Text

Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month.
	ML19109A100
Person / Time
Site:	Millstone
Issue date:	04/11/2019
From:	Mark D. Sartain; Dominion Energy Nuclear Connecticut
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	18-370
	Download: ML19109A100 (47)
	v • d • e

Dominion Energy Nuclear Connecticut, Inc.

~ Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Energy.com April 11, 2019 pr Energy U.S. Nuclear Regulatory Commission Serial No.18-370 Attention: Document Control Desk NSSL/TFO RO Washington, DC 20555 Docket Nos. 50-336 50-423 License Nos. DPR-65 NPF-49 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION "SYSTEM SURVEILLANCE REQUIREMENTS TO OPERArE FOR 10 HOURS PER MONTH" In accordance with the provisions of 10 CFR 50.90, Dominion Energy Nuclear Connecticut, Inc. (DENG) is submitting a request for an amendment to the Technical Specifications (TS) for Millstone Power St~tion

Unit 2 (MPS2) and Millstone Power Station Unit 3 * (MPS3). DENG proposes to adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month,"* and decrease ventilation system flow test requirements from 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months at the frequency specified in the MPS2 and MPS3 Surveillance Frequency Control Program (SFCP), to 15 continuous minutes at the frequency specified in the SFCP.

For MPS2, the r_evision is proposed for TS Surveillance Requirement (SR) 4.6.5.1 for the Enclosure Building Filtration System (EBFS). For MPS3, the revision is proposed for TS SR 4.6.6.1 for the Supplementary Leak Collection and Release System (SLCRS), TS SR 4.7.7 for the Control Room Emergency Ventilation System (CREVS), and TS SR 4.7.9 for th_e Auxiliary Building Filter System (ABFS).

Additionally, it is proposed that MPS2 TS SR 4.6.5.1.a be revised to remove the requirement to run the flow test with t_he duct heaters energized since the charcoal adsorption test is performed at 95% relative humidity. to this letter describes the proposed changes and provides justification for the changes. Attachment 2 provides marked-up MPS2 TS pages showing the proposed change. Attachment 3 provides marked-up MPS2 TS Bases pages showing the proposed change. Attachment 4 provides marked-up MPS3 TS pages showing the proposed change. Attachment 5 provides marked-up MPS3 TS Bases pages showing the proposed changes. The TS Bases mark-ups are provided for information only. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program after this LAR is approved.

The proposed amendment does not involve a Significant Hazards Consideration under the standards set *forth in 10 CFR 50.92. The basis for this determination is

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Serial No: 18-370 Docket Nos. 50-336/423 Page 2 of 3

" included in Attachment 1. DENC has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

The Facility Safety Review Committee has reviewed and concurred with the determinations herein.

DENC requests approval of this license amendment request by May 1, 2020, with implementation within 60 days of issuance.

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

If you have any questions or require additional information, please contact Mr.

Shayan Sinha at (804) 273-4687.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support 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 and Fleet Support of Dominion Energy Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document on behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

,th " .

/

Acknowledged before me this J..C.:_day of 1-tpr1 \ , 2019.

My Commission Expires: \ 2.( 31 J~

hoNotary~Publid#'UU l

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Serial No: 18-370 Docket Nos. 50-336/423 Page 3 of 3

.Attachments:

1. Evaluation of Proposed License Amendment

2. Marked-Up Technical Specification Pages for MPS2

3. Marked-Up Technical Specification Bases Pages for MPS2 for Information Only 4.* Marked-Up Technical Specification Pages for MPS3

5. Marked-Up Technical Specification Bases Pages for MPS3 for Information Only Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Richard V. Guzman Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2 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: 18-370 Docket Nos. 50-336/423 ATTACHMENT 1 EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 and 3

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 1 of 7 EVALUATION OF PROPOSED LICENSE AMENDMENT 1.0

SUMMARY

DESCRIPTION In accordance with the provisions

of 10 CFR 50.90, Dominion Energy Nuclear Connecticut, Inc. (DENG) is submitting a request for an amendment to the Technical Specifications (TS) for Millstone Power Station Unit 2 (MPS2) and Millstone Power Station Unit 3 (MPS3). DENG proposes to adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," and decrease ventilation system flow test requirements from 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months at the frequency specified in the MPS2 and MPS3 Surveillance Frequency Control Program (SFCP), to 15 continuous minutes at the frequency specified in the SFCP. For MPS2, the revision is proposed for TS Surveillance Requirement (SR) 4.6.5.1 for the Enclosure Building Filtration System (EBFS). For MPS3, the revision is proposed for TS SR 4.6.6.1 for the Supplementary Leak Collection and Release System (SLCRS), TS SR 4.7.7 for the Control Room Emergency Ventilation System (CREVS), and TS SR 4.7.9 for the Auxiliary Building Filter System (ABFS). Additionally, it is proposed that MPS2 TS SR 4.6.5.1.a be revised to remove the requirement to run the flow test with the duct heaters energized since the charcoal adsorption test is performed at 95% relative humidity.

These proposed changes do not impact the ability of EBFS, ABFS, CREVS, and SLCRS to perform their safety functions. Therefore, the proposed changes will not adversely affect control room habitability or result in any, significant increase in individual or cumulative occupational radiation exposure.

2.0 ASSESSMENT DENG proposes to adopt TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," (Reference 5.1) for MPS2 TS SR 4.6.5.1.a, and for MPS3 TS SRs 4.6.6.1.a, 4.7.7.b, and 4.7.9.a. These SRs currently require operating associated ventilation systems, with the heaters operating, for a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period at the frequency specified in the SFCP. The proposed change would modify these SRs to require operation of the systems for 15 continuous minutes at the frequency specified in the SFCP.

Additionally, it is proposed that MPS2 TS SR 4.6.5.1.a be revised to remove the requirement to conduct the flow test with the duct heaters energized. The charcoal filter adsorption test is performed at a relative humidity of 95%. TSTF-522 indicates that, in accordance with Regulatory Position 4.9 of Regulatory Guide 1.52, Revision 3, (Reference 5.2), plants that perform adsorption testing with a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function. In this case, TSTF-522 indicates that plants may eliminate reference to the heaters in the TS and TS Bases. provides marked-up MPS2 TS pages showing the proposed change. provides marked-up MPS2 TS Bases pages showing the proposed change. Attachment 4 provides marked-up MPS3 TS pages showing the proposed

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 2 of 7 changes. Attachment 5 provides marked-up MPS3 TS Bases pages showing the proposed changes. The TS Bases mark-ups are provided for information only. '

2.1 Applicability of Published Safety Evaluation DENG has reviewed the model safety evaluation (Reference 5.3) dated September 13, 2012 and issued in the Federal Register (Reference 5.4) on September 20, 2012 (77 FR 58421). This review included a review of the Nuclear Regulatory Commission (NRC) staff's evaluation, as well as the information provided in TSTF-522, Revision 0. DENG has concluded that the justification presented in the TSTF-522, Revision O proposal and the model safety evaluation prepared by the NRC staff are applicable to Millstone Power Station (MPS) and justify this amendment for the incorporation of the changes to the MPS TS.

2.2 Optional Changes and Variations DENG is proposing the following variations from th~ TS changes described in TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation dated September 13, 2012:

1. The NRC's model safety evaluation noted that some plants havecadopted TSTF-425, which relocated the fixed Surveillance Request Frequencies to a licensee-controlled SFCP. The SFCP was adopted under License Amendment 324 (Reference 5.5) for MPS2 and License Amendment 258 (Reference 5.6) for MPS3. The MPS2 and MPS3 SFCP currently specify performing filter runs every 31 days for the TS SRs being changed.

2. MPS2 and MPS3 have custom TSs. The inserts provided in TSTF-522 are revised to fit the MPS2 and MPS3 TS formats. Where the SR specifies "10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ", the SR is being revised to specify "15 continuous minutes". Where the SR specifies "10 continuous hours", the SR is being revised to specify "15 continuous minutes".

3. The MPS2 TS uses different numbering and titles than the Combustion Engineering Owners Group (GEOG) Standard Technical. Specifications (STS)

NUREG-1432 (Reference 5.7), which was the basis for the TSTF-522 mark-ups for Combustion Engineering plants. The difference is administrative and does not affect the applicability of TSTF-522 to the MPS2 TS. The table below shows the differences between the plant-specific TS numbering and titles and the corresponding TSTF-522 numbering and titles:

MPS2 TS TSTF-522 CEOG STS Number and Title Number and Title TS 3/4.6.5.1, Secondary Containment TS 3.6.8, Shield Building ~xhaust Air Enclosure Building Filtration System, Cleanup System (SBEACS) (Dual),

SR 4.6.5.1 SR 3.6.8.1

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 3 of 7

There are NUREG-1432 STS sections not contained in MPS2 TS. The corresponding mark-ups included in TSTF-522 for these surveillances are not identical to MPS2. Regulatory Guide 1.52 is applicable to the MPS2 Secondary Containment Enclosure Building Filtration System, because it is a post-accident Engineered Safety Feature (ESF) atmosphere cleanup system containing air filtration and adsorption units. Therefore, this is an administrative deviation from TSTF-522 with no impact on the NRC staff's model safety evaluation ..

Additionally, MPS2 does not have STS 5.5.11, "Ventilation Filter Testing Program (VTFP)". The requirements of the VFTP (laboratory test of a charcoal sample, HEPA filter bypass testing, and charcoal filter bypass testing) are performed as directed in TS 3/4.6.5.1.

