ML17212A083

Final Safety Analysis Report, Rev. 30, Chapter 13, Conduct of Operations

ML17212A083
Person / Time
Site:	Millstone
Issue date:	06/29/2017
From:	Dominion Nuclear Connecticut
To:	Office of Nuclear Reactor Regulation
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References
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Download: ML17212A083 (21)

Text

MPS-3 FSAR Millstone Power Station Unit 3 Safety Analysis Report Chapter 13

Table of Contents tion Title Page ORGANIZATIONAL STRUCTURE ...................................................... 13.1-1

.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION .................................................................................... 13.1-1

.1.1 Initial Design and Operating Responsibilities .......................................... 13.1-1

.1.2 Organizational Arrangement..................................................................... 13.1-5

.2 OPERATING ORGANIZATION ............................................................ 13.1-5

.2.1 Unit Organization ..................................................................................... 13.1-5

.2.2 Assumption of Responsibility................................................................... 13.1-5

.2.3 Operating Shift Crews .............................................................................. 13.1-5

.3 QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL ................. 13.1-5

.3.1 Qualification Requirements ...................................................................... 13.1-5

.3.1.1 Education and experience requirements are established by Section 6.3 of the Technical Specifications.............................................. 13.1-5

.4 REFERENCES ......................................................................................... 13.1-5

.5 QUALITY ASSURANCE PROGRAM DESCRIPTION TOPICAL REPORT. .................................................................................................. 13.1-5 TRAINING PROGRAMS ........................................................................ 13.2-1

.1 REFERENCES ......................................................................................... 13.2-1 EMERGENCY PLANNING .................................................................... 13.3-1

.1 REFERENCES ......................................................................................... 13.3-1 REVIEW AND AUDIT............................................................................ 13.4-1

.1 ONSITE REVIEW.................................................................................... 13.4-1

.2 INDEPENDENT REVIEW ...................................................................... 13.4-1

.3 AUDIT PROGRAM ................................................................................. 13.4-1

.4 INDEPENDENT SAFETY ENGINEERING GROUP FUNCTION (DELETED).............................................................................................. 13.4-1

.5 OTHER REVIEW GROUPS.................................................................... 13.4-1 PLANT PROCEDURES........................................................................... 13.5-1

.1 ADMINISTRATIVE PROCEDURES ..................................................... 13.5-1

.1.1 Conformance with Regulatory Guide 1.33 ............................................... 13.5-1

.1.2 Preparation of Procedures ......................................................................... 13.5-1 13-i Rev. 30

tion Title Page

.1.3 Procedures................................................................................................. 13.5-1

.2 OPERATING AND MAINTENANCE PROCEDURES......................... 13.5-3

.2.1 Operations Department Procedures .......................................................... 13.5-3

.2.1.1 General Operating Procedures .................................................................. 13.5-3

.2.1.2 System Operating Procedures ................................................................... 13.5-4

.2.1.3 Annunciation Response Procedures.......................................................... 13.5-4

.2.1.4 Abnormal Operating Procedures .............................................................. 13.5-4

.2.1.5 Emergency Operating Procedures ............................................................ 13.5-4

.2.1.6 Operations Surveillance Procedures ......................................................... 13.5-4

.2.2 Department Procedures............................................................................. 13.5-5

.2.2.1 Radiation Protection Procedures............................................................... 13.5-5

.2.2.2 Emergency Preparedness Procedures ....................................................... 13.5-5

.2.2.3 Instrumentation and Control Procedures .................................................. 13.5-5

.2.2.4 Condition Based Maintenance Procedures ............................................... 13.5-5

.2.2.5 Chemistry Procedures ............................................................................... 13.5-5

.2.2.6 Radioactive Waste System Procedures..................................................... 13.5-5

.2.2.7 Plant Security Instructions ........................................................................ 13.5-5

.2.2.8 Material Control Procedures ..................................................................... 13.5-6

.2.2.9 Maintenance Procedures ........................................................................... 13.5-6

.2.2.10 Fire Protection Procedures........................................................................ 13.5-6

.2.2.11 Special Procedures .................................................................................... 13.5-6 PHYSICAL SECURITY PLANS............................................................. 13.6-1

.1 REFERENCES ......................................................................................... 13.6-1 13-ii Rev. 30

