ML20045D586

Application for Amend to License DPR-49,clarifying Existing TS Wording for LPCI & Containment Spray Modes of RHR to Ensure Consistency W/Requirements Delineated in Updated FSAR

ML20045D586
Person / Time
Site:	Duane Arnold
Issue date:	06/18/1993
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20045D587	List: ML20045D586 ML20045D591
References
NG-93-2195, NUDOCS 9306290186
Download: ML20045D586 (8)

Text

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lowa Electric Light and Power Company JOHN T. FRANZ, JR.

m mswn.* "

t NG-93-2195 June 18, 1993 i

! Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission l Attn: Document Control Desk Mail Station F1-137 Washington, DC 20555

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request for Technical Specification Change (RTS-256): Low Pressure Coolant Injection (LPCI) Subsystem Operability

Reference:

1) Operating License Amendment No. 174, dated August 12, 1992 l

2) NRC Inspection Report IR-89-028, dated December 11, 1989 File: A-ll7, E-11 I

Dear Dr. Murley:

In accordance with the Code of Federal Regulations, Title 10, Sections 50.59 and 50.90, Iowa Electric Light and Power Company hereby requests revision to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

The proposed amendment request clarifies the existing TS wording for the Low Pressure Coolant Injection (LPCI) and Containment spray modes of the Residual Heat Removal (RHR) system to ensure consistency with requirements of the DAEC Updated Final Safety Analysis Report (UFSAR). The change will eliminate ambiguities which were inadvertently introduced to the DAEC TS by an earlier l amendment (Ref. 1). In addition, a new footnote is added to the ,

i LPCI TS to address OPERABILITY of that subsystem during mode  ;

changes when the RHR system is operating in the Shutdown Cooling mode. This item resolves a DAEC Inspection Report Open Item (Ref. 2). The proposed changes are consistent with those discussed with your Staff in our meeting of May 10, 1993.

This application has been reviewed by the DAEC Operations l Committee and the DAEC Safety Committee. A copy of this l submittal, along with the no significant hazards considerations l 9306290186 930618 '

p DR' hDOCK 05000333 PDR hg General oJJice

• l'.U. Box 351

• Cedar llapids, Iowa 52406

• 319!398 4411 ,

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.Dr. Thomas E. Murley l NG-93-2195 i June 18, 1993 Page 2 analysis, is being forwarded to our appointed state official pursuant to 10 CFR 50.91.

Should you have any questions regarding this matter, please contact this office.

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

! belief.

l IOWA ELECTRIC LIGHT AND POWER COMPANY I

By / b7 /,M

/ Uohn P. Franz Vice President, Nuclear

! State of Iowa

( (County) of Linn I

Signed and sworn to before me on this / 7 (' day of [//Inf l 1993, by 'T5hn F Fra n n -

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.Ib%1?':(l,(f/.' llL(/ l [

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u lic in and for the State of Iowa MARY MICHELE 0'NEAL mc,om9m y

/ l /g ( f Commission Expires JFF/RAB/pjv' '

l Attachments: 1) Evaluation of Change Pursuant to 10 CFR 50.92

2) Proposed Change RTS-256 to the DAEC Technical l Specifications

3) Safety Assessment

4) Environmental Consideration cc: R. Browning L. Liu L. Root R. Pulsifer (NRC-NRR)

J. Martin (Region III)

S. Brown (State of IA)

NRC Resident Office DCRC l

l l

RTS-256 Attachment 1 to NG-93-2195 Page 1 of 3 EVALUATION OF CHANGE PURSUANT TO 10 CFR 50.92 2

Background:

In an earlier application, RTS-228 (NG-90-1298, December 14, 1990), which was subsequently approved as Amendment 174 to the

DAEC Technical Specifications (TS), we revised the Limiting j Conditions for Operation (LCO) and Surveillance Requirements (SR) for the Emergency Core Cooling Systems (ECCS) to eliminate the requirement for conditional surveillances, i.e., the requirement

to demonstrate OPERABILITY of redundant trains of-equipment.by -

i actually operating one train when the other train is found to be

inoperable. In the process of revising the wording to eliminate

the conditional surveillances, we inadvertently deleted certain ,

, wording within the Low Pressure Coolant Injection (LPCI)

I subsystem LCO that clarified OPERABILITY for that subsystem.