4. The MPS3 TS uses different numbering and titles than the Westinghouse Owners Group (WOG) STS NUREG-1431 (Reference 5.8), which was t.he basis for the TSTF-522 mark-ups for Westinghouse plants. The difference is administrative and does not affect the applicability of TSTF-522 to the MPS3 TS. The table below shows the differences between the plant-specific TS numbering and titles and the corresponding TSTF-522 numbering and titles:

MPS3 TS TSTF-522 WOG STS I

Number and Title Number and Title TS 3/4.6.6. 1, Secondary Containment TS 3.6.13, Shield Building Air Cleanup Supplementary Leak Collection And System (SBACS) (Dual and Ice Release System, Condenser),

SR 4.6.6.1 SR 3.6.13.1 TS 3/4.7.7, Control Room Emergency TS 3.7.10, Control Room Emergency Ventilation System, Filtration System (CREFS),

SR 4.7.7 SR 3.7.10.1 TS 3/4.7.9, Auxilic;1ry Building Filter TS 3/4.7.14, Penetration Room System, Exhaust Air Cleanup System, SR 4.7.9 (PREACS) TS 3.7.14.1 There are NUREG-1431 STS sections not contained in MPS3 TS. The corresponding mark-ups included in TSTF-522 for these surveillances are not identical to MPS3. Regulatory Guide 1.52 is applicable to the MPS3 systems because they are post-accident Engineered Safety Feature (E:SF) atmosphere cleanup system containing air filtration and adsorption units. Therefore, this is an administrative deviation from TSTF-522 with no impact on the NRC staff's model safety evaluation dated September 20, 2012 (77 FR 58421). Additionally, MPS3 does not Have STS 5.5.11, "Ventilation Filter Testing Program (VTFP)". The requirements of the VFf P (laboratory test of a charcoal sample, HEPA filter bypass testing*, and charcoal filter bypass testing) are performed as directed in TS 3i4.6.6.1, 3/4.7.7, and 3/4.7.9.

The proposed changes are consistent with the current licensing basis, the NRC's model safety evaluation, and therefore, are an allowable variation from the approved Traveler.

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 4 of 7

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration DENC is submitting a request for an amendment to the TS for MPS2 and MPS3. DENC proposes to adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," and decrease the ventilation system flow durations from 1O hours at the frequency specified in the SFCP, to 15 continuous minutes at the frequency specified in the SFCP. For MPS2, the revision is proposed for TS SR 4.6.5.1 (EBFS). For MPS3, the 1 revision is proposed for TS SR 4.6.6.1 (SLCRS), TS SR 4.7.7 (CREVS), and TS SR 4.7.9 (ABFS). The proposed change revises the SRs which currently require operating ventilation systems with the heaters operating for a 1O hour period at the frequency specified in the SFCP with a requirement to operate systems for 15 continuous minutes at the frequency specified in the SFCP. Additionally, it is proposed that MPS2 TS SR 4.6.5.1.a be revised to remove the requirement to conduct the flow test with the duct heaters energized since the charcoal adsorption test is performed at 95% relative humidity.

As required by 10 CFR 50.91 (a), an analysis of the issue of no significant hazards consideration is presented below using the guidance provided in 10 CFR 50.92 and TSTF-522:

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

Response: No.

The proposed change modifies existing SRs to operate the EBFS system for MPS2 and ABFS, CREVS, and SLCR.S systems for MPS3 that are equipped with electric heaters for a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period at the frequency specified in the SFCP with a requirement to operate the systems for 15 continuous minutes. Additionally, the SR for EBFS will be revised to remove the requirement conduct the flow test with the duct heaters energized since the charcoal adsorption test is performed at 95%

relative humidity.

These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function which may include mitigating accidents. Thus the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 5 of 7

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change modifies existing SRs to operate the EBFS, ABFS, CREVS, and SLCRS systems equipped with electric heaters for a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period at the frequency specified in the SFCP with a requirement to operate the systems for 15 continuous minutes. Additionally, the SR for EBFS will be revised to remove the requirement conduct the flow test with the duct heaters energized since the charcoal adsorption test is performed at 95% relative humidity.

The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions.

The change does not create new failure modes or mechanisms and no new

. accident precursors are generated.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed change modifies existing SRs to operate the EBFS, ABFS, CREVS, and SLCRS systems equipped with electric heaters for a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months period at the frequency specified in the SFCP with a requirement to operate the systems for 15 continuous minutes. Additionally, TSTF-522 identifies a regulatory position which indicates that plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function systems and that reference to the heaters can be removed from the TS. Based on justification provided in TSTF-522, the existing SR for EBFS will be revised to remove the requirement to complete the ventilation system test with the duct heaters energized since the adsorption test is performed at 95%

relative humidity. EBFS will continue to have the heaters, but they will not be credited in the TS.

The design basis for the ventilation systems' heaters is to heat the incoming air which reduces the relative humidity. Per TSTF-522, the monthly 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months system operation utilizing the heaters was intended to remove moisture from the charcoal adsorber banks. Because the ASTM D3803-1989 Standard no longer requires this 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months operation utilizing the heaters, the duration is replaced with a continuous 15 minute operation requirement. The proposed change is consistent

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 6 of 7 with guidance provid_ed in Regulatory Position 4.9 of Regulatory Guide 1.52, Revision 3.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, DENG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that 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 effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

5.0 REFERENCES

5.1 Technical Specification Task Force TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per Month,"

(ML 100890~16), approved September 20, 2012.

5.2 NRC Regulatory Guide 1.52, "Design, Testing, and Maintenc~nce Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants", Revision 3 (ML011710176), issued June 2001.

5.3 NRC Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per Month," Using the Consolidated Line Item Improvement Process issued on September 20, 2012 (77 FR 58421).

5.4 Model Safety Evaluation for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," Using the Consolidated Line Item Improvement Process (ML12158A464), dated September 13,2012.

Serial No.18-370 Docket Nos. 50-336/423 Attachment 1, Page 7 of 7 5.5 Letter from R. V. Guzman (NRC) to D. A. Heacock (Dominion), "Millstone Power Station, Unit No. 2 - Issuance of Amendment re: Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program, Adoption of TSTF-425, Revision 3 (TAC No. MF5096),"

(ML15280A242), dated October 29, 2015.

5.6 Letter from J. Kim (NRC) to D. A. Heacock (Dominion), "Millstone Power Station, Unit No. 3 - Issuance of Amendment re: Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program, Adoption of TSTF-425, Revision 3 (TAC No. ME9733),"

(ML14023A748), dated February 25, 2014.

5.7 NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Specifications (ML12102A165), published April 2012.

5.8 NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications (ML 121 OOA222), published April 2012.

r

Serial No.18-370 Docket No. 50-336 ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES FOR MPS2 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.18-370 Docket No. 50-336 Attachment 2, Page 1 of 3 CONTAINMENT SYSTEMS 3/4.6.5 SECONDARY CONTAINMENT ENCLOSURE BUIIDING FILTRATION SYSTEM LIMITINGCONDll10NFOROPERATION 3.65.1 Twosepante andindependentEnclosm:eBuilctiDgFilba1icm.1iains shall be OPERABLE.

APPLICABlI.JIY: MODES 1,2,3:md4.

ACTION:

a. a.

at east one mun contamroeut spray JS OPERABLE within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months orbe in COID

NO!E----

SHUIDOWNwitbinthenext 36 homs..

Not applicable when second Enclosure Building Filllation Ai.'ID Train intentionally made inoperable. b.2 Restore at least one Enclosure Building Ftltration Train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in COID SHUIDOWN '11ithin the next 36 hams.

Two Enclosure Building Filtration Trnins.

SURVEILLANCE REQUIREMENTS 4.65.1 Each Enclosure Building Ftltr.ltion Tolin shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Program by r,.

initiating, from the control room, flow through the HEPA filter and charcoal adsorl>er train and verifying that the train opemtes for at least 10-hOUl'S-?Jith-the I' b.

-heatem-on. !15 continuous minutes j_1l At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or chan:oal adsorber-housings, and (2) followiDg painting, fire or chemical release in any ventilation zone I

COIDDlUllic:ati with the train by:

MILLSTONE-UNIT 2 3/46-25 AmeudroeutNo.~.m,~

Serial No.18-370 Docket No. 50-336 Attachment 2, Page 2 of 3 CONTAINMENT SYSTEMS

!Provided for Information Oruy I October 29. 2015 SURVEILLANCE REQUIREMENTS (Continued)

1. \mij,ing 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 ofRegulatozy Guide 1.52, Re\ision 2, March 1978, and the train flowrateis9000 c:lin+/- 10%.

2. Verifying v.iitbin. 31 days after removal that a laboratOiy analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b ofRegu]atozy Guide 1.52, Revision 2, March 1978, meets the Jaboratory testing criteria of Regulatory Position C.6.a ofRegulatoi:y Guide 1.52, Revision 2, March 1978.*

3. Verifying a train flow rate of 9000 c:li:n +/- 10% during train operation when tested in accordance with ANSIN510-1975.

c. Afierevery720 h!llllS of charcoal adsotber operation by verifying within 31 days after removal that a laboratory analysis of a representi.tive 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 ofRegulatory Position C.6.a of Regulatozy Guide 1.52, Revision 2, March 1978.*

d. At the frequency specified in the Surveillance Frequency Control Program by:

L Verifying that the pressure drop across the combined HEPA filters and chan:oal adsoroer banks is s 2.6 inches Water Gauge while operating the train at a flow rate of9000 din+/- 10%.

