ML20077P980
| ML20077P980 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 08/12/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20076E478 | List: |
| References | |
| NUDOCS 9108200165 | |
| Download: ML20077P980 (4) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION k (JI(/ f
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o WASHINGTON, D C. M65 SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.174 TO FACILITY OPERATING LICENSE NO. DPR-49 10WA ELECTRIC LIGHT AND POWER COMPANY
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CENTRAL IOWA POWER C00 PERATIVE CORN EELT POWET COOPERATIV I DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331,
1.0 INTRODUCTION
in the event that certain engineered safeguards, systems, subsystems or components are determined to be out of service, the Duane Arnold Energy Center (DAEC) Technical Specifications (TSs) presently require the redundant subsystem or train of that system, as well as other core and containment cooling systems and associated auxiliaries, to be tested immediately and daily thereaf ter to satisfy operability requirements.
By letter dated i
l December 14, 1990, Iowa Electric Light and Power Company (the licensee) requested changes to the DAEC TSs which ASME Section X1 In-Service Testing (IST) propose to take credit for the DAEC Program (currently being reviewed by the NRC) to provide the needed assurance that the alternate systems, subsystems, and components will operate when needed.
Previous testing under the IST Program has shown a high degree of reliability for the equipment in question.
The changes would eliminate the daily testing i
requirements which temporarily impair the systems' ability to perform and could cause more substantial degradation.
These changes are consistent with the BWR Standard Technical Specifications (NUREG-0123, Revision 3) for BWR-4 plants.
Other operability (ECCSs) and auxiliary systems are proposed.and/or surveillance Cooling Systems To clarify the operability requirements of containment pray, a Limitir.g Condition for Operation (LCO) for suppression pool sprays is proposed along with editorial changes.
Surveillance requirements for two items of plant instrumentation are increased for consistency with the requirements for other similar equipment.
LCOs for the High Pressure Coolant injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems are also revised based upon analyses using industry-accepted methodology.
In addition, shutdown LCOs are revised from requiring the plant to be in cold shutdown 9108200165 910012 J
PDR ADDCK 05000333 P
PDR in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to requiring the plant to be in hot shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown (or other condition where the equipment is not required to be operable) in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
These changes are consistent with the Standard Technical Specifications (NUREG-0123, Revision 3) for BWR-4 plants.
Minor editorial and administrative changes are also proposed for clarity and consistency throughout the Technical Specifications.
2.0 EVALUATION The licensee has proposed revisions to TS Sections 1 0, 3.4, 3.S. and 3.7 to eliminate conditional surveillances for the Standby Liquid Control Cooling Subsysk fRCIC) Standby Gas Treatment System (SG associated auxiliaries.
pressure Coolant Injection Subsystem (LPCI) High Pressure Coolant (E Injection System (HPCI), and Automatic Depressurization System (ADS)).
Currently, if an ECCS, SLCS, RCIC, or SGTS subsystem or component were also render the remaining subsystem or train of that system or o systems in a degraded mode for the length of the test.
of a failure of any component while undergoing testing or as a result ofAlso, in the event during the time permitted by the Technical Specifications. increase mandated by Technical Specifications _(i.e., during conditionalValv surveillances) defeats the ability of systems to perform and, in effect, reduces safety system reliability, compared to the changes proposed by this amendment request.
The requested chan remaining train (s)ges would eliminate the present requirements to test the of the ECCS/RCIC ne train has a component out of ser,vice.SLCS, SGTS and their auxiliaries when in lieu of the alternate testing togram presently required by the Technical Specifications when systems are etermined to be inoperable, the licensee proposes that the " alternate" ystem be determined operable based on the DAEC In-Service Testing (IST) rogram results and verification that a system is in an operable status.
. itle 10 CFR, Section S0.SSa, clearly indicates that " operational readiness f pumps and valves whose function is required for safety" is demonstrated y in-service examinations conducted in accordance with ASME Code, Sectioti 1.
The DAEC IST program, which is baseo on these generally recognized o NRC Generic Letter 89-04 odes and standards, has been previously submitted to the e NRC staff finds that it is consistent with the intent of the ASME ction X1 In-Service Testing Program to base system operability on annual, arterly, monthly, refueling interval, post maintenance or other specified rformance tests without requiring additional testing when another system
- l is inoperable (except for diesel generator testing).
operational experience, and on the fact that testing of the redundantOn this basis, past system creates the risk of the second system failing, the staff has determined that the revised testing requirements for the ECCS SGTS systems and subsystems, and associated auxiliaries are ac,ceptable.SLCS, RCIC, New surveillance requirements are added for transfer logic for HPCI suction on low condensate storage tank level and on high suppression pool level.
Surveillance requirements for instruments that monitor pressure in LPCI and Core Spray discharge piping to ensure it is filled are increased.
Functional testing of these instruments is increased from annually to quarterly and calibration once per operating cycle is added.
The containment spray specification is revised to require operability of suppression pool sprays.
the required actions.
Editorial changes to this specification clarify The added or increased frequency of surveillance requirements will ensure that the tested systems will be avail 6ble when needed.
Therefore, the staff finds that the margin of safety will increase due to these revisions, and they are acceptable.
The proposed revisions to the Limiting Conditions for Operations (LCOs),
which increase the allowed out-of-service time for the HPCI and RCIC systems from 7 to 14 days, are based upon determinations using industry recognized methodology (NE00-10739, " Methods for Calculating Safe Test Intervals and All Operable Repair Times for Engineered Safeguards Systems,"
January 1973 and ape 0 5736, " Guidelines for Determining) Safe Tes and Repair Times for Engineered Safeguards," April 1969 and the original DAEC licensing basis.
In addition, shutdown LCOs are revised from plant to be in hot shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown (or otherreq condition not requiring equipment operability) in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The action statements for HPCI and RCit are revised to require the reactor pressure to be reduced to less than 150 psig rather that cold shutdown for consistency with the operability requirements of these systems, increasing the allowed out-of-service time for the HPCI and RCIC systems ssing an industry recognized calculation methodology is acceptable to the taff.
The staff also finds that these changes are consistent with the BWR tandard Technical Specifications and those of recently licensed BWRs.
ased on these considerations, these proposed changes are acceptable, he bases have been changed to agree with the revised sections.
The ECCS urveillance basis has been corrected to reflect an annual frequency for he simulated automatic actuation test rather than once per operating ycle.
This change was overlooked in the request for changes approved in mendment No. 150.
ther minor editorial changes are also proposed.
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The above changes were made for the sake of consistency with the other revisions in this request, or are editorial in nature and are acceptable to the staff.
3.0 STATE CONSULTATION
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In accordance with the Commission's regulations, the lowa State official was notified of the proposed issuance of the amendment. The State official had no comments, j
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4.0 ENVIRONMENTAL CONSIDERATION
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This amendment involves a change to a requirement with respect to the instal-lation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or a change to a surveillance requirement. The staff has determined that the amendment involves no significant increase in the j
amounts, and no significant change in the types, of any effluents that may be i
released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously i
issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (56 FR 27275).
Accordingly, the amendment meets the eligibility criteria for categorical axclusion set forth in 10 CFR 51.22(c)(9).
This amendment also involves changes in recordkeeping, reporting or administrative procedures or requirements.
Accordingly, with respect to these items, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not r
be endangered by operation in the proposed manner, (2).such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance i
of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principel Contributor:
C. Y. Shiraki j
l Date:
August 12, 1991 i
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