ML031670914

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Issuance of Amendment No. 216, Revising the Technical Specifications Related to Containment System
ML031670914
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/29/2003
From: Nerses V
NRC/NRR/DLPM/LPD1
To: Christian D
Dominion Nuclear Connecticut
Nerses V, NRR//DLPM, 415-1484
References
TAC MB6212
Download: ML031670914 (14)
v • d • e


Text

September 29, 2003 Mr. David A. Christian Senior Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 3 - ISSUANCE OF AMENDMENT RE: CONTAINMENT ISOLATION VALVES (TAC NO. MB6212)

Dear Mr. Christian:

The Commission has issued the enclosed Amendment No. 216 to Facility Operating License No. NPF-49 for the Millstone Power Station, Unit No. 3, in response to your application dated August 14, 2002, as supplemented by letter dated December 19, 2002.

The amendment revises the Technical Specifications (TSs) related to Containment Systems.

Specifically, the proposed changes would: (1) add clarification to TS 1.7 Definitions -

Containment Integrity; (2) add clarifying information, as well as revise a portion of Surveillance Requirement 4.6.1.1 associated with the affected section of TS 3.6.1.1, Containment Integrity; (3) revise TS 3.6.3, Containment Isolation Valves, to make editorial changes, to add an action statement that would increase the allowed outage time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Containment Isolation Valves in closed systems; and (4) other changes that are clarifying and/or administrative in nature. In addition, the TS Bases would be revised to address the proposed changes.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Victor Nerses, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosures:

1. Amendment No. 216 to NPF-49
2. Safety Evaluation cc w/encls: See next page

Millstone Power Station Unit 3 cc:

Lillilan M. Cuoco, Esquire Senior Resident Inspector Senior Counsel Millstone Power Station Dominion Resources Services, Inc. c/o U.S. Nuclear Regulatory Commission Rope Ferry Road P. O. Box 513 Waterford, CT 06385 Niantic, CT 06357 Edward L. Wilds, Jr., Ph.D. Mr. G. D. Hicks Director, Division of Radiation Director - Nuclear Station Safety Department of Environmental Protection and Licensing 79 Elm Street Dominion Nuclear Connecticut, Inc.

Hartford, CT 06106-5127 Rope Ferry Road Waterford, CT 06385 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Ms. Nancy Burton 475 Allendale Road 147 Cross Highway King of Prussia, PA 19406 Redding Ridge, CT 00870 First Selectmen Mr. William D. Meinert Town of Waterford Nuclear Engineer 15 Rope Ferry Road Massachusetts Municipal Wholesale Waterford, CT 06385 Electric Company Moody Street Mr. P. J. Parulis P.O. Box 426 Manager - Nuclear Oversight Ludlow, MA 01056 Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Mr. J. Alan Price Waterford, CT 06385 Site Vice President Dominion Nuclear Connecticut, Inc.

Mr. W. R. Matthews Rope Ferry Road Senior Vice President - Nuclear Operations Waterford, CT 06385 Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Mr. Chris Funderburk Waterford, CT 06385 Director, Nuclear Licensing and Operations Support Mr. John Markowicz Dominion Resources Services, Inc.

Co-Chair 5000 Dominion Boulevard Nuclear Energy Advisory Council Glen Allen, VA 23060-6711 9 Susan Terrace Waterford, CT 06385 Mr. David W. Dodson Licensing Supervisor Mr. Evan W. Woollacott Dominion Nuclear Connecticut, Inc.

Co-Chair Rope Ferry Road Nuclear Energy Advisory Council Waterford, CT 06385 128 Terrys Plain Road Simsbury, CT 06070

Millstone Power Station Unit 3 cc:

Mr. S. E. Scace Assistant to the Site Vice President Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. M. J. Wilson Manager - Nuclear Training Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. A. J. Jordan, Jr.

Director - Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385 Mr. S. P. Sarver Director - Nuclear Station Operations and Maintenance Dominion Nuclear Connecticut, Inc.

Rope Ferry Road Waterford, CT 06385

ML031670914 *See previous concurrence OFFICE PDI-2/PM PDI-2/LA RORP/SC(A)* SPSB/SC* OGC* PDI-2/SC NAME VNerses CRaynor SMagruder RDennig SCole JBoska for JClifford DATE 9/25/03 9/25/03 6/25/03 7/8/03 7/16/03 9/26/03 DOMINION NUCLEAR CONNECTICUT, INC., ET AL.

