Text

TER to Request for TS Change,Ielp,Cipc & Cbpc,Daec
	ML112380516
Person / Time
Site:	Duane Arnold
Issue date:	11/12/1993
From:	; SCIENTECH
To:	; NRC
Shared Package
ML112380517	List: ML112380516; ML20058A678;
References
	NUDOCS 9312010177
	Download: ML112380516 (43)
	v • d • e

ENCLOSURE Technical Evaluation Report Prepared By SCIENTECH, Inc.

Related to Request for Technical Specification Change IOWA ELECTRIC LIGHT AND POWER COMPANY CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DUANE ARNOLD ENERGY CENTER DOCKET NO.

50-331 INTRODUCTION By letter dated March 27, 1992, Iowa Electric Light and Power Company, the licensee, requested changes to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC). On August 13, 1993, SCIENTECH, Inc. was tasked by the NRC to review the requested changes to the DAEC TS and prepare a Technical Evaluation Report (TER). A draft TER was provided to the NRC for review on September 29, 1993. The report was finalized following discussions with the NRC staff on October 13, 1993.

DISCUSSION The changes requested by the licensee would revise the limiting conditions for operation and the surveillance requirements for primary containment integrity, secondary containment integrity, and associated systems and equipment addressed in section 3.7 of the DAEC Technical Specifications, to improve their clarity and consistency with the Standard Technical Specifications (STS). The requested changes also would add limiting conditions for operation and surveillance requirements for drywell average air temperature and secondary containment automatic isolation dampers to the existing TS.

The requested changes resulted from an independent evaluation of the DAEC TS completed in 1991, conducted as part of DAEC TS Improvement Program, which included comparisons of the DAEC TS with TS from peer plants, Standard Technical Specifications, and the draftImproved Technical Specifications (NUREG-1433). This evaluation identified a number of improvements that should be made to the DAEC TS, including the addition of specifications related to the drywell temperature and secondary containment 9312010177 931112

-1 PDR ADOCK 05000331 P

PDR

isolation dampers. For comparison with the Standard Technical Specifications, the licensee used the Technical Specifications issued by the NRC for the Hope Creek Generating Station (NUREG-1202) in July 1986. These are the latest TS issued by the NRC for an operating BWR-4 plant and comparison of -. : -AEC TS to the Hope Creek TS is acceptable to the NRC staff. Accordingly, we have used NUREG-1202 as an example of the STS for comparison with the DAEC TS.

EVALUATION We have performed an item by item evaluation of each of the changes requested by the licensee. The results are presented in the enclosure. A large number of the changes are administrative or editorial in nature, resulting from a reorganization of the TS Section 3.7 material to track more closely the organization of the STS. These have no effect on plant safety. A number of proposed changes would result in no change or no change in intent from the existing limiting conditions for operation, action statements, and surveillance requirements of the DAEC TS; they merely move these requirements into the revised organizational format for Section 3.7, and do not impact plant safety. In many instances, where plant-specific considerations allow, the proposed changes would incorporate the limits of the STS in place of those in the existing DAEC TS. Finally, there are several instances where the proposed changes are not in accord with either the STS or the existing DAEC TS. In these cases, we have analyzedthe changes and found them to be acceptable.

However, in several instances, as noted in this TER and the evaluation matrix, we have identified shortcomings which we believe the licensee should be urged to correct.

For purposes of shorthand identification of the types of changes, the enclosure indicates for each change the assigned review category or categories. These review categories are defined as follows :

1.

Administrative/editorial change and therefore acceptable.

2.

No change from the intent of the existing TS. Does not result in a decrease in safety from the existing TS and therefore acceptable.

3.

Consistent with the STS and therefore acceptable.

4.

Not in accordance with the STS or the existing DAEC TS, but has been analyzed and found acceptable.

5.

Unacceptable without additional justification.

.2-

A problem arises when attempting to compare the DAEC TS with the STS due to variations in the definitions of Operational Conditions. These differences are compared in the following table:

Operational Condition Definitions Standard Tech Specs Duane Arnold Power Operation -

Reactor Power Operation Mode switch in RUN position Mode switch in STARTUP or RUN Reactor coolant at any temperature Reactor critical and above 1% rated power Startup Hot Standby Condition Mode switch in STARTUP / HOT Mode switch in STARTUP / HOT STANDBY STANDBY Reactor coolant at any temperature Reactor coolant temperature >212'F Reactor pressure <1055 psig Hot Shutdown Hot Shutdown Mode switch in SHUTDOWN Reactor in SHUTDOWN mode Reactor coolant >200*F Reactor coolant >212F Cold Shutdown Cold Condition Mode switch in SHUTDOWN Reactor coolant 5212'F Reactor coolant_5200*F Refueling Cold Shutdown Mode switch in SHUTDOWN or Reactor in SHUTDOWN mode REFUEL Reactor coolant 5212*F Reactor coolant 5140*F Reactor vessel vented to atmosphere When attempting to adjust the DAEC TS to the STS format, these variations in definitions of the operating conditions result in specified temperature limits for DAEC that are slightly higher than the limits specified in the STS. However, the 212*F used by DAEC has been previously reviewed and approved by the NRC staff, and there is no justification caused by this requested change for reducing this to the 200F value used in the STS.

In each instance, the proposed changes would result in TS which are as good as or better than the existing DAEC TS. The addition of requirements regarding the drywell average air temperature and secondary containment isolation dampers are distinct improvements from the existing TS. The licensee's letter states that as of the time of the submittal of the request, an acceptable method of performing surveillance testing for actuation times on the A, I I

secondary containment isolation dampers had not been developed, but that a test was under development and would be submitted as a separate request at a later date. While the absence of a suitable surveillance test for the isolation damper actuation times represents a deficiency in the proposed TS, we do not view it as critical at this juncture. The addition of requirements in the revised TS on the secondary containment isolation dampers is a considerable improvement in and of itself. The surveillance test can be added later.

However, the licensee should be encouraged to remedy this deficiency at an early date.

In addition, we have identified the following deficiencies which are not cause for rejection of the proposed TS change, but which we believe should be corrected by the licensee at an early date.

1. While the DAEC FSAR Section 6.5 states that the secondary containment is maintained at a negative 1/4-inch of water pressure during normal operation, there is no requirement in either the existing or proposed TS to periodically verify this negative pressure. Further, the TS do not specify or require testing to verify the maximum time for SGTS operation to achieve the 1/4-inch of water vacuum in secondary containment. These are shortcomings in the TS which the licensee should be urged to correct.

2. The Bases for new TS sections 3.7.Band 4.7.B include an added discussion of the actions to be taken in the event that one or more primary containment isolation valves are inoperable. In general, this is an improvement. However, the discussion includes use of "a check valve inside primary containment with flow through the valve secured" as an acceptable isolation barrier. These words are not consistent with TS 3.7.B and should be corrected.

3. The Bases for Section 3.7.L and 4.7.L in the proposed revised TS, which have not been changed from the Bases of the existing DAEC TS, state that "...air distribution (across the HEPA filter bank) should be determined annually...." However, proposed revised TS 4.7.L. 1.c requires an air distribution demonstration to be performed "after each complete or partial replacement of a HEPA filter bank or after any structural maintenance on the system housing." The Bases should be revised to support the revised requirement for the air flow demonstration.

CONCLUSION Overall, we conclude that the revised TS Section 3.7 would be a distinct improvement over the existing DAEC TS. The revised TS would track the STS more closely and would be more precise and easier to understand. We recommend that the NRC accept the requested changes to the DAEC TS and give consideration to the three deficiencies discussed above.

Enclosure:

Evaluation Matrix -- Proposed Changes to DAEC Technical Specifications Revisions to Section 3.7 (RTS 246)

-51

EVALUATION MATRIX PROPOSED CHANGES TO THE DAEC TECHNICAL SPECIFICATIONS CONTAINMENT SYSTEMS Section 3.7 (RTS 246)

Prepared By:

SCIENTECH, Inc.

Contract Number Task Order Number NRC-03-93-031 93-06

DUANE ARNOLD El WY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page I Review No.

Proposed Change Evaluation of the Proposed Change Category iii The Table of Contents has been revised to reflect that This is an administrative change to conform the Table Section 3.7, "Containment Systems," has been of Contents for Section 3.7 to the revised contents of' renamed "Plant Containment Systems." Subsections A-the section as proposed by this requested change. It D have been deleted and replaced with subsections A-does not affect plant safety and is therefore acceptable.

M which correspond to the revision to TS section 3.7.

The Surveillance Requirements and page numbers have also been revised accordingly.

vi In the List of Tables, the page at which Table 4.7-1 Revised pagination to reflect the proposed changes I

appears has been revised to correspond to the results in Table 4.7-1 appearing on a different page.

pagination of TS section 3.7.

This is an administrative change and is acceptable.

1.0-4 Definition 15, "Primary Containment Integrity", has This proposed change would bring the DAEC 2

been revised to be more consistent with STS dqfinition definition of Primary Containment Integrity mort 1.31, "Primary Containment Integrity", Subsection a. nearly into conformance with the Standard Technical and c. of previous TS definition 15 have been replaced Specifications (STS) definition.

