ML13322A415
ML13322A415 | |
Person / Time | |
---|---|
Site: | Millstone ![]() |
Issue date: | 11/06/2013 |
From: | Sartain M D Dominion, Dominion Nuclear Connecticut |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
13-582 | |
Download: ML13322A415 (29) | |
Text
Dominion Nuclear Connecticut, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060 OminiowWeb Address:
www.dom.com November 6, 2013U.S. Nuclear Regulatory Commission Serial No. 13-582Attention:
Document Control Desk NSSL/MAE ROWashington, DC 20555 Docket No. 50-423License No. NPF-49DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3LICENSE AMENDMENT REQUEST.
PROPOSED TECHNICAL SPECIFICATION CHANGES OF THE REFUELING WATER STORAGE TANK ALLOWABLE TEMPERATURES Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requestsamendment to Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3).The proposed changes will revise Technical Specification (TS) 3/4.5.4, "Refueling WaterStorage Tank," and TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment Quench Spray System,"
to provide additional operational margin for control of theRefueling Water Storage Tank (RWST) temperature.
The proposed changes have been reviewed and approved by the Facility Safety ReviewCommittee.
Information provided in the attachments to this letter is summarized below:* Attachment 1 provides Description, Technical Evaluation, Regulatory Evaluation and Environmental Consideration for the proposed Technical Specifications changes.
As discussed in this attachment, the proposed amendment does notinvolve a significant hazards consideration pursuant to the provisions of 10 CFR50.92." Attachment 2 provides marked-up pages of the proposed changes to thetechnical specifications.
" Attachment 3 provides marked-up pages of the proposed changes to theTechnical Specifications Bases for information only. These changes will beimplemented in accordance with the Technical Specification Bases ControlProgram.DNC requests approval of the proposed amendment by November 6, 2014. Onceapproved, the amendment will be implemented within 120 days.In accordance with 10 CFR 50.91(b),
a copy of this license amendment request is beingprovided to the State of Connecticut.
ýxcu Serial No. 13-582Docket No. 50-423Page 2 of 3If you have any questions regarding this submittal, please contact Wanda Craft at (804)273-4687.
Sincerely, Mark D. SartainVice President
-Nuclear Engineering and Development 3 VICKI L. HULLNotary PublicCommonwealth of Virginia140542COMMONWEALTH OF VIRGINIA)
My Commission Expires May 31, 2014COUNTY OF HENRICO )The foregoing document was acknowledged before me, in and for the County andCommonwealth aforesaid, today by Mark D. Sartain, who is Vice President
-NuclearEngineering and Development of Dominion Nuclear Connecticut, Inc. He has affirmed beforeme 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 andbelief.Acknowledged before me this d a y of /r, 2013.My Commission Expires:
4*.4v 31,. 1 .Notary Public Serial No. 13-582Docket No. 50-423Page 3 of 3Commitments made in this letter: NoneAttachments:
- 1. Evaluation of the Proposed Changes2. Marked-up Technical Specifications Pages3. Marked-up Technical Specifications Bases for Information Onlycc: U.S. Nuclear Regulatory Commission Region I2100 Renaissance BlvdSuite 100King of Prussia, PA 19406-2713 J. S. KimProject ManagerMail Stop 08 C2AU.S. Nuclear Regulatory Commission One White Flint North11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power StationDirector, Radiation DivisionDepartment of Energy and Environmental Protection 79 Elm StreetHartford, CT 06106-5127 Serial No. 13-582Docket No. 50-423Attachment 1Evaluation of the Proposed ChangesDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 Serial No. 13-582Docket No. 50-423Attachment 1, Page 1 of 141.0 SUMMARY DESCRIPTION The proposed changes would revise Technical Specification (TS) 3/4.5.4, "Refueling Water Storage Tank," and TS 3/4.6.2.1, "Depressurization and Cooling Systems,Containment Quench Spray System,"
to provide additional operational margin forcontrol of the Refueling Water Storage Tank (RWST) temperature.
2.0 DETAILED DESCRIPTION A. DETAILED DESCRIPTION OF THE PROPOSED CHANGESTS 3/4.5.4, "Refueling Water Storage Tank"* TS requirement 3.5.4.c for the minimum RWST solution temperature would beincreased from 40°F to 420F" TS requirement 3.5.4.d for the maximum RWST solution temperature would beincreased from 50°F to 73°FThe TS requirements would be changed to read as follows:"c. A minimum solution temperature of 420F.d. A maximum solution temperature of 730F."The ACTION statement would also be changed to include the wording "the next."The ACTION would read as follows:"With the RWST inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> orbe in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWNwithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment Quench SpraySystem"In TS requirement 4.6.2.1.a.2, the minimum and maximum RWST water temperature limits would be increased from the current values of 40°F and 500F, respectively tothe new values of 420F to 730F, respectively.
The TS requirement would be changed to read as follows:"2). Verifying the temperature of the borated water in the refueling waterstorage tank is between 420F and 730F."
Serial No. 13-582Docket No. 50-423Attachment 1, Page 2 of 14The proposed change is evaluated in Technical Evaluation, Section 3.0 of thisattachment.
TS Bases 3/4.5.4 Refuelinq Water Storage Tank:TS Bases 3/4.5.4 has been modified to include a discussion on the minimum andmaximum RWST solution temperature limits specified within the TSs. A paragraph was added to identify an operational margin of 2°F (e.g., measurement uncertainties, analytical uncertainties, and design uncertainties) between the TS limits and theactual values used in accident analysis/piping stress analysis.
