ML15205A341

Millstone Power Station, Unit 2, Response to Second Request for Additional Information Regarding Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TAC No. MF5096)

ML15205A341
Person / Time
Site:	Millstone
Issue date:	07/20/2015
From:	Sartain M D Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
15-342, TAC MF5096
Download: ML15205A341 (8)

Text

Dominion Nuclear Connecticut, Inc. D5.000 Dominion Boulevard, Glen Allen, VA 23060 DWeb Address:

www.dom.com July 20, 2015U.S. Nuclear Regulatory Commission Serial No. 15-342Attention:

Document Control Desk NLOSIWDC ROWashington, DC 20555 Docket No. 50-336License No. DPR-65DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2RESPONSE TO SECOND REQUEST FOR ADDITIONAL INFORMATION REGARDING RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (TAC NO. MF5096)By letter dated October 22, 2014, Dominion Nuclear Connecticut, Inc. (DNC)submitted a license amendment request (LAR) for Millstone Power Station Unit 2(MPS2). The proposed amendment would relocate certain technical specification (TS)surveillance frequencies to a licensee-controlled program by adopting Technical Specification Task Force (TSTF) -425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -RITSTF [Risk-Informed Technical Specification Task Force]Initiative 5b." The proposed change would also add a new program, the Surveillance Frequency Control Program, in accordance with TSTF-425.

In an email dated May 6,2015, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) related to the LAR. DNC responded to the RAI in a letter dated June5, 2015. In an email dated June 26, 2015, the NRC transmitted a second RAI. DNCagreed to respond to the RAI by July 27, 2015.Attachment 1 provides DNC's response to the second RAI.If you have any questions regarding this submittal, please contact Wanda Craft at(804) 273-4687.

Sincerely, Mark D. SartainVice President

-Nuclear Engineering COMMONWEALTH OF VIRGINIACOUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and State aforesaid, today by Mark D.Sartain, who is Vice President

-Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed beforeme that he is duly authorized to execute and file the foregoing document in behalf of that company, and that thestatements in the document are true to the best of his knowledge and belief.Acknowledged before me this _0 +4_ day of .,2015.My Commission Expires:

"G"oAJA!A\

I1 Z lo I toWANDA D. CRAFTNotary Publ, ~ I1 Notary PublicNotary Publi' Commonwealth of VirginiaMonReg. # 7520495]My Commission Expires January 31,20L6_

Serial No. 15-342Docket No. 50-336Page 2 of 2

Attachment:

1. Response to Second Request for Additional Information Regarding Relocation ofSpecific Surveillance Frequency Requirements to a Licensee Controlled Program2. Technical Specifications Marked-up PagesCommitments made in this letter: Nonecc: U.S. Nuclear Regulatory Commission Region I2100 Renaissance Blvd.Suite 100King of Prussia, PA 19406-2713 R. V. GuzmanSenior Project Manager -Millstone Power StationU.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C211555 Rockville PikeRockville, MD 20852-2738

Director, Radiation DivisionDepartment of Energy and Environmental Protection 79 Elm StreetHartford, CT 06106-5127 NRC Senior Resident Inspector Millstone Power Station Serial No. 15-342Docket No. 50-336ATTACHMENT 1RESPONSE TO SECOND REQUEST FOR ADDITIONAL INFORMATION REGARDING RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAMMILLSTONE POWER STATION UNIT 2DOMINION NUCLEAR CONNECTICUT, INC.

Serial No. 15-342Docket No. 50-336Attachment, Page 1 of 2By letter dated October 22, 2014, Dominion Nuclear Connecticut, Inc. (DNC) submitted alicense amendment request (LAR) for Millstone Power Station Unit 2 (MPS2). Theproposed amendment would relocate certain technical specification (TS) surveillance frequencies to.a licensee controlled program by adopting Technical Specification TaskForce (TSTF) -425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [Risk-Informed Technical Specification Task Force] Initiative 5b." Theproposed change would also add a new program, the Surveillance Frequency ControlProgram, in accordance with TSTF-425.

In an email dated May 6, 2015, the NuclearRegulatory Commission (NRC) transmitted a request for additional information (RAI)related to the LAR. DNC responded to the RAI in a letter dated June 5, 2015. In anemail dated June 26, 2015, the NRC transmitted a second RAI. This attachment provides DNC's response to the second RAI.RAI IPlease explain or provide adequate justification for the addition of the word "required" toSRs in all instances including 4.1.3.3, 4.3.1.1.1, 4.3.2.1.1, 4.3.3.1.1, 4.3.3.5, and 4.3.3.8.DNC ResponseDNC added the word "required" to Surveillance Requirements (SRs) 4.1.3.3, 4.3.1.1.1, 4.3.2.1.1, 4.3.3.1.1, 4.3.3.5, and 4.3.3.8 for clarification purposes only. The limitingconditions for operation (LCOs) associated with each of these SRs specify a minimumnumber of channels required to be operable in applicable modes of operation.

Undercertain conditions or modes, the LCOs allow less than the total number of channels to beoperable (e.g., 2 out of 4 channels).

As currently

written, these SRs may be misleading since they imply that all channels are required to be demonstrated operable.

