ML20198P887

Proposed Tech Specs Section 3.7.B LCO for PCIVs Revised to Allow 72 Hours to Isolate Failed Valve Associated W/Closed Sys

ML20198P887
Person / Time
Site:	Duane Arnold
Issue date:	01/09/1998
From:	IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:
Shared Package
ML20198P885	List: ML20198P887 NG-98-0016, Application for Amend to License DPR-49,revising LCO for PCIVs in TS Section 3.7.B to Allow 72 Hours to Isolate Failed Valve Associated W/Closed Sys,Per NUREG-1433
References
NUDOCS 9801220282
Download: ML20198P887 (7)

Text

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=. Attachment 2 to NG-98-0016 Page1

' PROPOSED CHANGE RTS-297 TO Tile DUANE ARNOLD ENERGY CENTER .

TEClINICAL SPECIFICATION _S The holders oflicense DPR-49 for the Duane Arnold Energy Center (DAEC) propose to L amend the Technical Specifications (TS) by deleting the following current l' ages and replacing them with the attached new pages. The Affected Pages are given below.

AFFECTED PAGES 3.7-7 3.7-8 3.7-26 SilMMARY OF CilANGES:

Pace Descrintion of Chance 3.7-7 This change extends the time to isolate single PCIV penetrations from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> tc 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.-

3.7-8 Administrative change.

3.7 26 Bases change to reflect changes to page 3.7-7.

L 9901220282 990109~ ~" -

PDR ADOCK 05000331 P PDR ,

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, DAEC-1 j

! LIMITING CONDITIONS FOR OPERATION fURVEf t TANCE REOUIREMENTS l B. Primary Centainment Pever o. Egjgggy,_pggyainment Power

• onerated Isolation valy.g3 onorated Isolatter va? m

1. During reactor power operating 1. The primary containment isolation conditions, all prisaary valves surveillance shall be contaisument isolation valves and performed as follows:  :

all instrument line flow check l valves shall be except a. At lea 1t once per operating cycle )

as specified in( .7.3. . th OPEPABLE isolation valves # ,

A that are power op3 rated and j

&f g'g* g 3 automatically initiated shall be torted for simulated automatic i

initiation and closure times.

b. At least once per quarter:

1) All normally open power operated isolation valves ## ahall be fully closed and reopened.

L 1 2) With the reactor power less than h Rf\e,,TTCC YwM

$)o y>

75%, trip main steam isolation valves individually and verify f% closure t M .

ho *fM (50ph M'M 1 eD Y

c. At least once per operating cycle the operability of the reactor cools.at system instrument line

\/o hs ! 5 L s d S) flow chock valves shall be verified.

2. With one or more of the primary  !

containement isolation valves )

, inoperable, maintain at least one l l isolation valve OPERABLE in each i affected penetration that is open ar4 wit.hin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> sithers

a. Restore the inoperable 1 valve (s) to OPERABLE status, or I

b. Isolate each affected

_ m penetration flow path.*

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• Penetrations isolated to satisfy these requirements may be reopened on an intermittent basis under admi is t e . G #Due to operation limitations, the Main

,3. "or p g pg Lot'd Steam Line Isolation Valves are exasapt from subsection 4.7.s.l.a.

o nI P g .A,g'0fulv ( exc- Pod

+ epcus

/ , ##Due to plant operational limitations, C.hach VO. N {'. N *

• the Well Cooling Water Supply / Return FO Igolaj gy one, hCBJ t

• Valves, Reactor Building Closed Cooling WLeer Supply / Return Valves and the NJg ) Containment compressor Discharge and

{Qc)t-eMI suction valves are exempt from the

(;0i dt A N gg g M OOC.e. fEJ' d requirements of Subsection 4.7.b.1.b.

M go VLA S. kC Y P"M$gn f(e[u.2 pa$h G tsolafd .

e Aow cAc k 3$Io +e- A 1' F#E

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R ms- m

DAEC-1 t.tMITTuc c mnITIONS FOR OPERATION

%^ SURVTT'1WCE R20DIREMrw?3 W 3.'7. B.3 1

. If spec cations 3.7.3.1, M "'

3.7.3.2 annot be met, an orderly (

shutdown shall be initiated and ,

.a the reactor shall be in at least N NOT SNUTDomt within the next- 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold sWUTDomt within the followin 24 h r rging

a. Containment vent / purge valves (CV-4300, cv-4301, cv-4002, CV-4303, CV-4306, CV-4307, CV-4308, cv-4309, and CV-4310) may not be opened so as to create a flow path from the primary containment while PRIMARY CONTAINMENT INTEGRITT is required oncept for inerting, de-inerting, vent / purge valve testing, or pressure control.

l

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9

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waNT NO. g,201' 3.7-8

l

+

DAEC-A environmental conattions will not preciude access to close the valves and that this action will prevent the releaseW PMcm of radioactivity outside Othe e ntai .

(pwmW@cm fled Pds toAhe P"NY O gd(slecAw FNn thepenArc b h event that one or more F m , a...... .-... ;;1 .e.. ....-

• • IVs\ are inoperable, either the inoperanle valve must be restored to OPERABLE etatus or

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the affected penetration must be isolated. The method of isolation must

\

include the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and deactivated automatic PCIV, a closed manual valve, a blind flange, or a check valve inside primary containment wit.h flow through the valve secured. The specified time period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is reasonable f considering the time required to isolate t!.O penetration and the relative h importance of maintaining primary containment integrity.