2. Verifying 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 &~SI N510-1975 while operating the train at a flow rate of9000 din+/- 10%.

ASThI D3803-89 shall be used in place of ANSIN509-1976 as referenced in table 2 of Regulatory Guide 1.52. The laboratory test of chan:oal should be conducted at a temperature of 30°C and a relative humidity of 95% within the tolerances .specified by ASTM D3803-89.

Additionally, the cban:oal sample shall have a rem.oval efficiency of~ 95%.

MILLSTONE- UNIT 2 3/46-26 Amendment No.~.~.~. :;iG&, ~ .

324

Serial No.18-370 Docket No. 50-336 Attachment 2, Page 3 of 3 IProvided fair Information Only I October 29, 2015 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

f. After each complete or partial replacement of a charcoal aclsorbe:r bank by verifying that the charcoal aclsorbers remove greater than or eqna1 to 99% of a halogenated hydrocarbon reftigerant test gas when they are tested in-place in accordance with ANSI NSl0-1975 while operating the train at a flow rate of9000 din+/-l0%.

MIILSTONE- UNIT 2 3/46-27 Amendment No. :;;Q3, 324

Serial No.18-370 Docket No. 50-336 ATTACHMENT 3 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES FOR MPS2 FOR INFORMATION ONLY DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.18-370 Docket No. 50-336 Attachment 3, Page 1 of 2

!Provided for Information Only I LBDCR.14~ 891 May-28;-ffl4 CONTAINMENT SYSTEMS BASES 314.65 SECONDARY CONI'AINMENT 3/4.65.1 ENCLOSUREBUilDING FJLTRATION SYSTEM The OPERABILITY ofthe Enclosme Building Filtration System ensures that cootamroeot leakage occmring during LOCA conditions into the amm1us will be filtered through the HEPA filtel!; and cmm:oal adsmbertrains prior to discbaigeto the atmosphere. This requirement is necessatyto meet the assumptions use.din the accident analyses and limit the SITE BOUNDARY radiation doses to within the limits of 10 CFR. 50_61 during LOCA conditions_

Wlfh one Enclosure BuildingFiltra1ion S:ystem Train inoperable, the inoperable train must be restored to OPER1\BLE status within 7 dajs_ The componeols in this degladed condition.are capable ofproviding 100% ofthe iodine removal needs atlera OBA The 7 day allowed outage 1ime is based on coosideiation of such :factms as the availability ofthe OPERABLE redundant Enclosure Building Filtration System Train and the low _probability of a DBA occmring during this period Iftwo Enclosure BuildingFiltra1ion System Tl3ins are inoperable, at least oneEnclosure Building Filtration System Train urust beretumed to OPERABLE status within 24 homs.. The Condition is modified by a Note slating it is not applicable if the second Enclosure Building Filuation System train is intentionally declared inoperable. The Condition does not apply to volontaiyremoval ofredundant SjStems or components fi:om service.. The Condition is only applicable if one train is inoperable for any reason and the second train is discovered to be inoperable, or ifboth trains are discovered to be inoperable at the same time. In addition, at least one train of containment spray urustbe verified to be OPERABLE within I hout. In the event of an accident, contlinment spray reduces the poteotial raclioacliverelease from the mntrinment, which reduces the consequences of the inoperable Enclosure BuildingFiltra1ion System Trains_

The allowed ont!ge 1ime is based on Reference I which demonstrated that the 24 hone allowed outage time is acceptable based on the illmquent use ofthe Ra¢red Actions and the small inaemen131 eflect on plant risk

'-Th,,faboiatmytestingrequjremeotfurthFchan:oalsampletollavearemovalefficiencyof

~ 95% ~ conservative than the elemental and mganic iodine removal efficiencies of90%

and 70%, ~ assumed in theDBA analyses fur the EBFS chaicoal adsomers in the Millstone Unit 2 Fin;il Safety Analysis Report_ A removal efficiency acceptance aiteria oP- 95%

will ensure the chaicoaNlas the capability to perlimn its intended safety function tbroughout the length of an opera1ing Operating each Enclosure Building Filtration System train for greater than or equal to 15 minutes ensures that all trains are OPERABLE and that all associated controls are functioning property_ It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action_ Per TSTF-522, the fiTter heaters are not required for the filters to be

MILLSTONE- UNIT 2 OPERABLE since adsorption testing is performed at 95% relative humidity.

Serial No.18-370 Docket No. 50-336 Attachment 3, Page 2 of 2

!Provided for Information Only I LBDCR.14-MP2-016 Septembel" 4, 2014 CONTAINMENT SYSTEMS BASES 3/4.5.5.1 ENCLOSURE BUilDING FIL1RATION SYSTEM (Continued)

Smveillance Requirement 4.65.1.bl dictates the test irequem:y, method and acceptance aiteria for the EBFS tr.lins (cleanup ttains). These criteria all originate in the Regulatmy Position

.sections ofRegu]atoiy Guide 152. Rev. 2, March 1978 as discussed below:

Section C.5.a requires a visual inspection ofthe cleanup SjSlem be made before the ibJhm.ing tests, inaccordaru:e with thepmvisions ofsection5 ofANSINS10-197S:

in-place air flow distribution test D0Ptest activated carbon adsotber section leak test Section C.5.c requires the in-place Dioctyl phthalate (DOP) test for HEPA filters to section 10 of ANSI N510-1975. The HEPA :filters should be tested in place (1) initially, (2) at the ftequency specified in the Smveillance Frequency Control Program. and (3) fbllowing painting, fire, or chemical release in anyventilationzone comuuinicatingwith the system. The testing is to confirm a penelration ofless than or equal to 1%* at rated flow.

Section C.5.drequires the c:hareoal adsorber section to be leak tested with a gaseous halogenated hydrocarbon refrigerant. in accordance with section 12 of ANSINSl0-1975 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 the frequency specified in the Smveillance Frequency Control Program, (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.

REFERENCE

1. WCAP-16125-NP-A, "Justification for Ri.sk:-Jnfomied Modifications to Selected Technical Specifications for Conditions Leading to F.xigent Plant Shutdown," Revision 2, August 2010.

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.

"* Means that the charcoal adsorbex seclions will allow passage of less than or equal to l % of the injected test concentration ~ d the charcoal adsorbel" sections.

MILISfONE- UNIT 2 B3/46-5a Amendment No. 2Q8,

Serial No.18-370 Docket No. 50-423 ATTACHMENT 4 MARKED-UP TECHNICAL SPECIFICATION PAGES FOR MPS3 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 1 of 9

-F~14-CONTAINMENTSYSTEMS 3/4.6.6 SECONDARY CONTAINMENT SUPPLEMENTARYLEAKCOll.ECTION AND RELEASE SYSTEM LIMITINGCONDn10NFOROPERATION 3.6.6.1 Two imlependellf Supplementa!yl.eak Collection and Release Systems shall be OPERABLE with each system comprised of

a. one OPERABLE filter and fan. and

b. one OPERABLE Auxiliary Building FJ.lter System as defined in Specification 3.7.9.

APPUCABILITY: MODES 1, 2, 3, and 4.

ACUQN*

With one SUpplemeotuy Leak Collection and Release S}'Sfeminopelable, restore the inoper.lble system to OPERABLE s1atus within 7 days orbe in at least HOT STANDBY within the next 6 houtS and in COID SHUIDOWN within the fullowing 30 holltS.

SURVEILLANCE REQUIREMENTS 4.6.6.1 Each Sopplememacy Leak Collection and Release System shall be demonstrated OPERABLE:

a At the ftequency specified in the Smveillance Frequency Control Program by '1-initiating. fiom the control mom, flow through the HEPA :filte1S and chan:oal adsm:bers and vetifyjng a system flow rate of7600 cfin to 9800 din and that the 11 ~ continuous mtem operates for at least lO..confumous.l with the heaters operating.

minutes

b. At the ftequency specified in the Smveillance Frequency Control Progr.un and 'J-.

fullowing painting, fire, or chemical release in any ventilation.z.mre communicating with the system by:

1) Verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less !ban 0.05% and uses the test procedure guidance in Regnlatozy Positions C.5.a, C.5.c, and C5.d of Regulato,:y Guide 1.52, Revision 2, March 1978,"' and the system flow rate is 7600 cfin to 9800 din; MILISfONE- UNIT 3 3/46-19 AmeudmentNo.g, .Q., s:il, M, rn.

gQi, ~ . "258-

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 2 of 9 Febmary25, 2014 CONTAINMENT SYSTEMS !Provided for lllformation Only I SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying, within 31 days a:fter removal, that a laboratory analysis of a representative carbon. sample obtained in accordance with Regulatoiy Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,* shows the methyl iodide penetration less than or equal to 2.5% when tested in accordance with ASTM D3803-89 at a temperature of 30°C (86"F) and a relative humidity of70%; and

3) Verifying a system flow rate of7600 din to 9800 din during system operation when tested in accordance with ANSIN510-1980.

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 laboratoiy analysis of a representative carbon sample obtained in accordance with Regulatoiy Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,* shows the methyl iodide penetration less than or equal to 2.5% when tested in accordance withASThI D3803-89 at a temperature of30°C (86°F) and a relative humidity of 70%:

d. At the frequency specified in the Surveillance Frequency Control Program by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.25 inches Water Gauge while operating the system at a flow rate of7600 din to 9800 din,

2) Verifying that the system starts on a Safety Injection test signal, and

3) Verifying that the heaters dissipate 50 :::5 kW when tested in accordance with ANSIN510-1980.