Adoption of this with new subsection a. which is identical to subsection revised definition would not result in any relaxation of

a. of STS definition 1.31 except for specific the requirements for closure of primary containment discussions of the PCIV Table (which have been penetrations from that required by the existing DAEC relocated to an Administrative Procedure) and Technical Specifications (TS), and would not result in incorporation of a statement allowing the valves to be any decrease in the integrity of the primary opened to perform necessary operational activities. containment. The change is, therefore, acceptable.

Subsection d. of previous TS definition 15 has been re rvd fiw loedesignated as subsection c.sulinanyrelaxation of Page I

DUANE ARNOLD ENY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS 1TSPage 1Review No.

Proposed Change Evaluation of the Proposed Change I Category 1.0-4 Definition 16, "Secondary Containment Integrity", has This proposed change would bring (he DAEC 2

been revised for clarity and to be more consistent with definition of Secondary Containment Integrity more STS definition 1.38, "Secondary Containment nearly into conformance with the STS definition.

Integrity". Subsection c. of previous TS definition 16 Adoption of his revised definition would not result in has been replaced with subsection a. of previous TS any relaxation of the requirements for closure of definition 1.38 except for the discussion of a secondary secondary containment penetrations from that required containment isolation valve/ damper table. The list of by the existing DAEC TS, and would not result in any applicable valves/dampers will be located in an decrease in the integrity of the secondary containment.

Administrative Procedure.

tidditionally, a note The change is, therfore, acceptable.

allowing the valves/dampers to be opened to perform operational activities has been added.

The term "OPERABLE" has been capitalized in subsections b.

and c. to denote that it is a term defined in TS section

_______1.0.

3.2-3 The reference to specification 3.7.B3 in TSsection Page 3.2-3 was changed by Amendment 196 to the NA 3.2.D.2, "Reactor Building Isolation and Standby Gas DAEC TS, issued April 14, 1993, after this Treatment System," has been changed to section 3.7. amendment request was submitted by the licensee. This This more general reference reflects the re-organization requested change, therefore, is no longer applicable.

of TS section 3.7.

3.5-10a The reference to specification 3.7.A.I in TS section This proposed change is administrative in nature and 3.5.G.4 has been changed to section 3.7. This more merely reflects the revisions in the organization of general reference reflects the re-organization of TS Section 3.7. It has no impact upon plant safety. It is, Thsection 3.7.

therefore, acceptable.

3.5-16 The reference to section 3.7.A.

B in the Bases to S This proposed change is administrative in nature and sections 3.5.

and 3.5.C has been changed to section merely reflects the reorganization of Section 37 of the 3.7. This more general reference reflects the re-DAEC TS that would result from this amendment organization of TS section 3.7.

request. It is, therefore, acceptable.

Page 2

DUANE ARNOLD ENEMY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-1 The title of TS section 3.7.A has been changed from This change is administrative in nature and is necessary I

"Primary Containment" to "Primary Containment to accommodate the revised organization of Section Integrity."

3.7. It does not affect plant safety and it is, therefore, acceptable.

3.7-1 Revised TS section 3.7.A.1 contains the Primary This is an administrative and editorial change that Containment LCO previously located in TS section moves the LCO for primary containment integrity from 3.7.A.2. The reference to section 3.7.D.2 has been its position in the existing DAEC TS to a new position revised to 3.7.B.2. The term, "Primary Containment in Section 3.7 and adds capitalization to the term Integrity" has been capitalized to denote that it is a term "Primary Containment Integrity" to indicate tiat it is defined in TS section 1.0.

defined in Section 1. No changes are made to the LCO

________itself, and the change is. therefore. acceptable.

3.7-1 The specifications in previous TS section 3.74k. I are This is an administrative change necessitated by the I

now located in TS section 3.7..

Ireorganization of Section 3.7. The movement oi the specifications to the new position does not afect plant safety and is acceptable.

3.7-1 New TS section 3.7.A.2 specifies what actions are to The movement of the LCO is administrative in nature 1,3 be taken when the requirements of Primary and is acceptable. The change to the LCO conforms Containment Integrity are not met.

The actions the DAEC TS to the STS, results in a more precise (previously located in TS section 3.7.A.8) have been statement of the requirements for maintaining Primary revised and are now consistent with the actions of STS Containment Integrity, and does not in any way relax section 3.6. 1. 1.

the requirements provided by the existing DAEC TS.

fThe changes are, therefore, acceptable.

3.7-1 The title of TS section 4.7.A has been changed from This is an administrative change, conforming the tie to "Primary Containment" to "Primary Containment its counterpart in Section 3.7.A. It does not affect

_______Integrity."

plant safety and is, therefore, acceptable.

Page 3

DUANE ARNOLD EN1WY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page

-- I I Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-1 Revised TS section 4.7.A.1 contains the Primary This is an administrative and editorial change that I

Containment Integrity surveillance requirements moves the surveillance requirements to verify primary previously located in TS section 4.7.A.2. The term, containment integrity from their position in the existing "Primary Containment Integrity" has been capitalized to DAEC TS to a new position in Section 4.7.A. I and denote that it is a term defined in the TS section 1.0.

adds capitalization to the term "Primary Containment Integrity" to indicate that it is defined in Section 1.

There are no changes to the surveillance requirements themselves. The change is, therefore, acceptable.

3.7-1 The subtitle of TS section 4.7.A. La, "Type A Test" is This is an editorial change and is acceptable.

no longer underlined.

3.7-1 In TS section 4.7.A.I.a. (1), the reference to TS This is an administrative change necessitated hv the section 4.7.A.2.a. (9) has been revised to 4.j.A. I.a. revised organization of Section 3.7. The existing TS (8).

,erroneously references 4.7.A.2.a. (9) instead of 4.7.A.2.a. (8). This change corrects the reference in the revised TS to 4.7.A.I.a. (8). The changes are, therefore, acceptable.

3.7-2 The underlining of subtitles of TS sections 4.7.A.l.a. These are editorial changes and are acceptable.

(7) - 4.7.A. La. (9) and 4.7.A..b has been deleted.

3.7-2 In TS section 4.7.A.I.a. (9), the reference to TS These are administrative changes to conform to the I

section 4.7.A.2. (a) (8) has been revised to 4.7.A.l.a. revised organization of Section 3.7 and are acceptable.

(8). The reference to TS section 4.7.A.2. (d) has been revised to 4.7.A.l.d.

3.7-3 The underlining of subtitles of TS sections 4.7.A. I.b. These are editorial changes only and are acceptable.

I (1),

4.7.A.I.b.

(2), 4.7.A.1.c, 4.7.A..d, and 4.7.A.l.d. (1) has been deleted.

3.7-4 The underlining of subtitles of TS sections 4.7.A.I.d. These are editorial changes only and are acceptable.

I (2) - 4.7.A.l.d. (4) has been deleted.

Page 4

DUANE ARNOLD ENY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-4 In TS section 4.7.A.I.d. (2) (a), the term "fueling" has This is an editorial change that clarifies the original I

been changed to "refueling".

intent of this section. It is acceptable.

3.7-5 The underlining of TS sections 4.7.A..e - 4.7.A. I.g These are editorial changes only and are acceptable.

I has been deleted.

3.7-5 In TS section 4.7.A.l.g, the reference to TS sectiol These are administrative changes necessitated by the 1

4.7.A.2.d.4 has been revised to 4.7.A..d. (4) and the reorganization of Section 3.7, and are acceptable.

reference to TS section 4.7.A.2.d.3 has been revised to 4.7.A.1.d.

(3).

3.7-7 TS section.3.7.B has been changed from "Standby Gas This is an administrative change to conform to the I

Treatment System" to "Primary Containment Power revised organization of Section 3.7.

Operated Isolation Valves".

3.7-7 New TS section 3.7.B.1 contains the Primary This is an administrative change to conform to the 1,2 Containment Power Operated Isolation Valve LCO revised organization of Section 3.7.

There is no previously located in TS section 3.7.D.I.

The change to the LCO from that of the existing TS except reference to TS section 3.7.D.2 has been revised to for the reference change necessitated by the 3.7.B.2.

reorganization of the material.

The change is, therefore, acceptable 3.7-7 In TS section 3.7.B. 2, (formerly section 3.7.D.2) the The revised wording better states the requirement for 2

requirement to "maintain at least one isolation valve isolation valve operability and conforms the DAEC TS OPERABLE or ISOLATED has been changed to to the STS wording, but does not affect the "Maintain at least one isolation valve OPERABLE in requirement for isolation valve operability. This each affected penetration that is open". The revised clarification improves the DAEC TS and it is, wording is consistent with action a. of STS section therefore, acceptable.

.3.6.3.__

3.7-7 TS section 3.7.B.2.b has been revised to be consistent The proposed wording of this section conforms to that 2

with action a. 2 of STS section 3.6.3.

of the STS. There is no change in the intent. The change is, therefore, acceptable.

Page 5

DUANE ARNOLD ENIMY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS I TSPage I Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-7 The note denoted by "*" has been deleted due to the This is an administrative change necessitated by the I

changes to TS section 3.7.B.2. The note denoted by revised wording of proposed Section 3.7.B.2.b. It has

"**" has been changed to "*."

no affect on plant safety and is acceptable.

3.7-7 TS section 4.7.B. has been changed from "Standby This is an administrative change necessitated by the I

Gas Treatment System" to "Primary Containment proposed change in the title of Section 3.7.B. It is Power Operated Isolation Valves."

acceptable.

