Text

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:	Mark D. Sartain; 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. DAminion Rope Ferry Rd., Waterford, CT 06385 D Mailing Address: P.O. Box 128 Waterford, CT 06385 dorn.con JAN 15 2015 U. S. Nuclear Regulatory Commission Serial No.: 15-012 Attention: Document Control Desk NL&OS/WDC: RO Washington, DC 20555-0001 Docket Nos.: 50-336 50-423 License Nos.: DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 PROPOSED LICENSE AMENDMENT REQUESTS TO ADOPT TSTF-523, REVISION 2, GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) is submitting a request for an amendment to the Technical Specifications (TS) for Millstone Power Station Unit 2 (MPS2) and Millstone Power Station Unit 3 (MPS3). The proposed amendments would modify TS requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in Technical Specifications Task Force (TSTF)-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." In DNC letter 09-790, dated January 14, 2010, DNC committed to evaluate the Nuclear Regulatory Commission (NRC)-approved TSTF traveler for applicability to MPS2 and MPS3 and, if a license amendment was determined to be necessary, to submit a license 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. The marked-up MPS2 TS Bases pages are provided for information only. The changes to the affected MPS2 TS Bases pages will be incorporated in accordance with the TS Bases 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. The marked-up MPS3 TS Bases pages are provided for information only. The changes to the affected MPS3 TS Bases pages will be incorporated in accordance with the TS Bases 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 has reviewed and concurred with the determinations herein.

Serial No.15-012 Docket Nos. 50-336/423 Page 2 of 3 Approval of the proposed amendments is requested by January 31, 2016. Once approved, the amendments shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the State of Connecticut.

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

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering STATE OF CONNECTICUT

)

COUNTY OF NEW LONDON The 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 has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, 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 ./6 THOMAS CLEARY __-___"_- _

NOTARY PUBLIC Notary Public MY COMMISSION EXPIRES FE BRUARY 28, 2016 Commitments contained in this letter: None Attachments:

1. MPS2 Description and Assessment of Technical Specification Change

2. MPS2 Marked-Up Technical Specifications Pages

3. MPS2 Technical Specifications Bases Pages - For Information Only

4. MPS3 Description and Assessment of Technical Specification Change

5. MPS3 Marked-Up Technical Specifications Pages

6. MPS3 Technical Specifications Bases Pages - For Information Only

Serial No.15-012 Docket Nos. 50-336/423 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 Mohan C. Thadani NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 B-1 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATION CHANGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.15-012 Docket Nos. 50-336/423 Attachment 1, Page 1 of 4 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification to the Technical Specifications (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 is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

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. This review 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 has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to Millstone Power Station Unit 2 (MPS2) and justify this amendment for the incorporation of the changes to the MPS2 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 gas management program. Currently, the gas monitoring program requires monitoring on a quarterly frequency. The existing surveillance frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation. Based on plant experience, the existing surveillance frequency of at least once per 92 days has been deemed acceptable per the gas monitoring program.

Serial No.15-012 Docket Nos. 50-336/423 Attachment 1, Page 2 of 4

2. 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 title 3.4.1.3, RCS - Hot Shutdown 3.4.6, RCS Loops - MODE 4 3.4.1.4, RCS - Cold Shutdown - Loops 3.4.7, RCS Loops - MODE 5, Loops Filled Filled 3.4.1.5, RCS - Cold Shutdown - Loops Not 3.4.8, RCS Loops - MODE 5, Loops Filled Not Filled 3.5.2, ECCS Subsystems - Tavg >300°F 3.5.2, ECCS - Operating 3.5.3, ECCS Subsystems - Tavg <300°F 3.5.3, ECCS - Shutdown 3.6.2, Depressurization And Cooling 3.6.6A Containment Spray and Systems - Containment Spray And Cooling Systems (Atmospheric and Cooling Systems Dual) 3.9.8.1, Refueling Operations - Shutdown 3.9.4, Shutdown Cooling (SDC) and Cooling And Coolant Circulation - High Coolant Circulation - High Water Water Level Level 3.9.8.2, Refueling Operations - Shutdown 3.9.5, Shutdown Cooling (SDC) and Cooling And Coolant Circulation - Low Coolant Circulation - Low Water Water Level Level These differences are administrative and do not affect the applicability of TSTF-523 to the MPS2 TS.

3.0 REGULATORY ANALYSIS

3.1 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 programs provide operating requirements.

The traveler and model safety evaluation discusses the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (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 comply with the intent of the newer GDC to the extent possible, recognizing previous design commitments. MPS2 FSAR Section 1.A "AEC General Design Criteria for "Nuclear Power Plants," provides an assessment against the 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants". A review has determined that the MPS2 plant-specific requirements are sufficiently similar to the Appendix A, GDC as related to the proposed change. Therefore, the proposed change is applicable to MPS2.

Serial No.15-012 Docket Nos. 50-336/423 Attachment 1, Page 3 of 4 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 to the standard technical specifications (STS), into the Millstone Power Station Unit 2 technical specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

DNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises or adds Surveillance Requirement(s) (SRs) that require verification that the Emergency Core Cooling System (ECCS), Shutdown Cooling (SDC) System, and the Containment Spray System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and 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 of accident 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 to accumulated gas and provide allowances which permit performance of the revised verification. 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 the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The

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

Therefore, the proposed change does not create the possibility of a new or different kind of 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 to accumulated gas and provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins 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 safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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 of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, 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), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

June 28, 2006 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWN linformati LIMITING CONDITION FOR OPERATION 3.4.1.3 Two loops or trains consisting of any combination of reactor coolant loops or shutdown cooling trains shall be OPERABLE and one loop or train shall be in operation.

NOITlS All reactor coolant pumps and 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 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 of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.1; and

b. core outlet temperature is maintained at least 10°F below saturation temperature.

2. The following restrictions apply when starting the first reactor coolant pump and any RCS cold leg temperature is < 275°F. The first reactor coolant pump shall not be started unless:

a. pressurizer water level is < 43.7%;

b. pressurizer pressure is < 340 psia; and

c. secondary water temperature in each steam generator is < 507F above each RCS cold leg temperature.

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

Immediately initiate action to restore a second reactor coolant loop, or one shutdown 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 one reactor coolant loop to OPERABLE status, and be in COLD SHUTDOWN within 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, OR no reactor coolant loop or shutdown cooling train in operation:

Immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of LCO

3. 1.1 and immediately initiate action to restore one reactor coolant loop or one shutdown cooling train to OPERABLE status and operation.

MILLSTONE - UNIT 2 3/4 4-1b Amendment No. 69, 2-19, 249, 293

September 14, 2000 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION HOT SHUTDOWN SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump, if not in operation, shall be determined OPERABLE once per 7 days 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 the secondary 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, Note 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 4.4.1.3.4 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.

MILLSTONE - UNIT 2 3/4 4-1c Amendment No. 69, 24-9

June 28, 2006 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - REACTOR COOLANT SYSTEM LOOPS FILLED Information y LIMITING 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; OR

b. The secondary side water level of each steam generator shall be > 10% narrow range.

NOTES I 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 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.11. 1.; and

b. core outlet temperature is maintained at least 10'F below saturation temperature.

3. The following restrictions apply when starting the first reactor coolant pump and any RCS cold leg temperature is *< 275'F. The first reactor coolant pump shall not be started unless:

a. pressurizer water level is < 43.7%;

b. pressurizer pressure is < 340 psia; and

c. secondary water temperature in each steam generator is < 50'F above each 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 for surveillance testing provided the other shutdown cooling train is OPERABLE and in operation.

