Text

License Amendment Request to Revise Technical Specifications to Adopt TSTF-426, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6B & 6C.
	ML14188B189
Person / Time
Site:	Millstone
Issue date:	06/30/2014
From:	Mark D. Sartain; Dominion, Dominion Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	14-072
	Download: ML14188B189 (61)
	v • d • e

Dominion Nuclear Connecticut, Inc. SVu 5000 Dominion Boulevard, Glen Allen, VA 23060 o mlnEon Web Address: www.dom.com June 30, 2014 U.S. Nuclear Regulatory Commission Serial No.14-072 Attention: Document Control Desk NSSL/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2 LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-426, "REVISE OR ADD ACTIONS TO PRECLUDE ENTRY INTO LCO 3.0.3 - RITSTF INITIATIVES 6B & 6C" Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests amendment to Operating License DPR-65 for Millstone Power Station Unit 2 (MPS2).

The proposed amendment would modify Technical Specifications requirements to adopt the changes described in TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c."

The proposed changes have been reviewed and approved by the Facility Safety Review Committee.

Information provided in the attachments to this letter is summarized below:

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. As discussed in this attachment, the proposed amendment does not involve a significant hazards consideration pursuant to the provisions of 10 CFR 50.92.

" Attachment 2 provides marked-up pages to reflect the proposed changes to the technical specifications.

Attachment 3 provides marked-up pages to reflect the proposed changes to the technical specifications bases for information only and will be implemented in accordance with the Technical Specification Bases Control Program.

DNC requests approval of the proposed amendment by June 30, 2015. Once approved, the amendment will be implemented within 120 days.

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.

Roo(

Serial No.14-072 Docket No. 50-336 Page 2 of 3 If you have any questions regarding this submittal, please contact Wanda Craft at (804) 273-4687.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering c~ron*

SCommoflveIh My of Virgfl ofvliom Reg. # 140542 COMMONWEALTH OF VIRGINIA ))

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. 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 ,2014.

My Commission Expires: "k ,A -31, cdoi.,,

d I Notary Public

Serial No.14-072 Docket No. 50-336 Page 3 of 3 Commitments made in this letter: None Attachments:

1. Description and Assessment

2. Marked-up Technical Specifications Pages

3. Marked-up Technical Specifications Bases for Information Only cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 Mohan C. Thadani 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, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.14-072 Docket No. 50-336 Attachment 1 DESCRIPTION AND ASSESSMENT DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 1 of 8 DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

The proposed change provides a short Allowed Outage Time.(AOT) to restore an inoperable system for conditions under which the existing Technical Specifications (TS) require a plant shutdown. The proposed amendment is consistent with TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c." The term AOT is used in lieu of Completion Time (CT) because Millstone Power Station Unit 2 (MPS2) has custom TS and uses NUREG-1432 terminology.

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Dominion Nuclear Connecticut, Inc. (DNC) has reviewed the model safety evaluation dated May 20, 2013 (ML13036A381) as part of the Federal Register Notice of Availability. This review included a review of the Nuclear Regulatory Commission (NRC) staff evaluation, as well as the information provided in TSTF-426, Revision 5, and the referenced Topical Report WCAP-16125-NP-A, Revision 2,"Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown." As described in the subsequent paragraphs, DNC has concluded that the justifications presented in the TSTF-426 proposal and the model safety evaluation prepared by the NRC staff are applicable to MPS2 and can be applied to justify the incorporation of the proposed changes into MPS2 TS.

2.2 Optional Changes and Variations The MPS2 TS uses different numbering and titles than the Standard Technical Specifications (STSs) on which TSTF-426 was based. The following table describes differences between the plant-specific TS numbering and titles used at MPS2 and the TSTF-426 numbering and titles which are based on NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants, Revision 4.0." These differences are administrative and do not affect the applicability of TSTF-426 to the MPS2 custom TS.

The following table also identifies the TSTF-426 TS changes, which are applicable to MPS2 TS. As the table illustrates, the changes proposed by TSTF-426 to STSs 3.6.10, 3.7.12, 3.7.13 and 3.7.15 are not applicable to MPS2 since MPS2 custom TS do not contain corresponding TS.

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 2 of 8 TSTF-426 MPS2 Custom TS TS SYSTEM/COMPONENT TS SYSTEM/COMPONENT 3.4.9 Pressurizer 3/4.4.4 Reactor Coolant System, Pressurizer 3.4.11 Power Operated Relief Valves 3/4.4.3 Reactor Coolant System, Relief (PORV) Valves 3.6.6.A Containment Spray and Cooling 3/4.6.2.1 Containment Systems, System (CSS) (credit taken for Depressurization and Cooling iodine removal) Systems, Containment Spray and Cooling Systems 3.6.8 Shield Building Exhaust Air 3/4.6.5.1 Containment Systems, Cleanup System (SBEACS) Secondary Containment, Enclosure Building Filtration System 3.6.10 Iodine Cleanup System (ICS) No No corresponding TS corresponding TS 3.7.11 Control Room Emergency Air 3/4.7.6.1 Plant Systems, Cleanup System (CREACS) Control Room Emergency Ventilation System 3.7.12 Control Room Emergency Air No No corresponding TS Temperature Control System corresponding (CREATCS) TS 3.7.13 Emergency Core Cooling System No No corresponding TS Pump Room Emergency Air corresponding Cleanup System (ECCS TS

_PREACS) 3.7.15 Penetration Room Emergency Air No No corresponding TS Cleanup System (PREACS) corresponding TS

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 3 of 8 The following table identifies the proposed changes to AOT in accordance with TSTF-426 for the affected MPS2 TS:

TS SYSTEM/COMPONENT CONDITION CURRENT PROPOSED AOT AOT 3/4.4.4 Reactor Coolant Two groups of Class 1E None/ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months System, Pressurizer heaters inoperable LCO 3.0.3 3/4.4.3 Reactor Coolant Two PORVs inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (')

System, Relief Valves and not capable of being cycled manually; or Two block valves inoperable 3/4.6.2.1 Containment Systems, Two containment spray None/ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (2)

Depressurization and trains inoperable (both LCO 3.0.3 Cooling Systems, containment cooling Containment Spray and trains must be operable)

Cooling Systems 3/4.6.5.1 Containment Systems, Two trains inoperable None/ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (3)

Secondary LCO 3.0.3 Containment, Enclosure Building Filtration System 3/4.7.6.1 Plant Systems, Control Two trains inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (4)

Room Emergency, (Modes 1-4) for reasons Ventilation System other than an inoperable boundary (1) Must include verification that the LCO for auxiliary feedwater is met, which requires all three pumps to be operable. In addition, the proposed 8-hour AOT does not apply to PORVs which are leaking and unisolable.

(2) Must include verification that LCO 3.7.6.1, "Control Room Emergency Ventilation System," is met.

(3) Must include verification that at least one train of the containment spray system is operable.

(4) Must include verification that LCO 3.4.8, "Reactor Coolant System, Specific Activity," is met.

For the affected TS, DNC is not proposing any variations or deviations from the TS changes described in TSTF-426, Revision 5 (other than formatting to accommodate the MPS2 custom TS format), or the applicable parts of the NRC staff's model safety evaluation dated May 20, 2013.

The MPS2 accident analyses credit containment spray for iodine removal as discussed in MPS2 Final Safety Analysis Report (FSAR) section 14.8.4.2 and MPS2 TS Bases 3/4.6.2.1.

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 4 of 8 In addition to the above mentioned changes in accordance with TSTF-426, the ACTION statements for the affected TS have been formatted into a two-column table consisting of a column describing the "INOPERABLE EQUIPMENT" and a column describing the "REQUIRED ACTION." The two-column table organizes the conditions and associated actions in a manner that eliminates ambiguity. The format changes are administrative in nature and will not modify any technical aspects of the action requirements. Similar format was used in:

" Technical Specification 3/4.6.2.1 which was approved by the NRC as part of Amendment No. 215, Dated May 26, 1998.