List of Figures mber Title

-1 Deleted by PKG FSC 01-MP3-013

-1 Control Room Area iii Rev. 30

ORGANIZATIONAL STRUCTURE rmation regarding the organizational structure is presented in Section 1.0 of the Quality urance Program Description (QAPD) Topical Report (Reference 13.1-1).

minion Nuclear Connecticut, Inc. (DNC) is an indirect wholly owned subsidiary of Dominion rgy, which is in turn wholly owned by Dominion Resources, Inc.

majority owner, holding 93.4707 percent of the Millstone 3 nuclear plant, is DNC. The aining 6.5293 percent is owned collectively by other electric utility entities. Their individual ership shares are:

Percent DNC 93.4707 Green Mountain Power Corporation 1.7303 Massachusetts Municipal Wholesale Electric company 4.7990 (Massachusetts Electric) 100.00 Principal Participants in the Millstone 3 license have designated DNC to act as agent and esentative for all of the owners of Millstone 3. DNC is responsible for the design, struction, operation, and fuel management of the unit and is authorized to act as Lead licant in all matters relating to the license.

ECO, formerly named the Millstone Point Company, was responsible for the design and struction of the Millstone Units 1, 2, and 3 nuclear plants. Millstone Units 1 and 2 are owned, rated and/or maintained by DNC.

.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION management and technical support organizations consist of DNC personnel. DNC is onsible for all support and operational activities. DNC is committed to ensuring that it ntains an acceptable organization and adequate resources to provide both on site and off site nical support for the operation of Millstone Units 1, 2 and 3 under both normal and rgency conditions.

.1.1 Initial Design and Operating Responsibilities ign and operating responsibilities are discussed in the following paragraphs in three general ses:

13.1-1 Rev. 30

2. Preoperational activities

3. Technical support for operations

.0.0(1) Design and Construction Activities (Project Phase) ne & Webster Engineering Corporation (SWEC), by contract with NUSCO, provided overall gn and construction for the Millstone 3. Westinghouse Electric Corporation, also by contract h NUSCO, designed and furnished the nuclear steam supply system (NSSS). Administration he contract with Westinghouse was assigned to SWEC. NUSCO, responsible to NNECO for gn and construction of all aspects of the plant, provided varying degrees of direct design olvement in establishing the overall design.

.0.0(1)(a) Site Related Engineering Work h Millstone 3, the third unit built on the site, the various kinds of site related engineering work uired had been completed.

meteorological tower met the requirements of NUREG-0654 prior to the Emergency Plan t-Up Appraisal. Hydrologic studies performed with updated hurricane and storm surge models e used as the design basis for shoreline and intake structure protection from storm wave on. The demography of the surrounding area has been updated to reflect both present ulation and the most recent projections of future growth. Dose estimates for both routine and dental releases have been made using the most recent five-year data base available from the eorological tower and the updated demography. The thermal effects of the condenser cooling er plume on the ecological balance of offshore waters have been extensively studied and the ies documented in annual reports. Using these studies as a baseline, and with the most recent rodynamic and biological models, the combined environmental effects of all three Millstone s have been projected.

details of this completed work are described in Chapter 2. Many of the studies, however, are oing and continuing past the startup of Millstone 3. For example, post-startup verification k was done to compare the hydrodynamic model projections of the three units cooling water me to the plume as it actually occurs in the offshore waters.

-related engineering work in geology and seismology was performed by SWEC and their contractors. Information and reports generated by SWEC were reviewed by NUSCO for eral information and content, as well as for comparison with work previously performed at the

.

.0.0(1)(b) Design of Plant and Ancillary Systems 13.1-2 Rev. 30

uired for their operation.

.0.0(1)(c) Review and Approval of Plant Features EC provided review and approval of plant design features of Millstone 3 in accordance with ngineering procedures. This review was subject to NUSCOs subsequent selective review and roval based upon NUSCOs experience in the design and support of operations for Millstone 1 2 and support of operations for the CY plant. NUSCOs review and approval included rdinated review and concurrence by appropriate personnel of NNECO.