The actual minimumand maximum RWST solution temperature limits used in the design analysis is 40°Fand 750F, respectively.
The proposed changes to the TS Bases are provided forinformation only and will be implemented in accordance with the TS Bases ControlProgram.B. A DISCUSSION OF CONDITIONS THAT THE PROPOSED AMENDMENT INTENDS TO RESOLVEThe current TS requirements limit RWST temperature between a minimum of 40°Fand a maximum of 50'F. The RWST is the source of water used for the Emergency Core Cooling System (ECCS) and the Quench Spray System (QSS). Each train ofthe ECCS system consists of a charging pump, a High Pressure Safety Injection (HPSI) pump and a Residual Heat Removal (RHR) pump. These systems arecredited for mitigation of design basis accidents as detailed in Table 1 of enclosure 1.The RWST is also used during a refueling outage as the source of water for fillingthe refueling cavity to allow refueling of the core. Following completion of refueling, the water from the refueling cavity is returned to the RWST. While the RWST wateris being used in the refueling cavity, the temperature of the water can increase to ashigh as 1000F. With the RWST containing a minimum of 1,166,000
- gallons, it cantake a significant time for the water to cool from 100°F to the current TS limit of 50'F.This can extend the duration of the refueling outage.In addition, in the summer, cooling is necessary to maintain the RWST temperature below 50'F. A failure of the RWST cooling system during the summer can result inan unplanned shutdown due to exceeding the RWST maximum temperature limit.Thus, a TS change is being proposed to raise the minimum and maximumtemperature limits to 420F and 730F respectively.
These values include a 20Foperational margin (e.g., measurement uncertainties, analytical uncertainties, anddesign uncertainties) from the values used within the accident analysis/piping stressanalysis.
The proposed change provides the opportunity to minimize the risk of anunplanned shutdown in the event of a failure of the RWST cooling system and Serial No. 13-582Docket No. 50-423Attachment 1, Page 3 of 14reduce the refueling outage length. Implementation of this proposed change isscheduled for the fall 2014 refueling outage (3R16).3.0 TECHNICAL EVALUATION 3.1 System Description A. The Refueling Water Storage TankThe RWST is a 59' X 59' stainless steel right circular cylinder that holdsapproximately 1,200,000 gallons of borated water.The RWST supplies borated water for refueling operations.
In addition, theRWST provides borated water to the charging pumps, the safety injection pumps,the RHR pumps, and the containment QSS pumps when a safety injection iswarranted.
The RWST water is aligned directly to the ECCS pumps except thecharging pumps. The suction of the charging pumps is normally aligned to thevolume control tank (VCT) of the chemical and volume control system (CVCS)but will automatically switch alignment from the VCT to the RWST on a safetyinjection signal (SIS).The RWST water is used for core injection and for quench spray, to reducecontainment pressure and temperature and for refueling cavity fill water. TheMillstone Power Station Unit 3 (MPS3) TSs require that a minimum volume ofborated water be available.
This minimum volume (1,166,000 gallons) providesborated water to insure:1. Adequate injection water to meet ECCS design objectives.
- 2. The reactor will remain subcritical with all control rods, except the mostreactive rod cluster control assembly, inserted into the core.3. A sufficient volume of water in the containment engineered safety feature(ESF) sump and recirculation pump suction to permit the initiation ofrecirculation.
A capacitance level probe provides three alarms to the operator:
- 1. High -High overflow at 1,195,000 gal.2. High -stop makeup at 1,189,000 gal.3. Low- start makeup at 1,171,000 gal.Makeup operations to the RWST are manually performed by an operator.
Serial No. 13-582Docket No. 50-423Attachment 1, Page 4 of 14Four differential pressure transmitters are used for level indication at the maincontrol board and auxiliary shutdown panel.Separate level switches provide two safety functions:
" Low -Low -RHR pump trip at 520,000 gallons in conjunction with a SI signal.* Empty -QSS pump trip at <59,718 gallonsAt the setpoint of 520,000 gallons, the remaining inventory in the RWST isdedicated to the QSS pumps while the other ECCS pumps are shifted to therecirculation mode using the water in the containment sump.Current TSs provide temperature limits for the RWST of 40'F minimum and 50°Fmaximum.
In order to meet these temperature requirements, the RWST isequipped with recirculation pumps and coolers.B. RWST Temperature Control SystemA relatively low RWST water temperature is desired to allow each spray waterdroplet to absorb more internal energy from the containment's atmosphere.
Thelower temperature causes an increased quenching effect on containment atmosphere following a LOCA. The RWST temperature control systemmaintains temperature within a band (46-480F) in a normally automatic operation.
Current TS RWST temperature limits are 40°F -50'F. Two RWST recirculation pumps are located in the ESF building on the ground floor adjacent to the RWST.The RWST recirculation pumps will receive an automatic trip signal when theauctioneered highest temperature of the RWST or pump suction drops to 460F.Water from the RWST is provided to the suction of the two refueling waterrecirculation QSS pumps through two air operated valves (AOVs). The twoAOVs are located on the west side of the RWST. The RWST water is pumpedthrough one of two RWST coolers cooled by the Chilled Water System and isreturned to the RWST by a connection to the RWST recirculation flow line.Recirculation through the coolers maintains the desired temperature band.Because the RWST is located outside the ESF building and exposed to theenvironment, exposed connections to the RWST are heat traced to preventfreezing.
The RWST cooling is initiated automatically by starting Recirculation Pump3QSS*P1AIB when RWST temperature reaches approximately 48°F.Recirculation pump operation continues until approximately 460F whereby thepump is automatically secured.
