NG-97-0846, Application for Amend to License DPR-49,consisting of Request for TS Change RTS-293 Which Would Revise Definitions of LSSS & Instrument/Channel Calibration to Ref New Program Being Added to TS for Control of Instrument Setpoints

Application for Amend to License DPR-49,consisting of Request for TS Change RTS-293 Which Would Revise Definitions of LSSS & Instrument/Channel Calibration to Ref New Program Being Added to TS for Control of Instrument Setpoints

ML20141D332
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
ML20141D337	List: ML20141D362 NG-97-0846, Application for Amend to License DPR-49,consisting of Request for TS Change RTS-293 Which Would Revise Definitions of LSSS & Instrument/Channel Calibration to Ref New Program Being Added to TS for Control of Instrument Setpoints
References
NG-97-0846, NG-97-846, NUDOCS 9705200070
Download: ML20141D332 (8)

Text

IES Utihties Inc.

200 Fest Street S2.

y *I PO Box 351 e ' Cedar Rapids. IA 52406-0351 Telephone 319 398 8162

- Fax 319 338 6192 UTlLITIES ,,,,,,,,,,,,,,,,,

Vice Presrdent, Nuclear May 9,1997 NG.97-0846 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-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-293): Instrument Setpoint Control Program.

Reference:

1) G. Kelly (NRC) to IES Utilities Inc.," Summary of March 20,1997 Meeting on Technical Specification Setpoints and the Practice of Not  :

Entering Limiting Conditions for Operation (LCO) Action Statements During Certain Surveillances," April 3,1997.

2) J. Franz (IES) to A. B. Beach (NRC),"lES Commitments Regarding Compliance with Technica: Specification Instrument Settings," NG 1 0395, dated February 25,1997 I File: A-ll 7 1

Dear Sir (s):

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 TS amendment would revise the definitions of Limiting Safety System Setting (LSSS) and Instrument / Channel Calibration to reference a new program being added to the TS (Section 6.13) for the control ofinstrument setpoints. This new program description is being added to include within the TS, our existing programmatic controls

$llipsygaj h '

9705200070 970509 PDR ADOCK 05000331 An tes industnes cwmnr P PDR -

NG-97-0846

, May 9,199'7

, . Page 2 of 3 for the establishment and control of the instrument setpoints used in plant procedures that implement TS surveillance requirements for instrument / channel calibrations, as discussed in the referenced meeting with the Staff (Reference 1). This TS amendment request is a follow-up to our commitment letter of February 25,1997 (Reference 2). In particular, our commitment to use a setpoint methodology that conforms to the guidelines contained in Regulatory Guide 1.105, Rev. 2. The TS Instrument Setpoint Control Program establishes the criteria under which the Limiting Trip Point for Operation,"as-found" and "as-left" tolerances in the plant surveillance procedures are determined and revised. The LSSS will continue to be controlled within the TS.

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 iIazards Consideration,is being forwarded to our appointed state official pursuant to 10 CFR Section 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.

IES UTILITIES INC.

By +at/ /Yart7'# TW Jc/n F. Franz Vice President, Nuclear State ofIowa r (County) of Linn Signed and swom to before me on this O'# day of / NAM ,1997,

./

by [.dA4/ [//la I/D yM , f r /, hj g f / ,

l

({d ,7]'f i, e M f f, "t}fp Notary Public in and for the State p[ Iowa Jl-AQ~Q)

Commission Expires

4 i NG.-97-084,6 May 9,1997 ,

, Page 3 of 3 l

1 .. .

i Attachments: 1) . Evaluation of Change Pursuant to 10 CFR Section 50.92 l

2) Proposed Change RTS-293 to the DAEC Technical l

. Specifications

3) Safety Assessment >

j 4) Environmental Consideration  ;

i JFF/RAB/rab  :

N:\lowa\ Licensing \ngi974)s46 cc: R. Browning i L. Root -

- G. Kelly (NRC-NRR) l A. B. Beach (Region III) ,

P. Baig (State ofIowa)

~

NRC Resident Office Docu

! (

1

?

