ML071300648

Supplement to Safety Evaluation for Amendment No. 254 Regarding Relocation of Requirements for Hydrogen and Oxygen Monitors

ML071300648
Person / Time
Site:	Duane Arnold
Issue date:	05/23/2007
From:	Feintuch K NRC/NRR/ADRO/DORL/LPLIII-1
To:	Vanmiddlesworth G Nuclear Management Co
Feintuch K, NRR/DORL/LPL3-1, 415-3079
References
TAC MC1900
Download: ML071300648 (5)

Text

May 23, 2007 Mr. Gary Van Middlesworth Site Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - SUPPLEMENT TO SAFETY EVALUATION FOR AMENDMENT NO. 254 REGARDING RELOCATION OF REQUIREMENTS FOR HYDROGEN AND OXYGEN MONITORS (TAC NO. MC1900)

Dear Mr. Van Middlesworth:

In your letter of July 17, 2006 (ADAMS Accession No. ML062080521), you requested that the safety evaluation for Amendment No. 254 be corrected to include, in the commitment for oxygen monitoring equipment, the following language, (for post-accident monitoring function).

This letter responds to that request.

On June 10, 2004, the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No.

254 to Facility Operating License DPR-49 for Duane Arnold Energy Center (DAEC). The Amendment consisted of changes to the DAEC Technical Specifications in response to an application letter from Nuclear Management Company, LLC (NMC) dated January 30, 2004 (ML040420424). Amendment No. 260, issued on January 27, 2006, transferred the DAEC license from NMC to FPL Energy Duane Arnold, LLC (FPL Energy).

In the application dated January 30, 2004, two new commitments were made; the second of which addressed the Oxygen Monitoring System. The application included site-specific information within Enclosure 1, Table 1, which contained a footnote (a) that applied to Monticello Nuclear Generating Plant (MNGP) and to DAEC. Footnote (a) clarified for both MNGP and DAEC, in part, that [o]nly the post-accident monitoring function will meet Regulatory Guide 1.97 and will be included in the Technical Requirements Manual [for DAEC]

or the Commitment Tracking Program [for MNGP]. DAEC implemented the change to its Technical Requirements Manual by modifying Table T3.3.3-1 on page 3.3-11.

The clarifying phrase (for post-accident monitoring function) should have been included in the safety evaluation (SE) Section 4.2 for DAEC Amendment No. 254, as it was in the SE Section 4.2 for MNGP Amendment No. 138 contained in the NRC letter dated May 21, 2004 (ML041180612), since both the DAEC and MNGP amendments were based on the same application dated January 30, 2004, and footnote (a) applied to the oxygen monitoring functions of both facilities. The NRC staff considers the omission to be an administrative error.

G. Van Middlesworth The enclosure provides a revised page 5 for the SE included in the NRC letter dated June 10, 2004. Please replace the current page 5 with the revised page 5.

Sincerely

/RA/

Karl Feintuch, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

Revised page 5 of Safety Evaluation for Amendment No. 254 cc w/encl: See next page

ML071300648 OFFICE LPL3-1/PM LPL3-1/LA OGC LPL3-1/BC NAME KFeintuch THarris BKlukan LRaghavan DATE 05/11/07 5/11/07 5/22/07 5/23/07 degradation of the reactor coolant pressure boundary. Oxygen monitors have not been shown by a probabilistic risk assessment to be risk-significant. Therefore, the staff finds that oxygen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TS and, therefore, may be relocated to other licensee-controlled documents.

However, for plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment. In addition, separate requirements for primary containment oxygen concentration will be retained in TS for plant designs with an inerted containment. The basis for retention of this requirement in TS is that it meets Criterion 2 of 10 CFR 50.36(c)(2)(ii) in that it is a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This is based on the fact that calculations typically included in Chapter 6 of Updated Final Safety Analysis Reports assume that the primary containment is inerted, that is, oxygen concentration < 4.0 volume percent, when a design-basis LOCA occurs.

4.0 VERIFICATIONS AND COMMITMENTS As requested by the staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.

4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.

The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. The licensee has committed to maintain the hydrogen monitors within its Technical Requirements Manual. The licensee will implement this commitment as part of the implementation of the amendment.

4.2 For plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment (for applicable plants).

The licensee has verified that it has an oxygen monitoring system capable of verifying the status of the inert containment (for post-accident monitoring function). The licensee l has committed to maintain the oxygen monitors within its Technical Requirements Manual. The licensee will implement this commitment as part of the implementation of the amendment.

The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.

Should the licensee choose to incorporate a regulatory commitment into the emergency plan, final safety analysis report, or other documents with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.

Revised by NRC letter dated May 23, 2007

Duane Arnold Energy Center cc:

Mr. J. A. Stall U.S. Nuclear Regulatory Commission Senior Vice President, Nuclear and Chief Suite 210 Nuclear Officer 2443 Warrenville Road Florida Power & Light Company Lisle, IL 60532-4351 P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. M. Warner Vice President, Nuclear Operations, Mr. M. S. Ross North Region Managing Attorney Florida Power & Light Company Florida Power & Light Company P. O. Box 14000 P. O. Box 14000 Juno Beach, FL 33408-0420 Juno Beach, FL 33408-0420 Mr. D. A. Curtland Marjan Mashhadi Plant Manager Senior Attorney Duane Arnold Energy Center Florida Power & Light Company 3277 DAEC Rd.

801 Pennsylvania Avenue, NW Palo, IA 52324-9785 Suite 220 Washington, DC 20004 Mr. R. S. Kundalkar Vice President, Technical Services Mr. W. E. Webster Florida Power & Light Company Vice President, Nuclear Operations P. O. Box 14000 South Region Juno Beach, FL 33408-0420 Florida Power & Light Company P. O. Box 14000 Daniel K. McGhee Juno Beach, FL 33408-0420 Iowa Department of Public Health Bureau of Radiological Health John Bjorseth 321 East 12th Street Site Director Lucas State Office Building, 5th Floor Duane Arnold Energy Center Des Moines, IA 50319-0075 3277 DAEC Road Palo, IA 52324 Chairman, Linn County Board of Supervisors Steven R. Catron 930 1st Street SW Manager, Regulatory Affairs Cedar Rapids, IA 52404 Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 May 4, 2007 Palo, IA 52324 Regional Administrator, Region III