ML20090L139
| ML20090L139 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 03/11/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20090L128 | List: |
| References | |
| NUDOCS 9203200080 | |
| Download: ML20090L139 (4) | |
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LAlOL[y6ALVATION BY Ttit OfflCE OF NUCl[AILBIAU.QB_J1[S2LAlla RELATEQ_TO AMENDMEtH_RO. 181 IQ.f M ilY_QELB611 M_llCllt1[ No. D & A2 IOWA ELECTRIC Ll.GHT A@_EQW{fLCOMfWH
((NLRAll0WA POW.[fLCQOfLRAllyL CORN BELT POWL[L[QQELRATIVE DVANE ARNOLD ENERGY CEN1ER RQG ET N0 J 0-331 1.0 INTRODUCTIM By letter dated September 20, 1991, Iowa Electric Light and Power Company (the licensee) requested an amendment to facility Operating Licenst No. DPR-49 for the Duane Arnold Energy Center (DAEC).
The proposed amendment would remove the Technical Specifications (TS) tables that include lists of components referenced in irHividual specifications.
In addition, the TS requirements have been modified such that all references to these tables heve been removed.
- Finally, the TS have been modified to state requirements in general terms that include the components listed in the tables removed from the TS. Guidance on the prcposed TS changes was provided by Generic Letter (GL) 91-08, dated May 6, 1991.
2.O f_YALQ6110H Qglt11.pn of Tables The licensee has proposed the removal of Teble 3.7-1, " Containment Penetrations Subject to Type B Test Requirements,' and Table 3.7-2, ' Containment Isclation Valves Subject to Type C Test Requirements." References to these tables in TS 4.7. A.2.b and 4.7. A.2.c respectively, are also being deleted since, with the removal of the tables, deletion of the references is also necenary.
The component lists formerly contained in the two tables will be incorporated into plant procedures that are subject to the change control provisions for plant procedures in the Administrative Controls Section of the TS.
This is an acceptable alternative to identifying each component by its plant identification number in these two tables since the change control provisions of tha TS provide an adequate means to control changes to these cumponent lists although the lists are not in the TS. The removal of these tables of component lists is acceptable because it does not alter existing TS requirements or those components to which they apply. Although the above component lists are not specifically described in Generic Letter 91-08, the licensee's proposal to remnve them from the TS is based on the guidance in the GL.
TS Section 4.7.A.2 contains appropriate descriptions of the scope of the components 'to which the removed TS requirements
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. apply. Since reguletory requirements and guidance further define the components and the testing involved and the Bases Section of the 15 already references the applicable requirements, no furthtr clarification is required.
Section 4.7.A.2.e has been modified to &dd the requirement to verify that the nchantcal modification which limits the a:aximum opening angle is intact when performing Type C testing on purge isolation valves.
Inis requirement was formerly contained in Note 5 to Table 3.7-2 and is in addition to the 15 requirements.
The modification to Section 4.7.A.2.e contains specific valve numbers. However, the Gl. guidance states that, if practical, valves should be identified by function rather than by component nunber.
For this proposed enange, there are other purge isolation valves to which the above requirement does not apply because the valves differ in design.
It i s, therefore, not practical to identify these valves solely by function. The change is consistent with the guidance of GL 93-08, and is acceptable.
1he licensee has also proposed the removal of Table 3,7-3. ' Primary Containment Power Operated Isolation Valves,* that is referenced in TS 3.2 Bases, 3.7.D.1, 4.7.D.I.b.1, and 3.7,0.2.
The addition of a limiting condition for operation that addresses the operability of containment isolation valves is not necessary t,ince 15 Section 3.7,0.1 already contains the requirement that:
During reactor power operating conditions all primary contain-t ment isolation valves and all instrument line flow check valves shall be OPERABLE except as specified in 3.7,0.2 This states the operability requirements in general tera; that apply to all containment isolation valves including those that are ' locked or sealed closed.
These valves would be locked or electrically deactivated in the isolated position 1
or blind flanged cotesistent with the reguletory requirements for manually-operated valvas that are used as containment isolation valves. Removal of Table 3.7-3 from the TS is consistent with the guidance of GL 91-08 and is, therefore, acceptable.
