NG-95-0286, Application for Amend to License DPR-49,consisting of Proposed Change RTS-279 to TS to Remove Redundant LCOs & SRs for Containment Hydrogen & Oxygen Monitors in TS

Application for Amend to License DPR-49,consisting of Proposed Change RTS-279 to TS to Remove Redundant LCOs & SRs for Containment Hydrogen & Oxygen Monitors in TS

ML20081C984
Person / Time
Site:	Duane Arnold
Issue date:	03/10/1995
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20081C985	List: ML20081C989 NG-95-0286, Application for Amend to License DPR-49,consisting of Proposed Change RTS-279 to TS to Remove Redundant LCOs & SRs for Containment Hydrogen & Oxygen Monitors in TS
References
NG-95-0286, NG-95-286, NUDOCS 9503200084
Download: ML20081C984 (4)

Text

___- _ _ _-___ - -_ _

N 4

.g IES '

. UTILITIES INC.

John F. Franz, Jr.

' Vice President. Nuclear March 10,1995 NG-95-0286 l

Mr. William T. Russell, Director Oflice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-37 Washington, DC 20555-0001 i

Subject:

Duane Arnold Energy Center Docket No: 50-331 i Op. License No: DPR-49  !

Request for Technical _ Specification Change (RTS-279): Deletion of H2-02 Analyzer Requirements from 3.7/4.7.H.3 File: A-117, T-48 )

Dear Mr. Russell:

In accordance with the Code of Federal Regulations, Title 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 change removes redundant Limiting Conditions for Operation and Surveillance Requirements foi the containment hydrogen and oxygen monitors in the TS.

This application has been reviewed by the DAEC Operations Committee and the Safety Committee. A copy of this submittal, along with the No Significant Hazards Considerations analysis, is being forwarded to our appointed state oflicial pursuant to 10 CFR Section 50.91.

We hereby request that this amendment be made effective 60 days after issuance to allow adequate time for implementation.

No new commitments are made by this letter.

E

c. c. r

• 95032000g4 950310 7 PDR ADOCK 05000331 PDR g[

General Office

• RO. Box 351

• Cedar Rapids, Iowa 52406

• 319/398-4411 An IES INDUSTRIES Company IlI

Mr. William T. Russell

< NG-95-0236 March 10,1995 Page 2  ;

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.

IES UTILITIES INC.

By uf &

f John F. franz [

Vice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this _ day of_f[lf ,1995, by 0\M E EdL O l I j{l kt0 / i c h li in and for the St'5te o'flowa'

$ MARY MICHELE O'NEAL

\

(fffj% ,

Con ion Expires' JFF/LIIS/pjv Nilima Ixcming pjv RTS-279 4w Attachments: 1) Evaluation of Change With Respect to 10 CFR Section 50.92

2) Proposed Change RTS-279 to the DAEC Technical Specifications

3) Safety Assessment

4) Environmental Consideration cc: L. Swenzinski L Liu

11. Fisher L. Root G. Kelly (NRC-NRR)

J. Martin (Region III)

S. Ilrown (State ofl A)

NRC Resident Ollice DOCU

RTS-279 Attachment I to

. NG-95-0286 Page 1 of 2 IWALUATION OF CHANGE WITH RESPECT TO 10 CFR SECTION 50.92 flag _kground:

The Containment Atmosphere Dilution (CAD) System provides a means to limit oxygen

, concentration in the containment, following a Loss of Coolant Accident (LOCA). The CAD l System is manually initiated by the Operators when directed by Emergency Operating Procedures.

Hydrogen and oxygen concentrations in the containment are continually monitored by the H2 -02 analyzers. These concentrations are continuously displayed in the Control Room.

The Duane Arnold Energy Center (DAEC) Technical Specifications (TS) Section 4.7.H.3. has been determined to be redundant to requirements of Table 4.2-11. Table 4.2-H requires a semi-annual test of the containment hydrogen and oxygen analyzers. This exceeds the frequency and duplicates the annual functional test required in Section 4.7.11.3. TS Section 3.7.H.3 refers directly to Table 3.2-1I for Limiting Conditions for Operation.

In addition, TS Section 4.7.H.3 currently requires that the containment hydrogen and oxygen j analyzers be functionally tested "in conjunction with" the annual CAD functional test. The requirement to perform the two tests in conjunction creates unnecessary scheduling constraints.

There is no technical or licensing basis fet performing these tests in conjunction.

!ES Unlitics Inc , D_ogket No. 50-331.

Duang_ Arnold Energy Center Linn County. Iowa Datc3nfAmendmenLRequnt: March 10,1995 IleEcliptio1Lof Amendment Request:

The proposed License Amendment would delete TS Sections 3.7/4.7.H.3 to eliminate redundant Limiting Conditions for Operation and Surveillance Requirements for the cont,inment hydrogen and oxygen analyzers.

IlAsil fer pippmeANstSignificant llazards 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 consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or con:,equences of an accident previously evaluated; (2) create the possibility of a new or dif*: rent

kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

l

.l RTS-279 Attachment I to l

, NG-95-0286

. Page 2 of 2 Aller reviewing this proposed request for Technical Speci0 cation change, we have concluded:

1) The proposed amendment does not involve a significant increase in the probability or ,

consequences of an accident previously evaluated. No physical changes will result from this amendment. This change deletes requirements that are redundant and unduly restrictive. The annual surveillance deleted by this amendment is redundant to the semi-annual surveillance required in Table 4.2-11. The Limiting Conditions for Operation are not changed by the propored amendment.

2) The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. No physical changes will result from this amendment.

Functional tests are performed on the hydrogen and oxygen analyzers semi-annually as required in TS Table 4.2-11. Deleting the annual requirement for a functional test of the same equipment will not reduce the amount of testing performed or increase the possibility of degraded equipment being undetected.

3) The proposed amendment does not involve a significant reduction in a margin of safety. No physical changes will result from this amendment. The existing requirement for a semi-annual ,

test of the hydrogen and oxygen analyzer in Table 4.2-11 exceeds the requirements to be deleted in Section 3.7/4.7-11. The frequency of testing of the hydrogen and oxygen analyzers will not be reduced as a resuh of this amendment.

Based upon the above, we have determined that the proposed amendment will not involve a significant hazards consideration.

LocalPMlic Docunjent Room Location: Cedar Rapids Public Library,500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licenlee; Jack Newman, Kathleen II. Shea; Morgan, Lewis & Dockius,1800 M Street NW, Washington, D.C. 20036-5869 c