NG-93-0111, Application for Amend to License DPR-49,revising TSs Re Source Range Monitor Functional Test Surveillance Interval

Application for Amend to License DPR-49,revising TSs Re Source Range Monitor Functional Test Surveillance Interval

ML20128D940
Person / Time
Site:	Duane Arnold
Issue date:	01/29/1993
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
ML20128D943	List: ML20128D969 NG-93-0111, Application for Amend to License DPR-49,revising TSs Re Source Range Monitor Functional Test Surveillance Interval
References
NG-93-0111, NG-93-111, NUDOCS 9302100271
Download: ML20128D940 (5)

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Iowa Electric Light and Power Company January 29, 1993 NG-93-011?.

JOllN L Fl' ANZ, JR.

4 % t PRhltaFNT 8*Vi( AR Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, DC 20555

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request for Technical Specification Change (RTS-255): Revision of Source Range Monitor Functional Test Surveillance Interval

Reference:

1) Letter NG-91-3504, Mineck (lELP) to Murley (NRC), dated November 15, 1991

2) Letter, Shiraki (NRC) to Liu (IELP), dated hugust 25, 1992 File: A-117-

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 (IELP) requests revision to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

In-Reference 1 (RTS-200), IELP requested revision to tne DAEC TS Section 3.9, " Core Alterations." This request, subsequently

-approved by Reference 2 (Amendment 186), revised the fuel loading requirements, incorporated DAEC procedural requirements and requirements from the Standard TS, and made various editorial changes to improve clarity and consjetency.

We,have subsequently determined that the surveillance interval for the Sourcs.-Range Monitor (SRM) functional test had been unintentionally specified as daily. This proposed amendment to the TS requests correction of this error and restoration of.the weekly interval for the SRM functional test.

This application has been reviewed by_the DAEC Operations' Committee and the DAEC Safety Comm1'ttee. A copy of this submittal, which includes _ our analysis loi significant hc.?ards ]

-93021002111930129 PDR ADOCK 05000331 .

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Dr. Thomas E. Murley January 29, 1993 NG-93-Olll Page 2 consideration, 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.

IOWA ELECTRIC LIGHT AND POWER COMPANY Y s By [. Jb- /SM Jonn'F. Fran2/

V/ce President, Nuclear State of Iowa (County) of Linn p Signed and sworn to before me on this _ cay of dIllYll'Y ,

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Hotar*y Pu 1dc in'and Yot the :itate of Iowa g

MARY MICHELEO'NEA1L tg COMW4310W FJMRI3 -

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Commission Expires Attachments: 1) Evaluation of Change Pursuant to 10 CFR-50.92

2) Proposed Change RTS-255 to the Duane Arnold Energy Center Technical Specifications

3) Safety Assessment

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

A. Bert Davis (Region III)

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An (State of Iowa)

NRC Hesident Office DCRC i

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' ~ *1RTS-255 Attachment 1 to

, NG-93-0111-Page 1 of 2' EVALUATION OF CHANGE PURSUANT TO 10'CFR 50.92 i

Background:

Amendment 186 to the Duane Arnold Energy Center (DAEC) Technical Specifications (TS) revised Section 3.9, Core Alterations. This j amendment revised the fuel loading requirements, incorporated DAEC -l procedural requirements and requirements from the Standard TS, and made other various editorial changes to improve clarity and consistency.

During implementation of this amendment, it war discovered that.the surveillance interval for the Source Range Monitor-(SRM) functional test had been inadvertently specified as daily. One of the goals of Amendment 186 was to improve the clarity of the TS. This was. achieved by separating L1miting Conditions for Operation (LCOs) and .

Surveillance Requirements (SRs) when appropriate._ The SRM functional l test and response check had previously been listed in the same -j Surveillance Requirement. A daily surveillance interval had been j specified for the response check. No interval was specified in the SR

- for the functional test. In the process of separating the_SRs for_the i SRM functional telt and the SRM response check, the daily requirement.

was inadvertently carried over into the functional test.

The functional test has historically been done at the DAEC on a weekly-basis during CORE ALTERATIONS in accordance with our Surveillance' Testing Program. The TS Bases supports this weakly interval. The Bases describes the intent of the functional test and response check.

The functional test assures that the SRM's are OPERABLE at the start j of CORE ALTERATIONS.- The ca.*1y response check ensures their continued-operability. This intersal la-consistent with the Standard TS.

Furthermore, a daily functional test is not directed by any other regulatory guidance and is unnecessary.

Iowa Electric Light and Power Company, Docket No. 50-331-Duane Arnold Energy Center, Linn County g ' Iowa Date of Amendment Request: January 29, 1993 Descri,ption af Amendment Request:

The proposed license amendment request would change the Source Range Monitor functional test surveillance interval-from daily to weekly.-

Easis_for proposed no signif.icant-hazards consideration:

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RTS-255 Attachment 1 to NG-93-0111 Page 2 of 2 The NRC has provided standards (10 CFR 550.92(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 possibility of a new or different kind of accident f rom any accider.t previously evalu.ded; or (3) involve a significant reduction in a margin of safety, (1) T:.e proposed change does not increase the probability or consequences of an accident occurring because it merely corrects an error and restores the appropriate surveillance interval for the SRM functional test. No other changes are proposed.

(2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because this change to the surveillance interval merely corrects a previous error and is consistent with DAEC and NRC guidance.

(3) The margin of safety will not be reduced since the change corrects an eiror as noted above and therefore does not affect the margin of safety.

Based on the above, we conclude that the proposed Amendment doec not involve a significant hazards consideration.

Loca] 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, DC 20036

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d RTS-255 AttachmentL2 to NG-93-0111 Page 1 of 1 PROPOSED CHANGE RTS-255 TO THE DUANS ARNOLD ENERGY CENTER TECHNICAL SPECIFICATIONS The holders of license DPR-49 for the Duane Arnold Energy Center propose to amend Appendix A (Technical Specifications) .ta) said-license.

by deleting one current page and replacing it with the' attached, new page. The'Affected Page is given below.

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.i Affectel Page 3.: 5 Description of Change-

.3.9-5 SR 4.9.B.1 has been revised to correct an error introduced' by-Amendment 186 regarding the'SRM-functional test SURVEILLANCE FREQUENCY. This frequency was. erroneously specified as daily in the above.amendinent. A weekly .

frequency is consistent with DAEC historical practice, the; DAEC TS Bases and the Standard TS and is incorporated back into.this SR.

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