Two footnotes have been added as references of Sections 4.7.D.1.a and 4.7.D.l.b.1, These footnotes were formerly a Note in Table 3.7-3.
Their addition is necessary because their content provides exceptions to TS require-monts.
Their addition is consistent with the guidance of GL 91-08 and is, therefore, acceptable.
There were other Notes in Tables 3.7-1, 3.7-2 and 3.7-3 tr t were not added to a
TS Sections because they were for information only and Jid not alte* any TS requircments. Their removal would therefore not affect the applicability of the TS requirements and their addition to TS Sections is not necessary. This is in accordance with the guidance of GL 91-08 and is, therefore, acceptable.
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3 Intermittent Oneration etyAlyn Intermittent operation ur. der administrative control of valves which are locked or electrically deactivated in the isolated position or blind flanged ts already addressed in the following footnrte referenced in Section 3.7.D.2.
Isolation valves closed to satisfy these,equirements may be reopened on an intermittent basis under administrative control, The definition of administrative control has been added to the 3.7.A Bases. This definition is consistent with the guidance in GL 91-08 and is, therefore, acceptable, blitprial and Clgifkation Chanoes In Section 3.7. A.2, a sentence has been added that states that co'npliance with Subsection 3.7 D 2 is a means of satisfying the requirement to maintain primary containment integrity.
This statnment wat, added to clarify that if a primary containment isolation volve is inoperable, and the actions of Section 3.7.D.2 are performed, the requirement to maintain primary containment integrity in Section 3.7.A.2 has been satisfied for the penetration in which the inoperable primary containment isolation valve is located. The added statement is a clarificatter and does not alter existing TS requirements or the components to which it applies, and is, therefore, acceptable.
A footnote below Section 4.7.D that defines an operating cycle has been deleted, since an operating cycle is clearly defined in Section 1.0.
This is an editorial change that does not modify any 15 requirements or plant equipment and is, therefere. acceptable, in 3.2 Bases, references to Specification 3.7 for required closing times and isolaticn valve closure group have been deleted since with the deletion of the Tables, this information is no longer contained in the TS.
These changes are made for consistency and are acceptable.
The one. time exemption footnotes referenced in Sections 4.7 A.2.d.2)a),
4.7.A.2.d.3) and 4.7.A.2.c have been deleted since the exemptions have expired and the footnotes are no longer needed.
These are editorial changes and are acceptable, in the 3.7 Bases, a reference to the plant Administrative Control Procedures was added to indicate that this is the location of the lists of testable components and primary containment power operated isolation valves. This is in accordance with the guidance of CL 91-08 and is acceptable, The licensee has proposed changes to the above TS that ure consistent with-the guidance provided in GL 91-08. In addition, the licensee has provided an updated copy of the Bases Section of TS 3.7.A that addresses appropriate considerations
4 for opening locked or sealed closed valves on an intermittent basis,
- finally, the licensee has confirmed that component lists removed from the TS have been updated to identify all components for which the 15 requirements apply and are located in contrulled plant procedures.
On the basis of the above review, the staff finds that tha proposed changes to the TS for the Duane Arnold Energy Center are primarily administrative in nature and do not alter the requirements set forth in the existing TS.
However, the appitcability ot' the operability requirements will extend to all containment isolation valves as noted in this evaluation. Overall, these changes will allow the Itcenset to make corrections and updates to the list of components for which these TS requirements apply, under the provisions that control changes to plant procedures as specified in the Administrative Controls Section of the 15.
Therefore, the staff finds that the proposed TS changes are acceptable.
3.0 STATE COM!)1]All.QN In accordance with the Commission's regulations, the Iowa State official was notified of the proposed issuance of the amendment.
The State official had no corsnents.
4.0 ENVIR0kMENTAL CONSID[ RATIONS This amendment ch6nges a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or chances a surveillance requirement.
The staff has determined that the amendment involves no significant increase in the amounts, and no significant change la_ the types, of any effluents that may be released offsite, and that there is no significant inc.rease in individual or cumulative occupational radiation exposure. The Comminion has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (50 TR 55947).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c){9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the ameniment.
5.0 CONCLtlSION The staff has concluded, based on the considerations discussed abcVe, that: (1) there is reasonable assurance that the health and safety of the public will not 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 of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
C. Y. Shiraki i
Date: March 11, ;992
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