3.7-7 TS section 4.7.B.1 contains the Primary Containment These surveillance requirements are moved without Power Operated Isolation Valve surveillance change in content to the new location. This change is requirements previously located in TS section 4.7.D. I. administrative in nature and is acceptable. The change The note previously denoted by "*" has been changed in reference to the footnotes avoids possible confusion to "#." The note previously denoted by "**" has been with the footnote to Section 3.7.B.2.b and is editorial changed to in nature. It is aCCLplabpe.

3.7-7 In the note denoted by "W', the reference to TS section This is an administrative change necessitated by h 4.7.1).La has been revised to 4.7.1.w.a.

reorganization of the material in Section 3.7. It is accepable. Itic__be 3.7-7 In the note denoted by "#", the reference to TS section This is an administrative change necessitated by the 1

4.7.D..b has been revised to 4.7.B..b. The word reorganization of the material in Section 3.7.

It is "suction" has been capitalized.

acceptable.

In the proposed revised TS, the word "suction" has not been capitalized as stated in the amendment request. However, this does not affect the acceptability of the proposed change.

3.7-8 TS section 3.7.B.2.c (formerly section 3.7.D.2.c) has The proposed revision clarifies the wording of this 2, 3 been revised to be consistent with action a.3 of STS section and brings it into conformance with the section 3.6.3. The footnote "**" has been changed to wording of the STS.

There is no change to the of_*."

requirement of the LCO. It is, therefore, acceptable.

Page 6

DUANE ARNOLD ENY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-8 In TS section 3.7.B.3 (formerly 3.7.D.3), the Te changes in the referenced TS sections are made to 1,2,3 references to TS sections 3.7.D.1 and 3.7.D.2 have accommodate the revised organization of Section 3.7, been revised to 3.7.B.I and 3.7.B.2 respectively. The and are acceptable.

The revised wording of the requirement to "be in the Cold Shutdown condition requirement )ovides a more precise description of within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " has been changed to "be in at least what is required, conforms the wording to the STS HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and COLD requirement, and does not result in any decrease in tie SHUTDOWN in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ."

These protection afforded to the primary containment shutdown requirements are consistent with the other integrity. It is, therefore, acceptable.

shutdown requirements of this chripter.equiremenn o

3.7-8 The note denoted by "w" has been added and is The addition of this footnote is an administrative identical to the note on TS page 3.7-7.

change necessitated by a page change for 3.7.B.2.c. It represents no change from the requirement of the shudonequreensaeonexisting TS, and it is, therefore, acceptable.

3.7-8 TS sections 3.7.b.4, "Purging," and TS 'section This is an administrative change to accommodate the 1,2 3.7.B.4.a contain the requirements previously located revised organization of Section 3.7.

There is no in TS section 3.7.A.9. The underlining of the subtitle change to the requirement from that in the existing TS of TS section 3.7.A.9 has been deleted.

and it is, therefore, acceptable.

3.7-9 The title of TS section 3.7.C has been changed from This is an administrative change to accommodate the I

"Secondary Containment to "Drywell Average Air revised organization of Section 3.7. It is acceptable.

Temperature."

Page 7

DUANE ARNOLD WGY CENTER (DAEC)

TECHNICAL SPECIFICXTION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Cateor 3.7-9 TS section 3.7.C.1 is a new specification for drywell This new specification makes the DAEC TS conform 4

average air temperature that is consistent with the more closely to the STS by the addition of an LCO on drywell average air temperature LCO contained in STS drywell temperature. The temperature limit is set at 3.6.1.7. The specified applicability, however, is the I35*F, which is the same as the STS temperature limit, same as specified in TS section 3.7.A.1, "Primary and is the temperature used in the DAEC Design Basis Containment Integrity" (without the exception for low Accident calculations. The LCO is applicable when the power physics testing).

reactor is critical or when fuel is in the reactor vessel and the reactor temperature is above 212F. The comparable STS requirement is that the drywell temperature LCO is applicable during Operational Conditions 1, 2 and 3. Operational Condition 3 specifies a reactor temperature >200'F. The proposed DAEC LCO thus is not quite as tight as the LCO for the STS.

However, the DAEC LCO applicability for control of drywell temperature is the same as the DAEC LCO applicability for control of primary containment integrity, which previously has been reviewed by the staff and found acceptable. There is no reason to have tighter controls on drywell temperature applicability than on primary containment integrity. Thus, since this is an added requirement not present in the existing TS; since it conforms closely to the STS requirement, varying only in the specified reactor coolant temperature above which the LCO is applicable; and since its applicability is the same as for the previously approved applicability for primary containment integrity controls, we find the change acceptable.

3.7-9 TS section 3.7.C.2 contains the action statement for This action statement conforms the DAEC TS to the 3

Specification 3.7.C.I. These actions are identical to action statement of the STS and is acceptable.

the actions required by STS section 3.6.1.7.

Page 8

DUANE ARNOLD El Y CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-9 The title of TS section 4.7.C has been changed from This is an administrative change to conform the section I

"Secondary Containment" to "Drywell Average Air title to the title its counterpart Section 3.7.C. It is Temperature."

acceptable.

3.7-9 TS section 4.7.C.1 contains drywell average air The specified surveillance requirements are the same as 4

temperature surveillance requirements similar to the those contained in the STS except that the locations for surveillance requirements of STS section 4.6.1.7. The sampling to determine volumetric average drywell reference to volumetric average contained in the STS temperature are not specified. The Bases for Section surveillance requirement is located in the Bases to 3/4.7.C discuss sampling at various elevations in the DAEC TS section 3.7.C.

drywell to obtain a volumetric average. Sample points are not specified, but the stated intent is similar to that of the STS.

Since the requirement for a drywell temperature limit is an added requirement that will enhance plant safety, we find this change acceptable.

3.7-10 The title of TS section 3.7.D has been changed from This is an administrative change to accommodate the 1

"Primary Containment Power Operated Isolation revised organization of Section 3.7. It is acceptable.

Valves" to "Pressure Suppression Chamber - Reactor Building Vacuum Breakers".

3.7-10 TS section 3.7.D.1 contains the LCO for the Pressure This LCO has been modified r correspond to the 1,3 Suppression Chamber - Reactor Building Vacuum wording of the STS.

The intent of the LCO has not Breakers previously located in TS section 3.7.A.3.a. changed from that of the existing TS. The change is an This section has been revised to be consistent with STS improvement and is, therefore, acceptable. The section 3.6.4.2 "Reactor Building - Suppression relocation of the setpoint specification to Section Chamber Vacuum Breakers".

The specified 4.7.D.3 is consistent with the organization of the TS applicability is the same as required in current TS and is acceptable. Capitalization of the term "primary section 3.7.A.3.a. The setpoint specified in present TS Containment integrity" has no affect on plant safety and section 3.7.A.3.a has been relocated to surveillance is acceptable.

requirement 4.7.Dn.3. The term, Primary Containment C

am iehnfoIntegrity, has been capitalized.nplansafetyand Page 9

DUANE ARNOLD El'Y CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-10 TS sections 3.7.D.2 - 3.7.D.4 contain the Action The action statements covered by sectiens 3.7.1.2 3

Statements for Specification 3.7.D.1. These actions, through 3.7.D.4 include all actions of the STS previously located in TS section 3.7.A.3.b. have been regarding the Pressure Suppression Chamber - Reactor revised to be consistent with the actions of STS section Building Vacuum Breakers. Together, these actions 3.6.4.2. Specifically:

provide for improved controls on the vacuum breakers from that afforded by the existing TS.

They are,

The actions of TS section 3.7.D.2 are identical to therefore, acceptable.

action a. of STS section 3.6.4.2.

h The actions of TS section 3.7.D.3 are identical to action b. of STS section 3.6.4.2.

The actions of TS section 3.7.D.4 are identical to action c. of STS section 3.6.4.2.

3.7-10 The title of TS section 4.7.D has been changed from This is an administrative change to accommodate the I

"Primary Containment Power Operated Isolation revised organization of Section 3.7. It is acceptable.

Valves" to "Pressure Suppression Chamber - Reactor Building Vacuum Breakers."

3.7-10 TS section 4.7.D.1 is a new surveillance requirement This new requirement is consistent with the STS, 3

and is consistent with STS section 4.6.4.2.a.

provides for enhanced plant safety, and is acceptable.

Page 10

DUANE ARNOLD ENERO'ENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-10 TS sections 4.7.D.2 and 4.7.D.3 contain the Pressure The relocation of these surveillance requirements is 2,4 Suppression Chamber Reactor Building Vacuum consistent with the revised organization ofTS Section Breakers surveillance requirements previously located 3/4.7 and is acceptable. The requirement of the new in TS section 4.7.A.3.a.

These surveillance TS Section 4.7.D.2 to verify operability of each requirements have been revised as follows:

vacuum breaker assembly valve once per quarter by cycling the valve through one complete cycle, with

TS section 4.7.D.2 now specifies that the position concurrent verification of the operability of the valve indication shall be verified as part of the quarterly position indicators, is a more precise way of stating cycling test.

the intent of existing TS 4.7.A.3.a. and is acceptable.

The requirement of Section 4.7.D.3 for quarterly

TS section 4.7.D.3 now specifies that the opening verification of the differential opening pressure for the setpoint of < 0.5 psid shall be demonstrated. This vacuum breakers is an improvement to the requirement setpoint was previously located in TS section of the existing TS Section 3.7.A.3.a and is acceptable.