.0.0(1)(d) Site Layout for Environmental Effects and Security Provisions ious figures in Chapter 2 show the location of the meteorological tower, environmental imetry stations, and the pattern of the condenser cooling water plume.

detail description of management responsibilities and control philosophies are included in the urity plan. The implementation schedule for major milestone events for establishing Millstone curity was as follows:

October 18, 1985-Rev. 0 of Security Plan for Millstone 3 became effective November 9, 1985-Security Plan implemented (prior to fuel load)

.0.0(1)(e) Development of Safety Analysis Report paration of the Millstone 3 FSAR was coordinated by NUSCOs Nuclear Licensing Group h support from NUSCO, NNECO, SWEC, and Westinghouse, and was submitted to the NRC upport of the November 1985 fuel load date.

.0.0(1)(f) Review and Approval of Material and Component Specifications EC provided review and approval of material and component specifications in accordance h its engineering procedures. This review was subject to NUSCOs subsequent review and roval selectively based upon NUSCO's experience in the design and support of operations for lstone 1 and 2 and support of operations for the CY plant. NUSCOs review and approval uded coordinated review and concurrence by appropriate personnel of NNECO.

.0.0(1)(g) Procurement of Materials and Equipment SCO procured the NSSS and the turbine generator for the Millstone 3 plant. SWEC procured balance-of-plant materials, components, and systems. NUSCO exercised its right of approval id lists and contract awards for SWEC procured equipment on a selective basis.

.0.0(1)(h) Management and Review of Construction Activities 13.1-3 Rev. 30

tract. To this end, NUSCO maintained from the start of site preparation an on site staff of erienced construction personnel under the direction of the on site NUSCO erintendent--New Site Construction. Provisions for control of construction quality assurance ects are in accordance with Chapter 17.

.0.0(2) Preoperational Activities

.0.0(2)(a) Human Engineering Design Objectives in Control Room Layout EC, under the direction of NUSCO and NNECO, developed human engineering design ctives that would enhance operator effectiveness during normal and abnormal plant rations.

design phase review of the proposed control room layout was an iterative process involving EC, NUSCO, and NNECO. During the review process the original operational design ctives were continually validated to ensure an effective control room work space. NUSCO NNECO remained continually involved in the design review of the control room by review of design documents, utilizing mock-ups, and considerable operating experience from CY and lstone 1 and 2.

.0.0(2)(b) Staff Recruiting and Training Programs staff recruiting program is designed to maintain adequate staffing. The training program is in ordance with Section 13.2.

.0.0(2)(c) Initial Testing development of plans for initial testing were as outlined in Chapter 14, Initial Test Program.

.0.0(2)(d) Plant Maintenance Programs development of the plant maintenance program included the initial staff buildup. In addition, r to initial plant testing the generic mechanical/electrical test procedures were completed and specific equipment and planned maintenance procedures development was initiated.

.0.0(2)(e) Emergency Plan ull-scale emergency preparedness exercise was performed prior to initial start-up.

.0.0(3) Technical Support for Operations organization providing technical support for operations is described in Section 1.0 of the PD Topical Report.

13.1-4 Rev. 30

organizational arrangement is as described in Section 1.0 of the QAPD Topical Report ference 13.1-1).

.2 OPERATING ORGANIZATION

.2.1 Unit Organization unit organizations are as shown in Reference 13.1-1.

.2.2 Assumption of Responsibility he event of unexpected contingencies of a temporary nature, the line of succession of authority responsibility for overall station operation will be delegated in writing in accordance with tion 6.1, Responsibility, of the Technical Specifications.

.2.3 Operating Shift Crews minimum shift crew composition and license requirements during all modes of operation are tained in Section 6.2 of the Technical Specifications.

.3 QUALIFICATIONS OF NUCLEAR PLANT PERSONNEL

.3.1 Qualification Requirements

.3.1.1 Education and experience requirements are established by Section 6.3 of the Technical Specifications.

.4 REFERENCES

.5 Quality Assurance Program Description Topical Report.