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

MILLSTONE - UNIT 2 3/4 4-1d Amendment No. 249, 293

Jul 1 1 .. 2--, 2v06 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - REACTOR COOLANT SYSTEM LOOPS FILLED LIMITING 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 either restore a second shutdown cooling train to OPERABLE status or restore steam generator 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 with boron concentration less than required to meet SDM of LCO 3.1.1.1 and /

immediately initiate action to restore one shutdown cooling train to OPERABLE 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 power available.

4.4.1.4.2 The required steam generators shall be determined OPERABLE, by verifying the secondary 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

,\-trains 4.4.1.4.4 be verifiedsusceptible shallLocations to be sufficiently filled with Water to gas accumulation in at theleast onceshutdown required per 92 days.I cooling MILLSTONE - UNIT 2 3/4 4-1 e Amendment No. _249, June 28, 2006 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - REACTOR COOLANT SYSTEM LOOPS NOT FILLED Information only LIMITING CONDITION FOR OPERATION 3.4.1.5 Two shutdown cooling trains shall be OPERABLE and one shutdown cooling train shall be in operation.

NOTES

1. 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 when switching from one train to another provided:

a. no operations are permitted that would cause introduction of coolant into the RCS with boron concentration less than required to meet the SDM of LCO 3.1.1.1;

b. core outlet temperature is maintained at least 10F below saturation temperature; and

c. no draining operations to further reduce Reactor Coolant System water volume are permitted.

3. The following restrictions apply when starting the first reactor coolant pump and any RCS cold leg temperature is < 275°F. The first reactor coolant pump shall noit be started unless:

a. pressurizer water level is < 43.7%;

b. pressurizer pressure is < 340 psia; and

c. secondary water temperature in each steam generator is < 50'F above eaca RCS 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 in operation.

APPLICABILITY: MODE 5 with Reactor Coolant System loops not filled.

ACTION: a. With one shutdown cooling train inoperable, immediately initiate action to restore 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 with boron concentration less than required to meet SDM of LCO 3.1 .1.1 and immediately initiate action to restore one shutdown cooling train to OPERABLE status and operation.

MILLSTONE - UNIT 2 3/4 4-1f Amendment No. 249, 293

Se-ptemb 14,

- 2900 REACTOR COOLANT SYSTEM COOLANT LOOPS AND COOLANT CIRCULATION COLD SHUTDOWN - REACTOR COOLANT SYSTEM LOOPS NOT FILLED SURVEILLANCE 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 power available.

4.4.1.5.2 One 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 .

4.4.1.5.3 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.

MILLSTONE - UNIT 2 3/4 4-1-M Amendment No.--94-91

EMERGENCY CORE COOLING SYSTEMS -------------..... NOTE ---------------

SURVILLNCEEQUIREMNTSNot required to be rnet for system vent flow paths opne une administratve control.

PERA B LE :

acswt t m hall be demonstrated O 4 .5:

a, t least once per 31 days by verifying each Emergency Core Cooling System manual, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the 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 Position 2-SI-306 Shutdown Cooling Open*

Flow Control 2-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 the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5.

d. By verifying the developed head of each low pressure safety injection pump at the flow test point is greater than or equal to the required developed head when tested pursuant 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 to Specification 4.0.5.

f. At least once per 18 months by verifying each Emergency Core Cooling System automatic valve in 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.

g. At least once per 18 months by verifying each high pressure safety injection pump and low pressure safety injection pump starts automatically on an actual or simulated actuation signal.

MILLSTONE - UNIT 2 314 5-4 Amendment No. &-2,4-59, 2-36,-2-8 September 18, 2007 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

h. At least once per 18 months by verifying each low pressure safety injection pump stops automatically on an actual or simulated actuation signal.

i. By verifying the correct position of each electrical and/or mechanical position stop for 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 the containment sump that each Emergency Core Cooling System subsystem suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.

k. At least once per 18 months by verifying the Shutdown Cooling System open permissive interlock prevents the Shutdown Cooling System inlet isolation valves from being opened with an actual or simulated Reactor Coolant System pressure signal of> 300 psia.

1. At least once per 92 days by verifying that ECCS locations susceptible to N gas accumulation are sufficiently filled with water.

MILLSTONE - UNIT 2 3/4 5-5 Amendment 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 SYSTEMS ECCS SUBSYSTEMS - _Trk. < 300°F LIMITING 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 4 for the high pressure safety injection pump that is inoperable pursuant to Specification 3.4.9.3 provided the high pressure safety injection pump is restored to OPERABLE status within 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 trip pushbuttons.

3. In MODE 4, the OPERABLE HPSI pump is not required to start automatically on a SIAS.

Therefore, the pump control switch for this OPERABLE pump may be placed in the pull-to-lock position without affecting the OPERABILITY of this pump.

APPLICABILITY: MODES 3* and 4.

ACTION:

a. With no high pressure safety injection subsystem OPERABLE, restore at least one high pressure safety injection subsystem to OPERABLE status within one hour or be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

b. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Coimmalission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

SURVEILLANCE REQUIREMENTS 4.5.3.1 The high pressure safety injection subsystem shall be demonstrated OPERABLE per the applicable portions of Surveillance Requirements 4.5.2.a, 4.5.2.b, 4.5.2.c, 4.5.21, 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, 3-2 . 6-,

Marchi 16,2006-CONTAINMENT SYSTEMS 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS CONTAINMENT SPRAY AND COOLING SYSTEMS LIMITING CONDITION FOR OPERATION 3.6.2.1. Two containment spray trains and two containment cooling trains, with each cooling train consisting of two containment air recirculation and cooling units, shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3*.

ACTION:

Inoperable Equipment Required ACTION

a. One containment a.1 Restore the inoperable containment spray train to spray train OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce pressurizer pressure to less than 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 to cooling train OPERABLE status within 7 days or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. One containment c.1 Restore the inoperable containment spray train or the spray train inoperable containment cooling train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in HOT SHUTDOWN within the next AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

One containment cooling train

d. Two containment d.1 Restore at least one inoperable containment cooling train to cooling trains OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in HOT SHUTDOWN 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, power pperated, 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 4-

NOTE ---------------------------- "29-

*__*Not required to be met for system vent flow paths**

" :opened under administrative control."

March 3, t7-2g CONTAINMENT SYSTEMS SURVEILLA,,.CE REQUIREMENTS (Continued)

b. By verifying the developed head of each containment spray pump at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5.

c. At least once per 18 months by verifying each automatic containment spray valve in 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 starts automatically on an actual or simulated actuation signal.

e. By verifying each spray nozzle is unobstructed following activities that could cause 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 and cooling unit in slow speed for> 15 minutes.

b. At least once per 31 days by verifying each containment air recirculation and cooling unit cooling water flow rate is > 500 gpm.

c. At least once per 18 months by verifying each containment air recirculation and cooling unit starts automatically on an actual or simulated actuation signal.

f. At least once per 92 days by verifying the Containment Spray System locations susceptible to gas accumulation are sufficiently filled with water.

MILLSTONE - UNIT 2 3/4 6-13 Amendment No. 2-14, 2-83, 43-

june -28,2&00&

REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION - HIGH WATER LEVEL LIMITING 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 RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1 j and the loading of irradiated fuel assemblies in the core; and

b. Immediately initate action to restore one shutdown cooling train to OPERABLE status and operation; and

c. 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; and

2. Close at least one personnel airlock door; and

3. 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 v7-'~1 4.9.8.1 One shutdown cooling train shall be verified to be in operation and circulating reactor coolant 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 cooling trttrains shall be verified to be sufficiently filled with water at least once per 92 days, MILLSTONE - UNIT 2 3/4 9-8a. Amendment No. 7-l-, 4-8-5, 2249, 28.4,

iT.... 28, 2066 REFUELING OPERATIONS SHUTDOWN COOLING AND COOLANT CIRCULATION - LOW WATER LEVEL LIMITING CONDITION FOR OPERATION (continued)

c. Each penetration providing direct access from the containment atmosphere f1 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 reactor coolant 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 power available.