The RWST is insulated thereby limiting theamount of temperature change to less than 0.50F per day. During summerperiods, it is expected that the RWST recirculation pump will be cycling on andoff to maintain temperature.
The only time the RWST tank temperature can Serial No. 13-582Docket No. 50-423Attachment 1, Page 5 of 14approach the new RWST TS upper limit of 73°F is if and when the recirculation pumps are not in service for an extended time or the time immediately aftercoming out of an outage. In the event the recirculation pumps are out of servicefor an extended time, RWST temperature becomes elevated, and temperature stratification does occur, the warmer (less dense) water within the RWST wouldtend to rise. Temperature element 3QSS-TE23 is located relatively high in thetank and thus is most likely the first sensor to read the onset of warmer (lessdense) RWST water. Operations will be reading and responding to this higherRWST water temperature, initiating appropriate actions to ensure the RWST ismaintained below the 730F TS limit.During winter operation, plant operators periodically have to take manual actionto add heat to the RWST. This involves running both recirculation pumps andopening RWST Cooler Return valve 3CDS-TV26 if RWST temperature is lessthan refueling water cooler chilled water supply temperature.
A review ofhistorical plant data for the two RWST temperature sensors revealed that RWSTtemperature does not fall below 450F for both sensors (3QSS-TE23 and 3QSS-TE37) during normal plant operations.
The RWST low temperature alarmsetpoint which is sensed by 3QSS-TE37 (located physically low on the RWST) isbeing increased from 41 OF to 430F. Given the lower elevation of the sensor andassuming temperature stratification is occurring, this low temperature alarm ismore likely to respond earlier than the other sensors due to colder more densewater sinking to the bottom of the RWST. With the existing procedures in placeand the increase in the low temperature alarm setpoint implemented, DNC doesnot consider temperature stratification will be an issue regarding the maintenance of overall RWST bulk temperature to ensure the safety analysis limit of 40°F ismet.3.2 Current Licensing BasesThe MPS3 design was reviewed in accordance with NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Report for Nuclear Power Plants,"SRP 6.2.1.1.A, Rev. 2, July 1981.As noted in the Final Safety Analysis Report (FSAR) Section 3.1, the designbases of MPS3 are measured against the NRC General Design Criteria forNuclear Power Plants, 10 CFR 50, Appendix A, as amended through October 27,1978. The adequacy of the MPS3 design relative to the design criteria isdiscussed in the FSAR Sections 3.1.1 and 3.1.2.The FSAR contains descriptions of the RWST as part of the containment heatremoval system. Table 6.2-61 of the FSAR contains RWST data. As a part ofcontainment heat removal system, the RWST is designed in accordance with thefollowing criteria:
Serial No. 13-582Docket No. 50-423Attachment 1, Page 6 of 141. General Design Criterion 38 with respect to containment heat removal.2. General Design Criterion 39 with respect to inspection of the containment heat removal system.3. General Design Criterion 40 with respect to testing of the containment heatremoval system.4. Regulatory Guide 1.1 as related to the net positive suction head (NPSH)available to the ECCS and containment heat removal system pumps (asclarified by SRP 6.2.2).5. Regulatory Guide 1.26 quality group standards.
The systems are designed inaccordance with ASME III, Class 2 and are designated Safety Class 2.6. Regulatory Guide 1.29 for seismic classification.
The systems are designedto Seismic Category 1.TS requirements associated with the RWST are provided in TS 3/4.5.4,"Refueling Water Storage Tank" and TS 3/4.6.2.1, "Depressurization and CoolingSystems, Containment Quench Spray System" as indicated in Section 2.0(A)above.The current analysis of record was reviewed and approved by the NRC in alicense amendment request (LAR) dated July 13, 2007 (References 1 and 2) fora stretch power uprate to increase rated power from 3411 megawatts thermal to3650 megawatts thermal.
That change required revisions to FSAR Chapter 15,Accident
- Analyses, and FSAR Chapter 6 for the containment analyses.
Theresults of these analyses were provided in the Licensing Report Sections 2.6,Containment Review Considerations, and 2.8, Reactor Systems, of the stretchpower uprate LAR (Reference 1). In anticipation of a request to increase theRWST maximum allowable temperature, a bounding RWST maximumtemperature of 1 00°F was used for the accident analyses submitted andapproved in the power uprate LAR. Details are provided in Licensing ReportSection 2.8 and the maximum containment pressure and temperature analysesprovided in Section 2.6 of that submittal.
While not using 100'F, subsequent analyses have been performed which continue to bound the RWST maximumtemperature of 73TF proposed herein.3.3 Analysis of the Proposed Changes1. TS 3/4.5.4, "Refueling Water Storage Tank":TS requirement 3.5.4.c for the minimum RWST solution temperature would be increased from 40°F to 420F and TS requirement 3.5.4.d for themaximum RWST solution temperature would be increased from 50°F to730F. The proposed changes in RWST solution temperature can bejustified as follows:
Serial No. 13-582Docket No. 50-423Attachment 1, Page 7 of 14To address the impact of raising the maximum RWST temperature onthe performance of the ECCS and QSS systems, engineering designand safety analysis calculations were reviewed to identify the RWSTtemperature assumed in safety analyses.
As described in MPS3 FSAR, Section 6.3.2.2.2, the RWST is used toprovide a sufficient supply of borated water to the safety injection (SI),charging (CHS), and RHR pumps during the injection mode of the ECCSoperation.