Technical Specification 3/4.8.1.1 which was approved by the NRC as part of Amendment No. 231, Dated March 20, 1999.

Technical Specifications 3/4.1.3.1, 3/4.1.3.5 and 3/4.1.3.6 which were approved by the NRC as part of Amendment No. 280, Dated September 25, 2003.

Technical Specifications 3/4.7.1.2 which was approved by the NRC as part of Amendment No. 297, Dated January 31, 2007.

In order to achieve a transition to the two column format in a manner consistent with NUREG-1432, the following additional changes are proposed:

TS 3/4.4.4:

ACTION b. in the existing custom TS stating "with the pressurizer otherwise inoperable", addresses other conditions rendering the pressurizer inoperable.

Hence ACTION b. encompasses both conditions identified in the LCO: (1) pressurizer water level not within limits, and (2) two groups of pressurizer heaters inoperable. For consistency with TSTF-426 to address the condition of two required groups of pressurizer heaters inoperable, an additional ACTION needs to be identified separately. The following changes are proposed in the two column format:

The original ACTION a. becomes ACTION b.1

The original ACTION b. becomes ACTION a.1 addressing the condition of pressurizer water level not within limit (maintaining the same AOT as the original ACTION b.).

ACTION c.1 is added to address two groups of pressurizer heaters inoperable (using the AOT provided in TSTF-426).

The two column format is now consistent with NUREG-1432.

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 5 of 8 TS 3/4.4.3:

ACTION d. in the existing custom TS addresses two conditions: (1) one block valve inoperable, and (2) two block valves inoperable. For consistency with TSTF-426 to address the ACTION for two block valves inoperable, the two conditions have to be identified separately. The following changes are proposed in the two column format:

" The ACTION for one block valve inoperable becomes ACTIONs d.1 and d.2 (maintaining the same AOT as the original ACTION d.).

The ACTION for two block valves inoperable becomes ACTIONs e.1 and e.2 including the additional requirement of verifying LCO 3.7.1.2 is met and using the AOT provided in TSTF-426.

ACTION c. for two PORVs inoperable and not capable of being manually cycled becomes ACTIONs c.1, c.2, c.3, and c.4 and has been revised to be consistent with TS 3.4.11 ACTION E. of TSTF-426, including the additional requirement of verifying LCO 3.7.1.2 is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and using the AOT of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided in TSTF-426.

TS 3/4.6.2. 1:

The ACTION for two containment spray trains inoperable is added as ACTIONs d.1 and d.2 consistent with TSTF-426.

Original ACTION d.1 is renamed ACTION e.1.

Original ACTION e.1 is renamed ACTION f.1.

TS 3/4.6.5. 1:

The ACTION in the existing custom TS addresses only one Enclosure Building Filtration Train inoperable. TS 3.0.3 becomes applicable for the condition of two Enclosure Building Filtration Trains inoperable. For consistency with TSTF-426 to address the ACTION for two Enclosure Building Filtration Trains inoperable, the ACTION was reformatted as follows:

" Original ACTION for one Enclosure Building Filtration Train inoperable becomes ACTION a. 1 (maintaining the same AOT as the original ACTION).

The ACTION for two Enclosure Building Filtration Trains inoperable becomes ACTIONs b. land b.2, including the additional requirement of verifying one train of containment spray is OPERABLE and using the AOT provided in TSTF-426.

TS 3/4.7.6. 1:

For consistency with TSTF-426 to address the ACTION for two Control Room Emergency Ventilations inoperable, original ACTION b. has been modified. In order

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 6 of 8 to be consistent with TS 3.7.11 ACTION C. as provided in TSTF-426, the following changes are incorporated:

Addition of ACTION b.1 to initiate implementation of mitigating actions.

Addition of ACTION b.2 to verify LCO 3.4.8 is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Addition of ACTION b.3 to restore at least one Control Room Emergency Ventilation to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The AOT is consistent with TSTF-426.

2.3 DNC Verifications The MPS2 TS are not based on NUREG-1432, "Standard Technical Specifications, Combustion Engineering Plants." DNC confirms the MPS2 pressurizer Power Operated Relief Valve (PORV) Technical Specification (3/4.4.3) contains requirements equivalent to NUREG-1432 with regard to leaking and unisolable PORVs.

3.0 REGULATORY ANALYSIS

3.1 No Sigqnificant Hazards Consideration Determination DNC requests adoption of TSTF-426, Revision 5, "Revise or Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c," which is an approved change to the standard technical specifications (STS), into the Millstone Power Station Unit 2 (MPS2) Technical Specifications. The proposed change provides a short Allowed Outage Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown to begin within one hour in accordance with Limiting Condition for Operation (LCO) 3.0.3.

DNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment 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 provides a short Allowed Outage Time to restore an inoperable system for conditions under which the existing Technical Specifications require a plant shutdown to begin within one hour in accordance with LCO 3.0.3. Entering into Technical Specification Actions is not an initiator of any accident previously evaluated. As a result, the probability of an accident previously evaluated is not significantly increased. The consequences of any previously evaluated accident that may occur during the proposed Allowed

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 7 of 8 Outage Times are no different than the consequences of the same accident during the existing one hour allowance. As a result, 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.

No new or different accidents result from the proposed change. The changes do 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 changes do not impose any new or different requirements. The proposed changes do not alter assumptions made in the safety analysis.

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

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

Response: No.

The proposed change increases the allowed outage time MPS2 may continue to operate without the operability of any one of the five identified systems proposed in this change for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The analyses in WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, August 2010, demonstrated that this limited increase in AOT results in an acceptably small increase in risk due to a limited period of continued operation in these conditions and that the associated risk is balanced by avoiding the similar risks associated with a plant shutdown. As a result, the change to the margin of safety proposed by modifying a plant shutdown within one hour is not significant.

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.

Serial No.14-072 Docket No. 50-336 Attachment 1, Page 8 of 8 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 significant increase in the amounts of any effluents 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.14-072 Docket No. 50-336 Attachment 2 Marked-Up Technical Specifications Pages DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 1 of 21

.... . 20-0 7 REACTOR COOLANT SYSTEM PRESSURIZER LIMITING CONDITION FOR OPERATION 3.4.4 The pressurizer shall be OPERABLE with:

a. Pressurizer water level < 70%, and

b. At least two groups of pressurizer heaters each having a capacity of at least 130 kW.

APPLICABILITY: MODES 1, 2 and 3.

ACTION: Insert A to page 3/4 4 0- With S~-i 811 ffki 6C 01-091M PRTL,... lrz gf.up ,tf*st to OPERABLE . withi

., 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or bei at lat HOT STANDB)Y

.tlhi th; .... id6 h.z Find in HO 8........OT DO: N tl..... t.he F..in. l1, ..

b-. With thz8 PrzeqqUriP8z katheqA.is ileper-able, be in FitlzAA HOPT STA NDBY with; the, rmaeir trip breakcr epen within 6L- haffs.ido HOT 8HU4TDOWAN within~ the f.'alie;;"ig 6 how"-r'.-

SURVEILLANCE REQUIREMENTS 4.4.4.1 The pressurizer water level shallbe determined to be within its limits at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4.4.4.2 Verify at least two groups of pressurizer heaters each have a capacity of at least 130 kW at least once per 92 days.

MILLSTONE - UNIT 2 3/4 4-4 Amendment No. 66, 44, 9-7, 4-30.,2-9, 264-, 296,

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 2 of 21 Insert A to page 3/4 4-4 Inoperable Equipment Required ACTION

a. Pressurizer water level not a.1. Be in at least HOT STANDBY with the within limit, reactor trip breakers open within 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. One group of pressurizer b.1. Restore the inoperable group of pressurizer heaters. heaters to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. c.1. Restore at least one group of pressurizer

-NOTE heaters to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Not applicable when second group or be in at least HOT STANDBY within the of required pressurizer heaters next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within intentionally made inoperable, the following 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Two groups of pressurizer heaters.