_4.9.8.2.3 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.

MILLSTONE - UNIT 2 3/4 9-8c Amendment No. 293 --

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 3 MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGES FOR INFORMATION ONLY DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 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, heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to determine RCS temperature. In addition, sufficient portions of the Reactor Building Closed Cooling Water (RBCCW) and Service Water (SW) Systems shall be OPERABLE as required to provide cooling to the SDC heat exchanger. The flow path starts at the RCS hot leg and is returned to 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 as the SDC pump;

4. The associated service water loop from the same facility as the SDC pump; and

5. All valves required to support SDC System operation are in the required position or 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 headers and 2 SW headers are required to support the SDC heat exchangers, consistent with the requirements 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, and RBCCW heat exchanger capable of cooling the associated SDC heat exchanger;

4. A SW pump, powered from the same facility as the SDC pump, capable of supplying cooling water to the associated RBCCW heat exchanger; and 5, All valves required to support SDC System operation are in the required position or are capable of being placed in the required position MILLSTONE - UNIT 2 B 3/4 4-1aaeiby- tri 6 Amendment No. 50, 66, 69, 4-3-9, 2-4g, 249,

3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 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 RBCCW headers are required to provide cooling to the SDC heat exchangers, but only 1 SW header is required to support the SDC trains, The equipment specified is sufficient to address a single active 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 these 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 event 125-volt D.C. power is lost. Consistent with the bases for LCO 3.8.2.4, the 125-volt D.C. support system operability requirements for both trains of SDC are satisfied in MODE 5 with at least one 125-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 provides adequate flow to ensure mixing, prevent stratification and produce gradual reactivity changes during boron concentration reductions in the Reactor Coolant System. The reactivity change rate associated 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 RCS cold legs < 275°F and in MODE 5 are provided to prevent RCS pressure transients, caused by energy additions from the secondary system, which could exceed the limits of Appendix G to 10 CFR Part 50. The RCS will be protected against overpressure transients and will not exceed the limits of Appendix G by:

1. Restricting pressurizer water volume to ensure sufficient steam volume is available to accomnodate the insurge;

2. Restricting pressurizer pressure to establish an initial pressure that will ensure system pressure does not exceed the limit; and

3. Restricting primary to secondary system delta-T to reduce the energy addition from the secondary system.

If these restrictions are met, the steam bubble in the pressurizer is sufficient to ensure the Appendix G limits will not be exceeded. No credit has been taken for PORV actuation to limit RCS 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 unfilled SDC 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 of the required SDC train(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of SDC System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate 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 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 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 volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent 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 System locations susceptible to gas accumulation and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The operating SDC pump and associated piping are exempted from this surveillance requirement, in that the operating train is self venting/flushing.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation in the SDC piping and the procedural controls governing system operation. Based on plant experience, 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 rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

BASES 3/4.5.1 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 allowed completion times are reasonable, based on operating experience, to reach the required plant condition 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 OPERABLE with 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 .a requirements, the valve operator is considered to be the valve motor and not the motor control circuit. Removing the closing coil while maintaining the breaker closed meets the intent of the Technical 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) meets the Technical Specification because it prevents energizing the valve operator to position the valve in the close direction.

Opening the breaker, in lieu of removing the closing coil, to remove power to the valve operator is not 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, to verify 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 of one subsystem through any single failure consideration. Either subsystem operating in conjunction with the safety injection tanks is capable of supplying sufficient core cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from 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)

BASES 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS (continued)

Surveillance Requirement 4.5.2,a verifies the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths to provide assurance that the proper flow paths will exist for ECCS operation. This surveillance does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be hi the correct position prior to locking, sealing, or securing. A valve that receives an actuation 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 valve manipulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. The 31 day frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train. This frequency has been shown to be acceptable through operating experience. -nsert Surveillance Requirement 4.5.2.b verifies proper valve position to ensure that the flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removing power to the valve operator ensures that the valves cannot be inadvertently misaligned or change position as the result of an active failure. A 31 day frequency is considered reasonable in view of other administrative 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 the ECCS 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 the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OMI Code). This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic 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 is greater than or equal to the performance assumned in the umit safety analysis. The surveillance requirements are specified in the Inservice Testing Program. The ASME OM Code provides the activities and frequencies necessary to satisfy the requirements.

Surveillance Requirement 4.5.2.e, which addresses periodic surveillance testing of the charging pumps to detect gross degradation caused by hydraulic component problems, is required by the ASME OM Code. For positive displacement pumps, this type of testing may be accomplished by comparing the measured pump flow, discharge pressure and vibration to their respective acceptance criteria. Acceptance criteria are verified to bound the assumptions utilized in accident analyses. 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 point is greater than or equal to the performance assumed for mitigation of the beyond design basis events. The surveillance requirements are specified in the Inservice Testing Program. The ASME OM Code provides 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-, 2*-3

- Sep er919 4 04--

3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

BASES 3/4.5.2 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 ECCS flow path valve actuates to the required position on an actual or simulated actuation signal (SIAS or 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 secured in the requiied position under administrative controls. The 18 month frequency is based on the need to perform these surveillances under the conditions that apply during a plant outage, and the potential 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 (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 4.5.2.i verifies the high and low pressure safety injection valves listed in Table 4.5-1 will align to the required positions on an SIAS for proper ECCS performance. The safety injection valves have stops to position them properly so that flow is restricted to a ruptured cold leg, ensuring that the other cold legs receive at least the required minimum flow. The 18 month frequency is based on the need to perform these surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the surveillances were performed with the reactor at power. The 18 mnonth frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.

Surveillance Requirement '4.5.2.j addresses periodic inspection of the contaimnent sump to ensure that it is unrestricted and stays in proper operating condition. The 18 month frequency is based 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 abnormal degradation and is confirmed by operating experience.

Surveillance Requirement 4.5.2.k verifies that the Shutdown Cooling (SDC) System open permissive 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 pressure of 300 psia. The suction piping of the SDC pumps (low pressure safety injection puinps) is the SDC component with the limiting design pressure rating. The interlock provides assurance that double isolation of the SDC System firom the RCS is preserved whenever RCS pressure is at or above 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 also

/

acceptable based on consideration of the design reliability (and confimxing operating experience) of the equipment.

<-- lnse-rt C I MILLSTONE1 - UNIT 2 B 3/4 5-2c Amendment No. 45,, 4-8-5, 24-4, 2-,22-0 2-- 236, 2 MPS2 Insert B - ECCS Subsystems Surveillance requirement 4.5.2.a 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 in the control room. This individual will have a method to rapidly close the system vent 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 proper operation of the ECCS and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel Surveillance requirement 4.5.2.1 verifies that the locations susceptible to gas accumulation in the ECCS are sufficiently full of water. Selection of ECCS locations 'susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations.

The design review is supplemented by system walk downs to validate 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 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 ECCS 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 volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent 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 gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the procedural controls governing system operation. Based on plant experience, the Surveillance Frequency of at least once per 92 days is acceptable.

+/-BDC04-vli2-01 CONTAINMENT SYSTEMS BASES 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS The OPERABILITY of the containment spray system ensures that containment depressurization and cooling capability will be available in the event of a LOCA. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in 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 heat removal capacity is available when operated in conjunction with the containment spray system during 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 of taking a suction from the refueling water storage tank on a containmnent spray actuation signal and automatically 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 an OPERABLE shutdown cooling heat exchanger.

