been entered that day and when the finalcontainment entry is made. This will reduce the number of unnecessary inspections and also reducepersonnel exposure.

Surveillance Requirement 4.5.2.d.2 addresses periodic inspection of the containment sump toensure that it is unrestricted and stays in proper operating condition.

The surveillance frequency is Vcontrolled under the Surveillance Frequency Control Program.

AThe Emergency Core Cooling System (ECCS) has several piping cross connection points foruse during the post-LOCA recirculation phase of operation.

These cross-connection points allow theRecirculation Spray System (RSS) to supply water from the contaimuent sump to the safety injection and charging pumps. The RSS has the capability to supply both Train A and B safety injection.

pumps and.both Train A and B charging pumps. Operator action is required to position valves toestablish flow from the containment sump through the RSS subsystems to the safety injection andcharging pumps since the valves are not automatically repositioned.

The quarterly stroke testing(Technical Specification 4.0.5) of the ECC/RSS recirculation flowpath valves discussed below willnot result in subsystem inoperability (except due to other equipment manipulations to support valvetesting) since these valves are manually aligned in accordance with the Emergency Operating Procedures (EOPs) to establish the recirculation flowpaths.

It is expected the valves will be returnedto the normal pre-test position following termination of the surveillance testing in response to theaccident.

Failure to restore any valve to the normal pre-test position will be indicated to the ControlRoom Operators when the ESF status panels are checked, as directed by the EOPs. The EOPs directthe Control Room Operators to check the ESF status panels early in the event to ensure properequipment alignment.

Sufficient time before the recirculation flowpath is required is expected to beavailable for operator action to position any valves that have not been restored to the pretest position, including local manual valve operation.

Even if the valves are not restored to the pre-test

position, sufficient capability will remain to meet ECCS post-LOCA recirculation requirements.

As a result,stroke testing of the ECCS recirculation valves discussed below will not result in a loss of systemindependence or redundancy, and both ECCS subsystems will remain OPERABLE.

When performing the quarterly stroke test of 3SHI*MV8923A, the control switch for safetyinjection pump 3SIH*PlA is placed in the pull-to-lock position to prevent an automatic pump startwith the suction valve closed. With the control switch for 3SIH*P1A in pull-to-lock, the Train AECCS subsystem is inoperable and Technical Specification 3.5.2, ACTION a., applies.

ThisACTION statement is sufficient to administratively control the plant configuration with theautomatic start of 3SIH*PIA defeated to allow stroke testing of 3SIH*MV8923A.

In addition, theEOPs and the ESF status panels will identify this abnormal plant configuration, if not corrected following the termination of the surveillance

testing, to the plant operators to allow restoration of thenbrmal post-LOCA recirculation flowpath.

Even if system restoration is not accomplished, sufficient equipment will be available to perform all ECCS and RSS injection and recirculation functions, provided no additional ECCS or RSS equipment is inoperable, and an additional single failure doesnot occur (an acceptable assumption since the Technical Specification ACTION statement limits theplant configuration time such that no additional equipment failure need be postulated).

During theinjection phase the redundant subsystem (Train B) is fully functional, as is a significant portion ofthe Train A subsystem.

During the recirculation phase, the Train A RSS subsystem can supply waterfrom the containment sump to the Train A..MILLSTONE

-UNIT 3B 3/4 5-2bAmendment No. 100, 447, 547 Insert C -ECCS Subsystems Surveillance requirement 4.5.2.b.1 verifies each valve (manual, power-operated, or automatic) inthe ECCS flow path that is not locked, sealed, or otherwise secured in position, is verified to be inits correct position is modified to exempt system vent flow paths opened under administrative control.

The administrative controls are proceduralized and include stationing a dedicated individual at the system vent flow path who is in continuous communication with the operators inthe control room. This individual will have a method to rapidly close the system vent flow path ifdirected.