3.7. A.3. a.

The STS require monh!y surveillance intervals for the vacuum breaker valves, while the proposed DAEC TS require quarterly surveillance intervals. Thus, the proposed DAEC requirements do not meet the STS requirements. However, they are the same as required by the existing DAEC TS which the staff has previously reviewed and found to be acceptable. The quarterly surveillance intervals are, therefore, acceptable.

3.7-11 The title of TS section 3.7-E has been changed from This is an administrative change to accommodate the "Main Steam Isolation Valve Leakage Control System revised organization of Section 3.7. It is acceptable.

(MSIV-LCS)" to "Drywell - Pressure Suppression vacuumChamber Vacuum Breakers".valveswhiletheprop Page II

DUANE ARNOLD ENEWCENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-11 TS section 3.7.E.1 contains the LCO for the Drywell - This LCO has been modified to correspond to the 3,4 Pressure Suppression Chamber Vacuum Breakers wording of the STS. The applicability of the LC) is previously located in TS section 3.7.A.4.a. This the same as is required by the existing TS which, as section has been revised to be consistent with the discussed ear.

in the evaluation for Section 3.7.C.1, Suppression Chamber - Drywell Vacuum Breaker LCO is nearly identiLal to the applicability requirements of contained in STS 3.6.4.1. The specified applicability, the STS and is acceptable. Deletion of the words however, is the same as required in current TS section "except during testing" strengthens the LCO and is 3.7.A.4.a except that the reference to "except during consistent with the STS which has no such exception.

testing" has been deleted.

"Primary Containment Capitalization of "primary containment integrity" has Integrity" has been capitalized, no affect on plant safety.

In sum, this proposed wordinoftchange strengthens the LCO and is acceptable.

3.7-11 TS sections 3.7.E.2

- 3.7.E.4 contain the action The action statements of TS sections 3.7.fo.2 through 2, 3 statements for specifications 3.7.E.1. These actions, 3.7.E.4 apply the requirements of the STS to the previously located in TS sections 3.7.A.t4.b

- DAEC LCO with one exception. The STS specifies 3.7.A.4.d, have been revised to be consistent with the that with one ofthe vacuum breaker position indicators actions of STS section 3.6.4.C1. Specifically:

inoperable, verification that the vacuum breaker is closed is determined by confirming the ability to 3 The actions of TS section 3.7.E.2 are identical to maintain a 0.5 psi AP across the breaker for one hour action a. of STS section 3.6.4.1.

without makeup.

The DAEC-specific method for verification that the vacuum breaker is closed is to

The actions of TS section 3.7.E.3 are identical to verify that the total drywell to suppression pool bypass action b. of STS section 3.6.4.1.

area is less than 0.2 ft 2. This is in the existing TS and is applied to the revised TS in lieu of the STS method.

The actions of TS section 3.7.E.4 are identical to This does not represent a reduction in safety from that action c. of STS section 3.6.4.1 with the following afforded by the existing TS and is acceptable. Overall, exception. The actions of TS section 3.7.E.4.b are the revised TS regarding the Drywell - Pressure DAEC-specific and were previously located in TS Suppression Pool Vacuum Breakers represents a section 3.7.A.4.b. The specified time limits, considerable improvement over the existing TS and is however, are in accordance with the time limits of acceptable.

action C.2 of STS section 3.6.4. 1.

Page 12

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page]

Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-11 The title of TS section 4.7.E has been changed from This is an administrative change to accommodate the 1

"Main Steam Isolation Valve Leakage Control System" revised organization of Section 3.7. It is acceptable.

to "Drywell - Pressure Suppression Chamber Vacuum Breakers".

3.7-11 TS section 4.7.E.1 is a new surveillance requirement This new surveillance requirement, conforming to the 3

and is consistent with STS section 4.6.4. 1.a.

STS, represents an improvement from the existing TS and is acceptable.

Page 13

DUANE ARNOLD ENEkW ENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-11 TS sections 4.7.E.2 - 4.7.E.4 contain the Drywell Pressure Suppression Chamber Vacuum Breaker surveillance requirements previously located in TS sections 4.7.A.4.a - 4.7.A.4.d. These surveillance requirements have been revised as follows:

TS section 4.7.E.2 has been reworded for clarity and now specifies that the position indication shall be verified as part of the cycling test. This surveillance requirement was previously located in TS section 4.7.A.4.a.

TS section4.7.E.3 contains the inspection requirement previously located in TS section 4.7.A.4.c. The requirement to exercise all OPERABLE vacuum breakers upon identification of a vacuum breaker which is inoperable for opening (also located in previous TS section 4.7.A.4.c) has been deleted. The asterisk "*" has also been deleted.

The surveillance requirement for determining Drywell - Pressure Suppression Chamber bypass leakage previously located in TS section 4.7.A.4.b has been deleted. This surveillance requirement is already part of the actions specified in TS section 3.7.E.4.b.

TS section 4.7.E.4 contains the test requirement previously located in TS section 4.7.A.4.d. The details of this test have been deleted.

Relocation of the surveillance requirements is an administrative change necessitated by the revised organization of Section 3.7, and is acceptable.

The rewording of this surveillance requirement is an editorial change to improve clarity, while the addition of the requirement to verify position indication is an improvement to the existing TS. This change is acceptable.

Deletion of the requirement to immediately exercise all OPERABLE vacuum breakers and at 15-day intervals thereafter upon discovery of an inoperable vacuum breaker represents an improvement in safety in that it eliminates the need for unwarranted wear of the OPERABLE equipment and decreases the possibility of human error.

The monthly cycle tests of the OPERABLE vacuum breakers is sufficient to assure their continuing operability. Deletion of the asterisk is an editorial change and is acceptable.

This change in the location of the requirement to monitor bypass leakage does not affect the intent of the existing DAEC TS and is acceptable.

Relocation of the test requirement does not affect the intent of the existing DAEC TS and is acceptable. Test details are not needed in the TS.

1 1, 2, 4 1,4 2

2 A

Page 14

DUANE ARNOLD ENERMCENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Calegory 3.7-11 The note "*" at the bottom of the page has been This footnote explained a previous amendment change.

I deleted.

Its deletion is editorial in nature and does not affect the TS requirements. The change is acceptable.

3.7-12 The title of TS section 3.7.F has been changed from This is an administrative change to accommodate the I

"Mechanical Vacuum Pump" to "Main Steam Isolation revised organization of Section 3.7. It is acceptable.

Valve Leakage Control System (MSIV-LCS)".

3.7-12 TS section 3.7.F.1 contains the LCO for the MSIV-Relocation of the LCO is an administrative change to I

LCS previously located in TS section 3.7.E. 1. The accommodate the revised organization of Section 3.7.

reference to TS section 3.7.E.2. has been revised to It is acceptable.

3.7.F.2.

3.7-12 TS section 3.7.F.2 contains the actions previoysly Relocation of this action statement is an administrative 1,3,4 located in TS section 3.7.E.2. The statement alloyving change to accommodate the revised organization of operation for 30 days after one MSIV-LCS is Section 3.7, and is acceptable. The addition of the inoperable "provided all active components of the other words "verified to be" allows the operators 10 rely MSIV-LCS subsystems are OPERABLE" has been upon the periodic (monthly) tests of the other MSIV changed to "verified to be OPERABLE".

components to verify operability rather than require potentially non-conservative, conditional surveillance testing of these components, which could result in equipment failure due to the testing and introduce the added possibility of human error. This verification of operability is consistent with the requirements of STS Section 4.4.7 for the MSIVs. Elimination of this additional testing does not substantially decrease the assurance of operability of the redundant MSIV components, and is acceptable.

Page 15

DUANE ARNOLD ENW CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page IReview No.

Proposed Change Evaluation of the Proposed Change Categor; 3.7-12 TS section 3.7.F.3 contains the actions previously Relocation of this action statement is an administrative 1,3,4 located in TS section 3.7.E.3. The reference to TS change to accommodate the revised organizaion of section 3.7.E has been revised to 3.7.F.

The Section 3.7, and s acceptable. The change to the action requirement to be in COLD SHUTDOWN in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months statement represents a relaxation of the requirement in has been changed to be in at least HOT SHUTDOWN the existing DAEC TS, but the resulting requirement is within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN consistent with the action statement of the in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

corresponding STS Section 3.4.7.a.2. It allows for a more orderly shutdown of the plant, if needed, and is acceptable._____

3.7-12 The title of TS sections 4.7.F has been changed from This is an administrative change to accommodate the 3

"Mechanical Vacuum Pump" to "Main Steam Isolation revised organization of Section 3.7. It is acceptable.

Valve Leakage Control System".Secon37,adsccepableThechan 3.7-12 TS section 4.7.F. contains the testing requirements Relocation of the n

testing requirements is an 1,4 previously stated in section 4.7.E.c. The footnote in administrative change to accommodate the revised TS sections 4.7.F.La and 4.7.F.Le has been deleted, organization of Section 3.7. It is acceptable. The footnote was in explanation of a previous TS change and is no longer needed. Its deletion is acceptable.

3.7-12 TS section 4.7.E.2 has been deleted. The operable This deletion is consistent with the revised wording of 4

MSIV-LCS subsystems are now only required to be Section 3.7.F.2 and is acceptable.