Althoughthis clarification is outside the scope of TSTF-425, Revision 3, it is consistent with thelicense amendment request to adopt TSTF-425 for Millstone Unit 3 which was approvedby the NRC under License Amendment 258 (ADAMS Accession No. ML14023A748).

RAI 2On page 2 of 5 of Attachment I in the LAR, the licensee states that the word"PROGRAM" will be deleted from the table 4.7-2 title, but that word also appears in theSR 4.7.1.4 description on page 3/4 7-7. Please submit a TS markup to remove thecorresponding word 'program" from the SR 4.7.1.4 description or alternatively provide anexplanation of why the word should be retained.

DNC ResponseDNC agrees that the word "program" in Surveillance Requirement (SR) 4.7.1.4 should bedeleted to be consistent with deletion of the word "PROGRAM" from the title descriptor in Serial No. 15-342Docket No. 50-336Attachment, Page 2 of 2'Table 4.7.2. The TS markup to reflect this change to SR 4.7.1.4 is provided inAttachment 2.RAI 3In SR 4.8.2. 1Ab, the licensee proposes to add "the frequency specified in theSurveillance Frequency Control Program (SFCP),"

in place of the "least once perrefueling" currently specified.

However, this does not appear to be a routine periodicsurveillance, in that this frequency appears to be a frequency that is "event-driven with atime component for performing the surveillance on a one-time basis once the eventoccurs."

Please provide the technical basis for relocating this frequency to the SFCP.Per Section 2.0 of the approved TSTF-425, Revision 3, relocation of "Frequencies thatare event-driven but have a time component for performing the surveillance on a onetime basis once the event occurs" are specifically prohibited.

DNC ResponseThe frequency specified in SR 4.8.2.lAb of "at least once per refueling" is a routineperiodic surveillance that is performed on an 18-month interval during each refueling outage. Due to the custom format and wording of the MPS2 TSs, the frequency canappear to be event-driven and therefore not a candidate for relocation to the SFCP.However, in this case, the term "refueling" is used to define the interval or frequency.

The wording contained in SR 4.8.2.lAb is similar to the wording in SRs 4.4.3.1.2 and4.4.3.2.2 for MPS3. These surveillances, which specified "at least once each refueling interval" were approved for relocation to the SFCP under MPS3 License Amendment 258 (ADAMS Accession No. ML14023A748).

RAI 4On page 4 of 12 of Attachment 4 in the LAR, the licensee indicated that SR 4.1.1.5would be included with the LAR. The NRC staff has not found page 3/4 1-7 includedwith the original submittal.

Does MPS2 intend to include the SR 4.1.1.5 frequency in thechange?DNC ResponseYes. DNC proposes to include SR 4.1.1.5 (i.e., SR 4.1.1.5.b) in the change since it doesnot meet any of the four exclusion criteria specified in TSTF-425, Revision

3. The TSmark-up to reflect relocation of the surveillance frequency in SR 4.1.1.5.b to the SFCP, isprovided in Attachment

2.

Serial No. 15-342Docket No. 50-336ATTACHMENT 2TECHNICAL SPECIFICATIONS MARKED-UP PAGESMILLSTONE POWER STATION UNIT 2DOMINION NUCLEAR CONNECTICUT, INC.

Serial No. 15-342Docket No. 50-336Attachment 2, Page 1 of 2Aug1iet 1,19:75PLANT SYSTEMSACTIVITYLIMITING CONDITION FOR OPERATION 3.7.1.4 The specific activity of the secondary coolant system shall be 0.10 uCi/gram DOSEEQUIVALENT 1- 13 1.APPLICABILITY:

MODES 1, 2, 3 and 4.ACTION:With the specific activity of the secondary coolant system > 0.10 uCi/gram DOSEEQUIVALENT 1- 131, be in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after detection.

SURVEILLANCE REQUIREMENTS 4.7.1.4 The specific activity of the secondary coolant system shall be determined to be withinthe limit by performance of the sampling and analysis pr-oegm of Table 4.7-2.MILLSTONE

-UNIT 23/4 7-7 Serial No. 15-342Docket No. 50-336Attachment 2, Page 2 of 2REACTIVITY CONTROL SYSTEMSMINIMUM TEMPERATURE FOR CRITICALITY LIMITING CONDITION FOR OPERATION 3.1.1.5 The Reactor Coolant System temperature (Tavg) shall be 515'F when the reactor iscritical.

APPLICABILITY:

MODES 1 and 2*.ACTION:With the Reactor Coolant System temperature (Tavg) < 515'F, restore Tavg to within its limitwithin 15 minutes or be in HOT STANDBY within the next 15 minutes.SURVEILLANCE REQUIREMENTS 4.1.1.5 The Reactor Coolant System temperature (Tavg) shall be determined to be 515'Ea. Within 15 minutes prior to making the reactor critical, andb. AfAlemt ,nee per when the reactor is critical and the Reactor Coolant Systememperature (Tavg) is < 525°F.Z[the frequency specified in the Surveillance Frequency Control Program* With Keff - 1.0.MILLSTONE

-UNIT 23/4 1-7AMENDMENT NO. -24, 480