The containment cooling system consists of two containment cooling trains. Each containmrent cooling train has two containmnent air recirculationi and cooling units. For the purpose of applying the appropriate ACTION statement, the loss of a single contaimnent air I, 11 recirculation and cooling unit will make the respective containment cooling train inoperable.

Either the containment spray system or the containment cooling system is sufficient to mitigate a loss of coolant accident. The contaimnent spray system is more effective than the containment 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 to mitigate a main steam line break accident inside containment. In addition, the contaimnent spray system 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 containm*.ent spray reflects the dual fumction of containment spray for heat removal and iodine removal.

Surveillance Requirement 4.6.2.1.1 .a verifies the correct aligniment for manual, power operated, 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 not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation 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 valve maniapulation. Rather, it involves verification that those valves capable of being mispositioned are in the correct position. he 31 day frequency is appropriate because the valves are operated under procedural control andj i improper valve position would only affect a single train. This frequency 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) 2-22 2~6, Insert D ] 1G+&ge4-by4NR l ~'2S,'O3

-t-B B R-D

ý1 CONTAINMENT SYSTEMS BASES 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (Continued)

Surveillance Requirement 4.6.2.1. Lb, which addresses periodic surveillance testing of the containment spray pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems, is required by the ASME 0M Code. This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic 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 is greater 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 the activities 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 or simulated 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 month frequency is based on the need to perform these surveillances under the conditions that apply during a plant outage and the potential 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 (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 is unobstructed 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 flow through the nozzles, a major configuration change, or a loss of foreign material control when working within the respective system boundary may require surveillance perfonnance. An evaluation, based on the specific situation, will determine the appropriate method (e.g., visual inspection, 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 and that all associated controls are functioning properly. It also ensures fani or motor failure can be detected and corrective action taken. The 31 day frequency considers the known reliability of the fan 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. 24, 23-6, 2-7, 244,

Insert D - Containment Spray System Surveillance requirement 4.6.2.1.1.a 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 in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

Insert E - Spray Systems Containment Spray 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 of the required containment spray trains and may also prevent water hammer and pump cavitation.

Surveillance requirement 4.6.2.1.1.f verifies that the locations susceptible to gas accumulation in the Containment Spray System are sufficiently full of water. Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate 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 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 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 of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray 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.

Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring Frequency takes into consideration the gradual nature of gas accumulation in the Containment Spray System piping and the procedural controls governing system operation. Based on plant experience, the Surveillance Frequency of at least once per 92 days is acceptable.

REFUELING OPERATIONS BASES 3/4.9.6 DELETED 3/4.9.7 DELETED 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION In MODE 6 the shutdown cooling trains are the primary means of heat removal. One SDC train provides sufficient heat removal capability. However, to provide redundant paths for heat removal either two SDC trains are required to be OPERABLE and one SDC train must be in operation, or one SDC train is required to be OPERABLE and in operation with the refueling cavity water level Ž: 23 feet above the reactor vessel flange. This volume of water in the refueling cavity will provide a large heat sink inthe event of a failure of the operating SDC train. Any exception to these requirements are contained in the LCO Notes.

An OPERABLE SDC train, for plant operation in MODE 6, includes a pump, heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to detennine RCS temperature. In addition, sufficient portions of the Reactor Building Closed Cooling Water (RBCCW) and Service Water (SW) Systems shall be OPERABLE as required to provide cooling to the SDC heat exchanger. The flow path starts at the RCS hot leg and is returned to the RCS cold legs. OPERABLE SDC train consists of the following equipment:

'------* ~Managerment 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 heat exchanger 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; and

5. All valves required to support SDC System operation are in the required position or are capable 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 RBCCW headers are required to' provide cooling to the SDC heat exchangers, but only 1 SW header is required to support the SDC trains. The equipment specified is sufficient to address a single active 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 BASES 3/4.9.8 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. Should these 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 event 125-volt D.C. power is lost. Consistent with the bases for LCO 3.8.2.4, the 125-volt D.C. support system operability requirements for both trains of SDC aye satisfied in MODE 6 with at least one 125-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 support filling the fueling cavity or for performance of required testing. A SDC pump may also be used to transfer water from the refueling cavity to the RWST. In addition, either SDC pump may be aligned to draw a suction on the spent fuel pool (SFP) through 2-RW-1I and 2-SI-442 instead of the normal SDC suction flow path, provided the SFP transfer canal gate valve 2-RW-280 is open under administrative control (e.g., caution tagged). When using this alternate SDC flow path, it will be necessary to secure the SFP cooling pumps, and limit SDC flow as specified in the appropriate 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 after the completion of the fuel shuffle such that approximately one third of the reactor core will contain new fuel. By waiting until the completion of the fuel shuffle, sufficient time (at least 14 days from reactor shutdownf) will have elapsed to ensure the limited SDC flow rate specified for this alternate lineup will be adequate for decay heat removal fiom the reactor core and the spent fuel pool. In addition, CORE ALTERATIONS shall be suspended when using this alternate flow path, 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 the alternate 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 not be 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 the minimum 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 no operations are permitted that would dilute the RCS boron concentration by introduction of coolant into the RCS with boron concentration less than required to meet the minimum boron concentration 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 because MAILLSTONE - UNIT 2 B 3/4 9-2a Amendment No. 69, q-, fl-7, 4-8, , 24G.,

24-, 249, 2-4, 29-3,

-Ae1"i*4.Lge-. By*.*k.

.L- 5U.,

RC JulyX~k 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 of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required SDC loop(s) and may also prevent water hammer, pump cavitation, 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 the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring frequency takes into consideration the gradual nature of gas accumulation in the SDC System piping and the procedural controls governing system operation. Based on plant experience, the Surveillance Frequency of at least once per 92 days is acceptable.

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 4 DESCRIPTION AND ASSESSMENT OF TECHNICAL SPECIFICATION CHANGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.15-012 Docket Nos. 50-336/423 Attachment 4, Page 1 of 5 DESCRIPTION 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 are sufficiently filled with water and to provide allowances which permit performance of the verification 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 is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

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. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-523. As described in the subsequent paragraphs, DNC has concluded that the justifications presented in the TSTF-523 proposal and the model safety evaluation prepared by the NRC staff are applicable to Millstone Power Station Unit 3 (MPS3) and justify this amendment for the incorporation of the changes to the MPS3 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 in Dominion Letter Serial No. 08-0013C, dated October 14, 2008 (ML082890266),

DNC is only proposing SRs for those systems that are susceptible to gas accumulation. 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 an equivalent level in the piping headers located inside containment, the remainder of the vertical headers and the spray rings are maintained dry.

The quarterly pump operability surveillances ensure adequate water volume is 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.15-012 Docket Nos. 50-336/423 Attachment 4, Page 2 of 5 There are no identified gas intrusion mechanisms for this system. Therefore, the QSS piping is free of potential gas voids and a routine surveillance to verify the QSS piping locations susceptible to gas accumulation are sufficiently 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 by design, excluding the ECCS cross connect piping, which is included with the ECCS piping that is susceptible to gas accumulations. The pump and piping fill and self-vent during the course of a loss-of-coolant event and the initial system operation. The RSS will only actuate based on specific actuation signals which will ensure there is adequate water available to meet NPSH requirements. The RSS is maintained dry and designed to fill and self vent.

Since there is no identified gas intrusion mechanism, a routine surveillance to verify the RSS piping locations are sufficiently filled with water is unnecessary.