S"verified to be OPERABLE" per TS section 3.7.F.2.

organiationofSeion_.7._Itisaceptabe._Th 3.7-12 The note "" at the bottom of the page has been The footnote was in explanation of a previous TS 4

deleted.

change and is no longer needed.

Its deletion is acceptable.

Page 16

DUANE ARNOLD EWGY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-13 TS section 3.7.G, "Suppression Pool Level and This is an administrative change to accommodate the 1,3,4 Temperature" has been added. This new TS section revised organization of Section 3.7. It is acceptable.

contains the suppression pool level and temperature Addition of the requirement for suppression pool requirements previously located in TS section 3.7.A. 1. operability t) the LCO is an enhancement to the The LCO now specifies that the suppression pool shall existing DAEC TS and is acceptable.

be OPERABLE. The applicability of the suppression pool level and temperature limits has been revised to Deletion of the requirement to maintain the limits on delete references to "work is being done which has the suppression pool water volume when "work is being potential to drain the vessel",

done which has t potential to drain the vessel" has no impact on plant safety during periods of reactor operation since such work is accomplished only during shutdown periods. The revised TS is consistent with the STS which requires suppression pool operability only during Operational Conditions 1, 2 and 3.

Existing DAEC TS 3.5.G.4.d requires that, during a refueling outage, operations that have the potential for draining the reactor vessel will he suspended whenever the water level in the suppression chamber falls below the minimum. This is consistent with STS section 3.5.3.b..

Thus, we find deletion of the words "work is being done which has the potential to drain the vessel" acceptable.

Page 17

DUANE ARNOLD ENMUY CENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7.13 TS section 3.7.G.1, "Suppression Pool Level", Relocation of the suppression pool level requirements 1,3 contains the LCO for Suppression Pool Level is an administrative change to accommodate the revised previously located in TS sections 3.7.A.I.a and organization of Section 3.7.

The revisions to the 3.7.A..b. This section has been revised for clarity wording improve the clarity and conform the wording and to be consistent with STS section 3.6.2.1.

to the STS format. The changes are acceptable.

Specifically:

The wording format now follows the STS wording

TS section 3.7.G.I.a is consistent with STS section format. There are no changes to the maximum and 2, 3 3.6.2.1.a.1. A reference to indicated suppression minimum specified water levels. Addition of the pool water level (in percent) has been added.

percentages of suppression pool volume to the water level limits adds information not previously provided.

These changes are acceptable.

This action statement is not present in the existing

TS section 3.7.G.I.b is consistent with acdon a. of DAEC TS. It is an improvement, consistent with the 3

STS section 3.6.2.1. A reference to indicated STS, and is acceptable.

suppression pool water level has been added.

Page 18

DUANE ARNOLD ENEIWCENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category I

I TS section 3.7.G.2, "Suppression Pool Temperature" contains the LCOs for suppression pool temperatures previously located in TS section 3.7.A. I.c. This section has been revised for clarity. The specified limits and actions are consistent with STS section 3.6.2.1. Specifically:

TS section 3.7.G.2.a specifies the normal suppression pool temperature limit previously located in TS section 3.7.A.I.c. (1). This temperature limit is consistent with the normal temperature limit specified in STS section 3.6.2.1.a.2.

TS section 3.7.G.2.b is a new LCO which spectfies what actions are to be taken when average suppression pool water temperature is > 95 *F but

< 110 F during operation and not performing testing which adds heat to the pool. These actions are consistent with action b. of STS section 3.6.2.1 and STS section 4.6.2.1.b.2.a.

TS section 3.7.G.2.c contains the suppression pool water temperature limits during the performance of testing which adds heat to the suppression pool previously located in TS section 3.7.A. I.c. (2).

This limit and the specified actions are consistent with STS section 3.6.2.1.a.2. (a) and action b. 1.

of STS section 3.6.2.1. The requirement to verify temperature is < 110 *F once/hr has been added as an additional conservatism and is consistent with STS section 4.6.2.1.b.2.a.

3.7-13 Relocation of the suppression pool temperature requirements is an administrative change to accommodate the revised organization of Section 3.7.

The revisions to the wording improve the clarity and conform the wording to the STS format. The changes are acceptable.

This is the same temperature limit specified in the existing DAEC TS. It is acceptable.

This LCO is not present in the existing DAEC TS, which are silent regarding actions to be taken when the pool temperature is >95'F but <l 10F and testing is not in progress which adds heat to the pool.

The I 10F upper limit is allowed by the existing DAEC TS.

This change is an improvement to the TS and is acceptable.

This LCO amplifies the requirements stated in the existing DAEC TS by specifying the actions to be taken if the temperature exceeds 105*F during testing which adds heat to the pool. The actions are consistent with the STS and are acceptable.

0 1,3 2

2, 4 2, 4 L

Page 19

DUANE ARNOLD ENER7RENTER (DAEC)

TECHNICAL SPECIFICATION CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page r -Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-13 TS section 4.7.G, "Suppression Pool Level and Relocation of the suppression pool surveillance 1

Temperature", has been added. This new TS section requirements is an administrative change to contains the suppression pool surveillance accommodate the revised organization of Section 3.7.

requirements previously located in TS section 4.7.A. I. It is acceptable.

3.7-13 TS sections 4.7.G.1, "Suppression Pool Level", and This requirement is the same as in the existing DAEC 2, 3 4.7.G. L.a contain the suppression pool level T3, but is reformatted to conform to the STS wording.

surveillance requirements previously located in TS It is acceptable.

section 4.7.A.I.a. This surveillance is consistent with STS section 4.6.2.1.a.

3.7-13 TS sections 4.7.G.2, "Suppression Pool Temperature" This requirement is the same as in the existing DAEC 2, 3 and 4.7.G.2.a contain the suppression pool TS. It has been reformatted to conform to the pattern temperature surveillance requirements previoqsly of the STS wording. It is acceptable.

located in TS section 4.7.A. I.a. This surveillane is consistent with STS section 4.6.2.1.b.

3.7-13 TS section 4.7.G.2.b contains the suppression pool This requirement is the same as in the existing DAEC 2,3,4 temperature surveillance requirement previously located TS but the 105'F limit has been added. It has been in TS section 4.7.A.I.b. The requirement to verify reformatted to conform to the pattern of the STS suppression pool water temperature every 5 minutes wording. The requirement for surveillance when there when there is indication of relief valve operation has is an indication of relief valve operation has been been deleted. This surveillance is consistent with STS deleted and is now incorporated into new TS section 4.6.2.1.b.l. The details of this verification 4.7.G.2.c. The change is an improvement and is (monitoring) have been deleted.

acceptable Page 20

DUANE ARNOLD ENERWCENTER (DAEC)

TECHNICAL SPECIFICATION CHANCE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-14 TS section 3.7.G.2.d contains the suppression pool The requirement to scram the reactor if the suppression 2,4 water temperature limits and actions previously located pooi average water temperature exceeds I 10"F is the in TS section 3.7.A.I.c. (3). These limits and actions same as in the existing DAEC TS and is acceptable.

are consistent with action b.2 of STS section 3.6.2. 1. The condition for resumption of power operation (pool The requirement for resuming power operation temperature equal to or less than 95T) is adequately previously included in TS section 3.7.A.I.c. (3) is stated in TS Section 3.7.G.2.a. Therefore, deletion of adequately covered by revised TS section 3.7.G.2.a this portion of the requirements from the existing TS is and has been deleted, acceptable.

3.7-14 TS section 3.7.G.2.e contains the suppression pool Relocation of the suppression pool water temperature 1, 3,4 water temperature limit and actions previously located limit requirement is an administrative change to in TS section 3.7.A.s.c.(4). This limit and specified accommodate the revied organization of Section 3.7.

action have been reworded to be consistent with ajtion The revisions to the wording improve the clarity and b.3 of STS section 3.6.2.1.

conform the wording to the STS format.

These changes are acceptable. The deletion of the phrase, "during reactor isolation conditions," make the requirement more restrictive and is therefore acceptable.

3.7-15 TS section 3.7.H, "Containment Atmosphere Relocation of the containment atmosphere dilution Dilution," has been added.

This new TS section requirements is an administrative change to contains the containment atmosphere dilution accommodate the revised organization of Section 3.7.

erequirements previously located in TS section 3.7.A.6.

a It is acceptable.

Page 21

1)UANE ARNOLD ENE CENTER (1)AEC)

TECHNICAL SPECIFICA CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-15 TS section 3.7.H.1 contains the requirements The revision of the applicability statement to specify 1,3,4 previously located in TS section 3.7.A.6.a.

The that the CAD system need be OPERABLE only when applicability has been revised to specify that the the containment is required to be inerted is a relaxation containment atmosphere dilution system is only of the requirement in the existing DAEC TS, but the required to be operable when the primary containment resulting applihility is consistent with STS 3.6.6.2 is required to be inerted. The term "operable" has been for when the coatainment must be incrtcd. There is no capitalized. Additionally, the requirement to take the need for the CAD system to be operable when the reactor "out of power operation" has been revised to containment is not required to be inerted. Therefore, "be in at least HOT SHUTDOWN within the next 12 this relaxation of the requirement in the existing TS is hours and in COLD SHUTDOWN in the following 24 acceptable. Capitalization of "operable" is an editorial hours" to be consistent with the other shutdown change and is acceptable. Replacement of the vague requirements of this chapter.

requirement to "take the reactor out of power operation" with the specified times to be in HOT SHUTDOWN and COLD SHUTDOWN will provide the operators with firm guidance as to what is required.