13.1-5 Rev. 30

mal training programs have been established to train and qualify the personnel who operate maintain the Millstone nuclear units. These programs are structured to fulfill the requirements 0 CFR 55 and 10 CFR 50.120 using training criteria set forth in ACAD 02-001 (Reference

-1). Descriptions of the training program processes exist in a set of training department uments. The programs are based on a systems approach to training and are accredited by the ional Academy for Nuclear Training. Initial accreditation of these programs was awarded on ust 21, 1986, for operator training and on December 15, 1987, for maintenance and technical ning. These programs are implemented for the following categories of nuclear power plant onnel:

Non-licensed Operator Reactor Operator Senior Reactor Operator Shift Manager Continuing (Requalification) Training for Licensed Personnel Shift Technical Advisor Instrument and Control Technician Electrical Maintenance Personnel Mechanical Maintenance Personnel Chemistry Technician Radiological Protection Technician Engineering Support Personnel

.1 REFERENCES

-1 ACAD 02-001, National Academy for Nuclear Training, The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry.

13.2-1 Rev. 30

staff-approved Millstone Nuclear Power Station Emergency Plan (Reference 13.3-1) resses the criteria set forth in NUREG-0654, FEMA-REP-1, Criteria for Preparation and luation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear er Plants, Revision 1, November 1980 and NUREG-0737, Supplement 1. As such, the ergency Plan provides for an acceptable state of emergency preparedness and meets the uirements of 10 CFR Part 50 and Appendix E thereto.

.1 REFERENCES

-1 J. F. Opeka letter to U.S. Nuclear Regulatory Commission Document Control Desk, transmitting Revision 6 to the Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3, Emergency Plan dated November 9, 1991, and subsequent revisions thereto submitted on an annual basis.

13.3-1 Rev. 30

rogram describing the review and audit of activities important to and affecting station safety ng the operational phase has been established and complies with Regulatory Guide 1.33, Rev.

Quality Assurance Program Requirements (Operation). The program provides a system to ure that these activities are performed in accordance with company policy, rules, and approved cedures.

.1 ONSITE REVIEW ite review is conducted by committee(s) as described in the Quality Assurance Program cription (QAPD) Topical Report.

.2 INDEPENDENT REVIEW ependent review of activities affecting the unit's safety is performed by the Management ety Review Committee, as described in the QAPD Topical Report.

.3 AUDIT PROGRAM audit program for activities affecting safety-related systems, structures, or components is as cribed in the QAPD Topical Report.

.4 INDEPENDENT SAFETY ENGINEERING GROUP FUNCTION (DELETED)

.5 OTHER REVIEW GROUPS er review groups evaluate, on a periodic basis, the effectiveness of the units. These groups are:

pendent consultants, task forces, nuclear industry management assessments, insurance ections, INPO Evaluation and Assistance Division, etc.

13.4-1 Rev. 30

ministrative procedures are written on a department (or common department), unit, and station common station) level. Technical Procedures are written on a unit and department (or common artment) level. These procedures are required for controlling the specifics of station rations, including specifications; maintenance and modification; periodic test, inspection, bration, and special processes; and plant and equipment operation.

.1 ADMINISTRATIVE PROCEDURES

.1.1 Conformance with Regulatory Guide 1.33 ulatory Guide 1.33, Rev. 2, issued February 1978, Quality Assurance Program Requirements, sed as guidance for the preparation of administrative and station procedures.

.1.2 Preparation of Procedures paration, review and approval of procedures is as described in the Quality Assurance Program cription Topical Report.

.1.3 Procedures ministrative Procedures include Department, Unit, and Station Procedures that cover a wide ge of topics. Major areas are described as follows.

nding Orders to Operating Personnel ministrative procedures define the authorities and responsibilities of operating personnel. The cedures specify the number of personnel with reactor operator and senior reactor operator nses required to be on site or at the controls in all plant conditions. (Figure 13.5-1 shows the of the control room which has been designated at the controls.) These procedures contain necessary directives to implement Sections i, j, k, l, and m of 10 CFR 50.54. The inistrative procedures direct the proper maintenance, review, and disposition of operating rds, establish requirements for shift turnover, and establish the authority and responsibilities he person in charge of the control room to limit access. Procedures also direct the assignment hift personnel to duty stations, establish limits for scheduled working hours, provide methods mely and concise feedback of operating experience to applicable plant staff, and describe hods used to verify operational activities are performed correctly. Procedures also provide for t turnover such that all necessary information is properly transmitted to the oncoming shifts.

ne Operations sonnel involved with crane operations over the fuel pool are qualified and conduct crane rations in accordance with ANSI B30.2-1976 (Chapter 2-3), Overhead and Gantry Cranes.