ANSIN510-1980 shall be used in place of Ai'l'SI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

MILLSTONE- UNIT 3 3/46-20 Amendment No. f!, ~. &7, ~ . rn.

~ . -Hl4* .!Ge. 258

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 3 of 9 January 3, 1995

!Provided for lnfomiatiorn Only !

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration and.bypass leakage testing acceptance criteria ofless than 0.05% in accordance v..ith .Ai~SI N510-1980 for a DOP test aerosol while operating the system at a flow rate of7600 cfin to 9800 dm;and

f. After each complete or partial replacement of a charcoal adsorberbank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria ofless than 0.05% in accordance ,1,ith ANSI N510-1980 for a halogenated hydrocarbon refiigerant test gas wbile operating the system at a flow rate of7600 cJin to 9800 din.

MIILSTONE- UNIT 3 3/46-21

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 4 of 9

!Provided for Information Only September 18, 2008 PLANT SYSTEMS 3/4_7-7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDIDONFOR OPERATION 3.7.7 Two in.dependent Control Room Emergency Air Filtration Systems shall be OPERABLE..*

APPLICABILITY: MODES 1, 2, 3, and4_

During movement of recently irradiated fuel assemblies.

ACTION:

MODES 1, 2, 3 and 4:

a_ Wrth one Control Room Emergency Air Filtration System inoperable, except as speci:lied in ACTION c~ restore the inoperable system to OPERABLE status within 7 days or be in at'Ieast HOT STAi'lDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHlITDOWN within the following 30 homs_

b. With both Control Room Emergency Air filtration Systems inoperable. except as speci:lied in ACTION c~ restore at least one inoperable system to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months orbe in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUIDOWN within the following 30 hOUIS.

c. Wrth one or more Control Room Emergency Air Filtration Systems inoperable due to an inoperable CRE boundary, peifo1D1 the following:

1. Immediately initiate action to implement mitigating actions, and

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 haz.ards will not exceed limits, and mitigating actions are taken for exposure to smoke haz.ards, and

3. Restore CRE boundary to OPERABLE status within 90 days.

Otherwise, be in HOT STANDBY ,,ithin the next 6 homs and COID SHUIDOWN within the following 30 hOUIS.

During movement ofrecently irradiated fuel assemblies:

d. With one Control Room Emergency Air Filtration System inoperable. restore the inoperable system to OPERABLE status within 7 days. After 7 days, either initiate and maintain operation of the remaining OPERABLE Control Room Emergency Air Filtration System in the emergency mode of operation, or immediately suspend the movement of recently irradiated fuel assemblies..

The Control Room Envelope (CRE) bound:u:y may be opened intermittently under administrative control MIILSTONE- UNIT 3 3/4 7-15 AmendmentNo. .!,~,',~,~

243

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 5 of 9 PLAi'IT SYSTEMS 3/4.7.7 CONTROLROOMEMER.GENCYVENTILATION SYSTEM LilvllTING CONDIDON FOR OPERATION ACTION: (Continued)

e. With both Control Room.Fmergency Air Filtration Systems inoperable, orwith the OPERABLE Control Room Emergency Air Filtration System required to be in the emergency mode by ACTION cl. not capable ofbeing powered byan OPERABLE emergency power source, or with one or more Control Room Fmergency Air Filtration System Trains inoperable due to an inoperable CRE boundary, immediately suspend the movement of recently irradiated :fuel assemblies.

SURVEILLANCE REQUIREMENTS

4. 7.7 Each Control Room Emergency Air Ftllration System shall be demonstrated OPERABLE:

a. At the frequency specified in the Surveillance Frequency Control Progxam by verifying that the control room air temperature is less than or equal to 95"F;

b. At the frequency specified in the Surveillance Frequency Control Progxam by 'I,..

initiating, from the control room, flow through the HEPA filters and charcoal adsoroers and verifying a system flow rate of 1,120 din+/- 20% and that the system 11~ corntnnuous m11mtes operates for at least¥>-5,ootimrons.homs with the heaters operating; At the frequency specified in the Surveillance Frequency Control Progxam and following painting, :fire, or chemical release in any ventilation zone 1,

communicating with the system by:

1) Verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatoty Position C.5.a, C.5.c, and C.5.d of Regulatmy Guide 1.52, Revisions 2, March 1978,* and the system flow rate is 1,120 din:::::20%;

2) Verifying, ~ithin 31 days after removal, that a laboratoty analysis of a representative carbon sample obtained in accordance with Regulatmy Position C.6.b of Regulatoty Guide 1.52, Revision 2, March 1978,* shows the methyl iodide penetration less than or equal to 2.5% when tested in accordance with ASTM D3803-89 at a temperature of30°C (86°F), a relative humidity of 70%, and a face velocity of 54 ft/min; and

3) Verifying a system flow rate of 1,120 din+/- 20% during system operation when tested in accordance with ANSI N510-1980.

1vllLLSTONE- UNIT 3 3/4 7-16 Amendment No. ~~,~.-184,~.

~.~.~,~

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 6 of 9 JPmVided for Information 011Iy Februa!y25, 2014 PLANT SYSTEMS 3/4.7.7 CONTROL ROOM B.,IER.GENCYVENTILATION SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

d. After every 720 ho= of cban:oal adsoroer 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," shows the methyl iodide peneuation less than or equal to 2.5%

when tested in accordance with ASTM D3803-89 at a temperature of30°C (86°F),

and a relative humidity of70%, and a face velocity of54 ft/min.

e. At the frequency specified in the Surveillance Frequency Control Program by:

l) Verifying that the pressure drop across the combined HEPA filters and charcoal adsoroer banks is less than 6.75 inches Water Gauge while operating the system at a flow rate of 1,120 cfin :!:: 20%;

2) Deleted

3) Verifying that the heatera dissipate 9.4 +/-1 kW when tested in accordance withANSIN510-1980.

f. After each complete or partial replacement ofa HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria ofless than 0.05% in accordance with ANSI NSl0-1980 for a DOP test aerosol while operating the system at a flow rate of 1120 din:!:: 20%; and

g. After each complete or partial replacement of a charcoal adsorberbank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria ofless than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon reftigerant test gas while operating the system at a flow rate of 1120 cfm :!:: 20%.

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

ANSINSl0-1980 shall be used in place of ANSINSl0-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

MILLSTONE- UNIT 3 3/4 7-17 Amendment No.~ ,H!;, -HH-, ~. ~. ~.

258

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 7 of 9 PLANf SYSTEMS 3/4_7.9 AUXIIlARY BUILDING FILTER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.9 Two independent Auxiliacy Building Filter Systems shall be OPERABLE.

APPLTCABJl,ITY; MODES 1, 2, 3, and 4.

ACTION:

With oneAuxilialy Building Filler S}istf:m inoperable,, mtorethe moperable system to OPERABLE status within 7 da}'S orbe in at least HOT STANDBY within tbenext 6 homs and in corn SHUTDOWN within the following 30 hems. In addition,. oomply with the ACTION requirements of Specification 3.6.6.1.

SURVEILLANCE REQUIREMENTS 4.1.9 Each Auxilialy Building Filter System shall be demODstr.lfed OPERABLE:

a At the frequency specified in the Smveillance Frequency Comrol Program by "'I...

initiating, fimn the control room, flow through the HEPA :filters and charcoal

~andverifyingasy.stem:flownteof30.0D0din+/-10"kamlthattbe 15 continuous system operates for at l e a s t ~ with the beaters operating; 1_minutes

b. At the frequency specffied in the Surveillance Frequency Control Program and. --1.._

ibllowing painting, :fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test proc:edore guidance in Regnlatmy Positions C5.a, C5.c, and C5.d of RcgolatOly Gnide 152, Relrision. 2, Man:h 1978.* and the system.flow i:ate is 30,000 din +/-10%;

2) Venfying, within 31 da}'S aflerremoval, lhat a laboiatmy amlysis ofa repre;eut.ati.ve cadxm S31Dple obtained in accoldance withRegulatmy Position C.6.b of Regulatory Guide 1.52, Revision 2, l'viarch 1978,* .shows the methyl MILLSTONE- UNIT 3 3/47-20 Amendment No. a~.~. -184. ~*.gg§,

~.~

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 8 of 9 February 25, 2014 PLANT SYSTEMS !Provided for l11fmmation Only I SURVEILLANCE REQUIREMB.'ITS iodide penetration less than or equal to 2.5% when tested in accordance withASTMD3803-89 at a temperature of30°C (86°F), a relative humidity of 70%, and a face velocity of 52 ft/min; and

3) Verifying a system flow rate of30,000 din+/-10% during system operation when tested in accordance with ANSI N510-1980.

c. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoa1 adsorber operation, by verifying, 1-liitbin 31 days after removal, that a laboratory analysis ofa representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, Jl.,farch 1978," shows the methyl iodide penetration less than or equal to 2.5% when tested in accordance withASTM D3803-89 at a temperature of30°C (86°F), a relative humidity of70%, and a fuce velocity of 52 ft/min;

d. At the frequency specified in the Surveillance Frequency Control Program by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.8 inches Water Gauge while operating the system at a flow rate of30,000 cftn+/-lO"/o,

2) Verifying that the system starts on a Safety Injection test signal, and

3) Verifying that the heaters dissipate 180 +/-18 kW when tested in accordance with ANSIN510-1980.

e. After each complete or partial replacement ofa HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accoroance \liith A.~SI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 30,000 din +/-lOo/o; and

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria ofless than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of30,000 din+/-l0%.