d 7

e B

k a

a e

, I a

i 5

RTS 293 , Attachment 1 to NG-97-0846

, . Page1of5 EVALUATION OF CHANGE PURSUANT TO 10 CFR SECTION 50.92 11ackgroundL In response to Staff questions regarding the control ofinstrument setpoints at the Duane Arnold Energy Center (DAEC), we provided a description of our existing process for the establishment and control of setpoints for instruments contained in the Technical Specifications (TS) (Ref. letter NG-97-0395, dated February 25,1997). That letter also included commitments that we made regarding the "as-found" and "as-left" settings of the TS-required instruments. The setpoint control process, and these additional commitments, were also the subject of a meeting with the Staff on March 20, 1997. As a follow-up to the meeting, we agreed to submit a license change request that incorporates the setpoint control process and subsequent commitments. The enclosed TS change request is intended to fulfill that agreement.

As discussed in our February 25,1997 letter, to fully understand the existing DAEC controls that ensure that our instrument setpoints are in compliance with our design and licensing basis, it is important to understand the terminology used to describe the different instrument settings and that their relationship to each other is understood. The attached, annotated diagram from Draft P.ephiory Guide DG 1045 (proposed Rev 3 to RG 1.105) illustrates and explains this nomenclature. The DAEC TS contain the definition of Limiting Safety System Setting (LSSS).

TS Definition 1.0.2 states:

The limiting safety system settings are settings on instrumentation which initiate the automatic protective action at a level such that the safety limits will not be exceeded. These settings take into consideration the instrumentation tolerances and the instruments are required to be periodically calibrated as specified in these Technical Specifications. The limiting safety system setting plus the tolerance of the instrument as given in the system design control document gives the limiting trip point for operation. This additional margin has been established so that with proper operation of the instrumentation the safety limits will never be exceeded. The inequality sign which may be given merely signifies the preferred direction of operational trip setting.

The LSSS, defined above,(also referred to in the TS as the Trip 1.evel Setting), is analogous to the Trip Setpoint in the attached figure. The LSSS is also referred to in the industry as the Nominal Trip Setpoint (NTSP). Definition 1.0.2 above also defines the Limiting Trip Point for Operation (LTPO), which is analogous to the Allowable Value (AV) in the attached figure. The LTPO( AV } is contained in the system design control documents and the LSSS {NTSP) is contained in the TS. It is the LTPO{ AV} that defines instrument / channel OPERABILITY.

The LTPO( AV) and the LSSS {NTSP) have been established by the DAEC Instrument Setpoint Control Program which is based on the General Electric (GE) Instrument Setpoint Methodology; NEDC-31336," General Electric Instrumentation Setpoint Methodology." The NRC approval of NEDC-31336 is documented in a Revision to the Safety Evaluation Report transmitted by letter

RTS-293 , Attachnent I to NG-97-0846

, . Page 2 of 5 from B. Boger (NRC) to R. Pinelli (BWROG) dated November 6,1995. The GE Instrumentation Setpoint Methodology conforms to the guidelines contained in Regulatory Guide 1.105, Rev. 2.

The setpoint calculations use the uncertainties associated with the DAEC instrumentation and actual DAEC physical data and operating practices to ensure the validity of the resulting LTPO{ AV} and LSSS{NTSP}. The methodology used to derive the LTPO{AV} and LSSS {NTSP) is based on combining the uncertainties of the associated channels. The resulting LTPO {AV} and LSSS {NTSP} have been established from each design or safety analysis limit by accounting for instrument accuracy, calibration and drift uncertainties, as well as process measurement accuracy and primary element accuracy using the GE Instrument Setpoint Methodology. The use of this methodology for establishing LTPO { AV} and LSSS {NTSP) ensures design or safety analysis limits are not exceeded in the event of transients or accidents.

The establishment of this TS program for the control ofinstrument setpoints will remain in place until our conversion package for the DAEC Improved Technical Speci6 cations (ITS), which was submitted to the NRC on October 30,1996 (Ref. NG-96-2322), is approved and implemented.

IES Utilities Inc.. Docket No. 50-331.