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 3 of 21 REACTOR COOLANT SYSTEM RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.3 Both power operated relief valves (PORVs) and their associated block valves shall be OPERABLE.

APPLICABILITY: MODES 1. 2, and 3. Insert A to Page 314 4-3 ACTION:

a- VI.h .. .onor .4othPOW, r iopra oleaind .a .abl. opf ing ... n....lly ". Ol.d. Wit.l..

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months eithor rostoro tie PORV1(1) to OPE.RABLE.. staa or Ao;T to- aoit.d hbn: vle Jf 'A'41 ;tl. ......... L:.ed to thebo. Week 7'oth..rwo....h e inot 14" L...t.1 TfollwT" th...o 1. eTi

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7

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.. ... ... .... .72 Lah.. . .... b .o.. at oo..t 11 4;TM;;D'V witkn -. the noi 6 ou,; and i T4--UTD.OWN ;;i:thin toe Following 6 A The block valve(s) may be stroked, as necessary, during plant cooldown to prevent thermal binding. t MILLSTONE - UNIT 2 3/4 4-3 Amendment No. 4-5, 66, 68, 4*-5-. -g-..

2-1-8,

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 4 of 21 Insert A to page 314 4-3 Inoperable Equipment Required ACTION

a. One or both PORVs, capable of a.1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to being manually cycled. OPERABLE status or close the associated block valve(s) with power maintained to the block valve(s)*; otherwise, 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. One PORV, not capable of b.1. Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to being manually cycled. OPERABLE status or close its associated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. c.-1 Close the associated block valves within 1 NOTE hour or be in at least HOT STANDBY within Not applicable when a second the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN PORV intentionally made within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

inoperable.

AND Two PORVs,: not capable of being c.2. Remove power from associated block valves manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 .

AND c.3. Verffy LCO 3.7.1.2, "Auxiliary Feedwater Pumps,* is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 .

AND c.4. Restore at least one PORV to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 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 .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 5 of 21

d. One block valve. d.l. Place associated PORV in manual control within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , 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 .

AND d.2. Restore the block valve to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , 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 .

e. e.l. Verify LCO 3.7.1.2, "Auxiliary Feedwater

-NOTE Pumps," is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; or be in at Not applicable when second block least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months valve intentionally made inoperable and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Two block valves. AND e.2. Restore at least one block valve to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , 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 .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 6 of 21

_No Change March 26, 2013 REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS 4.4.3.1 In addition to the requirements of Specification 4.05 each PORV shall be demonstrated OPERABLE:

a. Once per 31 days by performance of a CHANNEL FUNCTIONAL TEST, excluding valve operation, and

b. Once per 18 months by performance of a CHANNEL CALIBRATION.

C. Once per 18 months by operating the PORV through one complete cycle of fill travel at conditions representative of MODES 3 or 4.

4.4.3.2 Each block valve shall be demonstrated OPERABLE once per 92 days by operating the valve through one complete cycle of full travel. This demonstration is not required if a PORV block valve is closed in accordance with the ACTIONS of Specification 3.4.3.

MILLSTONE - UNIT 2 3/4 4-3a Amendment No. 66, 6, 5, .G2, 314

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 7 of 21 Mar-h 16. 906 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: A-Inoperable Equipment Required ACTION k1

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. I 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

0. Two contafi!!iý A.1 Restore at least one 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 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

All ot. -. I Enter LCO 3.0.3 immediately.

combinations SURVEILLANCE REQUIREMENTS

-- A to Page1ansert 3/4 6-12 s 4.6.'.4.1.1l Each containment spray train shallI be demonstrated OPERABLE:

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

The Containment Spray System is not required to be OPERABLE in MODE 3 if pressurizer pressure is < 1750 psia.

MILLSTONE - UNIT 2 3/4 6-12 Amendment No. 24-5. 2-2-, 2-36, 2,9-,

494-,

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 8 of 21 Insert A to Page 3/4 6-12 NOTE ------------

d.l. Verify LCO 3.7.6.1, "Control Room Emergency Not applicable when second Ventilation System," is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be containment spray train in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

intentionally made inoperable

d.2. Restore at least one inoperable containment spray train to OPERABLE status within 24

d. Two containment spray hours or be in HOT SHUTDOWN within the trains next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 9 of 21 March 31, 2008 CONTAINMENT SYSTEMS [NoChange SURVEILLANCE 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.

4.6.2.1.2 Each containment air recirculation and cooling unit shall be demonstrated OPERABLE:

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.

MILLSTONE - UNIT 2 3/4 6-13 Amendment No. 24-5, 2*9a, 303

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 10 of 21 ge pt b*,r. -30 1997 CONTAINMENT SYSTEMS 3/4.6.5 SECONDARY CONTAINMENT ENCLOSURE BUILDING FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.6.5.1 Two separate and independent Enclosure Building Filtration Trains shall be -I-OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION: Insert A ýtoPage 3/4 6-25

'.vtl L W._. B lx. F* f l'* OTTT OPERABLEREzUiREMEtl; 7ays orbe in COLD SIW4hOQtJ mthn tho z%,*"

"hzr

.... '#.'.+ ... )

...a 36 I...

. 1-SURVEILLANCE REQUIREMENTS 4.6.5.1 Each Enclosure Building Filtration Train shall be demonstrated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, fr'om the control room, flow through the HEPA filter and charcoal absorber train and verifying that the train operates for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months with the heaters on.

b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal absorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the train by: -It-MILLSTONE - UNIT 2 3/4 6-25 Aniendinent No. 2.04.

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 11 of 21 Insert A to Page 3/4 6-25 Inoperable Equipment Required ACTION

a. One Enclosure Building Filtration a.l. Restore the inoperable Enclosure Building Train. Filtration train to OPERABLE status within 7 days or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

b. b.1. Verify at least one train of containment spray

-NOTE

is OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in COLD Not applicable when second SHUTDOWN within the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Enclosure Building Filtration Train intentionally made inoperable AND b.2. Restore at least one Enclosure Building Two Enclosure Building Filtration Train to OPERABLE status within Filtration Trains. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 12 of 21 No Change March 10, 1999 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying that the cleanup train satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the train flow rate is 9000 cfm + 10%.

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.*

3. Verifying a train flow rate of 9000 cfn +/- 10% during train operation when tested in accordance with ANSI N5.10-1975.

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.*

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is

2.6 inches. Water Gauge while operating the train at a flow rate of 9000 cfm +/- 10%'.

2. Verify'ing that the train starts on an Enclosure Building Filtration Actuation Signal (EBFAS).

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 9000 cfm +/- 10%.

ASTM D3803-89 shall be used in place of ANSI N509-1976 as referenced in table 2 of Regulatory Guide 1.52. The laboratory test of charcoal should be conducted at a temperature of 300 C and a relative humidity of 95% within the tolerances specified by ASTM D3803-89.

Additionally, the charcoal sample shall have a removal efficiency ofŽ__ 95%.

MILLSTONE - UNIT 2 3/4 6-26 Amendment No. 2*, 72.4-74,24-8, 228,

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 13 of 21 No Change September 30, 1997 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

f. After each complete or partial replacement of a charcoal absorber bank by verifying that the charcoal absorbers remove greater than or equal to 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 9000 cfn +/- 10%.

MILLSTONE - UNIT 2 3/4 6-27 Amendment No. 208

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 14 of 21 Sopt....b.. 18, 2900 PLANT SYSTEMS 314.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent Control Room Emergency Ventilation Trains shall be OPERABLE.*

APPLICABILITY: MODES 1, 2, 3, 4, 5 and 6.

During movement of recently irradiated fuel assemblies. ,k ACTION:

lnsert A to page 314 7-16 1 MODES 1, 2, 3, and 4:

ft?