ANSIN510-1980 shall be used in place of ANSI N510-1975 referenced in Regu]atory Guide 1.52, Revision 2, March 1978.

MILLSTONE- UNIT 3 3/4 7-21 Amendment No.;;, .s:;t, ~ . -HW-, ~. 258

Serial No.18-370 Docket No. 50-423 Attachment 4, Page 9 of 9 Febma!y 6. 2013 Pl.Ai'IT SYSTEMS !Provided for infonnation Only I 3/4.7-10 SNUBBERS LlMITING CONDffiONFOROPERATION 3.7.10 AllsnnbbersshallbeOPERABLE. Theonlysnubbersexcludedftomtherequirements are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed would have no adverse effect on any safety-related system.

APPLICABILITY: MODES 1. 2. 3, and 4. MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.

ACTION:

With one or more snubbers inoperable on any system, *within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months replace or restore the inoperable snubber(s) to OPERABLE status and pafmm an engineering evaluation per Specification 4.7.10. on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.

SURVEILLANCE REQUIREMENTS

4. 7.10 Each snubber shall be demonstrated OPERABLE by petfonnance of the Snubber Examination, Testing. and Service Life MODitoring Program Plan.

MILLSTONE- UNIT 3 3/4 7-22 Amendment No.~@;-~~ 257

Serial No.18-370 Docket No. 50-423 ATTACHMENT 5 MARKED-UP TECHNICAL SPECIFICATION BASES PAGES FOR MPS3 FOR INFORMATION ONLY DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 1 of 18

!Provided! for Information Only June 3, 2002 CONTAINMENT SYSTEMS BASES 314.6.6 SECONDARYCONTAINMENT 3/4.6.6.1 SUPPLEMENTARYLEAKCOILECTIONANDRELEASE SYSTEM Backpmnpd TheOP.ERABn.nY ofthe SunolementarvLeak:ColledionandRelease System(~

ensures that r.i.dioactive materials thatTeak :from t h e ~ c:ootrimueot into the S ~

Containment fullqwing a Design Basis Accident (DBA) are filtered out and adsomed prior to any release to the environment.

SLCRS Ductwork Jmmjty; The Sum,~ Leak Collection and Release System(SLCRS) remains OPERABLE with the followmg bolting configuration:

a. For 3HVR.*DMPF44:

Eight bolts properly installed on the ductwork access panels.

At least one bolt must be installed in each comer area.

The remaining bolts should be msl3l1ed in the center area of each side.

b. For 3HVR.*DMPF29:

12 bolts properly installed on the dw:twmk access panel

At least one bolt 1IIDSt be installed in each comer area

'11].e remaining bo~ should be approximately equally spaced along each side with two bolts per side.

Wrth the abo'!_e bolting specified fbr3HVR*DMPF44 and 3HVR"DMPF29, reference (1) concluded the fullowmg:

~~ around~pl!res is miDima1 and causes negligible effect on the of the SLCRS system.

Assmes the irasket will not be extmded:ftom between the plate and duct flange when the SI:cRS fans are started.

The remaining bolts may be instilled with the fans l1llliliDg.

Proyides_~e~ integrity in the seismic event based on engmeenng analysis.

Applicable Safety Analyses The SLCRS design basis is established bvthe C O D S ~ ofthe limitingDBA, which is a LOCA. The accident analysis assumes that only one train of the SLCRS and one train of the a]Ptiliaiy building filter system is fimctional due to a single failure that disables the other train.

The aCCident an:uysis accounts for the reduction of the airbome radioactive material_ptovided by the~onetrainofthisfiltration~em. Theamountoffissionprodoctsavailablefor release ftomlhe contaiorneot is detemJined fuI a LOCA.

The SLCRS is not nommlly in O{!eration. The SLCRS starts ona SIS signal The modeled SLCRS actuation in the safely analysis (thelMillstone 3 MILLSTONE-UNIT 3 B3/46-4 Amendment No.-&+,~

"Revised by NR.C Letter A15710-~

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 2 of 18

!Provided for Information Only I LBDCR.No_ 04-MP3-015 February 24, 2005 CONTAINMENT SYSTEMS BASES 3/4 6 6 t SUPPLEMENTARY1,EAK COLLECTION AND RELEASE SYSTEM (Continued)

FSAR Chapter 15, Section 15.6) is based upon a worst-case response time following an SI initiated at the limiting setpoint One train of the SLCR.S in conjunction with the Auxiliary Buildin,g Filter (ABF) ~ i s capable ofdrawing a negative ~ e (0.4 inches water gauge at the auxiliary building 2'1-'6" elevation) within 120 seconns after a LOCA This time includes dies_el generafi?r startup~ sequencing time, system startup time, and time for the system to attain the required negative pressure after startmg..

In the event of a DBA, one SLCR.S is required to provide the minimJUD postulated iodine removal assumed in the safety analysis. Two trains of the SLCRS must be OPERABLE to ensure that at least one train will operate, assuming that the other train is disabled by a single-active failw:e_ The SLCRS \VOiks in c ~ o n with the ABF system. Inoperabilil:y of one train of the ABF system, also results in inoperability of the correspon_d!ng train of the SLCRS. Therefore, wheneverLCO 3-7_9 is entered due totheABFtrain.A.(B) being inoperable, LCO 3-6.6.1 nmstbe entered due to the SLCRS train A (B) being inoperable..

When a SLCRS LCO is not met, it is not necessaiy to declare the secondaiy containment inoperable_ However, in this event, it is necessary to determine that a loss of safety function does not exist A loss of safety function exists when, assumin_g no concurrent single failure, a safety

function assumed in the accident analysis cannot be pertormed.

AwJicabi]ity In MODES 1, 2, 3, and 4, a DBA could lead to a fission product release to containment that leaks to the secondary containment. The large break LOCA, on which this system's design is based, is a full-power event. Less severe LOCAs and leakage still re(Jll!{e the system to be OPERABLE throughout these MODES_ The probability and severity of a LOCA decrease as core power and reactor coolant system pressure decrease.. Wi1h the reactor shut clown, the probability ofrelease of radioactivity resulting from such an accident is low.

In MODES 5 and 6, the probability and cons~ces of a DBA are low due to the pressw:e and temperatw:e limitatJ.ons in these MODES. Under these conditions, the SLCRS is not required to be OPERABLE ACilONS Wrth one SLCR.S train inoperable, the inoperable train must be restored to OPERABLE status within 7 days. The OPERABLE trnin is capable of providing 100 percent of the iodine removal 1:1~ for a DBA The 7-day Completion Tlllle is !>3£ed on constderatio!l _of such factors as the reliability of the OPERABLE redundant SLCRS tram and the low probabili~ of a DBA o ~ during this period. The Completion Tune is adequate to make most repal!S. If the SLCR.S cannot be restored to OPERABLE status within the required Completion Tune, the plant must be brought to a MODE in which the LCO does not apply_ To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 301Iours.

The allowed Completion Tunes are reasonable, based on operating experience, to reach the required _plant conditions from full-power conditions in an orderly manner and without challengmg plant systems.

1\/llLLSTONE-UNIT 3 B 3/4 6-5 Amendment No_ 8,1., *6, Acknowledged by NRC letter dated 08/25/05

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 3 of 18

!Provided for Unformatioo Only j CONfAINMENT SYSTEMS Operating each SLCRS tram for greater than or equal to 15 minutes ensures that all linins are OPERABLE and that all associated controls are BASES functioning properly. It also ensures that blockage, fan or motorfnirure, or

==========:=,'.=~excessive vibration can be detected for corrective action. Since adsorption testing is peiformed al 70% relative humidity, the filler heatero are required

~JIJL.l..li.L!l;!fl.t.M.t:~All~IJ:.l~to operate.

-e-umulative-operatioo-of-fue-Sl:.GRS-with-heat~ting-for-at-least-W-oominuellS-hams-is-

_"l.lfficient.to.reduce.tl!e.buildup.of.moisrure.on.the.adsoroma1\!..IffiR<\-filreI& The snrv-eillance ,

I frequency is controlled tmder !he Surveillance Frequency Control Program. f' b.c. e. andf These surveillances verify that the required SLCRS filter testing is penormed in accordance with Regulatory Guide 1.52, Revision 2. ANSI NSl0-1980 shall be used in place of ANSI NSl0-1975 referenced in Regulatory Guide 1.52, Revision 2. Laboratmy testing ofmethyl iodide penetration shall be perlilnned in accordance with ASTM D3803-89 anii Mil1sfune Unit 3 specific pai:ameters. The surveillances include t ~ HEPA filterperlbnnance, charcoal adsoroer efficiency, system flow rate, and the physical'properties orthe activated charcoal (general use and following specific operations). The heater kW measured must be corrected to its nameplate rating.

Variations m system voltage can lead to measurements of kW which cannot be compared to the nameplate rating because the output kW is proportional to the square of the voltage.

Any time the OPERABILITY of a HEPA filter or charcoal adsoroerhousinghas been affected by repair. maintenance, modification. or replacement activity, post maintenance testing in accordance with SR 4.0.1 is required to demonstrate OPERABILITY.