Insert D -ECCS Subsystems ECCS piping and components have the potential to develop voids and pockets of entrained gases.Preventing and managing gas intrusion and accumulation is necessary for proper operation of theECCS and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas(e.g., air, nitrogen, or hydrogen) into the reactor vessel.Selection of ECCS locations susceptible to gas accumulation is based on a review of systemdesign information, including piping and instrumentation

drawings, isometric

drawings, plan andelevation

drawings, and calculations.

The design review is supplemented by system walk downs tovalidate the system high points and to confirm the location and orientation of important components that can become sources of gas, or could otherwise cause gas to be trapped ordifficult to remove during system maintenance or restoration.

Susceptible locations depend onplant and system configuration, such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria areestablished for the volume of accumulated gas at susceptible locations.

If accumulated gas isdiscovered that exceeds the acceptance criteria for the susceptible location (or the volume ofaccumulated gas at one or more susceptible locations exceeds an acceptance criterion for gasvolume at the suction or discharge of a pump), the Surveillance is not met. If it is determined bysubsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e., thesystem is sufficiently filled with water), the Surveillance may be declared met. Accumulated gasshould be eliminated or brought within the acceptance criteria limits.ECCS locations susceptible to gas accumulation are monitored and, if gas is found, the gasvolume is compared to the acceptance criteria for the location.

Susceptible locations in the samesystem flow path which are subject to the same gas intrusion mechanisms may be verified bymonitoring a representative sub-set of susceptible locations.

Monitoring may not be practical forlocations that are inaccessible due to radiological or environmental conditions, the plantconfiguration, or personnel safety. For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is notrequired for susceptible locations where the maximurn potential accumulated gas void volume hasbeen evaluated and determined to not challenge system OPERABILITY.

The accuracy of themethod used for monitoring the susceptible locations and trending of the results should besufficient to assure system OPERABILITY during the Surveillance interval.

Insert E -ECCS Subsystems The monitoring frequency of the locations that are susceptible to gas accumulation takes intoconsideration the gradual nature of gas accumulation in the ECCS Subsystem piping and theprocedural controls governing system operation.

The surveillance frequency is controlled by theSurveillance Frequency Control Program.

The surveillance frequency may vary by each location's susceptibility to gas accumulation.

CONTAINMENT SYSTEMSBASES3/4.6.1.6 CONTAINMENT STRUCTURAL INTEGRITY This limitation, ensures that the structural integrity of the containmient will be maintained comparable to the original design standards for the life of the facility.

Structural integrity isrequired to ensure that the containmnent will withstand the maximum pressure of 60 psia in theevent of a LOCA. A visual inspection, in accordance with the Containment Leakage Rate TestingProgram, is sufficient to demonstrate this capability.

3/4.6.1.7 CONTAINMENT VENTILATION SYSTEMThe 42-inch containment purge supply and exhaust isolation valves are required to be lockedclosed during plant operation since these valves have not been demonstrated capable of closingduring a LOCA or steam line break accident.

Maintaining these valves closed during plantoperations ensures that excessive quantities of radioactive materials will not be released via theContainment Purge System. To provide assurance that these containment valves camnot beinadvertently opened, the valves are locked closed in accordance with Standard Review Plan 6.2.4which includes mechanical devices to seal or lock the valve closed, or prevents power from beingsupplied to the valve operator.

The Type C testing frequency required by 4.6.1.2 is acceptable, provided that the resilient seats ofthese valves are replaced every other refueling outage.3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT QUENCH SPRAY SYSTEM and RECIRCULATION SPRAY SYSTEMThe OPERABILITY of the Containment Spray Systems ensures that contaimnent depressurization and iodine removal will occur in the event of a LOCA. The pressure reduction, iodine removal capabilities and resultant containmnent leakage are consistent with the assumptions used in the safety analyses.