The RWST also supplies water to the QSS and providesborated water to fill the refueling cavity for refueling operations.
RWST temperature is a key safety analysis parameter for FSARaccidents that initiate SI and/or the QSS. Enclosure 1, Table 1,identifies the FSAR accidents for which RWST temperature is anassumed analysis parameter, the minimum and maximum RWSTtemperature assumptions, and the SI and/or QSS function that theRWST fluid supports.
Enclosure 1, Table 2, provides the sameinformation for additional safety analysis and design basis calculations that provide input to plant design and programs.
From Tables 1 and 2,the engineering design and programs reviews conclude that:" the minimum RWST temperature operating limit is set by severalsafety analyses that assume 40°F; and" the maximum RWST temperature operating limit is set by a singlesafety analysis that assumes 750F (RSS/QSS piping thermalanalysis described in FSAR Sections 6.2.2 and 6.3.1).ResultsUsing information provided in Enclosure 1, the following table (Table 3in Enclosure 1, Proposed Technical Specification Limits for RWSTTemperature Based on Safety Analysis Limits) summarizes the safetyanalysis and design limits and the supported TS limits with a 2°Foperational margin (e.g., measurement uncertainties, analytical uncertainties, and design uncertainties) which is used to develop plantsurveillance limits.
Serial No. 13-582Docket No. 50-423Attachment 1, Page 8 of 14Minimum RWST Maximum RWSTTemperature Temperature Safety analysis and 40°F 750Fdesign basisSupported TS limits 420F 730Fwhich include a 2°Fmargin from safetyanalysis and designbasis limitsThe evaluations confirm that the Environmental Equipment Qualification (EEQ) program is based on containment response analyses based onat least a 770F RWST temperature and at least an 80'F Ultimate HeatSink (UHS). The FSAR Radiological Consequences Analyses havebeen confirmed to support the proposed change. The NPSH marginwill be maintained for the ECCS and QSS pumps that take suction fromthe RWST following a Safety Injection Actuation Signal or aContainment Depressurization Actuation Signal. The pipe andcomponent stress limits continue to be met for a 750F RWSTtemperature.
Thus, it is concluded that the ECCS and QSS will continue to meetdesign basis requirements.
The proposed change to add the wording "the next" in the ACTIONstatement is administrative and editorial in nature. This change will moreclosely align the current TS ACTION with other MPS3 TS ACTIONs.
Forexample:TS 3.6.1.1 ACTION states: "Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in atleast HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWNwithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."TS 3.6.1.2 ACTION states: "With the containment leakage ratesexceeding the limits, restore the leakage rates to within limits within 1 houror be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLDSHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."2. TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment QuenchSpray System" Serial No. 13-582Docket No. 50-423Attachment 1, Page 9 of 14TS requirement 4.6.2.1.a.2 for the minimum and maximum RWST solutiontemperature would be increased from the current values of 40OF and 50°F,respectively to the new values of 420F to 730F, respectively.
Theproposed changes in the minimum and maximum RWST solutiontemperatures can be justified as discussed in item 1 above.4.0 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Applicable Regulatory Requirements:
In Section 50.36, "Technical specifications,"
of Title 10 of the Code of FederalRegulations (10 CFR), the Commission established its regulatory requirements related to the content of technical specifications.
Pursuant to 10 CFR 50.36(c),
technical specifications are required to include items in the following five specificcategories related to station operation:
(1) safety limits, limiting safety systemsettings, and limiting control settings; (2) limiting conditions for operation; (3)surveillance requirements; (4) design features; and (5) administrative controls.
10 CFR 50.59(c)(1)(i) requires a licensee to submit a license amendment application pursuant to 10 CFR 50.90 if a change to the TS is required.
Furthermore, therequirements of 10 CFR 50.59 necessitate that NRC approve the TS changes beforethe TS changes are implemented.
Specifically, 10 CFR 50.36(c)(2)(ii) requires that a TS limiting condition for operation (LCO) be established for each item meeting one or more of the following criteria:
" Criterion 1: Installed instrumentation that is used to detect, and indicate in thecontrol room, a significant abnormal degradation of the reactor coolant pressureboundary.
" Criterion 2: A process variable, design feature, or operating restriction that is aninitial condition for a design basis accident or transient analysis that eitherassumes the failure of or presents a challenge to the integrity of the fissionproduct barrier." Criterion 3: A structure, system, or component that is part of the primary successpath and which functions or actuates to mitigate a design basis accident ortransient that either assumes the failure of or presents a challenge to the integrity of the fission product barrier.* Criterion 4: A structure, system, or component which operating experience orprobabilistic safety assessment has shown to be significant to public health andsafety.Acceptance Criteria:
The acceptance criteria for the Refueling Water Storage Tank design are based on:
Serial No. 13-582Docket No. 50-423Attachment 1, Page 10 of 141. GDC-38, insofar as it requires that the containment heat removal system(s) function to rapidly reduce the containment pressure and temperature following any LOCA and maintain them at acceptably low levels.2. GDC-39, insofar as it requires that the containment heat removal system shall bedesigned to permit appropriate periodic inspection of important components, such as the torus, sumps, spray nozzles, and piping to assure the integrity andcapability of the system.3. GDC-40, insofar as it requires that the containment heat removal system shall bedesigned to permit appropriate periodic pressure and functional testing to assure(1) the structural and leaktight integrity of its components, (2) the operability andperformance of the active components of the system, and (3) the operability ofthe system as a whole, and, under conditions as close to the design as practical, the performance of the full operational sequence that brings the system intooperation, including operation of applicable portions of the protection system, thetransfer between normal and emergency power sources, and the operation of theassociated cooling water system.4. Regulatory Guide 1.1 as related to the net positive suction head (NPSH)available to the ECCS and containment heat removal system pumps (as clarified by SRP 6.2.2).5. Regulatory Guide 1.26 quality group standards.