The time requirements are consistent with terminology used in the STS and with other action statements related to the primary containment and are acceptable.

3.7-15 TS section 3.7.H.2 contains the requirements The basic requirement for the minimum volume of N2 2, 4 previously located in TS section 3.7.A.6.b.

The to be available, and the need to restore this volume requirement to take the reactor "out of power within 7 days if the specification cannot be met, are operation" has been revised to "be in at least HOT unchanged from the existing TS and are acceptable.

SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD Replacement of the vague requirement to "take the SHUTDOWN in the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " to be reactor out of power operation" with the specified times consistent with the other shutdown requirements of this to be in HOT SHUTDOWN and COLD SHUTDOWN chapter.

will provide the operators with firm guidance as to what is required. Te time requirements are consistent with terminology used in the TS and with other action statements related to the primary containment and are acceptable.

Page 22

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICA CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-15 TS section 3.7.H.3 contains the requirements This proposed change is identical to the wording of the 2

previously located in TS section 3.7.A.6.c.

existing DAEC TS and is acceptable.

3.7-15 TS section 4.7.H., "Containment Atmosphere This is an administrative change to accommodate the I

Dilution", has been added. This new TS section revised organization of Section 3.7. It is acceptable.

contains the containment atmosphere dilution surveillance requirements previously located in TS section 4.7.A.6.

3.7-15 TS section 4.7.H.1 contains the surveillance This surveillance requirement is unchanged from the 2

requirements previously located in TS section requirement in the existing DAEC TS and is accepable.

4.7.A.6.a.

3.7-15 TS section 4.7.H.2 contains the surveillance This surveillance requirement is unchanged from the 2

requirements previously located in TS seption requirement in the existing DAEC TS and is acceptable.

4.7.A.6.b.

3.7-15 TS section 4.7.H.3 contains the surveillance This surveillance requirement is unchanged from the 1, 2 requirements previously located in TS section requirement in the existing DAEC TS and is acceptable.

4.7.A.6.c. The reference to TS section 4.7.A.6.a has Revision of the reference is an administrative change to been revised to 4.7.H.1.

accommodate the revised organization of Section 3.7 and is acceptable.

Page 23

DUANE ARNOLD ENI CENTER (DAEC)

TECHNICAL SPECIFICATMN CHANGE (RTS-246)

REVISIONS TO IS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-16 TS section 3.7.1, "Oxygen Concentration," has been This is an administrative change to accommodate the 1, 3 added. This new TS section contains the oxygen revised organization of Section 3.7. It is acceptable.

concentration requirement previously located in TS section 3.7.A.5.

These requirements have been revised for clarity and to be consistent with STS section 3.6.6.2. Specifically:

TS :ection 3.7.1.1 is consistent with STS section This revision conforms the DAEC TS wording to the 1, 2, 3 3.6.6.2. This section now specifies that both the STS requirement, while retaining the intent of the drywell and suppression chamber oxygen existing DAEC TS.

The change is acceptable.

concentration shall be less than 4%. The term Capitalization of "reactor power operation" is an "reactor power operation" has been capitalized.

editorial change and is acceptable.

TS sections 3.7.1.1. a and 3.7.1.1Lb contain the These revisions conform the DAEC TS wording 2, 3 applicability requirements previously located in TS generally to the wording of the STS requireniits, section 3.7.A.5.b. These requirements are while retaining the intent of the existing DAEC TS.

consistent with STS sections 3.6.6.2.a and '

Retention of the words "placing the reactor in the 3.6.6.2.b. There reference to 15% power RUN mode" rather than "15% of rated thermal power" contained in the STS, however, is changed to as in the STS is acceptable since it represents no "RUN" as per current TS section 3.7.A.5.b.

change from the existing DAEC TS and is more conservative than allowed by the STS.

References to the startup test program previously This requirement applied to the startup test program 4

located in TS section 3.7.A.5.a have been deleted.

only and is no longer needed.

The deletion is acceptable.

TS section 3.7.1.2 has been added and is consistent This is a new requirement, consistent with the STS, 3

with the action of STS section 3.6.6.2.

and is acceptable.

I_

I Page 24

DUANE ARNOLD ENE RENTER (DAEC)

TECHNICAL SPECIFICATC CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page R e view; No.

Proposed Change Evaluation of the Proposed Change Cateory 3.7-16 TS section 4.7.1, "Oxygen Concentration," has been The movement of the requirement to the new location is 134 added. This new TS section contains the oxygen an administrative change and is acceptable. Adtition of concentration surveillance requirements previously the requirement to verify the oxygen concentration located in TS section 4.7.A.5. The frequency of the within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after placing the mode switch in RUN surveillance however, has been revised to be consistent is a new requirement, comparable to the STS with STS section 4.6.6.2.

requirement, and consistent with the proposed new LCO 3.7.1.2.

It is acceptable.

The change in surveillance frequency from twice weekly to once eiery 7 days is consistent with the STS surveillance ianewrequirement, and is acceptable.

3.7-17 TS section 3th, "Secondary Containment" has been This is an administrative change to accommodate the added. This new TS section contains requirements revised organization of Section 3.7. It is acceptable.

previously loc-ated in TS section 3.7.C.

3.7-17 TS section 3.7.J.2 contains the requirembats This is an administrative change to accommodate the I

previously located in TS section 3.7.C.2. ' The revised organization of Section 3.7. It is acceptable.

reference to TS section 3.7.C.1 has been revised to 3.7.J.

1.

3.7-17 TS section 3.7.J.2.c has been revised to be consistent The change in the shutdown requirement provides for a 4

with the other shutdown requirements of this chapter.

more orderly shutdown, is consistent with the shutdown requirements elsewhere in this section, and is acceptable.

3.7-17 TS section 4.7.J, "Secondary Containment" has been This is an administrative change to accommodate the I

added. This new TS section contains surveillance revised organization of Section 3.7. It is acceptable.

requirements previously located in TS section 4.7.C.

Page 25

DUANE ARNOLD EN CENTER (DAEC)

TECHNICAL SPECIFICAIW CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-17 TS section 4.7.J.1 has been revised to delete all This is an administrative change, deleting material that 1,4 mention of historical testing previously described in TS no longer is applicable to the operation of the DAEC.

sections 4.7.C.l.a and 4.7.C.I.b.

It does not affect current plant operations and is acceptable.

3.7-17 TS section 4.7.J.1.a contains the surveillance The relocation of the surveillance requirement is an 1,4 requirements previously located in TS section administrative change and is acceptable. The change in 4.7.C. I.c. The reference to calm wind conditions as < the definition of calm wind speed from 5 mph to 15 5 mph has been revised to < 15 mph.

A new mph is based upon the licensee's engineering discussion of what constitutes calm wind conditions evaluation of the effect of wind speeds on the has been added to the Bases to TS section 3.7.L.

secondary containment manometer readings. The change is conservative in that it requires that secondary containment vacuum be maintained over a wider range of wind speeds. It is, therefore, acceptable.

3.7-17 Previous TS section 4.7.C.I.d has been deleted.? This Deletion of this requirement does not materially affect 4

type of verification testing is not required by STS.

plant safety and it eliminates unnecessary operation of the SGTS. Most violations of secondary containment are temporary and minor in nature (open doors, penetrations, etc.) and are readily correctable after identification. They do not demand a test to verify the capability of maintaining a vacuum after the violation has been corrected.

Any modifications to the secondary containment boundary which could result in a change in secondary containment operability are subjected to post-modification testing which would confirm the operability of the secondary containment.

The change is, therefore, acceptable.

Page 26

DUANE ARNOLD EN CENTER (DAEC)

TECHNICAL SPECIFICAWN CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS Page Proposed Change IEvaluation of the Proposed Change Categoryi 3.7-17 (Continued)

While there is no requirement in the STS to verify secondary containment integrity after identification of a violation, STS Section 4.6.5.1 does require periodic verification of reactor building negative pressure and closure of secondary containment penetrations, doors, hatches, and blowout panels. DAEC FSAR Section 6.5 states that the secondary containment is maintained at a 1/4-inch of water vacuum during normal operation, but neither the existing or the proposed DAEC TS require periodic verification of the secondary containment pressure. While this requested TS change does not justify adding such a requirement to the TS, this is a shortcoming that the licensee should be urged to correct.

Neither the existing nor the proposed TS state a time limit for the SGTS to reduce the secondary containment pressure to a negative 1/4 inch of water. Since the negative pressure in secondary containment is maintained during normal operation, this should not be a problem. However, upon loss of offsite power and transfer to emergency power, this could become a factor. The STS allow a 375 second time period to establish the negative pressure based upon the results of accident analyses. While this requested TS change does not provide justification for adding a time limit for operation of the SGTS to reduce the secondary containment pressure to the negative 1/4-inch of water, this is a shortcoming that the licensee should be urged to correct.

Page 27

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICA'IW CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-18 TS section 3.7.K., "Secondary Containment Automatic This is a new requirement, not present in the existing 3

Isolation Dampers", has been added.