L ---------- Insert FLCO 3.6.Z2.One Recirculation Spray System consists of:o Two OPERABLE contailnnent recirculation heat exchangers o Two OPERABLE contairnent recirculation punmpsThe Containment Recirculation Spray System (RSS) consists of two parallel redundant subsystems which feed two parallel 360 degree spray headers.

Each subsystem consists of twopumps and two heat exchangers.

Train A consists of 3RSS*PlA and 3RSS*P1C.

Train B consistsof 3RSS*PlB and 3RSS*PlD.

MILLSTONE

-UNIT 3 B 3/4 6-2 Amendment No. &9, 4-4, --,

Insert F -Containment Spray System BasesManagement of gas voids is important to the operability of the containment spray systems.Based on a review of system design information, including piping and instrumentation

drawings, isometric

drawings, plan and elevation

drawings, and calculations, as supplemented by systemwalk downs, the :Containment Quench Spray and Recirculation Spray Systems are notsusceptible to gas intrusion.

Once the piping in the Containment Quench Spray System isprocedurally filled and placed in service for normal operation, no external sources of gasaccumulation or intrusion have been identified for the system that would affect spray systemoperation or performance.

Thus, the piping in the Containment Quench Spray Systems willremain sufficiently full during normal operation and periodic monitoring for gas accumulation orintrusion is not required.

In the standby mode, the majority of the Recirculation Spray System isdry. The water filled portion of the Recirculation Spray System, which includes the ECCScross connect piping and loop seals, is monitored with the ECCS piping that issusceptible to gas accumulations 3/4.9 REFUELING OPERATIONS BASES3/4.9.8.1 HIGH WATER LEVEL (continued)

APPLICABLE SAFETY ANATYSESIf the reactor coolant temperature is not maintained below 200'F, boiling of the reactor coolantcould result. This could lead to a loss of coolant in the reactor vessel. Additionally, boiling of thereactor coolant could lead to a reduction in boron concentration in the coolant due to boronplating out on components near the areas of the boiling activity.

The loss of reactor coolant andthe reduction of boron concentration in the reactor coolant would eventually challenge theintegrity of the fuel cladding, which is fission product barrier.

One train of the RIR system isrequired to be operational in MODE 6, with the water level _ 23 ft above the top of the reactorvessel flange to prevent this challenge.

The LCO does permit deenergizing the RHR pump forshort durations, under the conditions that the boron concentration is not diluted.

This conditional deenergizing of the RHR pump does not result in a challenge to the fission product barrier.APPLICABILITY One RHR loop must be OPERABLE and in operation in MODE 6, with the water level _ 23 ftabove the top of the reactor vessel flange, to provide decay heat removal.

The 23 ft level wasselected because it corresponds to the 23 ft requirement established for fuel movement inLCO 3.9.10, "Water Level -Reactor Vessel."

Requirements for the RHR system in otherMODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5,Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the waterlevel < 23 ft are located in LCO 3.9.8.2, "Residual Heat Removal (RHR) and CoolantCirculatfon--Low Water Level."LIMITING CONDITTON FOR OPERATION dThe requirement that at least one RIR loop in operation ensures that: (1) sufficient coolingcapacity is available to remove decay heat an maintain the water in the reactor vessel below 140'Fas required during the REFUELING MODE, and (2) sufficient coolant circulation is maintained through the core to minimize the effect of a boron dilution incident and prevent stratification.

An OPERABLE RHR loop hicludes an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path. An operating RHR flow path should be capableof determining the low-end temperature.

The flow path starts in one of the RCS hot legs and isreturned to the RCS cold legs./\The LCO is modified by a Not(operation for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months perdilute the RCS boron concentrE concentration less than require(concentration reduction with c(boron concentration is maintaiicannot be ensured without forcalterations in the vicinity of th(testing.

During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months periof water in the refueling cavitythat allows the required operating RHR loop to be removed fromhour period, provided no operations are permitted that wouldtion by introduction of coolant into the RCS with boronto meet the minimum boron concentration of LCO 3.9.1.1.