The systems are designed inaccordance with ASME Ill, Class 2 and are designated Safety Class 2.6. Regulatory Guide 1.29 for seismic classification.
The systems are designed toSeismic Category 1.4.2 No Significant Hazards Consideration Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requestsamendment to Operating License NPF-49 for Millstone Power Station Unit 3(MPS3). The proposed amendment would revise Technical Specification (TS)3/4.5.4, "Refueling Water Storage Tank," and TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment Quench Spray System" to increase themaximum allowable refueling storage tank (RWST) temperature limit.According to 10 CFR 50.92(c),
a proposed amendment to an operating licenseinvolves no significant hazards consideration if operation of the facility inaccordance with the proposed amendment would not:1. Involve a significant increase in the probability or consequences of anaccident previously evaluated; or Serial No. 13-582Docket No. 50-423Attachment 1, Page 11 of 142. Create the possibility of a new or different kind of accident from any accidentpreviously evaluated; or3. Involve a significant reduction in a margin of safety.In support of this determination, an evaluation of each of the three criteria setforth in 10 CFR 50.92 is provided below regarding the proposed licenseamendment.
- 1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Response:
NoThe proposed change affects the allowable limit for RWST temperature.
Sincethe RWST is a passive component used as a water supply for ECCS and QSSthat operate only following an accident, the proposed change cannot cause anaccident or affect the probability of any accident.
Evaluations have been performed to address the impact of raising the maximumRWST temperature on the performance of the ECCS and QSS. The evaluations demonstrate that NPSH margin would be maintained for the ECCS and QSSpumps that take suction from the RWST following a Safety Injection Actuation Signal or a Containment Depressurization Actuation Signal. Pipe andcomponent stress limits continue to be met at the higher RWST temperature.
Thus, it is concluded that the ECCS and QSS will continue to meet the designbasis requirements.
The FSAR Chapter 15 accident analyses and Chapter 6 containment analyseswere performed assuming an RWST temperature that bounds the proposedtechnical specification change. Thus, the proposed change has no significant impact on the consequences of an accident as documented in the currentanalysis of record.Changing the ACTION statement to include the wording "the next" isadministrative and editorial in nature. This proposed change does not alter theeffective technical content of the ACTION statement.
Thus, it is concluded that the proposed changes do not involve a significant increase in the probability or consequences of any analyzed accident.
Serial No. 13-582Docket No. 50-423Attachment 1, Page 12 of 142. The proposed changes do not create the possibility of a new or different kindof accident from any accident previously evaluated.
Response:
NoThe proposed change only increases the allowable range for the RWSTtemperature.
As such, it cannot initiate a transient or accident.
Evaluations havebeen performed that demonstrate that the ECCS and QSS systems will haveadequate NPSH and the design bases will be met. Thus, the proposed changecannot create the possibility of a new or different kind of accident.
- 3. The proposed changes do not involve a significant reduction in a margin ofsafety?Response:
NoEvaluations have been performed that demonstrate that the ECCS and QSSpumps will maintain NPSH margin when taking suction from the RWST at thehigher temperature limit. The mechanical component stress requirements willcontinue to be met at the higher temperature.
Thus, the ECCS and QSS willcontinue to operate as required to mitigate a design basis accident.
The accident analyses were performed with assumed RWST temperatures thatbound this proposed change. The containment analysis and accident analysesdemonstrate that the design basis requirements are met.Thus, the proposed change does not involve a significant reduction in a margin ofsafety.Conclusion Based upon this discussion, it is concluded that the proposed TS change toincrease the minimum and maximum allowable RWST temperature does notinvolve a significant hazards consideration.
5.0 ENVIRONMENTAL CONSIDERATION DNC has evaluated this proposed license amendment consistent with the criteria foridentification of licensing and regulatory actions requiring environmental assessment inaccordance with 10 CFR 51.21, "Criteria for and identification of licensing andregulatory actions requiring environmental assessments."
DNC has determined thatthis proposed change meets the criteria for categorical exclusion set forth in paragraph (c)(9) of 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring Serial No. 13-582Docket No. 50-423Attachment 1, Page 13 of 14environmental review,"
and has determined that no irreversible consequences exist inaccordance with paragraph (b) of 10 CFR 50.92, "Issuance of amendment."
Thisdetermination is based on the fact that this proposed change is being processed as anamendment to the license issued pursuant to 10 CFR 50, "Domestic Licensing ofProduction and Utilization Facilities,"
which changes a requirement with respect toinstallation or use of a facility component located within the restricted area, as defined in10 CFR 20, "Standards for Protection Against Radiation,"
or which changes aninspection or surveillance requirement and the amendment meets the following specificcriteria:
- 1. The amendment involves no significant hazards consideration.
As demonstrated in Section 4.2 above, "No Significant Hazards Consideration,"
theproposed change does not involve any significant hazards consideration.
- 2. There is no significant change in the types or significant increase in the amounts ofany effluent that may be released offsite.The proposed changes would revise TS 3/4.5.4, "Refueling Water Storage Tank,"and TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment QuenchSpray System."
