ML20141D286
| ML20141D286 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 05/09/1997 |
| From: | Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20141D291 | List: |
| References | |
| NG-97-0847, NG-97-847, NUDOCS 9705200057 | |
| Download: ML20141D286 (5) | |
Text
IES Utikties Inc.
200 Fwst Street S.E.
PO. Box 351 Cedar Rapids, IA 52406-0351 Telephone 319 398 8162 Fax 319 398 8192 UTIUTIES.
Vce President, Nuclear May 9,1997 NG-97-0847 OfSce ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-37 Washington, DC 20555-0001
Subject:
Duane Amold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request for Technical Specification Change (RTS-292): Revision to Defmition of Limiting Conditions for Operation.
Reference:
G. Kelly (NRC) to IES Utilities Inc., " Summary of March 20,1997 Meeting on Technical Specification Setpoints and the Pra.:tice of Not Entering Limiting Conditions for Operation (LCO) Action Statements During Certain Surveillances," April 3,1997.
File:
A-ll7
Dear Sir (s):
In accordance with the Code of Federal Regulations, fitle 10, Sections 50.59 and 50.90, IES Utilities Inc. hereby requests revision to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).
The proposed TS amendment would revise the definition of Limiting Conditions for Operation (LCO) to address the situation when systems, components, etc. are removed from service or otherwise made inoperable during secondary modes of operation, without requiring entry into the LCO actions This is the current operating practice at the DAEC and is supported by the plant design and licensing basis, as discussed in the referenced meeting with the Staff. Within the dermition of LCO, such secondary modes are also being defined consistent with the DAEC design and licensing basis. As compensatory measures during such secondary modes of operation, criteria are established within the definition of LCO that ensure the plant is operated consistent with the original design basis assumptions, f
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NG-97-0847
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Page 2 of 2 This application has been reviewed by the DAEC Operations Committee and the Safety -
Committee. A copy of this submittal, along with the evaluation of No Significant Ilazards Consideration, is being forwarded to our appointed state official pursuant to 10 i
CFR Section 50.91, E
Should you have any questions regarding this matter, please contact this office.
This Ictter is true and accurate to the best of my knowledge and belief IES UTILITIES INC.
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'lohjfF.' Franz Vice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this W day of A1&/_.
,1997, by (Ash / dPOnnnn)/ Vr'mnd
} Afb lb) f00 Nota /y Public in and for the/ State ofj6wa fl8 -99 Commission Expires
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Attachments: 1)
Evaluation of Change Pursuant to 10 CFR Section 50.92 2)
Proposed Change RTS-292 to the DAEC Technical Specifications J
3)
Safety Assessment 4)
Environmental Consideration JFF/RAB/rab N.\\lowa\\Liecmingug\\97-0847 cc:
R. Browning L. Root G. Kelly (NRC-NRR)
A. B. Beach (Region 111)
P. Baig (State ofIowa)
NRC Resident Office
)
Docu i
l i
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l RTS-292 Attachment I to NG-97-0847 PageIof3 EVALUATION OF CIIANGE PURSUANT TO 10 CFR SECTION 50.92 Background; in a meeting with the NRC Staff on March 20,1997, we explained the DAEC's policy of not entering Limiting Conditions for Operation (LCO) actions for equipment removed from service during so-called " secondary modes of operation," such as surveillance testing, ir, this equipment is not in its nonnal standby readiness mode. This policy has also been the subject of previous communications with the Staff (Ref. September 22,1994 Meeting and IES letters NG-94-4017, dated November 30,1994 and NG-95-0815, dated March 10,1995) on the Generic Letter 89-10 Program for motor-operated valves. In these previous communications we have provided the Staff with the original design and licensing basis information that supports this policy. The fundamental premise of this original basis information is that LCO actions are only intended to be entered when equipment is removed fmm service for maintenance (either corrective or preventative), not when taken out of service for testing or other allowed secondary modes of operation (Ref. General Electric reports APED-5736: fluideline for Determining Safe Ic;t Intervals and Repair Times for Engineered Safeguards, and NEDO-10739: Methods for Calculating Safe Test Intervals and Allowable Renair Times for Engineered Safeguard Systems),
This was determined to be acceptable because the time in such secondary modes of operation (iz, the safe test interval) is very short in duration, especially when compared to the allowable repair time for maintenance (ir, LCO time); and, that redundant systems, trains, etc. would not be removed from service simultaneously.
As a follow-up to the March 20,1997 meeting, we agreed to incorporate the existing administrative controls used to assure that operation in such secondary modes was consistent with the above design and !icensing basis into the DAEC Operating License. Such controls will be applied uniformly to ali 15-required equipment during secondary modes of operation that preclude that equipnnnt from performing its intended safety function. The enclosed change request is intended to fulfill that agreement.
IES Utilities Inc.. Docket No. 50-331.