Boronolant at boron concentrations less than required to assure the RCSred is prohibited because uniform concentration distribution nd circulation.

This permits operations such as core mapping orreactor vessel hot leg nozzles and RCS to RHR isolation valveSd, decay heat is removed by natural convection to the large massL Management of gas voids is important to RHR System OPERABILITY.

MILLSTONE

-UNIT 3B 3/4 9-3Amendment No. --047, -249,4-25-+

3/4.9 REFUELING OPERATIONS BASES3/4.9.8.1 HIGH WATER LEVEL (continued)

ACTIONSRHR loop requirements are met by having one RHR loop OPERABLE and in operation/

exceptas permitted in the Note to the LCO.If RHR loop requirements are not met, there will be no forced circulation to provide mixing toestablish uniform boron concentrations.

Suspending positive reactivity additions that could resultin failure to meet the minimum boron concentration limit is required to assure continued safeoperation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum refueling boron concentration.

This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

If RHR loop requirements are not met, actions shall be taken immediately to suspend loading ofirradiated fuel assemblies in the core. With no forced circulation

cooling, decay heat reimovalfrom the core occurs by natural convection to the heat sink provided by the water above the core.A minimum refueling water level of 23 ft above the reactor vessel flange provides an adequateavailable heat sink. Suspending any operation that would increase decay heat load, such asloading a fuel assembly, is a prudent action under this condition.

If.RHR loop requirements are not met, actions shall be initiated and continued in order to satisfyR-R loop requirements.

With the unit in MODE 6 and the refueling water level 23 ft above thetop of the reactor vessel flange, corrective actions shall be initiated inunediately.

If RH-R loop requirements are not met, all containment penetrations providing direct access fromthe containment atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With theRHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the contaimnent atmosphere.

Closing penetrations that are open to the outsideatmosphere ensures dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boilingin that time.Surveillance Requirement Rquirement 4.9.8.1.1I Thiis Surveillance 6monstrates that the RER loop is in operation and circulating reactor coolant.The flow rate is determined by the flow rate necessary to provide sufficient decay heat removalcapability and to prevent thermal and boron stratification in the core. The surveillance frequency is controlled under the Surveillance Frequency Control Program.<--Ilns-ert 3nG,MILLSTONE

-UNIT 3 B 3/4 9-4 Amendmelnt Nio. 4-G57, 24-9, 2-M O)6ff#qOf-3/4.9 REFUELING OPERATIONS BASES3/4.9.8.2 LOW WATER LEVEL (continued)

An OPERABLE RIHR loop consists of an RHR pump, a heat exchanger, valves, piping,instruments, and controls to ensure an OPERABLE flow path. An operatihg RHR flow pathshould be capable of determining the low end temperature.

The flow path starts in one of the RCShot legs and is returned to the RCS cold legs.APPLICABILITY IManagement of gas voids is important to RHR System OPERABILITY.

Two RHR loops are required to be OPERABLE, and one RHR loop must be in operation inMODE 6, with the water level < 23 ft above the top of the reactor vessel flange, to provide decayheat removal.

Requirements for the RHR System in other MODES are covered by LCOs inSection 3.5, Emergency Core Cooling Systems (ECCS). RPHR loop requirements in MODE 6 withthe water level 23 ft are located in LCO 3.9.8.1, "Residual Removal (RHR) AND CoolantCirculation-High Water Level."ACTIONSa. If less than the required number of PI-R loops are OPERABLE, actions shall beimmediately initiated and continued until the RHR loop is restored to OPERABLE statusand to operation, or until >_ 23 ft of water level is established above the reactor vesselflange. When the water level is _> 23 ft above the reactor vessel flange, the Applicability changes to that of LCO 3.9.3.1, and only one RH-IR loop is required to be OPERABLE andin operation.