(NSERT '

• W.sg Drvwell Avernos Air **emnerature The drywell contains the reactor vessel and pipirg, which add heet to the airspace. Drywell coolers remove heat and maintain a muitable environment.

The average airspace toeperature affacts equipment OPERABILITY, paraonnel access, and the calculated response to postulated Design Basis Accidents (DBAs). The 1Amitatten en the drywell average att temperature was developed as a reasonable upper couno based on operating plant experience. The limitation on dryweil temperature is used in the safety analyses. Among the inputs to the design basis analysis is the initial drywell average air temperature. Analyses assume an initial average drywell Air toutperature of 135'F.

This limitation ensures that the safety analysis remains valid by maintaining the expected initial conditions and ensures that the peak LOCA drywell temperature does not exceed the maximum alicwacle.

In the event of a DEA, with an initial drywell average temperature less than or equal to the Leo toeperature limit, the resultant peak accident temperature AMENDMENT No. 201 3.7-26 kTS-89)

INSERT For penetration flow paths with only one PCIV, with the PCIV inoperable, the inoperable valve must be restored to OPERABLE status or the affected penetration flow path must be isolated.

The method ofisolation must include the use of at least one isolation barrier that camavt be adversely affected by a single active failure. Isolation barriers that meet this criterion are a closed and de-activated automatic valve, a closed manual vr've, and a blind flange. In addition, for the valve or flange to be acceptable for use as the OPERA ALE isolation device, it must meet all the design requirements for the PCIV it is replacing, such as,10 CFR 50, Appendix J leakage testing, seismic qualifications, piping code class provisions, etc. A check valve may not be used to isolate the affected penetration. The required action must be completed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for lines other than Excess Flow Check Valve (EFCV) lines. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is reasonable considering the relative stability of the closed system (hence, reliability) to act as a penetration isolation boundary and the relative importance of supporting primary containment OPERABILITY. The closed system must meet the requirements of Standard Review Plan 6.2.4. For affected penetrations that have been isolated in accordance with TS 3.7.B.3, the affected penetration flow path (s) must be verified to be isolated on a periodic basis. This is necessary to ensure that primary containment penetrations required to be isolated following an accident, and no longer capable of being automatically isolated, will be in the isolation position should an event occur.

This action does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment and capable of potentially being mispositioned are in the correct position. Once per 31 days for verifying each affected penetration is isolated is appropriate because the valves are operated t.nder administrative controls and the probability of their misalignment is low.

Rrs -2 rr

. Attachment 3 to NG-98-0016 Pane 1 SAFETY ASSESSMENT 1, Introduction By letter dated January 9,1998, IES Utilities requested a revision to the Duane Arnold Energy Center (DAEC) Technical Specifications (TS). The proposed change will revise TS Section 3.7.B. to allow 72 houn to isolate General Design Criteria (GDC) 57 (i.e., closed systems inside containment) isolation valves. The proposed change is consistent with Revision 2 to Improved Technical Specifica: ions Traveler TSTF-30 approved by the NRC on October 1,1997.

2. Evaluation Currently, TS Section 3.7.B does not allow the use of a closed system to isolate a failed containment isolation valve even though the closed system is subjected to a Type A containment leakage test, is missile protected, and is seismic category I piping. Therefore, TS Section 3.7.B is revised to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate a failed valve associated with a closed system. This 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period provides the necessary time to perform repairs on a failed containment isolation valve when relying on an intact closed system.

GDC-57 allows the use at a closed system in combination with a single containment isolation valve to provide two containment barriers against the release of radioactive material following an accident. As such, the use of a closed system is not different from isolating a failed containment isolation valve by use of a single valve. A closed system also typically has flow through it during normal operation such that any loss ofintegrity could be continually observed '

through the leakage detection system within containment and system walkdowns for closed systems outside containment. Seventy-two (72) hours is considered appropriate given that certain valves may be located inside containment, the reliability of the closed system, and that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is typically provided for losing one train of redundancy throughout the NUREG 1433.

Therefore, we conclude that the proposed revision to the DAEC TS is acceptable.

Attachment 4 to

. NG-98-0016

- Page1 ENVIRONMENTAL CONSIDERATION 10 CFR Section 51.22(c)(9) identifies cer:ain licensing and regulatory actions which are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; and (3) result in a significant increase in individual or cumulative occupational radiation exposure. IES Utilities Inc. has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Section 51.22(c)(9). Pursuant to 10 CFR Section 51.22(b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Basis The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR Section 51.22(c)(9) for the following reasons:

1. As demonstrated in Attachment I to this letter, the proposed amendment does not involve a significant hazards consideration.

- 2. The proposed change revises TS Section 3.7.B. to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate General Design Criteria (GDC) 57 (i.e., closed systems inside containment) isolation valves. There will be no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

3. The r:oposed change revises TS Section 3.7.B. to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate General Design Criteria (GDC) 57 (i.e., closed systems inside containment) isolation valves. There will be no significant increase in either individual or cumulative occupational radiation exposure.

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