The proposed changes do not result in an increase in power level,and do not increase the production nor alter the flow path or method of disposal ofradioactive waste or byproducts; thus, there will be no significant change in theamounts of radiological effluents released offsite.Based on the above evaluation, the proposed change will not result in a significant change in the types or significant increase in the amounts of any effluent releasedoffsite.3. There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed change would not result in any changes to the configuration of thefacility.
The proposed changes would revise TS 3/4.5.4, "Refueling Water StorageTank," and TS 3/4.6.2.1, "Depressurization and Cooling Systems, Containment Quench Spray System" which will not cause a change in the level of controls ormethodology used for the processing of radioactive effluents or handling of solidradioactive waste, nor will the proposed amendment result in any change in thenormal radiation levels in the plant. Therefore, there will be no increase in individual or cumulative occupational radiation exposure resulting from this change.
Serial No. 13-582Docket No. 50-423Attachment 1, Page 14 of 1
46.0 REFERENCES
- 1. G. T. Bischof to NRC, "Dominion Nuclear Connecticut, Inc., Millstone PowerStation Unit 3, License Amendment
- Request, Stretch Power Uprate,"
dated July13, 2007. (ML072000386)
- 2. J. C. Lamp to D. A. Christian, "Millstone
- Station, Unit No. 3 -Issuance ofAmendment RE: Stretch Power Uprate,"
Dated August 12, 2008. (ML081610585)
Serial No. 13-582Docket No. 50-423Enclosure 1Enclosure I to Attachment IAdditional Information DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 Serial No. 13-582Docket No. 50-423Enclosure 1 Page 1 of 4Enclosure I to Attachment 1The purpose of this enclosure is to identify the Refueling Water Storage Tank (RWST)temperature values assumed in the accident analysis calculations that support Millstone Power Station Unit 3 (MPS3) Final Safety Analysis Report (FSAR) Chapters 6 and 15. Inaddition, the RWST temperature assumptions are provided for evaluations performed orfacilitated by the safety analysis and used as input for plant design and programs.
As described in MPS3 FSAR, Section 6.3.2.2.2, the RWST is used to provide a sufficient supply of borated water to the safety injection (SI), charging (CHS) and residual heat removal(RHR) pumps during the injection mode of the emergency core cooling system (ECCS)operation.
The RWST also supplies water to the containment quench spray system (QSS) andprovides borated water to fill the refueling cavity for refueling operations.
RWST temperature is a key safety analysis parameter for FSAR accidents that initiate SIand/or QSS. Table 1 identifies the FSAR accidents for which RWST temperature is anassumed analysis parameter, the minimum and maximum RWST temperature assumptions, and the SI and/or QSS function that the RWST fluid supports.
Table 2provides the same information for additional safety analysis and design basis calculations that provide input to plant design and programs.
From Tables 1 and 2, the engineering design and programs reviews conclude that:" the minimum RWST temperature operating limit is set by several safety analysesthat assume 40°F; and" the maximum RWST temperature operating limit is set by a single safety analysisthat assumes 75°F (containment recirculation spray system (RSS) and QSS pipingthermal analysis described in FSAR Sections 6.2.2 and 6.3.1).Table 3 summarizes the safety analysis limits and the supported TS limits which include20F operational margin (e.g., measurement uncertainties, analytical uncertainties, and designuncertainties) from value limits used in accident analysis/piping stress analysis.
The evaluations confirm that the Environmental Equipment Qualification (EEQ) program isbased on containment response analyses for at least 770F RWST and at least 80°FUltimate Heat Sink (UHS). The FSAR Radiological Consequences Analyses have beenconfirmed to support the proposed change.Mechanical design calculations were reviewed and confirmed that the net positive suctionhead (NPSH) margin will be maintained for the ECCS and QSS pumps that take suctionfrom the RWST following a Safety Injection Actuation Signal or a Containment Depressurization Actuation Signal. The pipe and component stress limits are met for amaximum RWST temperature of 750F.Thus, it is concluded that the ECCS and QSS system will continue to meet design basisrequirements.
Serial No. 13-582Docket No. 50-423Enclosure 1 Page 2 of 4Table 1: RWST Temperature Assumed in the MPS3 Safety AnalysesFSAR Accident Criterion RWST Temperature Section6.0 Design Basis Containment pressure reduced to 19 psig in SI = 100'F / 770F in LBLOCA Mass andAccident 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; Energy (M&E) Analysis1(DBA) The reduced containment pressure QSS = 770F in LBLOCA Containment maintained following the DBA. Pressure/Temperature Analysis6.1.1.2 Large Break Sump pH due to RWST water boron SI & QSS = 40°F (minimum value)6.2.2 Loss of Coolant concentration.
Accident(LBLOCA)6.2.1.1.2 DBA The internal maximum design pressure is 45 SI = 100°F / 770F in LBLOCA M&E Analysis' psig. QSS = 770F in LBLOCA Containment Pressure/Temperature Analysis6.2.1.1.2 Inadvertent The internal minimum design pressure is QSS = 40°F (minimum value)6.2.1.1.3 QSS 8.00 psia.6.2.1.1.3 LBLOCA Containment Integrity Analysis:
SI = 100°F / 77°F in LBLOCA M&E Analysis' 6.2.1.3 Small Break
- Containment Peak Temperature Pressure and Temperature AnalysisAccident
- Containment Depressurization to yield SI & QSS = 100°F for SBLOCA(SBLOCA) 50% of the design leakage (at Pa) afterone hour.6.2.1.1.3 Steam Line Containment Integrity Analysis:
SI = 100°F in M&E Release6.2.1.4 Break (SLB)
- Containment Peak Pressure QSS = 100°F for containment response* Containment Peak Temperature
- Containment Liner Temperature 6.2.1.5 LBLOCA Peak Cladding Temperature and Cladding QSS = 40°F in minimum containment Oxidation.
pressure response (see also 15.6.5.2) 6.2.2 LBLOCA QSS spray nozzle droplet size QSS = 100'FSBLOCA6.3.2.5 LBLOCA Boric Acid Precipitation.