13.5-1 Rev. 30

ht orders can be issued when appropriate to provide guidance to operating shifts. When used, ht orders are of a temporary nature. When appropriate, night orders are incorporated into either ecial procedure or an administrative procedure if the need becomes permanent.

ipment Control Procedures ructions are written to specify proper methods of obtaining clearances on plant equipment for ntenance or construction and to specify procedures for control of jumper, lifted lead, and ass control. The clearance procedure assigns responsibility for clearance issue to the shift ager. A licensed operator, after ensuring he or she is aware of the effect of the activity on the em, is required to authorize all maintenance, tests, and surveillances performed on plant ems. Upon completion of the item, the document is returned to the operator for acceptance or the purpose of returning the system to service. The administrative procedures which control e evolutions provide the required explicit notification of operational personnel whenever a ty related system is removed from and returned to service. The clearance procedure also tains certain restrictions on the issuance of a clearance. The work control procedures for trol of jumper, lifted lead, and bypass control allow temporary alterations to critical structures, ems, or components to facilitate tests, maintenance, or operations. They specify inistrative procedures to be followed in performing such alterations.

trol of Maintenance and Modifications ministrative procedures implement the review and approval requirements for maintenance and difications. These procedures include the control of plant modifications and maintenance on ty-related equipment. These procedures establish a framework of special process and ntenance procedures.

ster Surveillance Testing Schedule administrative work control procedure establishes a master test control list, implements the eillance test program, and assigns responsibility for review and approval of surveillance cedures in accordance with Technical Specifications. Written surveillance procedures are trolled as Department or Common Department procedures.

cedures for Logbook Usage and Control administrative department procedure establishes the requirements for logbook usage and trol.

ntenance and Testing of Safety-Related Systems Work Control Process is used for administratively controlling maintenance and testing of ty-related systems so that prior to the removal of a safety-related system from service, the ited redundant system is verified operable. For equipment that requires specific surveillance 13.5-2 Rev. 30

system from service.

se procedures are reviewed and approved, if necessary, to ensure operability of safety systems r to taking credit for the system(s) to satisfy Technical Specification requirements.

ependent position verification of safety-related components/systems (valves, breakers, and trol switches) with no indication in the control room are performed prior to the return-to-ice of the component/system.

cial Procedures cial procedures are prepared as necessary to support infrequently performed activities which not to be included in the permanent list of procedures. A special procedure can be written for type of procedure (i.e., maintenance, operating, testing). The format of a special procedure is same as the applicable type of administrative or technical procedure. All requirements for ew, approval, revisions, and changes are the same as for permanent procedures.

.2 OPERATING AND MAINTENANCE PROCEDURES rating and maintenance procedures are divided into several categories which are described in following subsections. The list of these procedures is contained in the Master Document ex.

rating and maintenance procedures preparation is the responsibility of the appropriate artment head. When a procedure is written, the applicable department Head/Manager is onsible to forward the procedure for review and approval in accordance with Technical cifications.

nt operations are performed in accordance with written and approved Station and Department cedures.

.2.1 Operations Department Procedures

.2.1.1 General Operating Procedures se procedures cover major plant evolutions. The list of these procedures is controlled by NDM Controlled Document Distribution, and is contained in the Electronic Master Document ex. Step-by-step instructions are provided for the function or task with the appropriate cross rence to system operating procedures for details of specific system operation. Appropriate autions and limitations are included.

13.5-3 Rev. 30

se procedures provide step-by-step details for system operations with appropriate equisites, precautions, and limitations. Each procedure covers the expected modes of ration of the system as well as startup, shutdown, filling and venting, and standby operation as licable. The list of these procedures is controlled by NDM 4, Controlled Document tribution, and is contained in the Electronic Master Document Index.

.2.1.3 Annunciation Response Procedures se procedures provide step-by-step details for appropriate system operation in response to unciators. Annunciator alert plant personnel of a changing conditions which could lead to off mal system performance. The list of these procedures is controlled by NDM 4, Controlled ument Distribution, and is contained in the Electronic Master Document Index.