AC LaI

-ION0., r.t.;. th..e inoprabl; train to OPERABLE s4ttus y.-.;thx. 7 L,, ..

hOT* SllTAN".TDBY withi-n. t-h ... ,-t 671 ..... x1 .**a*in C OLD S ' r'TDOWN~r~ withi. ,th

.. 'I-ACTION e., .or,*o at lrt o... nJoporble train to OPERABL Fto . . :thi i hour.. or k beo inO TNB witlsin 4ho noest 6 htotrs, antd COLDE SHUTDOWN.64 wih 6 follow;ing 309 hU;..

e-4- Imnidtiazlly ittit..e.ae.tion. ton implemnent :itigactng actiono, and radiologi...al and .zlieo~nioa h..oords w11 not elfasd li aito+, ffld ;ntiitgafng aftions 4-. Retore C.RE'_ho .dar; to OPERAiBLE ,,Latu. St'hi:. 90,-., ..

OthorAisz, h3 in HOT STANDBY w;'!ithn th$,4:A 6i 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and COLD SHUTDOWN within49 t~i following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The Control Room Envelope (CRE) boundary may be opened intermittently under A, administrative control.

MILLSTONE - UNIT 2 3/4 7-16 Amendment No. 72-, +-2G, 449, 228, 2-39, -244, 2-4, 84, 4"$.

Serial No.14-072 Docket No. 50-336 I-Attachment 2, Page 15 of 21 Insert A to page 3/4 7-16 Inoperable Equipment Required ACTION

a. One Control Room Emergency a.l. Restore the inoperable Control Room Ventilation Train, except as specified Emergency Ventilation Train to in ACTION c. OPERABLE status within 7 days 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. b.1 Initiate action to implement mitigating

NOTE ------------------ actions immediately or be in HOT Not applicable when second Control STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Room Emergency Ventilation Train in COLD SHUTDOWN within the intentionaly made inoperable, following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

AND Two Control Room Emergency Ventilation Trains, except as specified b.2. Verify LCO 3.4.8, "Reactor Coolant in ACTION c. System, Specific Activity," is met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 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 in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

AND b.3. Restore at least one Control Room Emergency Ventilation Train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 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 in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 16 of 21 Inoperable Eauipment Required ACTION

c. One or more Control Room c.1. Immediately initiate action to implement Emergency Ventilation Trains, due to mitigating actions or be in HOT an inoperable CRE boundary. STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

AND c.2. Verify, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , mitigating actions ensure CRE occupant exposures to radiological and chemical hazards will not exceed limits, and mitigating actions are taken for exposure to smoke hazards 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

AND c.3. Restore CRE boundary to OPERABLE status within 90 days 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 17 of 21 Soptombor 18, a00" PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION ACTION (continued) [Insert A to page 3/4 7-16a MODES 5 and 6, and during movement of recently irradiated fuel assemblies:** /

I.

47 ... O... L r...... . . ........

ýbie .... * ......

do.... A er4 .d.y.,

.be,.r t

.....the,.__:.:

i mtLi thoer i. it. ........ d n nt.... 1 .

t "ogopt ot o to OPERABLEg 84.t.u. wthgO7L E t--t-i ft.*

f. .oua....... g OPER.BLE 1

0? W~ith PRL both1 Control Room1 Efforgonoyf VOotilai@0 TFAiR ino~porobl, or 'With to1

.oiou..io, Cr,-

.O.tr.I Room L...rgo... Vc.ti:t,.. Troi:; roqairod to ho in tho do...b ACT,4IO-N d. mot oopable ofboing poworod by an OPERABLE IF HOIA4 i effirgeneo' POWer- SOour, or withi otto or.moro C-nrlRe negta

\ZtlotionTi@ 4 hu Ins"oporablo doe fato i.nop:thale C-RE iqat.dflrý Amflodietoe.lpod t.i..on........ ...f .. . ........ I,. fi. J apd:L:d

.ef*...,.g L ...

- In MODES 5 and 6, when a Control Room Emergency Ventilation Train is determined to be inoperable solely because its emergency power source is inoperable, or solely because its nornal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of 3.7.6.1 Limiting Condition for Operation, provided: (1) its corresponding nornal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and device(s) are OPERABLE, or likewise satisfy the requirements of the specification. Unless both conditions (1) and (2) are satisfied within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , then ACTION 3.7.6.1.d or 3.7.6.1.e shall be invoked as applicable.

MILLSTONE - UNIT 2 3/4 7-16a Amendment No. 2-44, 248, 254, 2-84, 29g, *-,

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 18 of 21 Insert A to page 3/4 7-16a Inoperable Equipment Required ACTION

d. One Control Room Emergency d.1 Restore the inoperable Control Room Ventilation Train, except due to an Emergency Ventilation Train to inoperable CRE boundary. OPERABLE status within 7 days.

AND d.2 After 7 days, initiate and maintain operation of the remaining OPERABLE Control Room Emergency Ventilation Train in the recirculation mode of operation or immediately suspend the movement of recently irradiated fuel assemblies.

e.1 Both Control Room Emergency e.l. Immediately suspend the movement of Ventilation Trains, recently irradiated fuel assemblies.

OR e.2 The OPERABLE Control Room Emergency Ventilation Train required to be in the recirculation mode by ACTION d. not capable of being powered by an OPERABLE normal and emergency power source, OR e.3 One or more Control Room Emergency Ventilation Trains, due to an inoperable CRE boundary.

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 19 of 21 PLANT SYSTEMS No Change March 10, 1999 SURVEILLANCE REQUIREMENTS 4.7.6.1 Each Control Room Emergency Ventilation Train shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is <

100 0 F.

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating from the control room, flow through the HEPA filters and charcoal absorber train and verifying that the train operates for at least 15 minutes.

c. At least once per IS months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings., or (2) following painting, fire orchemical release in any ventilation zone communicating with the train by:

1. Verifying that the cleanup train satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the train flow rate is 2500 cfin +/- 10%.

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accor-dance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6. a of Regulatory Guide 1.52, Revi-sion 2, March 1978.* The carbon sample shall have a removal efficiency of Ž 95 percent.

3. Verifying a train flow rate of 2500 cfm +/- 10% during train operation when tested in accordance with ANSI N510-1975.

d. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.*

ASTM D3803-89 shall be used in place of ANSI N509-1976 as referenced in table 2 of Regulatory Guide 1.52. The laboratory test of charcoal should be conducted at a temperature of 30'C and a relative humidity of 95% within the tolerances specified by ASTM D3803-89.

MILLSTONE - UNIT 2 3/4 7-17 Amendment No. 5, 72, +G,414-9,4-2-5, 4-49, 4-7-, 228

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 20 of 21 I No Change March 10., 1999 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 3.4 inches Water Gauge while operating the train at a flow rate of 2500 cfmi +/- 10%.

2. Verifying that on a recirculation signal, with the Control Room Emergency Ventilation Train operating in the normal mode and the smoke purge mode, the train automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks.

MILLSTONE - UNIT 2 3/4 7-17a Amendment No. 5,4 J-O, , -49, 4-2, 449, 4-4, 228

Serial No.14-072 Docket No. 50-336 Attachment 2, Page 21 of 21 September 18, 2008 PLANT SYSTEMS I No Change SURVEILLANCE REQUIREMENTS (Continued)

3. Deleted I

f. After each complete or partial replacement of a HEPA filter batik by verifying that the HEPA filter banks remove greater than or equal to 99% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 2500 cfin +/- 10%.

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the train at a flow rate of 2500 cfim + 10%.

h. By perfornance of CRE unfiltered air inleakage testing in accordance with the CRE Habitability Program at a frequency in accordance with the CRE Habitability Program.

MILLSTONE - UNIT 2 3/4 7-18 Amendment No. 72, 4-G-,-149, 2-28, 298, 305

Serial No. 13-XXX Docket No. 50-336 Attachment 3 Attachment 3 Marked-Up Technical Specifications Bases Pages for Information Only DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 1 of 26 LBDCR 04-MP2-016 February 24, 2005 3/4.4 REACTOR COOLANT SYSTEM FNo Change BASES During operation, all pressurizer code safety valves must be OPERABLE to prevent the RCS from being pressurized above its safety limit of 2750 psia. The combined relief capacity of these valves is sufficient to limit the Reactor Coolant System pressure to within its Safety Limit of 2750 psia following a complete loss of turbine generator load while operating at RAfED THERMAL POWER and assuming no reactor trip until the first Reactor Protective System trip selpoint (Pressurizer Pressure-High) is reached (i.e., no credit is taken for a direct reactor trip on the loss of turbine) and also assuming no operation of the pressurizer power operated relief valve or steam dump valves.