See 15.6.5.212.3.1.3.2 Post-Accident Shine from RWST piping Boric Acid Solution
< 40°FAccess to VitalAreas15.1.4 SLB Return to Power; N/A for Hot Full Power Case15.1.5 Departure from Nucleate Boiling (DNB). SI = 40°F in Hot Zero Power Case15.1.5 M&E Releases for Radiological SI = 100'FConsequences.
15.2.8 Feedwater Line Overpressurization; SI = 100'FBreak Margin to Hot Leg Saturation.
15.5.1 Inadvertent SI Integrity of the reactor coolant system SI = 40°F (minimum) pressure boundary.
15.6.3 Steam Steam Generator Overfill SI = 40'F (minimum)
Generator Tube Radiological Consequences.
SI = 100'FI Rupture15.6.5.2 LBLOCA Peak Cladding Temperature and Cladding QSS = 40°F for minimum containment Oxidation.
pressure response (see also 6.2.1.5)SI = 40-100°F for core cooling responsePost-LOCA Subcriticality.
SI = 100'FI Post- LOCA long term cooling.
SI = 40-100OF15.6.5.3 SBLOCA Peak Cladding Temperature and Cladding SI = 1000FOxidation.
I Serial No. 13-582Docket No. 50-423Enclosure 1 Page 3 of 4FSAR Accident Criterion RWST Temperature Section15.6.5.4 LBLOCA Radiological Consequences.
QSS = 770F for containment depressurization to yield 50% of the design leakage (at Pa)after one hour.QSS < 40'F for iodine removal coefficient 1 The LBLOCA Mass & Energy Release analyses are performed by Westinghouse for the blowdown, refill and reflood phases using100°F for safety injection.
The NRC approved Dominion GOTHIC containment analysis methodology in DOM-NAF-3-P-A is used forthe post-reflood M&E analysis, and a value of at least 77°F is used for safety injection.
Serial No. 13-582Docket No. 50-423Enclosure 1 Page 4 of 4Table 2RWST Temperatures Assumed in Safety Analyses and Evaluations Supporting MPS3 Plant Design and ProgramsFSAR Accident Criterion RWST Temperature Section .Appendix 3B SLB in Main MSVB pressure and temperature SI = 100°FSteam Valve bounded by EEQ envelopeBuilding(MSVB)4.3.2.1 BORDER Boration requirements with RWST as 100°F for calculation of required RWSTAnalysis boration source volumes6.2.1.1.3 LBLOCA Containment pressures and vapor SI = 100'F / 77°F LBLOCA M&E1SBLOCA temperatures bounded by the EEQ QSS = 770F in LBLOCA Containment SLB envelope.
Pressure/Temperature AnalysisSI & QSS = 1 00°F for SBLOCA and SLBLBLOCA Containment sump temperature for SI = 100'F / 80'F LBLOCA M&E'SBLOCA system piping and components of QSS = 80°F in LBLOCA Containment SumpECCS and containment heat removal Temperature Analysissystems SI = 100°F for SBLOCA6.2.2 LBLOCA QSS/RSS Piping Thermal Analysis SI = 100°F / 75°F LBLOCA M&E'6.3.1 SBLOCA Following a LOCA and SLB QSS = 750F (maximum) for LBLOCASLB SI & QSS = 100'F for SBLOCA and SLB8.1.8 Station Coping Analysis 120 OF for RCS makeupBlackoutN/A Fire Minimum RWST inventory for Safe Boric Acid Solution
= 1 00°FProtection Shutdown (Technical Requirements Manual TR 7.4.1)1 The LBLOCA Mass & Energy Release analyses are performed by Westinghouse for the blowdown, refill and reflood phasesusing 1 00°F for safety injection.
The Dominion GOTHIC containment analysis methodology in DOM-NAF-3-P-A is used for thepost-reflood M&E analysis, and a value of 77°F is used for maximum containment pressure and temperature a value of 80°F isused for maximum sump temperature, a maximum of 75°F is used for QSS/RSS piping thermal analysis calculations.
Table 3Proposed Technical Specification Limits for RWST Temperature Based onSafety Analysis LimitsMinimum RWST Temperature Maximum RWST Temperature Safety Analysis and Design Basis 40°F 75°FSupported TS Limits which include 2°F 420F 730Fmargin from safety analysis and designbasis limits.
Serial No. 13-582Docket No. 50-423Attachment 2Attachment 2Marked-Up Technical Specifications PagesDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 Serial No. 13-582Docket No. 50-423Attachment 2M....h 11, 199iEMERGENCY CORE COOLING SYSTEMS3/4.5.4 REFUELING WATER STORAGE TANKLIMITING CONDITION FOR OPERATION 3.5.4 The refueling water storage tank (RWST) shall be OPERABLE with:a. A contained borated water volume between 1,166,000 and 1,207,000 gallons,b. A boron concentration between 2700 and 2900 mrn of boron,--42Ic. A minimum solution temperature of 4F, andd. A mnaximtun solution temperature of4APPLICABILITY:
MODES 1, 2,.3, and 4.ACTION Ithe nextWith the RWST inop' le, restore the tank to OPERABLE status within I hour or be in at leastHOT STANDBY witlu',6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.5.4 The RWST shall be demonstrated OPERABLE:
- a. At least once per 7 days by:1) Verifying the contained borated water volume in the tank, and2) Verifying the boron concentration of the water.b. At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying the RWST temperature.