DOCKET NO. 50-423 MILLSTONE POWER STATION, UNIT NO. 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 216 License No. NPF-49

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the applicant dated August 14, 2002, as supplemented December 19, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public; and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations, and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-49 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 216, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license.

Dominion Nuclear Connecticut, Inc. shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of issuance, and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA by JBoska/

James W. Clifford, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 29, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 216 FACILITY OPERATING LICENSE NO. NPF-49 DOCKET NO. 50-423 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert i i xiv xiv 1-2 1-2 1-3 1-3 3/4 6-1 3/4 6-1 3/4 6-15 3/4 6-15 B 3/4 6-1 B 3/4 6-1 B 3/4 6-3 B 3/4 6-3 B 3/4 6-3a B 3/4 6-3a B 3/4 6-3b B 3/4 6-3b B 3/4 6-3c B 3/4 6-3c B 3/4 6-3d B 3/4 6-3d

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 216 TO FACILITY OPERATING LICENSE NO. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION, UNIT NO. 3 DOCKET NO. 50-423

1.0 INTRODUCTION

By letter dated August 14, 2002, as supplemented by letter dated December 19, 2002, Dominion Nuclear Connecticut, Inc. (the licensee), submitted a request for changes to the Millstone Power Station, Unit No. 3 Technical Specifications (TSs). The requested changes would modify various specifications pertaining to containment isolation valves (CIVs) to clarify existing requirements, make wording improvements, revise existing limiting conditions for operation (LCOs), action statements, surveillance requirements (SRs), and to add an action statement that would increase the allowed outage time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for CIVs in closed systems.

The applicable current technical specifications (CTS) Bases have been revised to document the proposed technical specifications (PTS) changes and to provide supporting information. The December 19, 2002 letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination or expanded the application beyond the scope of the original Federal Register notice.

2.0 REGULATORY EVALUATION

In Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, the U.S. Nuclear Regulatory Commission (NRC or the Commission) established its regulatory requirements related to the content of TSs. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences. The Commission noted that applicants were expected to incorporate into their TSs those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity, as set forth in Statement of Consideration, Technical Specifications for Facility Licenses; Safety Analysis Reports, (33 FR 18610, December 17, 1968). Pursuant to 10 CFR 50.36(c), TSs are required to include items in a number of specific categories. Five of these specific categories related to station operation include: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plants TSs.

On July 22, 1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Atomic Energy

Act of 1954, as amended, and 10 CFR 50.36 (58 FR 39132). The Final Policy Statement described the safety benefits of the standard technical specifications (STS), and encouraged licensees to use the STSs as the basis for plant-specific TS amendments, and for complete conversions to improved technical specifications (ITSs) based on the STS.

The NRC staff (staff) finds that the licensee, in its application, identified the applicable regulatory requirements. The regulatory bases for which the staff based its acceptance criteria are:

  • The model TSs contained in the improved STS, NUREG-1431, Revision 2, Standard Technical Specifications, Westinghouse Plants, dated October 10, 2001.

3.0 TECHNICAL EVALUATION

The staff has reviewed the licensees regulatory and technical analyses in support of its proposed license amendment which are described in the licensees application.

3.1 Revision to Definition Containment Integrity (CTS 1.7.a)

The proposed changes to CTS 1.7.a are:

1. A footnote is added to the definition of Containment Integrity (CTS 1.7.a.1) that explains how the requirement for an Operable containment automatic isolation valve system is satisfied in Mode 4.
2. The references to operator action and the administrative control of opened CIVs will be relocated to PTS 3/4.6.3 and its associated Bases. The reference to CTS 4.6.1.1.a will also be deleted as a result of the change.
3. Additional text was added to CTS 1.7.a.2 to take exception for CIVs that are opened under administrative control.

The addition of the

  • footnote to CTS 1.7.a.1, explaining how the requirements for an Operable automatic CIV system is satisfied in Mode 4, is needed because the automatic containment isolation signals generated by low pressurizer pressure and high containment pressure are not required to be Operable when the plant is in Mode 4, per CTS 3/4.3.2, Engineered Safety Features Actuation Systems (ESFAS) Instrumentation, Table 3.3-3, Functional Unit, items 1.c and 1.d. Also, the low pressurizer pressure signal is blocked during the plant cooldown. This change is acceptable because in Mode 4, automatic actuation of ESFAS functions are not required consistent with CTS 3/4.3.2.