DRane Arnold Energy Center. I inn County. Iowa Date of Amendment Reauest: May 9,1997 Descrintion of Amendment Reouest:
The proposed TS amendment would revise the definition of LCO to address the situation when systemt, components, etc. are removed from service or otherwise made inoperable during secondary modes of operation, without requiring entry into the LCO actions. Within the definition of LCO, such secondary modes are def'med as " conditions or states other than the primary safety function." Some examples of such secondary modes of operation are surveillance testing of systems, torus cooling mode (test line-up) of Residual lleat Removal system, and use of fligh Pressure Coolant injection system or Reactor Core Isolation Cooling system in test line-up for reactor pressure control during transients. These modes require them to be placed in a line-up or configuration that is difTerent from their normal, standby readiness configuration. While
RTS-292 Attachment I to NG-97-0M7 Page 2 of 3 J
l these systems are generally " functional" during such secondary modes, they do not strictly meet the TS dermition of OPERABILITY, as they will not respond as assumed in the safety analysis (ca:,., slower response time, less than assumed flow, etc.) It is important to note that maintenance activities are not considered to be secondary modes of operation, as the system undergoing maintenance is not, in general, " functional" during those activities, k, easily and/or promptly retumed to the safety function line-up or configuration. Therefore, they are purposefully excluded from this definition.
As compensatory measures during such secondary modes of operation, criteria are established within the definition of LCO that ensure the plant is operated consistent with the original design basis assumptions. The criteria establish the administrative controls that ensure that the plant is under the control of the operators, k, use pre-approved plant procedures, limit the amount of time in such secondary modes, and ensure that a loss-of-function is not inadvertently created.
(Note: for some systems, surveillance testing will create a loss-of-function. For example, by design, Standby Liquid Control System has shared components between the two subsystems.
Consequently, when testing causes a loss-of-function, the above criteria are applied to both systems, trains, etc.). If these criteria are not met, then the L.CO will be entered and those actions will be taken in the specified time period.
Basis for Proposed No Significant iia 7;irds Consideration:
The Commission has provided standards (10 CFR Section 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 censideration 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 possibility of a new or different i.ind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
Aller reviewing this proposed amendment, we have concluded:
- 1) The proposed TS amendment will not significantly increase the probability or consequences of any previously evaluated accidents.
The proposed change merely adds criteria to the TS that are consistent with the original design and licensing basis assumptions. Operation in secondary modes of operation (such as surveillance testing, torus cooling mode (test line-up) of Residual IIcat Removal system, and use ofliigh Pressure Coolant Injection system or Reactor Core Isolation Cooling system in test line-up for reactor pressure control during transients) is assumed in the safety analysis report (Ref. UFSAR Section 6.3.4.2.1 and 7.3.4.2). Because no changes in actual equipment operation or testing are being made as part of this change, the probability of any event whici.
could be induced by such operation or testing is not increased. Also, the change will ensure that the time such equipment is removed from service is kept very short in duration, either through the existing TS Allowed Outage Time (AOT) notes or administratively by procedures. This is consistent with the assumption that the time in such secondary modes of
RTS-292 Anachment I to NG-97-0847 Page 3 of 3 operation (k, safe test interval) is much shorter than the allowable repair time (k, LCO time). Therefore, the proposed change will not significantly increase the probability of any previously evaluated accident.
The uniform application of the new TS criteria will further ensure that the plant remains within the original design and licensing basis assumptions for equipment removed from service during secondary modes of operation. In particular, in the special case where testing also removes the redundant system, train, component, etc., from service, these criteria ensure that both affected systems, trains, etc., are properly controlled This is acceptable because the time in such secondary modes of operation is very short in duration, such that the impact on overall availability / reliability is insignificant. Therefore, the consequences of any previously analyzed accident are not significantly increased by this change.
- 2) The proposed changes will not add a new or different kind of accident because the plant will not be operated in a different way. Operation in secondary modes has been previously evaluated and found to be acceptable (Ref. General Electric reports APED-5736: Guidehae for Determining Safe Test Intervals and Renair Times for Engineered Safeguards, and NEDO-10739: Methods for Calculatine Safe Test Intervals and Allowable Renair Times for Engineered Safeguard Systems.) The proposed change increly adds criteria to the TS that are consistent with the assumptions contained within these evaluations. Consequently, no new or different accidents are postulated as a result of this proposed change.
- 3) Because the criteria being added to the TS enforce the assumptions of the evaluations that form the basis of t.c aisting TS (Ref. TS Bases 4.1,4.2, and 3.5), the proposed change will not result in a significant reduction in any margin of safety.
Based upen the above, we have determined that the proposed amendment will not involve a significant hazards consideration.
Local Puble Document Room Location: Cedar Rapids Public Library,500 First Street SE, Cedar Rapids. Iowa 52401 Attorrwv for Licensee: Jack Newman, Al Gutterman; Morgan, Lewis & Bockius,1800 M Street NW, Washington, D.C. 20036-5869
.