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

MPS3 TS number and title STS TS number and title 3.4.1.3, RCS - Hot Shutdown 3.4.6, RCS Loops - MODE 4 3.4.1.4 1, RCS - Cold Shutdown - 3.4.7, RCS Loops - MODE 5, Loops Loops Filled Filled 3.4.1.4.2, RCS Cold Shutdown - Loops 3.4.8, RCS Loops - MODE 5, Loops Not Filled Not Filled 3.5.2, ECCS Subsystems - Tavg 3.5.2, ECCS - Operating Greater Than Or Equal To 350°F 3.5.3, ECCS Subsystems - Tavg Less 3.5.3, ECCS - Shutdown Than 350'F 3.9.8.1, Residual Heat Removal and 3.9.5, Residual Heat Removal (RHR)

Coolant Circulation - High Water Level and Coolant Circulation - High Water Level 3.9.8.2, Residual Heat Removal and 3.9.6, Residual Heat Removal (RHR) 3.9..2,ResiualHea Remvaland and Goolant Girculation - Low Water Level Coolant Circulation - low water level Level These differences are administrative and do not affect the applicability of TSTF-523 to the MPS3 TS.

Serial No.15-012 Docket Nos. 50-336/423 Attachment 4, Page 3 of 5

3.0 REGULATORY ANALYSIS

3.1 Applicable Regulatory Requirements The regulations in Appendix A to Title 10 of the Code of FederalRegulations (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 programs provide 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 Design Criteria (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, And Systems," provides an assessment against the 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants" as amended through 1978. A review has determined that the MPS3 plant-specific requirements are sufficiently similar to the Appendix A, GDC as related to the proposed change. Therefore, the proposed change is 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 to the standard technical specifications (STS), into the Millstone Power Station Unit 3 technical specifications (TS). The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water, and to provide allowances which permit performance of the verification.

DNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises or adds Surveillance Requirement(s) (SRs) that require verification that the Emergency Core Cooling System (ECCS) and the Residual Heat Removal (RHR) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any

Serial No.15-012 Docket Nos. 50-336/423 Attachment 4, Page 4 of 5 accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed or revised SRs ensure that the subject systems continue to be capable to perform their assumed safety function and 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 of accident from any accident previously evaluated?

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS and the RHR Systems are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. 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 the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of 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 and the RHR Systems, are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions. The proposed or revised SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins 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 safety as a result of the proposed change.

Serial No.15-012 Docket Nos. 50-336/423 Attachment 4, Page 5 of 5 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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 of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, 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), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 5 MARKED-UP TECHNICAL SPECIFICATION PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

06/28/06 REACTOR COOLANT SYSTEM HOT SHUTDOWN Information only LIMITING CONDITION FOR OPERATION 3.4.1.3 Either: *, **

a. With the Control Rod Drive System capable of rod withdrawal, at least two RCS loops shall be OPERABLE and in operation, or

b. With the Control Rod Drive System not capable of rod withdrawal, at least two loops 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 in operation. 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 initiate corrective action to return the required loops to OPERABLE status as soon as possible; if the remaining OPERABLE loop is an RHR loop, be in COLD SHUTDOWN 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 boron concentration less than required to meet the SDM of LCO 3.1.1.1.2, and (2) core outlet temperature 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 leg temperature 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 water temperature of each steam generator is < 50'F above each RCS cold leg temperature; OR

b. The secondary side water temperature of each steam generator is at or below each RCS cold leg temperature.

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

MILLSTONE - UNIT 3 3/4 4-3 Amendment No. 7-, 4-57-, 19-4, 230

REACTOR COOLANT SYSTEM HOT SHUTDOWN LIMITING CONDITION FOR OPERATION (continued)

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

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

SURVEILLANCE REQUIREMENTS 4.4.1.3.1 The required pump(s), if not in operation, shall be determined OPERABLE at the frequency 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 the Surveillance Frequency Control Program.

4.4.1.3.3 The required loop(s) shall be verified in operation and circulating reactor coolant at the frequency specified in the Suirveillance Frequency Control Program. '

Note 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 4.4.1.3.4 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...

MTLLSTONE - UNIT 3 3/4 4-4 Amendment No. 4-4-5, 4-9-7-, 2-3-0, 2-5 06/28/06 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED Information only LIMITING CONDITION FOR OPERATION 3.4.1.4.1 At least one residual heat removal (RHR) loop shall be OPERABLE and in operation*, and either:

a. One additional RHR loop shall be OPERABLE**, or

b. The secondary side water level of at least two steam generators shall be greater than 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 than required to meet the SDM of LCO 3.1.1.1.2, and (2) core outlet temperature is maintained at least 1 OF below saturation temperature.

b. All RHIR loops may be removed fiom operation. during a planned heatup to MODE 4 when at least one RCS loop is OPERABLE and in operation and when two additional steam generators 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 other RHR 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 water temperature of each steam generator is < 50°F above each RCS cold leg temperature; OR

2. The secondaiy side water temperature of each steam generator is at or below each RCS cold leg temperature.

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

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

MILLSTONE - UNIT 3 3/4 4-5 Amendment No. 47-7, 4-9-7, 230

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS FILLED LIMITING CONDITION FOR OPERATION ACTION:

a. With less than the required RHR loop(s) OPERABLE or with less than the required steam generator water level, immediately initiate corrective action to return the inoperable RHR loop to OPERABLE status or restore the required steam 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 SDM of LCO 3,1.1.1.2 and inmmediately initiate corrective action to return the required RHR loop to operation.

SURVEILLANCE REQUIREMENTS 4.4.1.4.1.1 The secondary side water level of at least two steam generators when required shall be detern-ined to be within limits at the frequency specified in the Surveillance Frequency Control Program.

4.4.1.4.1.2 At least one RHR loop shall be determined to be in operation and circulating reactor coolant 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 the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker alignment and indicated power availability.

4.4.1.4.1.4 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.

MILLSTONE - UNIT 3 3/4 4-5a Amendment No. 4-7-, 4-92-0, 2-5 06/28/06 REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED linformation only I LIMITING CONDITION FOR OPERATION 3.4.1.4.2 Two residual heat removal (RHR) loops shall be OPERABLE* and at least one RHR loop 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 initiate corrective action to return the required RHR loops to OPERABLE status as soon as 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 SDM of LCO 3.1.1.1.2 and inmnediately initiate corrective action to return the required RHR 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 other RHR 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 than required to meet the SDM of LCO 3.1.1.1.2, and (2) core outlet temperatuLre is maintained at least 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 water temperature of each steam generator is < 50°F above each RCS cold leg temperature; OR

2. The secondary side water temperature of each steam generator is at or below each RCS cold leg temperature.

b. All RCS loop wide range cold leg temperatures are

150'F unless the secondary side water temperature of each steam generator is < 50'F above each RCS cold leg temperature.

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

MILLSTONE - UNIT 3 3/4 4-6 Amendment No. 60, 99, 4-5f, 4,--7, 230

REACTOR COOLANT SYSTEM COLD SHUTDOWN - LOOPS NOT FILLED SURVEILLANCE REQUIREMENTS 4.4.1.4,2.1 The required pump, if not in operation, shall be determined OPERABLE at the frequency specified in the Surveillance Frequency Control Program by verifying correct breaker aligmnent and indicated power availability.

4.4.1.4.2.2 At least one RHR loop shall be determined to be in operation and circulating reactor 4

coolant at the frequency specified in the Surveillance Frequency Control Program.

S.44.1.4.2.3 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.

