NG-03-0355, Ctr Technical Specification Change Request, Eliminate Requirements for Post Accident Sampling System Using Consolidated Line Item Improvement Process

Ctr Technical Specification Change Request, Eliminate Requirements for Post Accident Sampling System Using Consolidated Line Item Improvement Process

ML031611045
Person / Time
Site:	Duane Arnold
Issue date:	05/30/2003
From:	Peifer M Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
NG-03-0355
Download: ML031611045 (9)

Text

Committed to Nuclear Excellence Duane Arnold Energy Center Operated by Nuclear Management Company, LLC May 30, 2003 NG-03-0355 10 CFR 50.90 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Document Control Desk Mail Station 0-P1-17 Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Technical Specification Change Request (TSCR-061)

Eliminate Requirements for Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process File: A-117 In accordance with the Code of Federal Regulations, Title 10 Section 50.90, Nuclear Management Company, LLC (NMC) is submitting a request for amendment to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

The proposed amendment would delete Technical Specification 5.5.3, "Post Accident Sampling,"

in the DAEC TS and thereby eliminate the requirements to have and maintain the Post Accident Sampling System (PASS) at DAEC. This change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-413, "Elimination of Requirements for a Post Accident Sampling System (PASS)." The availability of this technical specification improvement was announced in the FederalRegister on March 20, 2002, as part of the consolidated line item improvement process (CLIIP). As discussed in the model safety evaluation (SE) for this TS improvement, this request also revises TS 5.5.2, "Primary Coolant Sources Outside Containment" to reflect that a plant modification is planned for completion beyond the implementation period of this proposed Amendment to eliminate PASS as a potential leakage path outside of containment for highly radioactive fluids.

Attachment 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages.

Attachment 4 provides a summary of the regulatory commitments made in this submittal.

NMC requests approval of the proposed license amendment by September 1, 2003. Please issue the amendment to be effective on the date of issuance and to be implemented within 180 days of receipt by NMC.

3277 DAEC Road

• Palo, Iowa 52324-9785 ) L 1 Telephone: 319.851.7611

May 30, 2003 NG-03-0355 Page 2 of 2 This application has been reviewed by the DAEC Operations Committee. A copy of this submittal is being forwarded to our appointed state officials pursuant to 10 CFR Section 50.91.

This letter is true and accurate to the best of my knowledge and belief.

Nuclear Management Company, LLC By tfark APeiflv DAEC Site Vice-President State of Iowa (County) of Linn Signed and sworn to me before on this 3 day of 2003 By Ma&v A.PeAi,&

Notary Public in and for the State of Iowa Commission Expires : Description and Assessment : Marked Up DAEC Technical Specifications Page : Revised (Clean) DAEC Technical Specifications Page : List of Regulatory Commitments CC: C. Bleau (w/a)

D. Hood (NRC-NRR) (w/a)

J. Dyer (NRC-Region III) (w/a)

D. McGhee (State of Iowa) (w/a)

DAEC NRC Resident Office (w/a)

DAEC Document Control

Attachment I of NG-03-0355 Description and Assessment License Amendment Reguest TSCR-061 Technical Specification Improvement to Eliminate Requirements for Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process

1. Description The proposed license amendment deletes the program requirements of Technical Specifications (TS) 5.5.3, "Post Accident Sampling." The proposed license amendment also revises TS 5.5.2, "Primary Coolant Sources Outside Containment," to reflect the future planned elimination of the Post Accident Sampling System (PASS) as a potential leakage path outside of containment for highly radioactive fluids.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-413. The availability of this Technical Specification improvement was announced in the FederalRegister on March 20, 2002, as part of the consolidated line item improvement process (CLIIP).

2. Assessment 2.1 Applicability of Published Safety Evaluation NMC has reviewed the safety evaluation published on December 27, 2001 (66 FR 66949) as part of the CLIIP. This verification included a review of the NRC staffs evaluation (as modified slightly by the notice of availability) as well as the supporting information provided to support TSTF-413 (i.e., NEDO-32991, "Regulatory Relaxation for BWR Post Accident Sampling Stations (PASS)," submitted November 30, 2000, and the associated NRC safety evaluation dated June 12, 2001). NMC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Duane Arnold Energy center (DAEC) and justify this amendment for incorporation of the changes to the DAEC TS.

2.2 Optional Changes and Variations NMC is not proposing any variations or deviations from the Technical Specification changes described in TSTF-413 or the NRC staff's model safety evaluation published on December 27, 2001. The DAEC TS include an administrative requirement for a program to minimize the leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. PASS is specifically listed in TS 5.5.2 as falling under the scope of this requirement. As described in the staff s model safety evaluation published on December 27, 2001, NMC is proposing to implement a plant modification at a later date to eliminate PASS as a potential leakage path outside containment for highly radioactive fluids. Therefore, until the plant modification is implemented, PASS will continue to be a potential leakage path outside containment for highly radioactive fluids (e.g., the PASS piping will penetrate the containment with valves or other components in the system from which highly Page 1 of 2

Attachment 1 of NG-03-0355 indicate that PASS will radioactive fluid could leak). It is proposed that TS 5.5.2 be revised to radioactive fluid could leak). It is proposed that TS 5.5.2 be revised to indicate that PASS will remain a potential leakage path until modified.

The proposed TS change does not result in an associated TS Bases change.