3/4.4.3 RELIEF VALVES The power operated relief valves (PORVs) operate to relieve RCS pressure below the setting of the pressurizer code safety valves. These relief valves have remotely operated block valves to provide a positive shutoff capability should a relief Valve become inoperable. The electrical power for both the relief valves and the block valves is capable of being supplied from an emergency power source to ensure the ability to seal this possible RCS leakage path.

The PORVs are also used for low temperature overpressure protection when the RCS is cooled down to or below 275°F. This is covered by Technical Specification 3.4.9.3 and discussed in the respective Bases section. The discussion below only addresses the PORVs in MODES 1, 2 and 3.

With the PORV inoperable and capable of being manually cycled, either the PORV must be restored, or the flow path isolated within I hour. The block valve should be closed, but the power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. Although the PORV may be designated inoperable, it may be able to be manually opened and closed and in this marnner can be used to perform its function. PORV inoperability may be due to seat leakage, instrumentation problems, automatic control problems, or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. Operation of the plant may continue with the PORV in this inoperable condition for a limited period of time not to exceed the next refueling outage, so that maintenance can be performed on the PORVs to eliminate the degraded condition. The PORVs should normally be available for automatic mitigation of overpressure events when the plant is at power.

Quick access to the PORV for pressure control can be made when power remains on the closed block valve.

If one block valve is inoperable, then it must be restored to OPERABLE status, or the associated PORV prevented from opening automatically The prime importance for the capability to maintain closed the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the required ACTION is to prevent the associated PORV from automatically opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. This may be accomplished by MILLSTONE - UNIT 2 B 3/4 4-2 Amendment No. -54,66, 69, 4-39, -2+9, Acknowledged by NRC letter dated 6/28/05

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 2 of 26 LIBPDR 13gMP 016 October 16, 201-3 3/4.4 REACTOR COOLANT SYSTEM BASES various methods. These methods include, but are niot limited to, placing the NORMAL/ISOLATE switch at the associated Bottle Up Panel in the "ISOLATE" position or pulling the control power fuses for the associated PORV control circuit.

Although the block valve may be designated inoperable, it may be able to be manually opened and closed and in this manner can be used to perform its function. Block valve inoperability may be due to seat leakage, instrumentation problems, or other causes that do not prevent. manual use and do not create a possibility for a small break LOCA. This condition is only intended to permit operation of the plant. for a limited period of time. The block valve should normally be available to allow PORX' operation for automatic mitigation of overpressure events. The block valves must be returned to OPERABLE status prior to entering MODE 3 after a refuieling outage.

Insert A to Page B 3/4 4-2a If...r; tb a. .m .POi.---inoperable fnd nct ap..bl;

.. Ecing manu.- cycmled, itRs9 n,;cca v-yto

iher roo4$tr;, at Wm!t on: vzlv; With:;t thO nnMPlztioni timoftl 1 hou or olt t1 i ahb 81o8ing Wnd rON'icdngth: POw.'f to th1o- cooooictd block- wvýv cAd zooldowa tAi RCS-- to MODE 1.

SURVEILLANCE REQUIREMENT 4.4.3. .C requires operating each PORV through one complete cycle of fill travel at conditions representative of MODES 3 or 4. This is normally performed in MODE 3 or 4 as the unit is descending in power to commence a refueling outage.

This test will normally be a static test, whereby a PORV will be exposed to MODE 3 or 4 temperatures, the block valve closed, and the PORV tested to verify it strokes through one complete cycle of full travel. PORV cycling demonstrates its function. The Frequency of 18 months is based on a typical refueling cycle and industry accepted practice. SURVEILLANCE REQUIREMENT 4.4.3. .C is consistent with the NRC staff position outlined in Generic Letter 90-06, which requires that the 18-month PORV stroke test be performed at conditions representative of MODE 3 or 4. Testing in the manner described is also consistent with the guidance in NUREG 1482, "Guidelines for Inservice Testing at Nuclear Power Plants." Section 4.2.10, that describes the PORVs function during reactor startup and shutdown to protect the reactor vessel and coolant system from low-temperature overpressurization conditions, and indicates they should be exercised before system conditions warrant vessel protection. If post maintenance retest is warranted4 the affected valve(s) will be stroked under ambient conditions while in Mode 5, 6, or defuieled. A Hot Functional Test is required to be performed in MODE 4 prior to entry into MODE 3. The actual stroke time in the open and close direction will be measured, recorded and compared to the test results obtained during pre-installation testing to assess acceptability of the affected valve(s).

SURVEILLANCE REQUIREMENT 4.4.3.2 verifies that a block valve(s) can be closed if necessary. This SURVEILLANCE REQUIREMENT is not required to be perfonned with the block valve(s) closed in accordance with the ACTIONS of TS 3.4.3. Opening the block valve(s) in this condition increases the risk of an unisolable leak from the RCS since the PORV(s) is already inoperable. Insert B to Page B 3/4 4-2a MILLSTONE - UNIT 2 B 3/4 4-2a Amendment No. ,-W,- 66, 97, 4-", 244, 24

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 3 of 26 Insert A to Page B 3/4 4-2a If two PORVs are inoperable and not capable of being manually cycled, it is necessary to isolate the flow path by closing and removing the power to the associated block valves within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and to restore at least one PORV within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Condition is modified by a Note stating it is not applicable if the second PORV train is intentionally declared inoperable. The Condition does not apply to voluntary removal of redundant systems or components from service. The Condition is applicable if one PORV is inoperable for any reason and the second PORV is discovered to be inoperable, or if both PORVs are discovered to be inoperable at the same time.

In the event of a loss of feedwater, the PORVs would be used to remove core heat. In order to minimize the consequences of a loss of feedwater while two PORVs are inoperable, Required Action c.3 requires that LCO 3.7.1.2, "Auxiliary Feedwater Pumps," be met to ensure AFW is available. The inoperability of two PORVs during the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed outage time has been shown to be acceptable based on the infrequent use of the Required Action and the small incremental effect on plant risk (Ref. 1). If one PORV is restored and one PORV remains inoperable, then the plant will be in Condition

b. with the time clock started at the original declaration of having two PORVs inoperable.

If two block valves are inoperable, it is necessary to restore at least one block valve to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Condition is modified by a Note stating it is not applicable if the second block valve is intentionally declared inoperable. The Condition does not apply to voluntary removal of redundant systems or components from service.

The Condition is only applicable if one block valve is inoperable for any reason and the second block valve is discovered to be inoperable, or if both block valves are discovered to be inoperable at the same time. In the event of a loss of feedwater, the PORVs would be used to remove core heat. In order to minimize the consequences of a loss of feedwater while two block valves are inoperable, Required Action e.1 requires that LCO 3.7.1.2, "Auxiliary Feedwater Pumps," be verified to be met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The inoperability of two block valves during the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months allowed outage time has been shown to be acceptable based on the infrequent use of the Required Actions and the small incremental effect on plant risk (Ref. 1).