MILLSTONE - UNTIT 3 3/4 4-6a Amendment No. 4-54, +97,-2-F87

February 9, 1995 EMERGENCY CORE COOLING SYSTEMS For Information 1 3/4.5.2 ECCS SUBSYSTEMS - Ta GREATER THAN OR EQUAL TO 350°F LIMITING CONDITION FOR OPERATION 3.5.2 Two independent Emergency Core Cooling System (ECCS) subsystems shall be OPERABLE 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, and

g. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a Safety Injection signal and capable of automatically stopping the RER 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 STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the usage factor for each affected Safety Injection nozzle shall be provided in this Special Report whenever its value exceeds 0.70.

The allowable outage time for each RHR pump/RHR heat exchanger may be extended to 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months for the purpose of pump modification to change mechanical seal and other related modifications. This exception may only be used one time per RHR pump/RHR heat exchanger and is not valid after April 30, 1995.

MILLSTONE - UNIT 3 3/4 5-3 Amendment No. 103

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 a.

Each ECCS subsystem shall be demonstrated OPERABLE:

At the frequency specified in the Surveillance Frequency Control Program by verifying that the following valves are in the indicated positions with power to the y

valve operators removed:

Valve Number Valve Function Valve Position 3SIH*MV8806 RWST Supply to SI Pumps OPEN 3SIH*MV8802A SI Pump A to Hot Leg Injection CLOSED 3SIH*MV8802B SI Pump B to Hot Leg Injection CLOSED 3SIH*MV8835 SI Cold Leg Master Isolation OPEN 3SIH*MV8813 SI Pump Master Miniflow OPEN Isolation 3SIL*MV8840 RHR to I-lot Leg Injection CLOSED 3SIL*MV8809A RHR Pump A to Cold Leg OPEN Injection 3SIL*MV8809B RHR Pump B to Cold Leg OPEN Injection 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 heat exchanger and associated piping, v mtdpa and are sufficiently tilled with water

2) Verifying that each valve (manual, power-operated, or automatic n the flow path that is not locked, sealed, or otherwise secured in position, is in its 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. This vi ual. inspection shall be performed:

1 For all accessible areas of the contaimnent prior to establishing CONTAINMENT INTEGRITY, and At least once daily of the areas affected (during each day) within containment by containmuent entry and during the final entry when CONTAINMENT 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 Reactor Coolant System by ensuring that with a simulated signal greater than or equal 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, 44*,

--.. NOTE ---------------------------------

-.-------- 4-56, 2 a0 , "65{-

Not required to be met for system vent flow paths opened under administrative control.

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

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is greater than or equal to 23 feet.

ACTION:

With no RHR loop OPERABLE or in operation, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.1 and suspend loading irradiated fuel assemblies in the core and immediately initiate corrective action to return the required RHR loop to OPERABLE and operating status as soon as possible. Close all containment penetrations providing direct access fiom 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 at a 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 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8-hour period, provided no operations are permitted that could cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1 .1.

MILLSTONE - UNIT 3 3/4 9-8 Amendment No. 4--7, 2 G.-2-5-8

REFUELING OPERATIONS LOW WATER LEVEL LIMITING CONDITION FOR OPERATION 3.9.8.2 Two independent residual heat removal (RHR) loops shall be OPERABLE, and at least one R-SR loop shall be in operation.*

APPLICABILITY: MODE 6, when the water level above the top of the reactor vessel flange is less than 23 feet.

ACTION:

a. With less than the required R-HR loops OPERABLE, immediately initiate corrective action to return the required RER loops to OPERABLE status, or to establish 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 the boron concentration of LCO 3.9.1 .1 and immediately initiate corrective action to return the required RPHR loop to operation. Close all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.9.8.2 At least one RHR loop shall be verified in operation and circulating reactor coolant at a 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, provided no operations are permitted that could cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.1.

MILLSTONE - UNIT 3 3/4 9-9 Amendment No. 4-0-7, 23-0, 2-5-&

Serial No.15-012 Docket Nos. 50-336/423 ATTACHMENT 6 MARKED-UP TECHNICAL SPECIFICATIONS BASES PAGES FOR INFORMATION ONLY DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

-L-BDCR-N-ot0'M fP3 O5*-05

@&;ia'.25, 2p6-3/4.4 REACTOR COOLANT SYSTEM BASES 3/4.4.1 REACTOR COOLANT LOOPS AND COOLANT CIRCULATION The purpose of Specification 3.4. 1 is to require adequate forced flow rate for core heat removal in MODES 1 and 2 during all normal operations and anticipated transients. Flow is represented by the number of reactor coolant pumps in operation for removal of heat by the steam generators. To meet safety analysis acceptance criteria for DNB, four reactor coolant pumps are required at rated power. An OPERABLE reactor coolant loop consists of an OPERABLE reactor coolant pump in operation providing forced flow for heat transport and an OPERABLE steam generator. 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 loops provide sufficient heat removal capability for removing core decay heat even in the event of a bank 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 Drive System is not capable of rod withdrawal.

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

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 least two 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 the unavailability of the steam generators as a heat removing comiponent, require that at least two RHR loops be OPERABLE.

In MODE 5, during a planned heatup to MODE 4 with all RHR loops removed from operation, an RCS loop, OPERABLE and in operation, meets the requirements of an OPERABLE and operating RHR loop to circulate reactor coolant. During the heatup there is no requirement for heat removal capability so the OPERABLE and operating RCS loop meets all of the required functions for the heatup condition. Since failure of the RCS loop, which is OPERABLE and operating, could also cause the associated steam generator to be inoperable, the associated steam generator cannot be used as one of the steam generators used to meet the requirement of LCO 3.4.1.4.1.b.

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

3/4.4 REACTOR COOLANT SYSTEM BASES (Continued)

The operation of one reactor coolant pump (RCP) or one RHR pump provides adequate flow to ensure mixing, prevent stratification and produce gradual reactivity changes during boron concentration 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 pressure transients. These transients, energy additions due to the differential temperature between the steam generator secondary side and the RCS, can result in pressure excursions which could challenge the P/T limits. The RCS will be protected against overpressure transients and will not exceed the reactor vessel isothermal beltline P/T linmt by restricting RCP starts based on the differential water temperature between the secondary side of each steam generator and the RCS cold 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 in service 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 and the RCS cold legs is based on the equipment providing cold overpressure protection as required by 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 is limited 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 cold overpressure 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 3.4.1.5 The reactor coolant loops are equipped with loop stop valves that permit any loop to be isolated 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 MODES 1-4 with a RCS loop stop valve closed is not permitted except for the mitigation of emergency or abnormal events. If a loop stop valve is closed for any reason, the required ACTIONS of this specification must be completed. To ensure that inadvertent closure of a loop stop valve does not occur, thevalves must be open with power to the valve operators removed in MODES 1, 2, 3 and 4.

MNLLSTONE - UNIT 3 . B 3/44-la AmendmentNo. gO, ,P-, 4-, -- 202,2-7, ,j'

-*B-DC-H--N-0705-.~i*-g--

3/4.4 REACTOR COOLANT SYSTEM BASES (Continued)

Specification 3.4.1.6 Specifications 3.4.1.4.1 and 2 The re rement to maintain the isolated loop stop valves shut with power removed ensures 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 loop CS Loops Filled/Not Filled:

In MODE 5, any RHR train with only one cold leg injection path is sufficient to provide adequate 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 of performing 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 the RCS The definition of "Reactor coolant loops filled" includes a loop that is filled, swept, and vented, 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 steam generators 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. The process of sweep and vent will make the previously OPERABLE loops inoperable and the requirements of LCO 3.4.1.4.2, "Reactor Coolant System, COLD SHUTDOWN -Loops Not Filled," are applicable. When the RCS has been filled, swept and vented using an appro.ed procedure, all unisolated loops may be declared OPERABLE.