Because of the large number of valves actuated by a containment isolation actuation signal (CIAS), actuation is simplified by the use of the manual pushbuttons. Since the manual CIAS pushbuttons are required to be Operable in Mode 4, per CTS 3/4.3.2, Table 3.3-3, credit can be taken for remote manual operation to close the CIVs. The staff finds this change acceptable because it continues to meet GDC 56.

The change that deletes the phrase in CTS 1.7.a.1 that references operator action during periods when CIVs are opened under administrative control relocates this information to the Bases. In the PTS, the use of administrative control for CIVs is based upon the application of the guidance in GL 91-08. The approach presented in this guidance is that the removal from the TS does not alter existing TS requirements or those components to which they apply. The guidance in GL 91-08 includes the use of plant procedures that are subject to the change control provisions for plant procedures in the Administrative Controls Section of the TSs.

Details for performing actions and SRs are specified in the plant procedures required by the updated final safety analysis report (UFSAR) and ITS Bases. As indicated in GL 91-08, allowing this procedures control is consistent with other SRs that do not dictate plant conditions for surveillances. Prescriptive procedural information in an action requirement is unlikely to contain all procedural considerations necessary for the plant operators to complete the actions required, and referral to plant procedures is, therefore, required in any event. Further, this guidance includes consideration for necessary operator actions. The PTS 3/4.6.3 Bases for CIVs includes this expanded discussion that related to these considerations. The removal of these kinds of procedural details from CTS 1.7.a.1 is acceptable, because they will not have an impact on the safe operation of the facility and, therefore, does not meet the criteria of 10 CFR 50.36(c)(5) for items to be included in the TSs. Procedural details will be controlled in the UFSAR and Bases, as appropriate. This approach provides an effective level of regulatory control and change control process.

The additional text to be added to CTS 1.7.a.2, that takes exception for valves that are opened under administrative control, is a clarifying and administrative type change. The change directs the operator to the appropriate specification for maintaining containment integrity with regard to administratively-opened CIVs. Even though this change does expand the number of CIVs allowed to be opened under administrative control to all CIVs, this change does not alter the intent of the definition or surveillance, has no impact on health and safety and is, therefore, acceptable.

3.2 Revision to Containment Integrity (CTS 3/4.6.1.1)

The proposed changes to CTS 3/4.6.1.1 are:

1. A new footnote 2" is added to CTS 4.6.1.1.a that explains how the requirement for an Operable containment automatic isolation valve system is satisfied in Mode 4.

Corresponding Bases changes are added to support this change.

2. The references to operator action and the administrative control of open CIVs in CTS 4.6.1.1.a, as well as the associated ** footnote, will be relocated to PTS 3/4.6.3, and its associated Bases.
3. Additional text was added to CTS 4.6.1.1.a to make specific reference to the administrative controls for open CIVs permitted by PTS 3/4.6.3 and the Bases for CTS 3/4.6.1.1 has been modified.
4. The
  • footnote, associated with CTS 4.6.1.1.a, is relabeled as footnote (1).
5. A new footnote (3) will be added to CTS 4.6.1.1.a to state that isolation devices in high radiation areas may be verified by use of administrative means.

The addition of footnote 2" to CTS 4.6.1.1.a, explaining how the requirements for an Operable automatic CIV system is satisfied in Mode 4, is needed because the automatic containment isolation signals generated by low pressurizer pressure and high containment pressure are not required to be Operable when the plant is in Mode 4, per CTS 3/4.3.2 Engineered Safety Features Actuation Systems (ESFAS) Instrumentation Table 3.3-3, Functional Unit, items 1.c and 1.d. Also, the low pressurizer pressure signal is blocked during the plant cooldown. This is acceptable because in Mode 4, automatic actuation of ESFAS functions are not required consistent with CTS 3/4.3.2.

The change that deletes the phrase in CTS 4.6.1.1.a that references operator action during periods when CIVs are opened under administrative control relocates this information to the Bases. In the PTS, the use of administrative control for CIVs is based upon the application of the guidance in GL 91-08 The approach presented in this guidance is that the removal from the TS does not alter existing TS requirements or those components to which they apply. The guidance in GL 91-08 includes the use of plant procedures that are subject to the change control provisions for plant procedures in the Administrative Controls Section of the TSs.