The 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of operation rf9Uilement originates from ReroilatOIY Guide 1.52, Revision 2, March 1978, Table"2, Note ..c , which states that 'Testing snould be performed (1) initially, (2) at least once per 18 months thereafter for systems maintained in a standby status or after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months ofsystem operations, and (3) folio~ painting, fire, or chemical release in any ventilation zone communicating with the system." This testing ensures that the charcoal adsorbency c;ipacity has J not degraded l>elow acceptable limits, as well as providing trend data. The 720 hour0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months figure JS an arbitrary number which JS equivalent to a 30 day period. This criteria is directed to filter systems that are normally in o~on and also provide emergency air cleaning functions in the event of a Design.Basis Accident. The applicable filtertmits are not nonnally in operation and the sample canisters are fypicallyremovro due to the 18 month criteria.

r 4

The periodic automatic startup ensures that eachSLCRS trainresoonds properly. The surveillance

fre~y is controlled under the Surveillance Frequency Contro1 Program. Tiie smveillance J,

1 verifies that the SLCRS starts on a SIS test signal It also includes the automatic functions to isolate the other ventilation systems that are not part of the safety-related postaccident operating configuration and to start up and to align the ventilation systems that flow through the seconda!y containment to the accident condition.

}.,llILS'fONE- UNIT 3 B 3/46-6 Amendment No.~,~. -IM,~

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 4 of 18

!Provided for Information Only I LBDCR 05-MP3-025 March 7, 2006 CONTAINMENT SYSTEMS BASES 3t4 6 6 1 SUPPLEMENTARY LEAK COLLECTION AND REI.EASE SYSTEM (Continued)

The main steam val,;,-e building ventilation system isohtes.

AuxiliaIY building ventilation (nonnal) system isolates.

Charging pump/reactor plant component cooling *water pump area cooling subsystem aligns and discharges to the auxiliaiy building filters and a filter fan starts.

Hydrogen recombiner ventilation system aligns to the postaccident configuration_

The engineered safety features building ventilation system aligns to the postaccident configuration.

References:

1. Engineering analysis, Memo MPJ-DE-94-539, Bolting Requirements for Access Panels on Dampers 3H.VR"DMPF29 & 44," dated June 16, 1994.

1\illLLSTONE- UNIT 3 B3/46-6a Amendment No. gjl, ~ . ,H;4,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 5 of 18

!Provided for Information Only I LBDCR.13-JIJP3-002 May2,2013 PLANT SYSTEMS BASES SURVEILLANCE REQUIREMENTS This surveillance requirement verifies that the UHS is capable of providing a 30 day cooling water supply to safety related equipment \llithout exceeding its design basis temperature. This surveillance requirement verifies that the water temperature ofthe UHS is S 80°F.

REFERENCES

1. FSAR, Section 6.2, Containment Systems

2. FSAR, Section 9.2, Water Systems

3. FSAR, Section 15.6, Decrease in Reactor Coolant Inventocy 3/4.7.6 DELETED 3/4.7.7 CONIROL ROOM EMERGENCY VENTILATION SYSTEl\11 BACK.GROUND The control room emergency venfilation system provides a protected environment: ftom which operators can control the unit follov..ing an uncontrolled release of radioactivity. hazardous chemicals, or smoke. Additionally, the system provides temperature control for the control room envelope (CRE) during nonnal and post-accident operatiOllS.

The control room emergency ventilation system is comprised of the CRE emergency air filtration system and a temperature control system.

The control room emergency air filtration system consists of two red1llldant systems that recirculate and filter the air in the CRE and a CRE bmmdary that limits the inleakage ofunfiltered air. Each control room emergency air filtration system consists of a moisture separator, electric heater, prefilter, upstream. high efficiency particulate air (HEPA) filter, charcoal adsoroer, downstream HEPA filter, and fan. Additionally, ductwmk, valves or dampers, and instnunentation form part of the system The CR.Eis the area within the confines of the CRE bo1llldarythat contains the spaces that control room occupants inhabit to control the unit during nmmal and accident conditions. This area encompasses the control room, and other non~tical areas including adjacent support offices, MILLSTONE- UNIT 3 B3/4 7-10 AmendmentNo. -H9, ~ , H4, *4

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 6 of 18 LBDCR.No_ 08-lMP3-014 jProvided for Information Only j October 21, 2008 PLANT SYSTEMS BASES 3/4_7_7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

BACKGROUND (Continued) toilet and utility rooms_ The CRE is protected during nonna1 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 OPERABIU1Y of the CRE bound:uy must be maintained to ensure that the inleakage of unfiltered air into the CRE vliJ.1 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 and UFSAR Section 6-4.2.L Normal Operation A portion of the control room emergency ventilation system is required to operate during normal operations to ensure the temperature of the control room is maintained at or below 95°F.

Post Accident Operation The control room emergency ventilation system is required to operate during post-accident operations to ensure the temperature of the CRE is maintained and to ensure the CRE will remain habitable during at;d following accident conditions.

The following event occurs upon receipt ofa control building isolation (CBI) signal or a signal indicating high radiation in the air supply duct to the CRE.

The control room emergency ventilation system will automatically start in the emergency mode (filtered pressurization whereby outside air is diverted through the filters to the CRE to maintain a positive pressure).

APPLICABLE SAFETY ANALYSIS 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 CRE will remain MII.LSTONE- UNIT 3 B3/4 7-11 Amendment No. m,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 7 of 18

!Pro\fided for lnfomnatiori Only I LBDCR. No_ 08-l.\ifP3--014 October 21, 2008 PLANT SYSTEMS BASES 3/4.7.7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

APPLICABLE SAFETY ANALYSIS (Continued) habitable for occupants during and following all credible accident conditions. The OPERABILITY of this system in conjunction "'ith control room design provisions is based on limiting the radiation exposure to CRE occupants. For all postulated design basis accidents, the radiation exposure to CRE occupants shall be 5 rem TEDE or less, consistent with the requirements of 10 CFR 50.67_ This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR Part 50_

LIMITING CONDITION FOR OPERATION Two independent control room emergency air filtration systems are required to be OPERABLE to ensure that at least one is available in the event the other system is disabled_

Total system failure, such as from a loss ofboth ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

A control room emergency air filtration system is OPERABLE when the associated:

a_ Fan is OPERABLE;

b. HEPA filters and charcoal adsorbers are not excessively restricting flow and are capable of perfonning theirfiltration functions; and

c. moisture separator, heater, ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In order for the CREVs to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the 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_7 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 the design condition, such as doors, hatches, 1v1ILLSTONE- UNIT 3 B3/4 7-12 Amendment No_ He,',~,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 8 of 18

!Provided for Information Only I LBDCRNo_ 08-JMP3-014 October 21, 2008 PLANT SYSTEMS BASES 314 7 7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

LIMITING CONDffiON FOR OPERATION (Continued) floor plugs, and access panels_ For entry and exit through doors, the administrative control of the opening is performed 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.

Operation of the Control Room Emeigency Ventilation System in the emergency mode is credited for design basis accident mitigation. The fuel handling accident analyses assume the emergency mode will be established within 30 minutes of a fuel handling accident. The other applicable design basis accidents (e.g_, large break: loss of coolant accident) assume the emergency mode will be established within 101 minutes of the accident. Even though manual operator action to establish the emergency mode could be credited within these time periods, the system has been designed to automatically establish the required equipment alignment upon receipt of a Control Building Isolation signal Therefore, when stopping a Control Room Emergency Filter Fan by placing the control switch in OFF, the fan remains OPERABLE. The administrative controls associated with the procedure in use to stop the fan are sufficient to ensure the associated control switch is returned to the AUTO position.

In addition, the Emergency Operating Procedure will ensure a Control Room Emeigency Filter fan is running in the emergency mode post accident well within the credited accident mitigation time frame.

Control Room inlet isolation valves 3HVC"AOV25 and 3HVC"AOV26 are maintained open with air isolated whenever Technical Specification 3_7_7 is applicable. The only procedural guidance to close 3HVC*AOV25 when this specification is applicable is in the alarm response procedure for smoke in the control room air inlet ventilation duct The alarm response procedure will provide direction to establish the filtered recirculation mode of operation by restoring air and closing 3HVC*AOV25_ During this limited time period. both Control Room Emergency Filtration trains remain OPERABLE, but degraded. Even though 3HVC*AOV25 is closed, it is a fail open valve and will automatically open on a Control Building Isolation signal, making it OPERABLE. However, should it to fail open, the system will not function. Therefore, it is not single failure proof and is degraded. Operation in this condition should be minimized.

MILLSTONE- UNIT 3 B 3/4 7-12a Amendment No_ ,H;j, ~ . '*9-,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 9 of 18

!Provided for Information Only I REVERSE OF PAGE B 3/4 7-12a INIENTIONALLYLEFr BLANK

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 1O of 18 jPmllided for l11formation Only j LBDCR.10-MP3-003 Febrnacy-23, 2010 PLAiW SYSTEMS BASES 314 7 7 CONTROL ROOM EMERGENCTVENTILATIQN SVSJ:EM (Continued)

APPUCABIIlTY InMODES 1, 2, 3, and 4.

During movement ofrecently inadiated fuel assemblies.

ACTIONS a., b., and c. of this specification are applicable at all times during plant operation in MODES 1, 2, 3, and 4. ACTIONS d and e. are applicable during movement of recently inacliated fuel assemblies. The CREVs is required to be OPERABLE during fuel handling involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous 350 hour0.00405 days 0.0972 hours 5.787037e-4 weeks 1.33175e-4 months sj_

An analysis was completed that analyzed a bounding drop of a non-spent fuel component The analysis showed that the amount of fuel damage from this drop resulted in control room dose less than 5 rem TEDE without operation of the control room ventilation system.