Specifically, the revised LCO failed to state that inability of ,

, two (or more) Residual Heat Removal (RHR) pumps to deliver their  !

j rated flow to the Reactor Pressure Vessel (RPV) constitutes subsystem inoperability, resulting in a 7-day Allowed Outage Time (AOT).

i

The design of the Low Pressure Core Cooling system for the DAEC j is based upon a triad of subsystems

Core Spray "A"; Core Spray j "B"; and, the LPCI mode of the RHR system. While the RHR system is physically and electrically divisionalized, the LPCI mode of RHR is not considered to be a divisionalized function as there i are several single component failures that can cause the entire j LPCI mode to become disabled. The LPCI mode of the RHR system

] utilizes a " loop-select-logic" to determine which, if any, of the 4

two Reactor Recirculation system loops has suffered a rupture.

~

Based upon the choice this logic makes, all of the LPCI design flow is directed into the intact recirculation loop. The design ,

] flowrate is based upon three-out-of-four RHR pumps running. With l

this " loop-select" design, the valve in the cross-tie piping l i between the two divisions of the RHR system must be open, as  !

opposed to the two LPCI subsystem design (referred to as the

" modified LPCI design"), which must lock closed this " cross-tie" valve to ensure satisfactory completion of the LPCI function.

The accident analysis includes various single equipment failures and confirms that the remaining combinations of equipment in this triad are sufficient to satisfy the acceptance criteria of 10 CFR Part 50.46 (Ref. DAEC Updated Final Safety Analysis Report (UFSAR) Section 6.3.1).

The RTS-228 application also revised the LCOs and SRs for the Containment Spray subsystem to make them more consistent with the j NRC Standard Technical Specifications (STS). However, in doing so, we failed to accommodate DAEC-specific design differences i from the standard design upon which the STS is based.  !

Specifically, because the cross-tie valve between the two  !

divisions of the DAEC RHR system is not required to be locked l closed, it is not accurate to describe the containment Spray loops as being " independent", as the capability exists to utilize multiple combinations of pumps, valves and spray headers between the divisions of the system to perform the spray function.

RTS-256 Attachment 1 to NG-93-2195 Page 2 of 3 Consequently, this submittal revises these TS to eliminate these ambiguities and discrepancies.

In response to concerns raised by the NRC Senior Resident Inspector regarding the lack of a footnote for LPCI OPERABILITY while in Shutdown Cooling Mode of RHR (Ref. 50-331/IR-89-028-02),

we committed to add such a clarification to the next planned amendment request for the RHR system (Ref. Letter, Mineck to Murley, NG-91-4028, dated December 26, 1991). Consequently, we have included this footnote in this request. l l

The changes proposed herein are consistent with those of other i

plants with custom-formatted TS and similar LPCI and Containment I

Spray design as the DAEC. Specifically, the proposed changes to l the LPCI LCO and BASES are similar to those recently-approved for j the Pilgrim plant (Amendments 135 and 163 to Docket No. 50- l

~

293/Op. License No. DPR-35).

Iowa Electric Light and Power Company, Docket No. 50-331 t Duane Arnold Energy Center, Linn County, Iowa Date of Amendment Request: June 18, 1993 Description of Amendment Request:

! The proposed changes to the Core and Containment Cooling Section of the DAEC TS are intended to clarify system / subsystem OPERABILITY within the LCOs and improve the BASES to reflect the I actual requirements for these systems / subsystems based upon the UFSAR accident analysis. These changes are necessary to correct ambiguities and discrepancies that were inadvertently introduced in an earlier amendment to the TS (Amendment No. 174).  !

Basis for proposed no significant hazards consideration:

The Commission has provided standards (10 CFR 50.92(c)) for determining whether a significant hazards consideration exists.

A proposed amendment to an operating license for a facility )

involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possiollity of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

After reviewing this proposed request for Technical Specification change, we have concluded:

1) The probability or consequences of a previously-analyzed accident will not be increased by these proposed changes to the LPCI and Containment Spray LCOs and BASES because they merely clarify existing TS requirements and are consistent with the DAEC UFSAR accident analysis. The addition'of the footnote clarifying LPCI OPERABILITY during RHR system operation in the Shutdown Cooling mode.is' consistent with the. requirements in the NRC Standard TS-(NUREG-1433). No

RTS-256 Attachment 1 to NG-93-2195 Page 3 of 3-changes in either system design or operating strategies will be made as a result of these changes, thus no opportunity exists to increase the probability or consequences of a previously-analyzed accident.

1 The possibility of a new or different kind of accident from I 2) those previously analyzed will not be created by these changes to the LPCI and Containment Spray LCOs and BASES because they merely clarify existing requirements. The addition of the footnote clarifying LPCI OPERABILITY during RHR system operation in the Shutdown Cooling mode is consistent with the requirements in the NRC Standard TS (NUREG-1433). No changes in either system design or  ;

operating strategies will be made as a result of these changes, thus no possibility exists to introduce a new or different kind of accident.

