NG-95-0934, Application for Amend to License DPR-49,consisting of Request for TS Change (RTS-282),revising TS Table 3.2-A, Isolation Actuation Instrumentation

Application for Amend to License DPR-49,consisting of Request for TS Change (RTS-282),revising TS Table 3.2-A, Isolation Actuation Instrumentation

ML20082D103
Person / Time
Site:	Duane Arnold
Issue date:	03/28/1995
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
ML20082D106	List: ML20082D117 NG-95-0934, Application for Amend to License DPR-49,consisting of Request for TS Change (RTS-282),revising TS Table 3.2-A, Isolation Actuation Instrumentation
References
NG-95-0934, NG-95-934, NUDOCS 9504070296
Download: ML20082D103 (6)

Text

IES Utilites Inc.

f e 200 First Street SE.

P.O. Box 351 Cedar Rap 4s, IA 52406-0351.

Telephone 319 398 8162 Fax 319 398 819; UTILITIES , , , , , ,

March 28,1995 NG-95-0934 Mr. William T. Russell, Director Ollice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Statio.n Pl-37 ,

Washington, DC 20555-0001 .

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request for Technical Specification Change (RTS-282): Instrument Table 3.2-A Revisions

Reference:

R. Pulsifer to L. Liu; Amendment No; 193 to Facility Operating License No. DPR-49, April 14,1993 ,

File: A-117 ' >

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 referenced TS Amendment incorporated extended allowable out-of-service times and surveillance test intervals for various instrumentation and made other changes to improve clarity and provide consistency with the NRC Standard Technical Specifications ( NUREG-0123) and the rest of the DAEC TS.

A recent review of TS Table 3.2-A identified inconsistencies with some line items that need clarification. These items are included in this submittal and are discussed in detail in Attachment 1.

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 Hazards Consideration, is being fonvarded to our appointed state oflicial pursuant to 10 CFR Section 50.91, 9504070296 950320 '30 q

PDR ADOCK 05000331 PDR j (g3 g P An IES Industnes Combany

7 ,

Y hit. William T. Russell March 28,1995  ;

NG-95-0934 Pape 2 Should you have any questions regarding this matter, please contact this office. -

s

~ This letter is true and accurate to the best of my knowledge and belief. .

IES UTILITIES INC. ,

By Ik

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I

/foim'F. Franz Vice President, Nuclear f

State oflowa '

(County) of Linn ' .

Signed and sworn to before me on this N day of /1 1 ,1995, by 04E. T (L h b P k i $w l%

b y P &b ad h h h ed 4g- gggy yieggtg - o.uggtI C

m q,oeo lission Expirek JFF/TWP/pjv MJowaVJieciming \954934As Attachments: 1) Evaluation of Change Pursuant to 10 CFR Section 50.92

2) Proposed Change [RTS-282] to the Duane Arnold Energy Center Technical Specifications

3) Safety Assessment ,

4) Erwironmental Consideration cc: T. Page '[

L.Liu ,

B. Fisher L. Root G. Kei.y (NRC-NRR)

J. Martin (Region III)

S. Browm (State ofIA)

NRC Resident Oflice Docu

r d

. kTS-282 . Attachment i to NG-95-0934

• Page I of 3

' f;YALUATION OF CHANGE PURSUANT TO 10 CFR SECTION 50.92 i

IhckgroumL Technical Specification (TS) Amendment No.193 incorporated extended allowable out-of-service times and surveillance test intervals for various instrumentation and made other changes to improve clarity and provide consistency with the NRC Standard Technical Specifications (NUREG-0123) and the rest of the DAEC TS.

During a review of maintenance activities planned on the Main Steam Line (MSL) Tunnel Temperature-liigh trip switches, a question arose as to whether TS Table 3.2-A was inconsistent with the existing (and original) plant design. Specifically, the TS " MINIMUM OPERABLE CilANNELS PER TRIP SYSTEM" requirement is "2/line." It Was not, clear that, with the physical design and the TS definitions of channel and logic, the "2 instrument channels /line/ trip system" requirement could be met. Subsequent investigation determined that the existing design i of the system is in conformance with the Architect / Engineer's design documentation and that the ,

system has not been modified since original plant startup. The existing con 6guration provides the intended function. A Technical Specification Interpretation Memorandum (TSIM) was issued to clarify that an instrument temperature sensor fulfills the requirements of an instrument channel and to provide the direction necessary to assure compliance with the TS. This change request proposes permanent wording changes to incorporate that clarification into the TS.

In addition, other line items in Table 3.2-A were identified that needed correction or clarification.

These changes will improve clarity and consistency within the Table and are described further below.

IliS_Utili. tics Inc.. Docket No. 50-331.

[htagelrnold Energy Center. Linn County. Iowa Qate of Amendment Request: March 28.1995 MesGLiplimlof AmejdntenLEe. quest:

The various requested changes to Table 3.2-A are identified below in the order they appear in the TS by trip fimetion title. Amplifying information about each change is provided as necessary.

1. Reactor Water Level - Low-Low-Low, ,

For the valve group 7 isolation signal, the Minimum Operable Channels Per Trip System is being changed from "2" to "4" with note (n) added. There are four channels but only one trip system for this logic arrangement. This change will ensure that the column heading of Minimum Operable Channels Per Trip System can be applied consistently, except where a note indicates otherwise.

\ h:

t.,

RTS-383 Attachment I to .

NG-95-0934 Page 2 of 3 b

2. Drywell Pressure - liigh. ,

a) For the valve group 3 isolation signal, the "and *" is being deleted. Note

• on pg.