ACTIONS MODES 1 2, 3. and4 a With one control room emeigency air filtration system inoperable for reasons other than an inoperable CRE boundary, action must be taken to restore the inoperable system to an OPERABLE status within 7 clays. In this condition, the remaining control room emergency air filtration system is adequate to perfom1 the CRE occupant protection

function. However, the overall reliability is reduced because a single failure in the OPERABLE train could result in a loss of the control room emergency air filtration system function. The 7-day completion 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 the inoperable train cannot be restored to an OPERABLE status v..ithin 7 clays, the unit must be placed in at least HOT STANDBY within the n~16 hours and in COLD SHUIDOWN within the fullowing 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . These completion times are reasonable, based on operating experience, to reach the required unit condition from :full power conditions in an oroerly manner and without challenging unit systems.

" During fuel assembly cleaning evolutions that involve the handling or cleaning oftwo fuel assemblies coincidentally, recently inadiated :fuel is :fuel that has occupied part ofa critical reactor core within the previous 525 hOU!S.

MILLSTONE- UNIT 3 B3/4 7-13 Amendment No.~,'*~

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 11 of 18 LBDCR 07-MP3-033 jProvideol for lnfom1ation Only j June 25, 2007 PLANT SYSTEMS BASES 3/4 7 7 CQN[RQL ROOM EMERGENCY VENTILATION SYSTEM (('.ontjnued)

ACQQNS <Contjmu:d)

b. Withbothcon!rolroomernergencyairfillrationsystemsinoperable,exceptduetoaninoperable CRE boundaiy, at lf2St one contmlroomemeigencyair filtration system nmst be restored to OPERABLE stan.5 '1iithin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; or the Ullit must 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 COID SHUIDOTuN '1iithin thefollmving 30 hams. These completion times are reasonable, based on operating experience, to n2ch the required unit conditions from full pcm-er conditions in.an orderly manner and without challengjng unit systems..

c. With one or more control room emergency air filtration systems inoperable due to an inoperable CRE boundary, (1) action must be immediately initiated to implement mitigating actions; (2) action must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify 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; and (3) the CRE boundary must be restored to OPERABLE status within 90 days. Otherwise, the unit must be in.HOT STANDBY within the neict 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COID SHUIDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

If the unfiltered inleakage ofpotentially 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 ofDBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from haz.ardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within90 days.

During the period that the CRE boundary is considered inoperable, actionnrustbe 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 (ie., actions that are taken to offset the consequences of the inoperable CRE bounda!y) should be preplanned for implementation upon enliy into the conditiOll, regardless ofwhether enliy is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Tlllle is reasonable based on the low probability of a DBA occmring during this time period, and the use ofmitigating actions. The 90 day Completion Tmre is reasonable based on the detennination that the mitigating actions will ensure protection of CRE occupants '1iithin analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect MILLSTONE- UNIT 3 B3/4 7-13a Amendment No. He,~.~, ,w.},,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 12 of 18

!Provided for Information Only I LBDCR 12-MP3-010 September 20, 2012 PLANT SYSTEMS BASES 3/4_7_7 CONIR.OL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

ACTIONS (Continued) their ability to control the reactor and maintain it ina safe shutdown condition in the event of a DBA In addition, the 90 day Completion Tune 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 manner.

During movement of recently irradiated fuel assemblies cl With one control room emergency air filtration system inoperable, action must be taken to restore the inoperable system to an OPERABLE status within 7 days_ After 7 days, either initiate and maintain operation of the remaining OPER.<IBLE control room emergency air

filtration system in the emergency mode or suspend the movement of fuel Initiating and maiofaining operation of the OPERABLE train in the emergency mode ensures:

(i) OPERABILTIY ofthe train will not be compromised by a flilure of the automatic actuation logic; and (11) active failures will be readily detected

e. With both control room emergency air filtration systems inoperable, or with the train required by ACI10N 'd' not capable ofbeing powered by an OPERABLE emergency power source, actions must be taken to suspend all operations involving the movement of recently irradiated fuel assemblies. This action places the unit in a condition that minimizes risk. This action does not preclude the movement of fuel to a safe position.

SURVEILLANCE REQUIREMENTS

!.Z:il.

The CRE environment should be checked periodically to ensure that the CRE temperature control system is functioning properly. The surveillance frequency is controlled under the Smveillance Frequency Control Program. It is not necessaty to cycle the CRE ventilation chillers. The CRE is manned during operations covered by the technical specifications. Typically, temperature abmations will be readily apparent.

Standby systems should be checked periodically to ensure that they function properly. The surveillance fiequency is controlled under the Smveillance Frequency Control Program.

l\lllLLSTONE- UNIT 3 B3/4 7-13b Amendment No.

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 13 of 18 LRDCR-~

!Provided for Information Only I S!lpremb~l2 PI.Ai~ SYSTEMS BASES 3/4 7 7 CQNTR,OI, ROOM EMER,GENCYVENTII,A'ITON SYSTEM (Continued)

SURVEILLANCE REQUIREMENTS (Continued)

This surveillance requirement verifies a system flow rate of 1,120 din= 20%. Adaitimlally;-tke 'I,

~.A-to-o~re-f=t.!~Clltinmms-h.OUI5-VJith~t .,.?,!,'. -..~ e

-e~ti~si~oredut;P.....tlre-bui!du tmoisture-en-th=dsm:b filPA-filt~

-E!ue-to-the-humic!ity-m-the-runbiellt-aiE Operation ,r1ith the heaters on for greater than or equal to 15 conlinuom1 minutes demonsbntes OPERABILITY of the system. Periodic operation ensures that heater failure, blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Since adsorption testing is performed at 70% relative humidity, the 1ilter heaters are required to operate.

The petfonnance of the control room bn~cn:;y-n:rm,crw:lr3Jr.m::==nmnn:,..c,,:cc,=----------'

periodically by verifying the HEPA filter efficiency, charcoal ad.sorber efficiency, ruiniumm flow rate;and the physical properties of the activated charcoal. The frequency is as specified in ..J the Surveillance Frequency Control Program and following painting, fire, or chemical release in l' any ventilation zone comnrunicatingwith the system ANSI N510-1980 will be used as a procedural guide for smveillance testing.

Any time the OPERABILITY of a HEPA filter or charcoal ad.soroer housing has been affected by repair, maintenance, modification, or replacement activity, post maintenance testing in accordance with SR. 4.0.1 is required to demonstrate OPERABILITY.

This snnreillance verifies that the system satisfies the in-place penetration and b)lPass leakage testing acceptance criterion of less than 0.05% in accordance with Regulatory Position C.5.a, C.5.c, and C.5.d ofRegulatozy Guide 1.52, Revision 2, Maich 1978, while operating the system at a flow rate ofl,120 din+/- 20%. A."N'SI NSl0-1980 is used in lieu of ANSI NSl0-1975 referenced in the regulatory guide.

This surveillance requires that a representative carbon sample be obtained in accordance with Regulatoiy Position C.6.b ofRegulatoiy Guide 1.52, Revision 2, March 1978 and that a laboratory analysis verify that the representative carbon sample meets the laboratoiy le.sting criteria ofAS1M D3803-89 and :Millstone Unit 3 specific parnmeters. The laboratoiy analysis is required to beperfonnedwithin31 days afterremovalofthesample. ANSINSI0-1980 is used in lien of ANSI N510-1975 referenced in Revision 2 ofRegulatozy Guide 1.52.

MILLSTONE- UNIT 3 B 3/4 7-14 Amendment No.~, -Hl4, .;Ge

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 14 of 18

!Provided for Information Only I LBDCR 12-l\4P3--010 September 20, 2012 PLANT SYSTEMS BASES 3/4-7.7 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

SURVEII,LANCE REQ1JIREMENIS (Continued)

~

This surveillance verifies that a system flow rate of 1,120 cfm +/- 20"/o, during system operation when testing in accordance with Ai~SIN510-1980.

4.7.7.d After 720 hOUili of chan:oal adsorller operation, a representative carbon sample must be obtained in accordance \\"ith Regulatory Position C.6.b ofRegulatoiy Guide 1.52, Revision 2, March 1978, and a laboratory analysis must verify that the representative carbon sample meets the laboratory testing criteria of ASTM D3803-89 and:l\liillstone Unit 3 specific parameters.

The laboratory analysis is required to be perfoID1ed within 31 days after removal of the sample.

ANSI NS 10-1980 is used in lieu ofANSI N510-1975 referenced in Revision 2 of Regulatoi:y Guidel.52.

The maximum surveillance interval is 900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months , per Surveillance Requirement 4.0.2. The 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of operation requirement originates from Nuclear Regulatoi:y Guide 1.52, Table 2, Note C. This testing ensures that the charcoal adsorbency capacity has not degraded below acceptable limits as well as providing trending data.

4.7.7.e.1 This surveillance verifies that the pressure drop across the combined HEPA filters and charcoal adsorbers banks at less than. 6.75 inches water gauge when the system is operated at a flow rate of 1,120 cfm+/- 20%. The surveillance ftequency is controlled under the Smveillance Frequency Control Program.

4.7.7.e.2 Deleted.