An immediate Completion Time is necessary for an operator to initiatecorrective action.b. If no RI-IR loop is in operation, there will be no forced circulation to provide minrng toestablish uniform boron concentrations.

Suspending positive reactivity additions thatcould result in failure to meet the minimum boron concentration limit is required to assurecontinued safe operation.

Introduction of coolant inventory must be from sources thathave a boron concentration greater than that what would be required in the RCS forminimum refueling boron concentration.

This may result in an overall reduction in RCSboron concentration, but provides acceptable margin to maintaining subcritical operation.

If no RHR loop is in operation, actions shall be initiated inunediately, and continued, to restoreone RHR loop to operation.

Since the unit is in ACTIONS 'a' and 'b' concurrently, the restoration of two OPERABLE RHR loops and one operating RHR loop should be accomplished expeditiously.

If no RPR loop is in operation, all containment penetrations providing direct access from thecontaimnent atmosphere to the outside atmosphere must be closed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . With the RHRloop requirements not met, the potential exists for the coolant to boil and release radioactive gasto the containment atmosphere.

Closing containment penetrations that are open to the outsideatmosphere ensures that dose limits are not exceeded.

MILLSTONE

-UNIT 3B 3/4 9-6Amendment No. 44)4, 2-30 3/4.9 REFUELING OPERATIONS BASESThe Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability of the coolant boilingin that tine.Surveillance Requirement Requirement 4T-is Surveillance

=monstrates that one RHR loop is in operation and circulating reactor coolant.The flow rate is determined by the flow rate necessary to provide sufficient decay heat removalcapability and to prevent thermal and boron stratification in the core. In addition, during operation of the RHR loop with the water level in the vicinity of the reactor vessel nozzles, the RHR pumpsuction requirements must be met. The surveillance frequency is controlled under theSurveillance Frequency Control Program.MILLSTONE

-UNITB 3/4 9-7Amendment No. 4-G-7, 4-9, 23 Insert G, Bases Refueling Operations

-RHR and Coolant Circulation High Water LevelRHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumul1ation is necessary for proper operation ofthe RHR loops and may also prevent water hammer, pump cavitation, and pumping ofnoncondensible gas into the reactor vessel.Surveillance Requirement 4.9.8.1.2 is performed for RHR System locations susceptible to gasaccumulation and, if gas is found, the gas volume is compared to the acceptance criteria for thelocation.

Susceptible locations in the same system flow path which are subject to the same gasintrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations, alternative methods (e.g.,operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gasvoid volume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring frequency of the locations that are susceptible to gas accumulation takes intoconsideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.

The frequency is controlled by the Surveillance Frequency Control Program.

The frequency may vary by each location's susceptibility to gas accumulation.

Insert H, Bases Refueling Operations

-RHR and Coolant Circulation Low Water LevelRHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation ofthe RHR loops and may also prevent water hammer, pump cavitation, and pumping ofnoncondensible gas into the reactor vessel.Surveillance Requirement 4.9.8.2.2 is performed for RHR System locations susceptible to gasaccumulation and, if gas is found, the gas volume is compared to the acceptance criteria for thelocation.

Susceptible locations in the same system flow path which are subject to the same gasintrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations, alternative methods (e.g.,operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gasvoid volume has been evaluated and determined to not challenge system OPERABILITY.

Theaccuracy of the method used for monitoring the susceptible locations and trending of the resultsshould be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring frequency of the locations that are susceptible to gas accumulation takes intoconsideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation.

The frequency is controlled by the Surveillance Frequency Control Program.

The frequency may vary by each location's susceptibility to gas accumulation.

v t e Letter Sequence Request
TAC:MF5715, Generic Letter 2008-01, Managing Gas Accumulation (Open)
Initiation Request Acceptance Supplement Administration Questions 1 June 2015 2 October 2015 Answers 16 July 2015 30 July 2015 Results Approval... Other:
MONTHYEAR2015-04-25 [Table View]

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