3.2-7 was inadvertently and incorrectly added to this item by Amendment No.193. ,

b) For the valve groups 4 and 9 isolation signal, valve group 9 is being made a separate '-

line item, since the logics for groups 4 and 9 are different. There is only "1" channel per trip system by design for group 9. Also, note (f) is being moved to the Minimum' Operable Channels Per Trip System column. This is more appropriate, since R L

provides additional logic and trip system information. -

3. Main Steam Line Tunnel Temperature - liigh.

The Minimum Operable Channels Per Trip System is being changed from "2/line" to "4" .,

with note (o) added. There are 16 temperature sensors (instrument channels) total, with 8  ;

per trip system. There are 4 temperature sensors providing input to a single logic channel ,

along each MSL, which provide redundant spatial coverage for the main steam tunnel ,

area. The change provides the same coverage as the current TS and provides clarification  ;

as to the minimum required temperature sensors (instrument channels) per MSL~.

I

4. Standby Liquid Control (SBLC) System Initiation.

' The Minimum Operable Channels Per Trip System is being changed from "1" to "l/SBLC System." There is only I channel and 1 trip system for this isolation signal. This is consistent with the wording for similar logics for the RCIC and IIPCI Systems.

5. Notes (n) and (o) are being added as described above.

6. The Bases are being revised to provide additional information as appropriate for the above ' -

logic arrangements. Additionally, clarification is being made regarding Allowed Outage Times for the MSL Flow - liigh and MSL Tunnel Temperature - liigh isolations.

his for oroposed No Significant 11azards ConsideratioJL 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 consequences of an accident previously evaluated; (2) create the possibility of a new or difTerent kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a orgin of safety.

l l

I i

i

"RTS-282 - Attachment I to NG-95-o934 Page 3 of 3 After reviewing this proposed amendment, we have concluded:

1)- The proposed changes to TS Table 3.2-A will not significantly increase the probability or consequences of an accident previously evaluated. The changes do not alter the physical design or operation of the plant and serve to describe more accurately and clearly the actual logic configurations. The existing logic designs are in conformance with the Architect / Engineer's design documentation since plant startup. These changes will assure that the information in the tables is clearer and more consistent with the column headings of the table. The proposed changes do not affect assumptions contained in the plant safety analysis.

The Bases changes provide additional information about the logic arrangements as appropriate to idedtify unique or different logic configurations. Changed to the hilowed Outage Time (AOT) descriptions for the MSL Flow -Iligh and MSL Tunnel Temperature - Ifigh provide clarification regarding application of the AOT to these logic arrangements, since multiple ,

instrument channels provide input into multiple logic channels. This application conforms to the single failure criterion of the design basis (NEDO-lD139, Compliance of Protection Systems to Industry Criteria: General Electric BWR Nulcar Steam Supply System, dated June 1970) and to the analytical basis for the TS (NEDC-31677P-A, Technical Specification improvement Analysis for BWR Isolation Actuation Instrumentation, dated July 1990).

2) The proposed changes to Table 3.2-A will not introduce a new or different kind of accident from any accident previously evaluated. The changes do not alter the physical design of the plant or affect any modes of operation. The proposed changes serve to clarify the existing information to better assure that the trip instrumentation will be maintained as assumed in the accident analyses contained in the Updated Final Safety Analysis Report.

3) The proposed changes do not involve a significant reduction in a margin of safety.

Clarification of the logic arrangements in both Table 3.2-A and the TS Bases and how the AOT is applied does not affect the ability of the isolation logic to perform its intended fimetion. No physical changes to the plant are being made as part of this amendment.

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

lagdPublic Donument Room L_qqatiom Cedar Rapids Public Library,500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licemer Jack Newman, Kathleen H. Shea; Morgan, Lewis & Bockius, 1800 M Street NW, Washington, D.C. 20036-5869 i

MIOWad 3CCI'Ain[iCmplalCENISCY8] dOf i

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'RTS-283 Attachment 2 to NG-95-0934 ,

Page1of 1

- PROPOSED CHANGE [RTS-282] TO THE DUANE ARNOLD ENERGY CENTER ,

TECHNICAL SPECIFICATIONS - ,

The holders oflicense DPR-49 for the Duane Arnold Energy Center propose to amend Appendix A (Technical Specifications) to said license by deleting certain current pages and replacing them

- with the attached, new pages. The List of Affected Pages is given below.

LIST OF AFFECTED PAGES  :

3.2-3 j 3.2-4*

- - 3.2-7 * '

I  ?

3.2-44 4 9

• Pages common to RTS-267, submitted by NG-94-3575, dated November 10,1994.

fiUMMARY OF CHANGES: 9 The following list of proposed changes is in the order that the changes appear in the Technical Specifications (TS), ,

Eags p_escriotion of Changes -

3.2-3 Revise the " Reactor Water Level - Low-Low-Low" trip function Minimum i

Operable Channels Per Trip System for the valve group 7 isolation to "4" with note (n). Revise the "Drywell Pressure - High" trip function to delete "and *"

from the Applicable Operating Modes for valve group 3, separate the valve ,

groups 4 and 9 isolation signals, change the group 9 requirement to a Minimum Operable Channel Per Trip System 00 "1" and move note (f) to this i column. These changes make the TS wording more consistent with plant design. Revise the " Main Steam Line Tunnel Temperature - High" trip function Minimum Operable Channels Per Trip System to "4" with note (o).

3.2-4 Revise the " Standby Liquid Control System Initiation" trip function Minimum Operable Channels Per Trip System to "l/SBLC System."  ;

3.2-7 Add notes (n) and (o) which correspond to the items discussed above.

{

3.2-44 Revise the Bases to provide additional information as appropriate to more clearly describe the logic anangements for the above items. Clarification is also being made regarding Allowed Outage Times (AOTs) for two instrument trip functions.

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