Details for performing actions and SRs are specified in the plant procedures required by the UFSAR and ITS Bases. As indicated in GL 91-08, allowing this procedures control is consistent with other SRs that do not dictate plant conditions for surveillances. Prescriptive procedural information in an action requirement is unlikely to contain all procedural considerations necessary for the plant operators to complete the actions required, and referral to plant procedures is, therefore, required in any event. Further, the guidance in GL 91-08 includes consideration for necessary operator actions. The PTS 3/4.6.3 Bases for CIVs includes this expanded discussion that related to these considerations. The removal of these kinds of procedural details from CTS 4.6.1.1.a. is acceptable, because they will not have an impact on the safe operation of the facility and, therefore, does not meet the criteria of 10 CFR 50.36(c)(5) for items to be included in the TSs. Procedural details will be controlled in the UFSAR and Bases, as appropriate. This approach provides an effective level of regulatory control and change control process.

The additional text to be added to CTS 4.6.1.1.a that takes exception for valves that are opened under administrative control is a clarifying and administrative type change. The change directs the operator to the appropriate specification for maintaining containment integrity with regard to administratively-opened CIVs. Even though this change does expand the number of CIVs allowed to be opened under administrative control from those valves specified in CTS 4.6.1.1.a footnote ** to all CIVs, this change does not alter the intent of the definition or surveillance, has no impact on health and safety and is, therefore, acceptable.

The ** footnote in CTS 4.6.1.1.a, was initially addressed in License Amendment No. 28. The change, approved by the staff on December 19, 1988, relocated the valve list included in CTS

Table 3.6-2, Containment Isolation Valves. The purpose of the ** footnote to CTS 4.6.1.1.a, was to provide reasonable operational flexibility regarding containment penetrations by retaining the provision for the use of administrative controls. However, in the current application, the licensee requested to relocate the footnote to CTS 3/4.6.3. The details of this specific change, which the staff found acceptable, is addressed in Section 3.3.

Because of the large number of valves actuated by a CIAS, actuation is simplified by the use of the manual pushbuttons. Since the manual CIAS pushbuttons are required to be Operable in Mode 4, per CTS 3/4.3.2, Table 3.3-3, credit can be taken for remote manual operation to close the CIVs. The Bases for CTS 3/4.6.1.1 has been modified to discuss the Operability of the CIVs in Mode 4 by using the manual actuation pushbuttons to initiate closure of the CIVs. In addition, the Bases discussion emphasizes that the automatic actuation logic and actuation relays must also be Operable in Mode 4, per CTS 3/4.3.2, Table 3.3-3, to support system-level manual initiation. The staff finds these changes acceptable because it continues to meet GDC 56.

The relabeling of footnote

  • is considered administrative, it has no impact on health and safety and is, therefore, acceptable.

Verification by administrative means for isolation devices in high radiation areas is considered acceptable since access to these areas is typically restricted. Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper position, is small. This requirement provides a practical means to perform this verification in high radiation areas and, therefore, the staff considers the new footnote (3) is acceptable.

3.3 Revision to Containment Isolation Valves (CTS 3/4.6.3)

The proposed changes to CTS 3/4.6.3 are:

1. The existing footnote
  • to CTS 3.6.3 is renumbered as footnote (1).
2. A new footnote (2) will be added to CTS 3.6.3 to state that CIVs may be opened on an intermittent basis under administrative controls.
3. The wording of CTS 3.6.3 will be modified by the deletion of the words with isolation times less than or equal to the required isolation times. The revised text of this LCO will simply state that the CIVs shall be Operable.
4. The wording of the Action statement for CTS 3.6.3 is modified from maintain at least one isolation valve Operable in each effected penetration that is open and: to maintain at least one isolation barrier Operable in the affected penetration(s) and:.
5. A new Action item d is added to CTS 3.6.3 Actions that states the following: Isolate the affected penetration with only one containment isolation valve and a closed system within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange; or.
6. Various editorial changes are being made to the Action statement text. Action items a.

through d. will be changed to items a. through e. to accommodate the separate allowed outage time (AOT) related to isolation valves in closed systems. Other changes to the text are made to clarify each items text.

7. Corresponding Bases changes are added to support some of these changes and describe what constitutes an Operable isolation barrier.

Renumbering footnote

  • is an editorial change with no change in requirements and is, therefore, acceptable.

The proposed change relocates the footnote ** in CTS 4.6.1.1.a to a footnote (2) in PTS 3/4.6.3. In addition to relocating the footnote, the licensee requests changing the sentence The following valves may be opened on an intermittent basis under administrative control to Containment Isolation valves may be opened on an intermittent basis under administrative controls. The licensee also eliminated the listed valves in footnote ** in CTS 4.6.1.1.a, since the proposed footnote to PTS 3/4.6.3 expands its scope to all CIVs, which include the valves listed in footnote **. With these proposed changes, the LCO requirements will continue to ensure that the structures, systems and components are maintained consistent with the safety analyses and licensing basis. Therefore, these proposed changes are acceptable because they continue to meet 10 CFR 50.36(c)(2)(ii).