These DAEC TS. As such, it is an improvement to the requirements were not previously included in the existing TS, consistent with the STS, and is DAEC TS. The requirements of TS section 3.7.K. I acceptable.

are consistent with the requirements of STS section 3.6.5.2. Specifically:

TS section 3.7.K.1 is consistent with STS This requirement is consistent with the intent of the 3, 4 3.6.5.2. The applicability, however, is DAEC-STS, but is tailored to be specific to DAEC. It is an specific and the list of applicable valves/dampers is improvement to the existing TS and is acceptable.

not included in the TS but will be incorporated into an administrative procedure.

TS section 3.7.K.2 (including sub items a., b., This new requirement, not present in the existing 3,4 and c) are consistent with actions a., b., and c., of DAEC TS, conforms the revised TS to the STS STS sections 3.6.5.2. A note, however, has been requirements with the exception of the note allowing added to TS section 3.7.K.2.c.

This ndte is intermittent opening of the isolated penetrations under consistent with the note for closed/isolated primary administrative control. This exception is the same as is containment isolation valves, allowed for the primary containment isolation valves in existing DAEC TS 3.7.D.2 and in proposed revised DAEC TS 3.7..2. There is no reason for this new requirement regarding secondary containment isolation dampers to be more restrictive than the requirement for the primary containment isolation valves.

It is,

___________________________________________therefore, acceptable.

3.7-18 TS section 3.7.K.3 is consistent with the shutdown This action statement follows the format of, but is not 3,4 action statement of STD section 3.6.5.2.

The as all-inclusive as, the STS in that it does not address requirement to suspend reactor building fuel cask and suspension of core alterations and operations with the irradiated fuel movement is consistent with TS section potential for draining the reactor vessel. However, it is 3.7.J.2.ha.

a considerable improvement to the existing DAEC TS, and it is acceptable.

Page 28

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICA '

CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category I 3.7-18 TS section 4.7.K "Secondary Containment Automatic This is a new surveillance requirement, not present in 3,

Isolation Dampers", has been added. This surveillance the existing DAEC TS. It is consistent with the STS requirement was not previously required by DAEC TS. requirement for testing at least once per operating The surveillance requirement of TS section 4.7.K is cycle, but omits the STS requirement for verifying consistent with the surveillance requirements of STS isolation damper operating times and the requirement section 4.6.5.2 except that surveillance requirements a. for post-maintenance testing of the dampers. Still, it is and c. of STS section 4.6.5.2 are not included. (Post-an improvement over the existing TS and is acceptable.

maintenance testing has not historically been included in DAEC TS.) Specifically:

IS section 4.7.K.1 is consistent with STS section This statement is partially true, but the proposed 4

4.6.5.2. b.

surveillance requirement calls only for simulated initiation of the dampers, while the SS require verification that the dampers actuate to their isolaed position on the test signal.

It is, however, an r__n improvement over the existing TS and is acceptable.

3.7-19 T section 3.7.L, "Standby Gas Treatment System," This is an administrative change to accommodate the 4

has been added. This new TS section contains the revised organization of Section 3.7. It is, acceptable.

standby gas treatment system requirements previously located in IS section 3.7.B.

The reference to tS section 3.7.ta.3 has been revised to 3.7.L.3.

3.7-19 TS section 4.7.L Standby Gas Treatment System", has This is an administrative change to accommodate the I

been added. This new IS section contains the standby revised organization of Section 3.7. It is acceptable.

gas treatment system surveillance requirements previously located in TS section 4.7.B.

Page 29

DUANE ARNOLD EN CENTER (DAEC)

TECHNICAL SPECIFICA CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.

-- CONTAINMENT SYSTEMS TS Page Revie No.

Proposed Change Evaluation of the Proposed Change Cate 3.7-19 TS section 4.7.L.1.b has been revised to require that The 22 kw requirement in the revised TS is more 4

the inlet heaters of each train be capable of an output of restrictive than the II kw requirement in the existing at least 22 kw. The previous TS requirement was II TS. The licensee states that the 22 kw minimum is kw.

needed to assure that the assumed initial conditions for inlet to the SGTS can be met, but that the temperature rise across the heaters at this heat rate still would be less than the 20*F maximum differential temperature specified in the UFSAR Section 6.5.3.3. The change, iherefore, is acceptable.

3.7-19 TS section 4.7.L.1.c has been revised to require that The requirement to demonstrate air distribution after 4

the air distribution demonstration be performed "after "each complete or partial replacement of the HEPA each complete or partial replacement of the HEPA filter filter bank or after any structural maintenance on the bank or after any structural maintenance on the system system housing" is an improvement to the present housing." This test was previously required to be requirement for annual demonstration.

The performedannually.

requirement is consistent with ASME N510-1989, "Testing of Nuclear Air Treatment Systems."

Any changes to the flow distribution would be expected to occur after changes are made to the filters or filter housing rather than on a time-dependent basis. The change, therefore, is acceptable.

3.7-19 In TS section 4.7.L..g, the reference to TS section This is an administrative change to accommodate the 1

3.7.B.2.b. has been revised to 3.7.L.2.b.

revised organization of Section 3.7. It is acceptable.

3.7-19 In TS section 4.7.L.2.a, the reference to TS section This is an administrative change to accommodate the 1

3.7.B.2 has been revised to 3.7.L.2.

revised organization of Section 3.7. It is acceptable.

Page 30 P

DUANE ARNOLD EN CENTER (DAEC)

TECHNICAL SPECIFICA 1RN CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page IReview No.

Proposed Change Evaluation of the Proposed Change Category Nor ati w

TS section 3.7.L.3 contains the requirements previously located in TS section 3.7.B.3.

The wording has been revised for consistency.

Specifically:

The wording "HOT SHUTDOWN within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " has been revised to 'HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ".

The wording "suspend fuel handling operations" has been revised to "suspend reactor building fuel cask and irradiated fuel movement." This wording is consistent with TS sections 3.7.J and 3.7.K.

3.7-20 1

4 TS section 3.7.M, "Mechanical Vacuum Pump" has This is an administrative change to accommodate the I

been added.

This new TS section contains the revised organization of Section 3.7. It is acceptable.

mechanical vacuum pump requirements previously located in TS section 3.7.F.

In TS section 3.7.M.3, the references to TS sections This is an administrative change to accommodate the I

3.7.F. I and 3.7.F.2 have been revised to 3.7.M. 1 and revised organization of Section 3.7. It is acceptable.

3.7.M.2.

1 Page 31 This is an administrative change to accommodate the revised organization of Section 3.7. It is acceptable.

This is an editorial change which clarifies the intent of the action statement. It is acceptable.

This change makes the action statement for an inoperable SGTS comparable to the action statements for lack of secondary containment integrity or for inoperability of the secondary containment isolation dampers. The reviszd words are more explicit, but may not be as all-inclusive as the existing words, e.g.,

they could allow movement of fresh fuel to continue.

However, since the principal danger of radioactive release stems from movement of irradiated fuel or movement of the fuel cask, the net effect of the change with regard to safety is minimal. Since the safety impact is minimal and since the change conforms the action statement to the comparable statements for secondary containment integrity and for inoperability of the secondary containment isolation dampers, the change is acceptable.

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICA CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS I-TS Page I

IReview No.

Proposed Change Evaluation of the Proposed Change Category 3.7-21 TS section 4.7.M, "Mechanical Vacuum Pump" has This is an administrative change to accommodate the I

been added. This new TS section contains surveillance revised organization of Section 3.7. It is acceptable.

requirements previously located in TS section 4.7.F.

3.7-22 The Bases for TS sections 3.7.A and 4.7.A has been This is an editw'.d change necessary to accommodate 1,2,4 changed from "Primary Containment" to "Primary the revised organization of Section 3.7.

The new Containment Integrity."

A discussion of the Bases for TS Sections 3.7.A and 4.7.A incorporate requirement to restore primary containment within I those portions of the existing TS Bases that relate to hour in the event primary containmeat is inoperable has primary containment integrity and leak rate testing. The been added.

The Bases information has been added discussion regarding the need to restore primary reorganized for clarity, containment integrity within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is an improvement. The changes are acceptable._____

3.7-24 The Bases fo TS sections 3.7.13 and 4.7.1, "Primary This is an administrative change to account for the 1

Containment Power Operated Isolation Valves", revised organization of Section 3.7, and is acceptable.

contains the information previously located in g'ases section 3/4.7.A.8.

This information has 'been

________reorganized for clarity.

3.7-26 A discussion of the actions to be taken in the event that This discussion regarding the need for isolation and the 4

one or more primary containment isolation valves are method of isolation of inoperable PCIVs is generally an inoperable has been added to the Bases of section improvement. However, the words relating to use of 3.7.B. and 4.7.Bl.

"a check valve inside primary containment with flow through the valve secured" as an acceptable isolation barrier is not consistent with the TS 3.7.B3 and should be corrected.

3.7-26 The Bases for TS sections 3.7.C and 4.7.C, "Drywell This is a new Bases section supporting the new TS 4

Average Air Temperature" has been added to provide Section 3/4 7.C. It provides the rationale for selecting additional information on this new specification.

the related LCO limits and surveillance frequency, and one_ _ or__

more__primarycontainmentisolationvalv explains the need for Drywell temperature control._sgnrlya Page 32

DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICATW CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

I Proposed Change Evaluation of the Proposed Change Category 3.7-27 The Bases for TS sections 3.7.D and 4.7.D, "Pressure This is an administrative change to account for the 1, 4 Suppression Chamber - Reactor Building Vacuum revised organization of Section 3.7, and is acceptable.