.2.1.4 Abnormal Operating Procedures ormal Operating Procedures are prepared for abnormal operation of the unit. Abnormal ration is a condition that could degrade into an emergency or could violate Technical cifications if proper action were not taken. These procedures identify the symptoms of the ormal condition, automatic actions that may occur, and the appropriate immediate and sequent operator actions. The list of these procedures is controlled by NDM 4, Controlled ument Distribution, and is contained in the Electronic Master Document Index.

.2.1.5 Emergency Operating Procedures ergency Operating Procedures are prepared for conditions which might possibly lead to injury lant personnel or the public if the release of radioactivity in excess of established limits urs. These procedures include symptoms of the emergency conditions, automatic actions that or should occur, and immediate and subsequent operator actions. All immediate actions are uired to be memorized by the operator since the primary responsibility for detection of an rgency and initiation of corrective action rests upon the operator. Emergency operating cedures are prepared based upon Revision 1B to the Westinghouse Owners Group Emergency delines, and subsequent revision thereto, as implemented pending approval by the NRC. The of these procedures is controlled by NDM 4, Controlled Document Distribution, and is tained in the Electronic Master Document Index.

.2.1.6 Operations Surveillance Procedures se procedures provide step-by-step details for system or component surveillance. These cedures verify the operability of the system or component in accordance with Technical cifications. The list of these procedures is controlled by NDM 4, Controlled Document tribution, and is contained in the Electronic Master Document Index.

13.5-4 Rev. 30

cedures are written by the chemistry, radiation protection, instrumentation and controls, dition based maintenance, security, generation test, maintenance services, material control, lear document services, computer services, engineering and any other group. These cedures control the specific activities of these departments in support of unit or station ration (may be common or unit specific). Station calibration procedures written by the ntenance or Instrument Action and Control departments are also Common or Unit specific cedures.

.2.2.1 Radiation Protection Procedures iation protection procedures support Section 12.5 and 10 CFR 20 requirements.

.2.2.2 Emergency Preparedness Procedures ergency preparedness procedures support and implement the Emergency Plan.

.2.2.3 Instrumentation and Control Procedures rumentation and Control Procedures are prepared for the performance of periodic calibration, ing, and channel checking of safety-related plant instrumentation and all instruments used to sfy technical specification requirements. These procedures ensure measurement accuracies quate to maintain plant safety parameters within operational and safety limits. In addition, rumentation and control procedures outline the periodic calibration and accuracy requirements est equipment necessary to support the calibration of safety related instrumentation.

.2.2.4 Condition Based Maintenance Procedures dition Based Maintenance Procedures are prepared to monitor the condition of safety related balance of plant equipment.

.2.2.5 Chemistry Procedures mistry procedures are prepared covering the routine analysis and sampling methods to ensure pliance with plant chemistry and discharge limits.

.2.2.6 Radioactive Waste System Procedures cedures for operation of radwaste systems are included in system operating procedures.

.2.2.7 Plant Security Instructions s topic is discussed in Section 13.6.

13.5-5 Rev. 30

s topic is covered by administrative procedures in Section 13.5.1.3.

.2.2.9 Maintenance Procedures ntenance procedures are prepared to cover safety-related work which requires a specific nique or sequence not normally part of an individuals routine skill.

procedures support the requirements and programs of Section 13.5.1.3 which covers inistrative control of maintenance.

.2.2.10 Fire Protection Procedures Fire Protection Program is described in Section 9.5.1. The list of these procedures is trolled by NDM 4, Controlled Document Distribution, and is contained in the Electronic ster Document Index.

.2.2.11 Special Procedures s topic is covered by administrative procedures (refer to FSAR Section 13.5.1.3, Special cedures).

13.5-6 Rev. 30

ithheld under 10 CFR 2.390 (d)(1)

.6 PHYSICAL SECURITY PLANS 13.6-1 Rev. 30

MPS-3 FSAR FIGURE 13.1 - 1 DELETED BY PKG FSC 01-MP3-013 FIGURE 13.1-1 WAS REMOVED BY FSARCR 01-MP3-013 Rev. 20.3

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--- MASON RY BLOCK WALLS IN SAFETY-RELATED AREAS FIGURE 13.5-1 CONTROL ROOM AREA MILLSTONE NUCLEAR POWER STATION UNIT 3 * .

FTNAL SAFETY ANALYSIS REPORT Rev. 20.1