The definition of "Reactor coolant loops filled" also includes a loop that has been vacuuim i filled and capable of supporting natural circulation heat transfer. Any isolated loop that has been vacuum 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 957F o Initial RHR temperature is below 184'F MILLSTONE - UNIT 3 B 3/4 4-1ic Amendment No. 24-,

-Aeknwl Vaed041 dgly+R&f+/-e /'

LBDCRNo. 08-MP3-014 October 21, 2008 3/4.4 REACTOR COOLANT SYSTEM BASES (Continued) o The single RHR cold leg injection flow path is not utilized until a minimum of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after reactor shutdown

" CCP flow is at least 6,600 gpm

° RHR flow is at least 2,000 gpm In the above system lineup, total flow to the core is decreased compared to the flow when two cold legs are in service. This is acceptable due to the substantial margin between the flow required 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 point line, indicates there will not be a significant change in the flow rate or distribution through the core, 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 loading standpoint. There are no loads imposed on the piping system which would exceed those experienced in a seismic event. The temperature of the fluid is low and is not significant fr'om a flow erosion standpoint.

The boron dilution accident analysis, for Millstone Unit 3 in MODE 5, assumes a full RIHR System flow of approximately 4,000 gpm. Westinghouse analysis, Reference (1), for RHR flows down to 1,000 gpm, determined adequate mixing results. As the configuration will result in a RHR flow rate only slightly less then 4,000 gpm there is no concern in regards to a boron dilution accident.

The basis for the requirement of two RCS loops OPERABLE is to provide natural circulation heat sink in the event the operating RHR loop is lost. If the RPIR loop were lost, with two 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 be no circulation in the air bound loops, there would be no mechanism for the air in those loops to be carried to the vessel, and subsequently into the filled loops rendering them inoperable for heat sink requirements.

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

o One RHR loop is OPERABLE and in operation, with exceptions as allowed in Technical Specifications; and MILLSTONE - UNIT 3 B 3/4 4-1d Amendment No. 24-7,

Insert A, Bases - RCS Loops Mode 4 During any mode where RHR is required for decay heat removal, management of gas voids is important to RHR System OPERABILITY. RHR 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 of the required RHR loop(s) and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Insert B, Bases - RCS Loops Modes 4 and 5 loops filled or unfilled The RHR 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 volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent 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 of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate 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 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 RHR System locations susceptible to gas accumulation and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval. The operating RHR pump and associated piping are exempted from this surveillance requirement, in that the operating train is self venting/flushing.

The monitoring frequency of the locations that are susceptible to gas accumulation takes into consideration 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 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 rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

3/4.5 EMERGENCY CORE COOLING SYSTEMS BASES 3/4,5.1 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 cold legs in the event the RCS pressure falls below the pressure of the accumulators, This initial surge of 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 single failure criteria, removal of power to the valves is required.

The limits for operation with an accumulator inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occurring concurrent with failure of an additional accumulator which may result in unacceptable pealk cladding temperatures. If a closed isolation valve cannot be immediately opened, the full capability of one accumulator is not available and prompt action is required to place the reactor in a mode where this 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 one subsystem through any single failure consideration. Either subsystem operating ihncnjunction with the accumulators is capable of supplying sufficient core cooling to limit the peal lIadding temperatures within acceptable limits for all postulated break sizes ranging from the doub'l ended break 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 without single failure consideration and with some valves out of normal injection lineup, on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

The Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation System is required to be available to support charging pump operation. The Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation System consists of two redundant trains, each capable 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, the system is capable of automatically transferring operation to the redundant train in the event of a low flow condition in the operating train. The associated fans do not receive any safety related automatic start signals (e.g., Safety Injection Signal).

MILLSTONE - UNIT 3 B 3/4 5-1 AmendmentNo. 4-5-7,

-4a, 2 %56-EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued)

Placing the remote control switch for a Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation Train in the "Off' position to start the redundant train or to perform post maintenance testing to verify availability of the redundant train will not affect the availability of that train, provided appropriate administrative controls have been established to ensure the remote control 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 an approved procedure and a designated individual at the control switch for the respective Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation Train who can rapidly respond to instructions from procedures, or control room personnel, based on plant conditions.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops provide assurance that proper ECCS flows will be maintained in the event of a LOCA. /1 Maintenance 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 the system is in its minimum resistance conifiguration, (2) provide the proper flow split between injection 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 that assumed in the ECCS-LOCA analyses. sufficiently Ilnsert C ->- ... ... " '

Any time the OPERABILITY of an ECCS throttle valve or an ECCS subsyst imhas been affected by repair, maintenance, modification, or replacement activity that alter flow ,nharacteristics, post maintenance 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. The ECCS 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 develop voids 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 ofECCS pumps, 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 demand VENTING the ECCS pump casings and VENTING or Ultrasonic Test (UT) of the accessible suction and discharge piping high points including the ECCS pump suction crossover piping (i.e., downstream of valves 3RSS*MV8837A/B and 3RSS*MV8838A/B to safety injection and charging pump suction). VENTING of the MILLSTONE - UNIT 3 B 3/4 5-2 Amendment No. 4-N0, 7, 447,

EMERGENCY CORE COOLING SYSTEMS BASES ECCS SUBSYSTEMS (Continued) ilnsert E flush upon heat exchanger return to service and procedural compliance is relied upon to ensure 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 be performed at least once daily if the containment has been entered that day and when the final containment entry is made. This will reduce the number of unnecessary inspections and also reduce personnel exposure.

Surveillance Requirement 4.5.2.d.2 addresses periodic inspection of the containment sump to ensure that it is unrestricted and stays in proper operating condition. The surveillance frequency is V controlled under the Surveillance Frequency Control Program. A The Emergency Core Cooling System (ECCS) has several piping cross connection points for use during the post-LOCA recirculation phase of operation. These cross-connection points allow the Recirculation 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 to establish flow from the containment sump through the RSS subsystems to the safety injection and charging 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 will not result in subsystem inoperability (except due to other equipment manipulations to support valve testing) 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 returned to the normal pre-test position following termination of the surveillance testing in response to the accident. Failure to restore any valve to the normal pre-test position will be indicated to the Control Room Operators when the ESF status panels are checked, as directed by the EOPs. The EOPs direct the Control Room Operators to check the ESF status panels early in the event to ensure proper equipment alignment. Sufficient time before the recirculation flowpath is required is expected to be available 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 system independence or redundancy, and both ECCS subsystems will remain OPERABLE.

When performing the quarterly stroke test of 3SHI*MV8923A, the control switch for safety injection pump 3SIH*PlA is placed in the pull-to-lock position to prevent an automatic pump start with the suction valve closed. With the control switch for 3SIH*P1A in pull-to-lock, the Train A ECCS subsystem is inoperable and Technical Specification 3.5.2, ACTION a., applies. This ACTION statement is sufficient to administratively control the plant configuration with the automatic start of 3SIH*PIA defeated to allow stroke testing of 3SIH*MV8923A. In addition, the EOPs 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 the nbrmal 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 does not occur (an acceptable assumption since the Technical Specification ACTION statement limits the plant configuration time such that no additional equipment failure need be postulated). During the injection phase the redundant subsystem (Train B) is fully functional, as is a significant portion of the Train A subsystem. During the recirculation phase, the Train A RSS subsystem can supply water from the containment sump to the Train A

. . MILLSTONE -UNIT 3 B 3/4 5-2b Amendment No. 100, 447, 547

Insert C - ECCS Subsystems Surveillance requirement 4.5.2.b.1 verifies each valve (manual, power-operated, or automatic) in the ECCS flow path that is not locked, sealed, or otherwise secured in position, is verified to be in its 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 in the control room. This individual will have a method to rapidly close the system vent flow path if directed.