Breakers" contains the information previously located The added discussion regarding the need to restore in Bases section 3/4.7.A.3.

This section has been operability of inoperable vacuum breakers explains the expanded to provide additional information specific to need for the action statements of TS Section 3.7.D and these vacuum breakers.

is a considerable improvement over the existing wording in the present Bases. It is acceptable.

3.7-28 The Bases for TS sections 3.7.E and 4.7.E, "Drywell-This is an administrative change to account for the 1,4 Pressure Suppression Chamber Vacuum Breakers" revised organization of Section 3.7, and is acceptable.

contains the information previously located in Bases The added discussion regarding the need to restore section 3/4.7.A.3. This section has been expanded to operability of inoperable vacuum breakers explains the provide additional information specific to these vacuum need for the action statements of TS Section 3.7.E and breakers.

-is a considerable improvement over the existing

_______________________________________wording in the present Bases. It is acceptable.

3.7-29 The Bases for TS section 3.7.F and 4.7.F, '%lain This is an administrative change to account for the I

Steam Isolation Valve Leakage Control System (MSIV-revised organization of Section 3.7, and is acceptable.

LCS)" contains the information previously located in Bases section 3f4.7.E.orheacionstaementsofTSSecion3.E a

3.7-30 The Bases for TS sections 3.7.G and 4.7.G, This is an administrative change to account for the 1,4 "Suppression Pool Level and Temperature" contains revised organization of Section 3.7, and is acceptable.

the information previously located in Bases sections The added discussion regarding the need for a 3/4.7.A.1, 3/4.7.A.5, and 3/4.7.A.8.

This maximum water volume in the suppression pool is an information has been reorganized for clarity. improvement and is acceptable.

Additional details regarding the bases for the maximum suppression pool volume and equivalent indicated levels has been added.

Page 33 i, I

S DUANE ARNOLD ENE CENTER (DAEC)

TECHNICAL SPECIFICATW CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS V

TS Page Review No.

Proposed Change Evaluation of the Proposed Change ICategory 3.7-32 The requirement to maintain the suppression pool This is an editorial change to conform the Bases words I

temperature "below" the normal operating limit of 95 to the requirements of the TS. It does not change the

F has been changed to "at or below" the normal intent of the wording in the present BASES and is operating limit of 95 *F. This change is consistent with acceptable.

TS section 3.7.G.2.a.

3.7-33 The reference to Bases section 3.7.A.1 (previously This is an editorial change. The deleted reference is no I

located in the first paragraph of previous TS page 3.7-longer needed since the words from previous Bases 48a) has been deleted.

Section 3.7.A.I are now incorporated in the new Bases section. The change is acceptable.

3.7-33 The discussion of the daily suppression pool level and The deleted discussion regarding daily volume and 4

temperature surveillance previously located in the first temperature checks of' the suppression pool water are paragraph of the Bases section 3/4.7.A.4, "Leak Rate adequately covered in the revised Bases for Sections Testing" (but applicable to suppression pool levelkand 3.7.G and 4.7.G. Inclusion of this discussion would temperature) has been deleted. This information is be redundant. Therefore, this change is acceptable.

redundant to the surveillance discussion already included in the Bases for section 3.7.0 and 4.7.a.

d e

o 3.7-34 The Bases for TS section 3.7.H and 4.7.H, This is an administrative change to account for the 1

"Containment Atmosphere Dilution" contains the revised organization of Section 3.7, and is acceptable.

information previously located in the Bases for sections 3/4.7. A. 6.

3.7-35 The Bases for TS sections 3.7.1 and 4.7.1, "Oxygen This is an administrative change to account for the I

Concentration", contains the information previously revised organization of Section 3.7, and is acceptable.

located in Bases section 3/4.7.A.2.

Page 34

4.

DUANE ARNOLD ENE ICENTER (DAEC)

TECHNICAL SPECIFICATW CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page J-Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-36 Additional information has been added to the Bases for This additional information is consistent with the 4

TS section 3.7.1 and 4.7.1 stating that the CAD system requirement of revised TS Section 3.7.H (which refers is not required to be operable during drywell to TS Section 3.7 1.1) and is acceptable.

Contrary to inspections and when the containment is not inerted. the licensee's statement, there is no note added to TS This note is consistent with the note added to TS Section 3.7.1. Rather, the information apparently was section 3.7.1.

incorporated in the text of the TS. In any event, the additional information provided in the Bases supports the requirements of the TS and is acceptable.

3.7-36 The discussion of oxygen monitoring in the last This revision conforms the Bases' wording to the TS 4

paragraph of the Bases for TS sections 3.7.1 and 4.7.1 requirement, which was previously found acceptable.

has been changed from "twice a week" to "once per Therefore, this change is acceptable.

week".

This corresponds to revised surveillance requirement 4.7.1.1.

3.7-36 The Bases for TS sections 3.7.3 and 4.7.3, "Secondhry This is an administrative change to account for the 1

Containment" contains the information previously revised organization of Section 3.7, and is acceptable.

located in Bases section 3/4.7.A.7.

3.7-37 The Bases for TS sections 3.7.K and 4.7.K, This additional information explains the need for 4

"Secondary Containment Automatic Isolation controls on the operability of the secondary Dampers", has been added to provide additional containment automatic isolation dampers, supporting information on this new specification.

the new TS on this equipment. It is acceptable.

3.7-38 The Bases for TS sections 3.7.L and 4.7.L, "Standby This is an administrative change to account for the I

Gas Treatment System" contains the information revised organization of Section 3.7, and is acceptable.

previously contained in Bases section 3/4.7.A.7. The previous reference to TS section 3.7.B.3 has been changed to TS section 3.7.L.3.

Page 35

DUANE ARNOLD ENE tA ENTER (DAEC)

TECHNICAL SPECIFICAT CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS f

V TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-39 The Bases for TS section 3.7.L and 4.7.L, "Standby These revisions conform the discussion in the Bases to 4

Gas Treatment System", has been revised to clarify dhe the requirements of the proposed revised TS and are in-place and laboratory tests performed on the system. acceptable. The corresponding numbers presented in Specifically, the previous reference to "less than 1 the present Bases Section 3/4.7.A.7 are in error.

percent bypass leakage" for the charcoal absorbers has been changed to " 0.1 percent bypass leakage" for the charcoal absorbers. This change is consistent with the requirements of TS sections 3.7.L.2.a. The discussion of laboratory carbon sample test results previously described a radioactive methyl iodide removal efficiency of "at least 99.9 percent for expected accident conditions." This has been changed to "at least 99% for expected accident conditions." This change is consistent with the requirements of TS section 3.7.L.2.b.

3.7.39 None The Bases for Section 3.7.L and 4.7.L, carried 4

forward from the Bases of the existing DAEC TS, state that "Heater capability, pressure drop, and air distribution should be determined annually to show system performance capability." However, proposed revised TS 4.7.L.l.c now requires an air distibution demonstration to be performed "after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing," in lieu of the requirement in existing DAEC TS 4.7.B. L.c for an annual demonstration of the air flow distribution.

The proposed revised Bases thus needs to be modified to state that air flow distribution is determined following complete or partial replacement of the HEPA filter bank and after any structural maintenance on the system housing instead of the annual determination.

Page 36

I DUANE ARNOLD EN

' CENTER (DAEC)

TECHNICAL SPECIFICA CHANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-40 The description of standby gas treatment system The change conforms the wording in the Bases to the 4

(SGTS) inlet heater capacity in Bases section 3.7.L and requirement of the revised TS 4.7.L.1.b and is 4.7.L has been revised from 11 kw to 22 kw. This acceptable.

change is consistent with revised TS section 4.7.L.1.b.

3.7-40 A specific discussion of the engineering evaluation New TS 4.7.J.l.a requires the capability of 4

regarding the effects of differing wind speeds on maintaining a 1/4-inch water vacuum in the secondary SGTS testing has been added to the Bases of TS containment with wind speeds up to 15 mph. This sections 3.7.L and 4.7.L.

additional discussion explains how the averaged manometer readings 3ompensate for wind speeds up to 15 mph.

The change adds clarification and is acceptable.

3.7-41 The Bases for TS sections 3.7.M and 4.7.M This is an administrative change to account for the 1

"Mechanical Vacuum Pump", contains the information revised organization of Section 3.7, and is acceptable.

previously located in Bases sections 3.7.F and 4.7.F.

3.7-42 Previous TS page number 3.7-49 has been renumbered This is an administrative change to account for the I

to page 3.7-42.

revised organization of Section 3.7, and is acceptable.

3.7-43 Previous TS page number 3.7-50 has been renumbered This is an administrative change to account for the I

to page 3.7-43.

revised organization of Section 3.7, and is acceptable.

3.7-43 Previous TS page 3.7-20 has been deleted.

The deleted page, inserted by Amendment 181, noted 4

that a series of tables had been deleted from the TS, which resulted in a number of pages no longer being used. With this revision to the TS, this note is no longer needed. This change, therefore, is acceptable.

Page 37

ML112380516

Text

Enclosure:

Navigation menu

Search