The added footnote to PTS 3/4.6.3 allows any CIV (not just locked or sealed closed valves) to be opened on an intermittent basis under administrative controls. The administrative controls that are used and described in the revised Bases for CTS 3/4.6.3, provide the same level of protection regardless of whether the flow paths include locked or sealed valves. Administrative controls are in procedures, and the considerations for administrative controls are stated in the Bases. Therefore, the administrative controls include considerations that containment integrity will be established, when required. This provides assurance that these valves will be closed, and that allowing them to be opened will not adversely impact the consequences of the analyzed FSAR Chapter events. Thus, the staff finds this change acceptable because there is no reduction in requirements and there is no impact on health and safety.

The deletion of the LCO requirement in CTS 3.6.3 on isolation times is consistent with GL 91-08. GL 91-08 recognized that the removal from the TS of a table listing CIVs could also remove valve isolation times that were included in the table, and that this would not alter the TS requirements to verify the times. In this change, there is no reduction in requirements for verification of OPERABILITY of CIVs since the isolation time verification is captured by CTS 4.6.3.3. Therefore, this is a clarifying change with no reduction in requirements and with no impact on health and safety and is, therefore, acceptable.

To remove any ambiguity, changes to the CTS 3.6.3 Action statement were made by replacing the word valve with the word barrier in the statement, and the words each affected penetration that is open with the affected penetration(s). The term barrier that is used in this PTS 3.6.3 Action is described by PTS 3.6.3 Bases to be synonymous with either a CIV, or the closed system that is associated with containment penetrations that conform to GDC 57 applications for closed system isolation valves. As is required by the CTS, in PTS 3.6.3 Action, an immediate shutdown will be required by entry to either CTS 3.0.3, or to PTS 3.6.3.e, when two isolation valves in a penetration are not OPERABLE, or when at least one isolation valve is

not OPERABLE and the OPERABLE isolation barrier in the affected penetration is not maintained. This change clarifies the applicability of the Action to GDC 57 applications, and will not modify requirements of the CTS 3.6.3 for CIVs. Similarly, the words each affected penetration that is open are synonymous with the proposed words that state the affected penetration(s). The changes are proposed to improve consistency in the format of this Actions text without modifying the Actions applicability or the CTS 3.6.3 operability requirements.

These changes are considered editorial; they have no impact on health and safety, therefore, the staff finds the changes acceptable.

Under the current TS requirements, penetrations that have only one CIV and a closed system are not differentiated from penetrations that have two or more CIVs. With an inoperable CIV, any type of penetration that is affected would require to be isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or less in accordance with current the TSs. The proposed new TS would provide an action statement specific to penetrations that have only one CIV and a closed system and would increase the AOT for isolating these type penetrations. Specifically, the proposed change will add a separate AOT (Action item d.) to incorporate the changes included in TSTF-30 and STS 3.6.3 Action C of NUREG-1431, Revision 2, which allows an AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for those penetrations with a single CIV and a closed system. Consistent with Required Actions in TSTF-30 and STS 3.6.3 Action C of NUREG-1431, Revision 2, the verification of the affected penetration flow path that is isolated would be required at least once per 31 days by PTS 4.6.1.1.a. The proposed increase to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (CTS 3.6.3 action d requires immediate shutdown) is considered reasonable given that certain valves may be located inside containment, considering the reliability of the closed system to act as a penetration isolation barrier, given the relative importance of maintaining containment integrity in Modes 1, 2, 3, and 4, and that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is typically provided for losing one train of redundancy throughout the Millstone, Unit No. 3 TSs (e.g., AOT for restoration of one emergency diesel generator is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). Based on the considerations noted above, the staff finds this change acceptable.

3.4 Summary The staff has reviewed the changes associated with CTS/PTS 1.7, 3/4.6.1.1, 3.6.3, and their associated Bases, and based on the considerations discussed for each change, finds them acceptable. Also, the changes are consistent with NUREG-1431.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Connecticut State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, and changes SRs.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (67 FR 61678). Accordingly, the amendment meets the eligibility criteria for categorical

exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Giardina V. Nerses Date: September 29, 2003

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