3) The margin of safety will not be decreased as a result of these changes because they merely clarify existing TS '

requirements and are consistent with the UFSAR accident ,

analysis. The addition of the footnote clarifying LPCI '

OPERABILITY during RHR system operation in the Shutdown Cooling mode is consistent with the requirements in the NRC Standard TS (NUREG-1433). No changes in either system design or operating strategies will be made as a result of these changes, thus no possibility exists to reduce a margin of safety, t Based upon the above, we have determined that the proposed  :

Amendment will not involve a significant hazards consideration.  ;

Local Public Document Room Location: Cedar Rapids Public Library, 500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licensee: Jack Newman, Kathleen H. Shea, Newman and Holtzinger, 1615 L Street NW, Washington, D.C. 20036 J

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RTS-256 Attachment'2 to NG-93-2195 Page 1 of 3 PROPOSED CHANGE RTS-256 TO THE DUANE ARNOLD ENERGY CENTER TECHNICAL SPECIFICATIONS The holders of license DPR-49 for the Duane Arnold Energy Center propose to amend Appendix A (Technical Specifications) to said license by deleting certain current pages and replacing them with the attached, new pages. The List of Affected Pages is given below.

LIST OF AFFECTED PAGES 3.5-3 3.5-4 ,

3.5-14 3.5-15 3.5-16+

+ Page is common to RTS-246

SUMMARY

OF CHANGES:

The following list of proposed changes is in the order that the changes appear in the Technical Specifications.

I Page Description of Changes 3.5-3 Revise Specification 3.5.A.5 from "two RHR (LPCI) pumps inoperable, providing" to "the LPCI subsystem made or found to be inoperable for any reason *,

provided". In addition, revise the phrase "at least one RHR (LPCI) pump" to "the LPCI subsystem".

l Add the footnote, "*The LPCI subsystem may be considered OPERABLE during alignment to, and operation in, RHR Shutdown Cooling mode if capable of being manually re-aligned (remote or local) to the LPCI mode."

l 3.5-4 Revise Specification 3.5.B.1 to delete the word

" independent".

Revise Specification 3.5.B.2 to clarify the action statement to provide for.the situation of one loop of each spray type (suppression pool and drywell) being inoperable by making the word " loop" plural as a parenthetical.

.RTS-256 Attachment 2 to NG-93-2195 i Page 2 of 3 Revise Specification 3.5.B.3 to clarify the action l statement to provide for the situation of both loops of each spray type (suppression pool and drywell) being inoperable by adding a statement to require that one loop of each type be restored within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> LCO.

3.5-14 Revise the BASES for the Core Spray and LPCI Subsystems to: update the reference to the current Loss-of-Coolant Accident analysis; add information on the single failure analysis for the DBA-LOCA, similar to that in UFSAR Section 6.3.1; and, make ,

various editorial changes =(e.g., define acronyms, capitalize system names and TS-defined terms).

3.5-15 Revise the BASES for the Core Spray and LPCI '

Subsystems to: ensure consistency in terminology between subsystems and systems; add a detailed discussion of what constitutes OPERABILITY for the LPCI subsystem; clarify the difference between RHR pumps and the LPCI mode of RHR; correct the description of the number of low pressure ECCS components that remain available with the loss of a single RHR pump; add clarifying language regarding ,

i the number of RHR pumps that must be OPERABLE to j l satisfy the Containment Spray Specification 3.5.B.2; add a paragraph to explain the new footnote to Specification 3.5.A.5 regarding the l specific allowance for LPCI OPERABILITY when the

, RHR system is in the Shutdown Cooling mode; and, l make various editorial changes (e.g., capitalize l system names and TS-defined terms).

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3.5-16 Revise the BASES for the Containment Spray subsystem and RHR Service Water system to: add a discussion of what constitutes OPERABILITY for the l Containment Spray subsystem; clarify the difference between RHR pumps and the LPCI mode of RHR; correct l the description of the UFSAR analysis assumptions on the use of Containment Sprays after the.DBA-LOCA; add clarifying language regarding the allowed out-of-service time for one Containment Spray-loop of each type being inoperable; include text to note that system OPERABILITY is verified via the In-Service Testing program; and, make various

editorial changes (e.g., capitalize system names

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.RTS-256 Attachment 2 to NG-93-2195 Page 3 of 3 l and TS-defined terms and separate text into ')

paragraphs).

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