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 4 of 26 Insert B to Page B 3/4 4-2a

1. WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, August 2010.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 5 of 26 REACTOR COOLANT SYSTEM BASES

3/4.4.4 PRESSURIZER Insert A to Page B 3/4 4-2b r

An OPERABLE pressurizer p ides pressure control for the reactor coolant system during operations with both forced actor coolant flow and with natural circulation flow. The minimum water level in the presItI rizer assures the pressurizer heaters, which are required to achieve and maintain pressur oontrol, remain covered with water to prevent failure, which occurs if the heaters are energize ncovered. The maximum water level in the pressurizer ensures that this parameter is maint ed within the envelope of operation assumed in the safety analysis. The maximum water lev also ensures that the RCS is not a hydraulically solid system and that a steam bubble wil e provided to accommodate pressure surges during operation. The steam bubble also pr cts the pressurizer code safety valves and power operated relief valve against water relief.. ie requirement that a minimum number of pressurizer heaters be OPERABLE enhances the capability of the plant to control Reactor Coolant System pressure and establish and maintain natural circulation. Insert B to Page B 3/4 4-2b The requirement for two groups of pressurizer heaters, each having a capacity B 1304-2b of3/4 kW, i

C to Page is met by verifying the capacity of the pressurizer proportional heaterllnsert groups I and 2. Since the pressurizer proportional heater groups 1 and 2 are supplied from the emergency 480V electrical buses, there is reasonable assurance that these heaters can be energized during a loss of offsite power to maintain natural circulation at HOT STANDBY.

3/4.4.5 STEAM GENERATOR TUBE INTEGRITY The LCO requires that steam generator (SG) tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the plugging criteria be plugged in accordance with the Steam Generator Program.

During a SG inspection, any inspected tube that satisfies the Steani Generator Program plugging criteria is removed from service by plugging. If a tube was determined to satisfy the plugging criteria but was not plugged, the tube may still have tube integrity.

the tube-to-weld at the tube inlet and In the context ofbetween this Specification, the a SG tube tube-to-tubesheet is defined as the entire length of the tube, wall including the tube tubesheet weld at the tube outlet. The tube-to-tubesheet weld is not considered part of the tube.

MILLSTONE - UNIT 2 B 3/4 4-2b Amendment No. 2,, 7, 4194 4-3-,89,

-, 66,

+44-1,4-2+-,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 6 of 26 Insert A to Page B 3/4 4-2b With pressurizer water level not within the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses. To achieve this status, the unit must be brought to at least HOT STANDBY with the reactor trip breakers open within 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 . This takes the plant out of the applicable MODES and restores the plant to operation within the bounds of the safety analyses.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 7 of 26 Insert B to Page B 3/4 4-2b If two required groups of pressurizer heaters are inoperable, restoring at least one group of pressurizer heaters to OPERABLE status is required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Condition is modified by a Note stating it is not applicable ifthe second group of required pressurized heaters is intentionally declared inoperable. The Condition is not intended for voluntary removal of redundant systems or components from service. The Condition is only applicable if one group of required pressurized heaters is inoperable for any reason and the second group of required pressurized heaters is discovered to be inoperable, or if both groups of required pressurized heaters are discovered to be inoperable at the same time. If both required groups of pressurizer heaters are inoperable, the pressurizer heaters may not be available to help maintain subcooling in the RCS loops during a natural circulation cooldown following a loss of offsite power.

The inoperability of two groups of required pressurizer heaters during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time has been shown to be acceptable based on the infrequent use of the Required Action and the small incremental effect on plant risk (Ref. 1).

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 8 of 26 Insert C to Page B 3/4 4-2b

1. WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown,"

Revision 2, August 2010.

I Serial No.14-072 Docket No. 50-336 Attachment 3, Page 9 of 26 LBDCP-R 01 MP2 016 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 containment cooling system ensures that 1) the containment 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.

To be OPERABLE, the two trains of the containment spray system shall be capable of taking a suction from the refueling water storage tank on a containment spray actuation signal and automatically transferring suction to the contaiunent sump on a sump recirculation actuation signal. Each containment spray train flow path from the containment sump shall be via an OPERABLE shutdown cooling heat exchanger.

The containment cooling system consists of two containment cooling trains. Each containment cooling train has two containment air recirculation and cooling units. For the purpose of applying the appropriate ACTION statement, the loss of a single containment air 4-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 containment 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 containment spray system is required to mitigate a main steam line break accident inside containment. In addition, the containment spray system provides a mechanism for removing iodine from the containment atmosphere. Therefore, at least one train of containment spray is required to be OPERABLE when pressurizer pressure is

Ž 1750 psia, and the allowed outage time for one train of containment spray reflects the dual tiunetion of containment spray for heat removal and iodine removal. Insert A to Page B 3/4 6-3 Surveillance Requirement 4.6.2.1.. .a verifies the correct alignment for manual, power operated, and automatic valves in the Containment Spray System flow paths to provide assurance that the proper flow paths w ill 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 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.

MILLSTONE - UNIT 2 B 3/4.6-3 Amendment No. 24, 6-1-, 24-0, *-5, 2428, 246, 99;,

Acknowledged by NRC letter dated 6/28/05

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 10 of 26 Insert A to Page B 3/4 6-3 With one containment spray train inoperable, the inoperable containment spray train must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions. The 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed outage time takes into account the redundant heat removal capability afforded by the Containment Spray System and reasonable time for repairs.

With one required containment cooling train inoperable, the inoperable containment cooling train must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing greater than 100% of the heat removal needs (for the condition of one containment cooling train inoperable) after an accident.

With one containment spray train and one containment cooling train inoperable, one required containment spray train or one required containment cooling train must be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100%

of the heat removal needs after an accident. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowed outage time was developed taking into account the redundant heat removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

With two required containment spray trains inoperable, at least one of the required containment spray trains must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Both trains of containment cooling must be OPERABLE or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Condition is modified by a. Note stating it is not applicable if the second containment spray train is intentionally declared inoperable. The Condition does not apply to voluntary removal of redundant systems or components from service. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or if both trains are discovered to be inoperable at the same time. In addition, LCO 3.7.6.1, "Control Room Emergency Ventilation System," must be verified to be met within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The components in this degraded condition are capable. of providing greater than 100% of the heat removal needs after an accident. The allowed outage time is based on Reference 1 which demonstrated that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time is acceptable based on the redundant heat removal capabilities afforded by the Containment Cooling System, the iodine removal capability of the Control Room Emergency Air Cleanup System, the infrequent use of the Required Action, and the small incremental effect on plant risk.

With two required containment cooling trains inoperable, one of the required containment cooling trains must be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The components in this degraded condition provide iodine removal capabilities and are capable of providing at least 100% of the heat removal needs after an accident. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months allowed outage time was developed taking into account the redundant heat

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 11 of 26 removal capabilities afforded by combinations of the Containment Spray System and Containment Cooling System, the iodine removal function of the Containment Spray System, and the low probability of a DBA occurring during this period.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 12 of 26 January 12, 2012 LBDCR 12-MP2-001 CONTAINMENT SYSTEMS No Change BASES 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (Continued)

Surveillance Requirement 4.6.2. I.1.b, 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 OM Code. This type of testing may be accomplished by measuring tile 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 perfornmance 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. .c and 4.6.2.11. ld demonstrate that each automatic containment spray valve actuates to the required position on an actual or simulated actuation signal (CSASor 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 perforn 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 performance. An evaluation, based onl the specific situation, will determine the appropriate method (e.g., visual inspection, air or smoke flow test) to verify no nozzle obstruction.

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 fan 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. 24-9, 24--5..236, 2 Serial No.14-072 Docket No. 50-336 Attachment 3, Page 13 of 26 LBDCR, 09 NM2 010 CONTAINMENT SYSTEMS BASES 3/4.6.2.1 CONTAINMENT SPRAY AND COOLING SYSTEMS (Continued)

Surveillance Requirement 4.6.2.1.2.b demonstrates a cooling water flow rate of> 500 gpm to each contaimnent air recirculation and cooling unit to provide assurance a cooling water flow path through the cooling unit is available. The 31 day frequency considers the known reliability of the cooling water system, the two train redundancy available, and the low probability of a significant degradation of flow occurring between surveillances. This frequency has been shown to be acceptable through operating experience.

Surveillance Requirement 4.6.2.1.2.c demonstrates that each containment air recirculation and cooling unit starts on receipt of an actual or simulated actuation signal (SIAS). 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 confinning 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.