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 the ECCS 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 system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate 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 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 ECCS 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 volume of accumulated gas at one or more susceptible locations exceeds an acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent 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 gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 maximurn 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 the results should be sufficient 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 into consideration the gradual nature of gas accumulation in the ECCS Subsystem piping and the procedural controls governing system operation. The surveillance frequency is controlled by the Surveillance Frequency Control Program. The surveillance frequency may vary by each location's susceptibility to gas accumulation.

CONTAINMENT SYSTEMS BASES 3/4.6.1.6 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 is required to ensure that the containmnent will withstand the maximum pressure of 60 psia in the event of a LOCA. A visual inspection, in accordance with the Containment Leakage Rate Testing Program, is sufficient to demonstrate this capability.

3/4.6.1.7 CONTAINMENT VENTILATION SYSTEM The 42-inch containment purge supply and exhaust isolation valves are required to be locked closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA or steam line break accident. Maintaining these valves closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the Containment Purge System. To provide assurance that these containment valves camnot be inadvertently opened, the valves are locked closed in accordance with Standard Review Plan 6.2.4 which includes mechanical devices to seal or lock the valve closed, or prevents power from being supplied to the valve operator.

The Type C testing frequency required by 4.6.1.2 is acceptable, provided that the resilient seats of these valves are replaced every other refueling outage.

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 and 3/4.6.2.2 CONTAINMENT QUENCH SPRAY SYSTEM and RECIRCULATION SPRAY SYSTEM The 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-------

LCO * ---

3.6.Z2. Insert F One Recirculation Spray System consists of:

o Two OPERABLE contailnnent recirculation heat exchangers o Two OPERABLE contairnent recirculation punmps The Containment Recirculation Spray System (RSS) consists of two parallel redundant subsystems which feed two parallel 360 degree spray headers. Each subsystem consists of two pumps and two heat exchangers. Train A consists of 3RSS*PlA and 3RSS*P1C. Train B consists of 3RSS*PlB and 3RSS*PlD.

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

Insert F - Containment Spray System Bases Management 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 system walk downs, the :Containment Quench Spray and Recirculation Spray Systems are not susceptible to gas intrusion. Once the piping in the Containment Quench Spray System is procedurally filled and placed in service for normal operation, no external sources of gas accumulation or intrusion have been identified for the system that would affect spray system operation or performance. Thus, the piping in the Containment Quench Spray Systems will remain sufficiently full during normal operation and periodic monitoring for gas accumulation or intrusion is not required. In the standby mode, the majority of the Recirculation Spray System is dry. The water filled portion of the Recirculation Spray System, which includes the ECCS cross connect piping and loop seals, is monitored with the ECCS piping that is susceptible to gas accumulations

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

APPLICABLE SAFETY ANATYSES If the reactor coolant temperature is not maintained below 200'F, boiling of the reactor coolant could result. This could lead to a loss of coolant in the reactor vessel. Additionally, boiling of the reactor coolant could lead to a reduction in boron concentration in the coolant due to boron plating out on components near the areas of the boiling activity. The loss of reactor coolant and the reduction of boron concentration in the reactor coolant would eventually challenge the integrity of the fuel cladding, which is fission product barrier. One train of the RIR system is required to be operational in MODE 6, with the water level Ž_23 ft above the top of the reactor vessel flange to prevent this challenge. The LCO does permit deenergizing the RHR pump for short 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 Ž_23 ft above the top of the reactor vessel flange, to provide decay heat removal. The 23 ft level was selected because it corresponds to the 23 ft requirement established for fuel movement in LCO 3.9.10, "Water Level - Reactor Vessel." Requirements for the RHR system in other MODES 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 water level < 23 ft are located in LCO 3.9.8.2, "Residual Heat Removal (RHR) and Coolant Circulatfon--Low Water Level."

LIMITING CONDITTON FOR OPERATION d

The requirement that at least one RIR loop in operation ensures that: (1) sufficient cooling capacity is available to remove decay heat an maintain the water in the reactor vessel below 140'F as 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 capable of determining the low-end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs./\

The LCO is modified by a Not( that allows the required operating RHR loop to 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 hour period, provided no operations are permitted that would dilute the RCS boron concentrE tion by introduction of coolant into the RCS with boron concentration less than require( to meet the minimum boron concentration of LCO 3.9.1.1. Boron concentration reduction with c( olant at boron concentrations less than required to assure the RCS boron concentration is maintaii red is prohibited because uniform concentration distribution cannot be ensured without forc nd circulation. This permits operations such as core mapping or alterations in the vicinity of th( reactor vessel hot leg nozzles and RCS to RHR isolation valve testing. During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months peri Sd, decay heat is removed by natural convection to the large mass of water in the refueling cavity L Management of gas voids is important to RHR System OPERABILITY.

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

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

ACTIONS RHR loop requirements are met by having one RHR loop OPERABLE and in operation/ except as permitted in the Note to the LCO.

If RHR loop requirements are not met, there will be no forced circulation to provide mixing to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. 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 of irradiated fuel assemblies in the core. With no forced circulation cooling, decay heat reimoval from 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 adequate available heat sink. Suspending any operation that would increase decay heat load, such as loading 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 satisfy R-R loop requirements. With the unit in MODE 6 and the refueling water level Ž 23 ft above the top 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 from the 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 the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the contaimnent atmosphere. Closing contai*nent penetrations that are open to the outside atmosphere 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 boiling in 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 removal capability 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 BASES 3/4.9.8.2 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 path should be capable of determining the low end temperature. The flow path starts in one of the RCS hot 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 in MODE 6, with the water level < 23 ft above the top of the reactor vessel flange, to provide decay heat removal. Requirements for the RHR System in other MODES are covered by LCOs in Section 3.5, Emergency Core Cooling Systems (ECCS). RPHR loop requirements in MODE 6 with the water level Ž 23 ft are located in LCO 3.9.8.1, "Residual Removal (RHR) AND Coolant Circulation-High Water Level."

ACTIONS

a. If less than the required number of PI-R loops are OPERABLE, actions shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status and to operation, or until >_23 ft of water level is established above the reactor vessel flange. 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 and in operation. An immediate Completion Time is necessary for an operator to initiate corrective action.

b. If no RI-IR loop is in operation, there will be no forced circulation to provide minrng to establish uniform boron concentrations. Suspending positive reactivity additions that could result in failure to meet the minimum boron concentration limit is required to assure continued safe operation. 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 no RHR loop is in operation, actions shall be initiated inunediately, and continued, to restore one 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 the contaimnent 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 RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures that dose limits are not exceeded.

MILLSTONE - UNIT 3 B 3/4 9-6 Amendment No. 44)4, 2-30

-Sepme*

3/4.9 REFUELING OPERATIONS BASES 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 boiling in that tine.

Surveillance Requirement Requirement 4 T-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 removal capability 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 pump suction requirements must be met. The surveillance frequency is controlled under the Surveillance Frequency Control Program.

MILLSTONE - UNIT B 3/4 9-7 Amendment No. 4-G-7, 4-9, 23

Insert G, Bases Refueling Operations - RHR and Coolant Circulation High Water Level RHR 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 of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Surveillance Requirement 4.9.8.1.2 is performed for RHR System locations susceptible to gas accumulation and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring frequency of the locations that are susceptible to gas accumulation takes into consideration 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 Level RHR 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 of the RHR loops and may also prevent water hammer, pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Surveillance Requirement 4.9.8.2.2 is performed for RHR System locations susceptible to gas accumulation and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion 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 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 the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The monitoring frequency of the locations that are susceptible to gas accumulation takes into consideration 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]

ML15021A128

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3.0 REGULATORY ANALYSIS

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