4.7.7.e.3 This sutVeillance verifies that the heaters can dissipate 9.4 +/- 1 kW at 480V when tested in accordance with ANSI N510-1980. The surveillance frequency is controlled under the Surveillance Frequency Control Program. The heater kW measured nrust be corrected to its nameplate rating. v.iriations in system *1mltage can lead to measurements of kW which cannot be compared to the nameplate rating because the output kW is proportional to the square of the voltage.

MILLSTONE- UNIT 3 B 3/4 7-15 Amendment No. -He, -HH-, i-84, ~ . ~

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 15 of 18

!Provided for lnformatio11 Only j LBDCR 07-MP3-033 June 25, 2007 PLANT SYSTEMS BASES 31411 CONTROL ROOM EMER.GENCTVENTILA'IJON SYSTEM (Continued)

SURVEILLANCE REQUIREMENTS (Continued)

!.J..li.

Following the complete or partial replacement of a HEPA filter bank, the OPERABILI1Y of the cleanup system should be confumed. This is accomplished by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criterion ofless than 0.05% in accordance with ANSI NSl0-1980 for a DOP test aerosol while operating the system at a flow rate of 1,120 din::!: 20%.

Following the complete or partial replacement of a charcoal adsoroerbank, the OPERABILITY of the cleanup system should be confirmed. This is accomplished by verifying that the cleanup system satisfied the in-place penetration and bypass leakage testing acceptance criterion ofless th.,n 0.05% in accordance \liith .A!~SI NSI0-1980 fur a halogenated hydrocarbon reftigerant test gas while operating the system at a flow of 1,120 din= 20%,_

This Sulveillance verifies the OPERABILI1Y 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 Toe CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses ofDBA consequences is no more than 5 rem TEDE and the CRE occupants are protected ftomhazardous 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 ofDBA consequences_ When unfiltered air inleakage is greater than the assumed flow rate, ACTION c_ must be entered. ACTION c_ allows lime to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits 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_

Temporaiy analytical methods may also be used as compensatmy measures to restore OPERABILITY. Options forrestoring the CRE bound:nyto OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE bmmdary; or a combination of these actions. Depending upon the nature of the problem and the conective action, a full scope inleakage test may not be necessaiy to establish that the CRE boundaty has been restored to OPERABLE status. ,

MILLSTONE- UNIT 3 B3/4 7-16 Amendment No. He,'* .;Qe,

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 16 of 18 IIPmvidedl for lnfomiation Only I LBDCR 07-I\,fP3-033 JWJ.e 25, 2007 PLA..°l'IT SYSTEM:S BASES 3/4 ZZ CQN[ROL ROOM EMER,GENCVVENTILATION SYSTEM (Continued)

References:

(1) Nuclear Regulatoiy Guide 1-52, Revision 2 (2) I\,fP3 UFSAR, Table 1.8-1, NRC Regulatoiy Guide 1..52 (3) NRC Generic Letter 91-04 (4) Condition Report (CR) #MJ-99-0271 (5) NEI 99-03, "Control Room Habitability AssessmenC (6) Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White paper, Use of Generic Letter 91-18 Process and Alternative Source Teims in the Context of Conlrol Room Habitability."

3/4.7-8 DELETED MILISIONE- UNIT 3 B 3/4 7-17 .Amendment No. He;

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 17 of 18 LBDCR l?-:MPJ-010

!Provided for Information Only S~rmlm'JO, 2012 PLANT SYSTEMS Operating each AuxmaJY Building Fi[tration System train for greater than or equal to 15 minutes ensures that atl trains are BASES OPERABLE and that aa associated controls are functioning

================:;;:;jproperly. It also ensures !hat blockage, fan or motorfaJlure, or excessive vfbration can be detected for corrective action.

3/4.7.9 AUXIUARY BUIIDJNG FILTER SYS

Since acisorplion testing is peifonned at 70% relative humidity, the filter heaters are required to operate.

The OPERABILlTY ofthe Auxiliary Buil

g Filter System, and associated filters and fans, ensures that radioactive materials leaking m the equipment within the charging pump, component cooling water pump and heat exchan areas following a LOCA are :filtered prior to reaching the environment. Periodicope,.-.atiorrof ~-tem-wifu-the-'..ieatcrs-operatiag-fel=-at-least-

-l().eonf..m:a~1Y.u:s-is-suffieienHe-redi:re-the-lruildap-0HnOismre-an-th.."ildsmee?".rami-HfillA:--

I

....filtei:s. The SU1Veillance frequency is controlled under the Sunreillance Frequency Control ,

Program. The operation of this system and the resultant effect on oifsite dosage calculations was f' assumed in the safety analyses. ANSI N510-1980 will be used as a procedural guide for SU1Veillance testing. LaboratOIY testing of methyl iodide penetration shall be perfonned in accordance with AS1M D3803-89 and Millstone Unit 3 specific parameters. The heater kW measured must be corrected to its nameplate rating. Variations in system voltage can lead to measurements of kW which cannot be compared to the nameplate rating because the output kW is proportional to the square of the voltage.

The Chaiging PumpJR.eactor Plant Component Cooling Water Pump Ventilation System is required to be available to support the Auxiliary Building Filter System and the Suppleme:ntai:y Leak Collection and Release System (SLCRS). The Chaiging Pump/Reactor Plant Component Cooling Water Pump Ventilation System consists of two redundant trains, each capable of providing 100% of the required flow. Each train has a t\'\i"O position, Off' and "Auto," remote control switch. With the remote control switches for each train in the "Auto" position, the system is capable of antomatica11yttansfening operation to the redundant train in the event of a low flow condition in the operating train. The associated fans do not receive any safety related automatic start signals (e.g., Safety Injection Signal).

Placing the remote control miitch for a Charging Pump/Reactor Plant Component Cooling Water Pump Ventilation Train in the "Off' position to start the redundant train or to perform post maintenance testing to verify availability ofthe redundant train will not affect the availability of that train, provided appropriate administrative controls have been established to ensure the remote control switch is immediately returned to the "Auto" position after the completion ofthe specified activities or in response to plant conditiOllS. These administrative controls include the use of an approved procedure and a designated individual at the control switch for the re.-pective Chaiging Pump/Reactor Plant Component Cooling Water Pump Ventilation Train who can rapidly respond to instructions from procedures, or control room personnel, based on plant conditions.

MILLSTONE- UNIT 3 B3/4 7-23 Amendment No. &,I,, -H9, ~*.;84,

,1,e;

Serial No.18-370 Docket No. 50-423 Attachment 5, Page 18 of 18

\i

!Provided for Information Only I LBDCR 12-MP~03 March 12, 2012 PLAIW SYSTEMS BASES LCO 3.7.9 ACTION statement:

Wrth one Auxili3IY Building Filter System inoperable. restoration to OPERABLE status within 7 days is required.

Toe 7 days restoration time requirement is based on the following: Toe risk contribution is less fur an inoperable Auxiliaiy Building Filter System, than for the charging pump or reactor plant component cooling water (RPCCW) systems, which have a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restoration time requirement. The AuxiliaIY Building Filter System is not a direct support system for the charging pumps or RPCCW p1D11ps. Because the pump area is a common area, and as long as the other train of the Auxiliary Building FJ.lter System remains OPERABLE, the 7 day restoration time limit is acceptable based on the low probability of a DBA occwring during the time period and the ability ofthe remaining train to provide the required capability. A concurrent failure ofboth trains would require en!Iyinto LCO 3.0.3 due to the loss of functional capability. The Auxiliaty Building Filter System does support the Snpplementuy Leak Collection and Release System (SLCRS) and the LCO ACTION statement time of7 days is consistent with that specified for SLCRS (See LCO 3.6.6.1).

Any time the OPERABIUTY of a HEPA :filter or charcoal adsoroerhousing has been affected by rep~ maintenance, modification, or replacement activity, post maintenance testing in accordance with SR 4.0.1 is required to demonstrate OPERABILITY.

Smyeilfance Rs:QJ*ire,pent 4 Z2 c Surveillance requirement 4.7.9.c requires that after 720 hows of operation a cbail::oal sample must be taken and the sample must be analyzed within 31 days after removal.

Toe 720 homs of operation requirement originates ftom Regulatmy Guide 1.52, Revision 2, March 1978, Table 2, Note "c", which states that 'Testing should be ped"onned (1) initially, (2) at least once per 18 months thereafter for systems maintained in a standby status or after 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months ofsystem operations, and (3) following painting, fire,, or chemical release in any ventilation zone communicating with the system" This testing ensures that the cbarcoal adsorbency capacity has not degraded below acceptable limits as well as providing trending data. The 720 hour0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months figure is anarbitrarynwnberwhich is equivalent to a 30 day period. This criteria is directed to filter systems tl!at are nonnally in operation and also provide emergency air cleaning functions in the event of a Design Basis Accident. The applicable :filter units are not normally in operation and sample canisters are typically removed due to the 18 month criteria..

3/4 Z JO SNQBBERS All snubbers are required OPERABLE to ensure that the structural integrity ofthe Reactor Coolant System and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads. For the pmpose of declaring the affected system OPERABLE with the inoperable snubber(s), an engineering evaluation maybe perfom1ed, in accordance with Section 50.59 oflO CFR. Part 50.

l\l!ILLSTONE- UNIT 3 B3/4 7-23a Amendment No.~, -H9, He,~

v t e Letter Sequence Request
EPID:L-2019-LLA-0077, TSTF-522 (Open)
Initiation Request Acceptance Administration Questions Answers Results Approval... Other:
MONTHYEAR2019-04-11 [Table View]

ML19109A100

Text

SUMMARY

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

References:

References:

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