3. Regulatory Analysis 3.1 No Significant Hazards Determination NMC has reviewed the proposed no significant hazards consideration determination published on December 27, 2001 (66 FR 66949) as part of the CLIIP. NMC has concluded that the proposed determination presented in the notice is applicable to DAEC and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the model Safety Evaluation published in the FederalRegister on December 27, 2001, for this Technical Specification improvement, plant-specific verifications were performed as follows:

1. NMC will develop contingency plans for obtaining and analyzing highly radioactive samples from the reactor coolant system (RCS), the suppression pool, and the containment atmosphere. The contingency plans will be contained in the plant technical procedures and implementation will be completed within the 180-day implementation period for the Amendment when approved. Establishment and maintenance of contingency plans is considered a regulatory commitment.

2. The capability for classifying fuel damage events at the Alert level threshold will be established for DAEC at radioactivity levels of 300 iCiIgm dose equivalent iodine. This capability will be described in the emergency plan implementing procedures and implementation will be completed within the 180-day implementation period for the Amendment when approved. The capability for classifying fuel damage events is considered a regulatory commitrnent.

3. The NMC has developed an I-131 site survey detection capability, including an ability to assess radioactive iodines released to offsite environs by using effluent monitoring systems or portable sampling equipment. The capability for monitoring iodines is maintained within the emergency plan implementing procedures. The capability to monitor radioactive iodines is considered a regulatory commitment. Implementation of this commitment is complete.

4. Environmental Evaluation NMC has reviewed the environmental evaluation included in the model safety evaluation published on December 27, 2001 (66 FR 66949) as part of the CLIIP. NMC has concluded that the staffs findings presented in that evaluation are applicable to DAEC and the evaluation is hereby incorporated by reference for this application.

Page 2 of 2

Attachment 2 of NG-03-0355 Marked Up DAEC Technical Specification Page License Amendment Request TSCR-061 Technical Specification Improvement to Eliminate Requirements for Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process Current Technical Specification Page Marked Up with Proposed Changes Page 5.0-8 Page 1 of 2

Programs and Manuals Programs and Manuals 5.5 p 5.5 Programs and Manuals 5.5.1 Offsite Dose Assessment Manual (ODM) (continued) narkings in the margin of the affected pages. clearly Indicating the area of the page that was changed, and shall ndicate the date (.e.. month and year) the change was Implemented.

5.5.2 Primary Coolant Sources Outside Containnent This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practlcable. The systems nclude Core Spray.

High Pressure Coolant Injection. Residual Heat Removal. Reactor Core Isolation Cooling. Reactor Water Cleanup (only to second isolation valve). Post Accident Sampling Containment Atmos eric Monitoring. Control Rod Drive (scram disc arge volume on y) a Liquid Radwaste (only Reactor Building Floor and Equipment Drain

-sump pumps. piping. and tanks up to and including collector tanks). The program shall nclude the following:.

a. Preventive maintenance and periodic visual inspection requirements: and

b. System leak test requirements for each system at 0.5 refueling cycle intervals or less. eliminate PAS

\ i rogrm g es c tat e ethe capab i 0obaln a Malz colng neStRdioactive 94~s. and', ¢ particu kes in plsS seous elntad oEiniment a ihre sa. unde 7 n s h hall in e.

a. Tr ingofper nnel/

b. rocedu o sampling an lysis; a

c. Pro Io10ns for mainte ce of sampli and ana ss (continued)

DAEC 5.0-8 A.mndmdent-22-3

-rs C- - o

Attachment 3 of NG.03-0355 Revised (Clean) DAEC Technical Specification Page License Amendnient lRecuest TSCR-061 Technical Specification Improvement to Eliminate Requirements for Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process Revised Technical Specification Page Pae 5.0-8 Page 1 of 2

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.1 Offsite Dose Assessment Manu0l (ODAM) (continued) markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.

5.5.2 Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include Core Spray, High Pressure Coolant Injection, Residual Heat Removal, Reactor Core Isolation Cooling, Reactor Water Cleanup (only to second isolation valve), Post Accident Sampling (until such time as a modification eliminates PASS as a potential leakage path),

Containment Atmospheric Monitoring. Control Rod Drive (scram discharge volume only) and Liquid Radwaste (only Reactor Building Floor and Equipment Drain sump pumps, piping, and tanks up to and including collector tanks). The program shall include the following:

a. Preventive maintenance and periodic visual inspection requirements; and

b. System leak test requirements for each system at refueling cycle intervals or less.

5.5.3 DELETED (continued)

DAEC 5.0-8 TSCR-061

Attachment 4 of NG-03-0355 List of Regulatory Commitments License Amendient Request TSCR-061 Technical Specification Improvement to Eliminate Requirements for Post Accident Sampling Systems Using the Consolidated Line Item Improvement Process The following table identifies those actions committed to by NMC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Regulatory Commitments Due Date/Event

-f NMC will develop contingency plans for obtaining and Will be completed within 180 day analyzing highly radioactive samples from the reactor implementation period for the coolant system (RCS), the suppression pool, and the Amendment containment atmosphere. The contingency plans will be contained in the plant technical procedures and implementation will be completed within the 180-day implementation period for the Amendment when approved. Establishment and maintenance of contingency plans is considered a regulatory commitment.

The capability for classifying fuel damage events at the Will be completed within 180 day Alert level threshold will be established for DAEC at implementation period for the radioactivity levels of 300 pCi/gm dose equivalent Amendment iodine. This capability will be described in the emergency plan implementing procedures and implementation will be completed within the 180-day implementation period for the Amendment when approved. The capability for classifying fuel damage events is considered a regulatory commitment.

NMC has developed an 1-13 1 site survey detection Complete capability, including an ability to assess radioactive iodines released to offsite environs by using effluent monitoring systems or portable sampling equipment.

The capability for monitoring iodines is maintained within the emergency plan implementing procedures.

Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment Page 1 of I