< r- Insert Ato Page B 3/4 6-3b 3/4.6.3 CONTAINMENT ISOLATION VALVES I The Technical Requirements Manual contains the list of containment isolation valves (except the containment air lock and equipment hatch). Any changes to this list will be reviewed under 10CFR50.59 and approved by the committee(s) as described in the QAP Topical Report.

The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environmnent in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

The containment isolation valves are used to close all fluid (liquid and gas) penetrations not required for operation of the engineered safety feature systems, to prevent the leakage of radioactive materials to the environment. The fluid penetrations which may require isolation after an accident are categorized as Type P, 0, or N. The penetration types for each containment isolation valve are listed in FSAR Table 5.2-11, Containment Structure Isolation Valve Information.

4, Type P penetrations are lines that connect to the reactor coolant pressure boundary (Criterion 55 of 10CFR50, Appendix A). These lines are provided with two containment isolation valves, one inside containment, and one outside containment.

Type 0 penetrations are lines that are open to the containment internal atmosphere (Criterion 56 of 10CFR50, Appendix A). These lines are provided with two containment isolation valves, one inside containment, and one outside containment.

MILLSTONE - UNIT 2 B 3/4 6-3b Amendment No. 21-9, . 2-36, 278.,

48-,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 14 of 26 Insert A to Page B 3/4 6-3b

1. WCAP-16125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown," Revision 2, August 2010.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 15 of 26 LBDCR 09 NPZ012W CONTAINMENT SYSTEMS BASES 3/4.6.5 SECONDARY CONTAINMENT 3/4.6.5.1 ENCLOSURE BUILDING FILTRATION SYSTEM Insert A to Page B 3/4 6-5 The OPERABILITY of the Enclosure Building Filtration System ensures that containment leakage occurring during LOCA conditions into the annulus will be filtered through the HEPA filters and charcoal adsorber trains prior to discharge to the atmosphere. This requirement is necessary to meet the assumptions used in the accident analyses and limit the SITE BOUNDARY radiation doses to within the limits of 10 CFR 50.67 during LOCA conditions.

The laboratory testing requirement for the charcoal sample to have a removal efficiency of

Ž_95q/0 is more conservative than the elemental and organic iodine removal efficiencies of 90%

and 7 0%, respectively, assumed in the DBA analyses for the EBFS charcoal adsorbers in the Millstone Unit 2 Final Safety Analysis Report. A removal efficiency acceptance criteria of> 95%

will ensure the charcoal has the capability to perform its intended safety function throughout the length of an operating cycle.

Surveillance Requirement 4.6.5.1.b.l dictates the test frequency, method and acceptance criteria for the EBFS trains.(cleanup trains). These criteria all originate in the Regulatory Position sections of Regulatory Guide 1.52, Rev. 2, March 1978 as discussed below:

Section C.5.a requires a visual inspection of the cleanup system be made before the following tests, in accordance with the provisions of section 5 of ANSI N510-1975:

in-place air flow distribution test

DOP test

activated carbon adsorber section leak test Section C.5.c requires the in-place Dioctyl phthalate (DOP) test for HEPA filters to conform to section 10 of ANSI N510-1975. The HEPA filters should be tested in place (I) initially, (2) at least once per 18 months thereafter, and (3) following painting, fire, or chemical release in any ventilation zone communicating with the system. The testing is to confirm a penetration of less than or equal to 1%* at rated flow. J,,

Section C.5.d requires the charcoal adsorber section to be leak tested with a gaseous halogenated hydrocarbon refrigerant, in accordance with section 12 of ANSI N510-1975 to ensure that bypass leakage through the adsorber section is less than or equal to 1%.** Adsorber leak testing should be conducted (1) initially, (2) at least once per 18 months thereafter, (3) following removal of an adsorber sample for laboratory testing if the integrity of the adsorber

Means that the HEPA filter will allow passage of less than or equal to 1% of the test concentration injected at the filter inlet from a standard DOP concentration injection.

- - /lMeans that the charcoal adsorber sections will allow passage of less than or equal to.1% of 4,'

the injected test concentration around the charcoal adsorber sections.

MILLSTONE - UNIT 2 B 3/4 6-5 Amendment No. 409,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 16 of 26 Insert A to Page B 3/4 6-5 With one Enclosure Building Filtration System Train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The components in this degraded condition are capable of providing 100% of the iodine removal needs after a DBA. The 7 day allowed outage time is based on consideration of such factors as the availability of the OPERABLE redundant Enclosure Building Filtration System Train and the low probability of a DBA occurring during this period.

If two Enclosure Building Filtration System Trains are inoperable, at least one Enclosure Building Filtration System Train must be returned to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Condition is modified by a Note stating it is not applicable if the second Enclosure Building Filtration System train is intentionally declared inoperable. The Condition does not apply voluntary removal of redundant systems or components from service. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or if both trains are discovered to be inoperable at the same time. In addition, at least one train of containment spray must be verified to be OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . In the event of an accident, containment spray reduces the potential radioactive release from the containment, which reduces the consequences of the inoperable Enclosure Building Filtration System Trains. The allowed outage time is based on Reference 1 which demonstrated that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time is acceptable based on the infrequent use of the Required Actions and the small incremental effect on plant risk.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 17 of 26 LIBDCR 08 N~02W9 Dcz;mhcr 9, 2008° CONTAINMENT SYSTEMS BASES Section C.5.d (Continued) section is affected, and (4) following painting, fire, or chemical release in any ventilation zone communicating with the system. Insert A to Page B 3/4 6-5a 3/4.6.5.2 ENCLOSURE BUILDING The OPERABILITY of the Enclosure Building ensures that the releases of radioactive materials from the primary containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with operation of the Enclosure Building Filtration System, will limit the SITE BOUNDARY radiation doses to within the limits of 10 CFR 50.67 during accident conditions. ,,

One Enclosure Building Filtration System train is required to establish a negative pressure of 0.25 inches W.G in the Enclosure Building Filtration Region within one minute after an Enclosure Building Filtration Actuation Signal is generated. The one minute time requirement does not include the time necessary for the associated emergency diesel generator to start and power Enclosure Building Filtration System equipment.

To enable the Enclosure Building Filtration System to establish the required negative pressure in the Enclosure Building, it is necessary to ensure that all Enclosure Building access openings are closed. For double door access openings, only one door is required to be closed and latched, except for nonmal passage. For single door access openings, that door is required to be closed and latched, except for nonnal passage.

If a required door that is designated to automatically close and latch is not capable of automatically closing and latching, the door shall be maintained closed and latched, or personnel shall be stationed at the door to ensure that the door is closed and latched after each transit through the door. Otherwise, the access opening (door) should be declared inoperable and appropriate technical specification ACTION statement entered.

MILLSTONE - UNIT 2 B 3/4 6-5a Amendment No. 2G8,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 18 of 26 Insert B to Page B 3/4 6-5

1. WCAP-1 6125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown,"

Revision 2, August 2010.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 19 of 26 June 25, 2007 LBDCR 07-MP2-013 PLANT SYSTEMS No Change BASES 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM The OPERABILITY of the Control Room Emergency Ventilation System ensures that

1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room. For all postulated design basis accidents, the radiation exposure to personnel occupying the control room shall be 5 rem TEDE or less consistent with the requirements of 10 CFR 50.67 The Control Room Envelope (CRE) is the area within the confines of the. CRE. boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room, and other non-critical areas including adjacent support offices, and utility rooms. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, ceiling, ducting, valves, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

In order for the control room emergency ventilation systems to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed tile calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

TS LCO 3.7.6.1 is modified by a footnote allowing the CRE boundary to be opened intermittently under administrative controls. This footnote only applies to openings in the CRE boundary that can be rapidly restored to tile design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is perfonned by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

MILLSTONE - UNIT 2 B 3/4 7-4a Amendment No. 2-8, 236, 242, 2-T4, 2-84,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 20 of 26 Fehm:afy 19, ;909.