MILLSTONE
-UNIT 33/4 5-9Amendment No. 4-1-, 69, Serial No. 13-582Docket No. 50-423Attachment 2CONTAINMENT SYSTEMS3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMSCONTAINMENT OUENCH SPRAY SYSTEMLIMITING CONDITION FOR OPERATION 3.6.2.1 Two independent Containment Quench Spray subsystems shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.ACTION:With one Containment Quench Spray subsystem inoperable, restore the inoperable system toOPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> andin COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.SURVEILLANCE REQUIREMENTS 4.6.2.1 Each Containment Quench Spray subsystem shall be demonstrated OPERABLE:
- a. At least once per 31 days, by:1) Verifying that each valve (manual, power operated, or automatic) ih.theflow path that is not locked, sealed, or otherwise secured in position, is inits correct position; and 42[ 732) Verifying the temperatur if the bo ed water in the refueling waterstorage tank is between 4;'F and 40'F.b. By verifying that each pump's developed head at the test flow point is greater thanor equal to the required developed head when tested pursuant to Specification 4.0.5;c. At least once. per 24 months, by:1) Verifying that each automatic valve in the flow path actuates to its correctposition on a CDA test signal, and2) Verifying that each spray pump starts automatically on a CDA test signal.d. By verifying each spray nozzle is unobstructed following maintenance that could 1,,cause nozzle blockage.
4MILLSTONE
-UNIT.3 3/4 6-12 Amendment No. -5, -54O, 4-00,94,
+22-44-5, 4-W, 2,06, Q.U ,
Serial No. 13-582Docket No. 50-423Attachment 3Attachment 3Marked-Up Technical Specifications Bases Pages for Information OnlyDOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 3 Serial No. 13-582Docket No. 50-423Attachment 3LBDCR Ne. 014 MP3 01i5EMERGENCY CORE COOLING SYSTEMSBASESECCS Subsystems:
Auxiliary Building RPCCW Ventilation Area Temnerature Maintenance:
In MODES 1, 2, 3 and 4, two trains of 4 heaters each, powered from class IE powersupplies, are required to support charging pump OPERABILITY during cold weather conditions.
These heaters are required whenever outside temperature is less than or equal to 17'F.When outside air temperature is below 17'F, if both trains of heaters in the RPCCWVentilation Area are availableto maintain at.least 65'F in the Charging Pump and ReactorComponent Cooling Water Pump arcas of the Auxiliary
- Building, both charging pumps-are OPERABLE for MODES 1, 2 and 3.When outside air temperature is below 17'F, if one train of heaters in the RPCCWVentilation Area is available to maintain at least 32CF in the Charging Pump and ReactorComponent Cooling Water Pump areas of the Auxiliary
- Building, the operating charging pump isOPERABLE, for MODE 4.With less than 4 OPERABLE heaters in either train, the corresponding train of charging is [,inoperable.
This condition will require entry into the applicable ACTION statement for LCOs3.5.2 and 3.5.3.LCO 3.5.2 ACTION statement "b", and LCO 3.5.3 ACTION statement "c" addressspecial reporting requirements in response to ECCS actuation with water injection to the RCS.The special report completion is not a requirement for logging out of the ACTION statements thatrequire the reports.3/4.5.4 REFUELING WATER STORAGE TANKThe OPERABILITY of the refueling water storage tank (RWST) as part of the ECCSensures that a sufficient supply of borated water is available for injection by the ECCS in theevent of a LOCA. The limits on RWST minimum volume and boron concentration ensure that: (1)sufficient water is available within containment to permit recirculation cooling flow to the core,and (2) the reactor will remain subcritical in the cold condition following a large break (LB)LOCA, assuming mixing of the RWST, RCS, ECCS water, and other sources of water that mayeventually reside in the sump, with all control rods assumedto be out. These assumptions areconsistent with the LOCA analyses.
The contained water volume limit includes an allowance for water not usable because oftank discharge line location or other physical characteristics.
The limits on contained water volume and boron concentration of the RWST also ensure a pHvalue of between 7.0 and 7.5 for the solution recirculated within containment after a LOCA. ThispH band minimizes the effect of chloride and caustic stress corrosion on mechanical systems andcomponents.
Th:p ' ' ai'-i' t41r@tu:rak1.
fzr kth R'.'.'SFT M.ODES 4, 2, 3 and 4 I.etased 8ti ..... ." .... ...MILLSTONE
-UNIT 3B 3/4 5-2dAmendment No. 40, 44-7, 4-57,Acklz,':,'l.Jgzd h;' ,NrPC lz.ttr d"atz, pg,'25,'p5 Serial No. 13-582Docket No. 50-423Attachment 3Insert AThe minimum and maximum solution temperatures for the RWST in MODES 1,2, 3 and 4 are based on the following:
The 420F minimum and 73°F maximum solution temperature values identified within the Technical Specifications include an operational margin of 2°F (e.g.,measurement uncertainties, analytical uncertainties, and design uncertainties) from values used in accident analysis/piping stress analysis.
Accidentanalysis/piping stress analysis used 40°F and 750F for the minimum andmaximum RWST solution temperature.