LBDCGR 09 44P9 002 PLANT SYSTEMS BASES

,Ma.l, b.1, b.2, b.3, c.1, c.2 and c.3 3/4.7.6 CONTROL RQ6M EMERGENCY VENTILATION SYSTEM (Continued) z/... d.1W2, and e. 1 ACTIONS , b., m-id e. of this specificatio are a nes during p ant operation in MODES 1, 2, 3, and 4. ACTIONS are applicable in MODE5 and 6, or when recently irradiated fuel assemblies are being moved. The control room emergency ventilation system is required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e.,

fuel that has occupied part of a critical rea'tor core within the previous 300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months .

< !insert A to page 3/4 7-4b I

-.[

The control room radiological dose calculations use the conservative minimum acceptable flow of 2250 cfin based on the flowrate surveillance requirement of 2500 cfm +/- 10%.

Currently there are some situations where the CREV System may not automatically start on an accidcnt signal, without operator action. Under most situations, the emergency filtration fans will start and the CREV System will be in the accident lineup. However, a failure of a supply fan (F21 A or B) or an exhaust fan (F31 A or B), will require operator action to return to a full train lineup. Also, if a single emergency bus does not power up for one train of the CREV System, the opposite train filter fan will automatically start, but the required supply and exhaust fans will not automatically start. Therefore, operator action is required to establish the whole train lineup.

This action is specified in the Emergency Operating Procedures. The radiological dose calculations do not take credit for CREV System cleanup action until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months into the accident to allow for operator action.

When the CREV System is checked to shift to the recirculation mode of operation, this will be performed from the nornal mode of operation, and from the smoke purge mode of operation.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

MILLSTONE - UNIT 2 B 3/4 7-4b Amendment No. 29., 2366, 2-4-5. 2 8, -54,

-24,

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 21 of 26 Insert A to page 3/4 7-4b With one Control Room Emergency Ventilation (CREV) train inoperable except due to an inoperable CREV boundary, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREV subsystem is adequate to perform control room radiation protection function. However, the overall reliability is reduced because a single failure in the OPERABLE CREV train could result in loss of CREV function. The 7 day allowed outage time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

If both CREV trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable control room boundary (i.e., Condition c), at least one CREV train must be returned to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The Condition is modified by a Note stating it is not applicable if the second CREV train is intentionally declared inoperable.

The Condition does not apply to voluntary removal of redundantsystems or components from service. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or if both trains are discovered to be inoperable at the same time. During the period that the CREV trains are inoperable, action must be initiated to implement mitigating actions to lessen the effect on control room (CR) occupants from potential hazards while both trains of CREV are inoperable. In the event of a DBA, the mitigating actions will reduce the consequences of radiological exposures to the CR occupants.

Specification 3.4.8, "Reactor Coolant System Specific Activity," allows limited operation with the reactor coolant system (RCS) activity significantly greater than the LCO limit.

This presents a risk to the plant operator during an accident when all CREV trains are inoperable. Therefore, it must be verified within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months that LCO 3.4.8 is met. This Required Action does not require additional RCS sampling beyond that normally required by LCO 3.4.8.

At least one CREV train must be returned to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The allowed outage time is based on Reference 1 which demonstrated that the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time is acceptable based on on the infrequent use of the Required Actions and the small incremental effect on plant risk.

If the control room boundary is inoperable in MODES 1,2, 3, and 4, the CREV trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 90 days. During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. The 90 days allowed outage time is reasonable based on the low probability of a DBA occurring

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 22 of 26 during this time period, and the use of compensatory measures. The 90 days allowed outage time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room boundary.

In MODE 5 or 6, or during movement of recently irradiated fuel assemblies, if Required Action d.1 cannot be completed within the required allowed outage time, the OPERABLE CREV train must be immediately placed in the recirculation mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any actiVe failure will be readily detected.

An alternative to Required Action d.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

When in MODES 5 and 6, or during movement of recently irradiated fuel assemblies, with two CREV trains inoperable, action must.be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 23 of 26 June 25, 2007 PLANToSYSange LBDCR 07-MP2-013 PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke.

These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed outage time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day allowed outage time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day allowed outage time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

Immediate action(s). in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled marner.

Surveillance Requirement 4.7.6.1.c. l dictates the test frequency, methods and acceptance criteria for the Control Room Emergency Ventilation System trains (cleanup trains). These criteria all originate in the Regulatory Position sections of Regulatory Guide 1.52, Rev. 2, March 1978 as discussed below.

Section C.5.a requires a visual inspection of the cleanup system be made before the following tests, in accordance with the provisions of section 5 of ANSI N510-1975:

in-place air flow distribution test

DOP test

activated carbon adsorber section leak test MILLSTONE - UNIT 2 B 3/4 7-4e Amendment No. 2-28, 246., 24-5, 248,

'L 24

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 24 of 26 LBDCR 09-MP2-012 April 13, 2010 PLANT SYSTEMS N nge BASES 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Section C.5.c requires the in-place Dioctyl phthalate (DOP) test for HEPA filters to conform to section 10 of ANSI N510-1975. The HEPA filters should be tested in place (1) initially, (2) at least once per 18 months thereafter, and (3) following painting, fire, or chemical release in any ventilation zone communicating with the system. The testing is to confirm a penetration of less than or equal to 1%* at rated flow; Section C.5.d requires the charcoal adsorber section to be leak tested with a gaseous halogenated hydrocarbon refrigerant, in accordance with section 12 of ANSI N510-1975 to ensure that bypass leakage through the adsorber section is less than or equal to 1%.** Adsorber leak testing should be conducted (I) initially, (2) at least once per 18 months thereafter, (3) following removal of an adsorber sample for laboratory testing if the integrity of the adsorber section is affected, and (4) following painting, fire, or chemical release in any ventilation zone communicating with the system.

The ACTION requirements to immediately suspend various activities (CORE ALTERATIONS, irradiated fuel movement, etc.) do not preclude completion of the movement of a component to a safe position.

Technical Specification 3.7.6.1 provides the OPERABILITY requirements for the Control Room Emergency Ventilation Trains. If a Control Room Emergency Ventilation Train emergency power source or normal power source becomes inoperable in MODES 1, 2, 3, or 4 the requirements of Technical Specification 3.0.5 apply in determining the OPERABILITY of the affected Control Room Emergency Ventilation Train. If a Control Room Emergency Ventilation Train emergency power source or normal power source becomes inoperable in MODES 5 or 6 the guidance provided by Note "**" of this specification applies in determining the OPERABILITY of the affected Control Room Emergency Ventilation Train. If a Control Room Emergency Ventilation Train emergency power source or normal power source becomes inoperable while not in MODES 1, 2, 3, 4, 5, or 6 the requirements of Technical Specification 3.0.5 apply in determining the OPERABILITY of the affected Control Room Emergency Ventilation Train.

Means that the HEPA filter will allow passage of less than or equal to 1% of the test concentration injection at the filter inlet from a standard DOP concentration injection.

- Means that the charcoal adsorber sections will allow passage of less than or equal to 1% of the injected test concentration around the charcoal adsorber section.

MILLSTONE - UNIT 2 B 3/4 7-4d Amendment No.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 25 of 26 LIBDCR 07 MP2 013 PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Surveillance Requirement 4.7.6.1.h verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program. 1 The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 remn TEDE and the CRE occupants are protected from hazardous chemicals and smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, ACTION c. must be entered. ACTION c. allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability linits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, which endorses, with exceptions, NEI 99-03.

These compensatory measures may also be used as mitigating actions as required by ACTION c.

Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY. Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

< insert A to page 3/4 7-4e

! I MILLSTONE - UNIT 2 B 3/4 7-4e Amendment No.

Serial No.14-072 Docket No. 50-336 Attachment 3, Page 26 of 26 Insert A to page 3/4 7-4e

1. WCAP-1 6125-NP-A, "Justification for Risk-Informed Modifications to Selected Technical Specifications for Conditions Leading to Exigent Plant Shutdown,"

Revision 2, August 2010.

ML14188B189

Text

1.0 DESCRIPTION

3.0 REGULATORY ANALYSIS

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