Duane Arnold Energy Center. I inn County. Iowa Date of Amendment Reauest: May 9,1997 Descrintion of Amendment Reauest-1 The proposed TS amendment would revise the deHnitions of Limiting Safety System Setting (LSSS) l and instrument / Channel Calibration to reference a new program being added to the TS (Section l 6.13) Ibr the control ofinstrument setpoints. This new program description is being added to include j within the TS, our existing programmatic controls for the establishment and control of the j instrument setpoints used in plant procedures that implement TS surveillance requirements for instrument / channel calibrations. This TS amendment request is the fbilow-up to our commitment letter of February 25,1997, as discussed in our meeting with the Staff on March 20,1997. In I particular, our commitment to use a setpoint methodology that conforms to the guidelines contained in Regulatory Guide 1.105, Rev. 2. The TS Instrument Setpoint Control Program establishes the criteria under w hich the LTPO,"as-found" and "as-left" tolerances in the plant surveillance j procedures are determined and revised. The LSSS will continue to be controlled within the TS.

l 1

Basis for Proposed No Significant lla7ards Consideration:

The Commission has provided standards (10 CFR Section 50.92(c)) for determining whether a signincant hazards consideration exists. A proposed amendment to an operating license for a facility involves no signiGcant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a signincant increase in the probability or consequences J

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 signincant reduction in a margin of safety.

Afler reviewing this proposed amendment, we have concluded:

l l

l

_ _ _ _ - ._____--___-_______-__________i

I RTS-293 Attachment I to NG-97-0846 Page 3 of 5 l) The proposed TS amendment will not significantly increase the probability or consequences of any previously-evaluated accidents.

The proposed changes will not result in any direct hardware changes. The change only adds a program to the TS for the establishment and control ofinstrumentation setpoints that is consistent with current DAEC practice. The Instrument Setpoint Control Program is based upon a methodology for the calculation ofinstrument setpoints that conforms to the guidelines of Regulatory Guide 1.105, Rev.2. The methodology ensures that adequate margin exists between the normal plant operating conditions and actual instrument setpoints to preclude spurious plant / equipment trips. As a result, the proposed program establishes the criteria for changes in instmment setpoints to ensure that such changes will not result in unnecessary pise transients.

Consequently, the probability of any previously-analyzed event is not increased by this change.

The role of the instrumentation and their associated setpoints is in detecting and mitigating plant events and thereby limiting the consequences of any previously-analyzed event. The LSSS{NTSP} and corresponding LTPO{ AV) have been developed in accordance with the DAEC Instrument Setpoint Control Program criteria to ensure that the instrumentation remains capchle of mitigating events as described in the safety analyses and that the results and consequences described in the safety enalyses remain bounding. Therefore, these changes do not involve a significant increas: in the consequences of an accident previously evaluated.

2) The proposed changes will not create a new or different kind of accident from those previously evaluated.

The proposed changes will not change the method or manner of plant operation, in particular, calibration of TS-required instrumentation. The use of the proposed TS program for the control of changes to instrument setpoints does not impact safe operation of the DAEC in that the design and safety analysis limits will continue to be satisfied. The proposed TS program involves no system additions or physical modifications, other than setpoint changes. Any setpoint changes ,

must conform to the criteria set forth in the TS Instrument Setpoint Control Program. The instrument setpoints are developed using a methodology that conforms to the guidelines contained in Regulatory Guide 1.105, Rev. 2 to ensure the affected instrumentation remains capable of mitigating accidents and transients. Since operational methods remain unchanged and the instrument setpoints have been evaluated to maintain the plant within existing design basis criteria, no new or different type of accident is created.

3) The proposed change will not result in a significant reduction in any margin of safety.

The proposed TS program establishes the DAEC Instrument Setpoint Control Program, which is based upon an NRC-approved methodology. The program establishes the controls and criteria used to establish and revise instrument setpoints. The setpoint calculations use the uncertainties associated with the DAEC instrumentation and actual DAEC physical data and operating practices to ensure the validity of the resulting LTPO{ AV} and LSSS{NTSP). The methodology is based upon combining the uncertainties of the associated channels and takes into account calibration accuracy, instrument uncertainties, drift, etc. The use of this methodology

_ _ _ . . . . _ _ . _ - . . _ _ _ , . . - . _ . . _ . . _ , _ _ _ . . . . - _ _ .. - _. . . _ . ~...-_

l RTS-293 .. Attachment I to

. . NG-97-0846

, . Page 4 cf 5 N

for establishing these setpoints ensures that design and/or safety analysis limits are not exceeded

, in any transient or accident. Therefore, the proposed change does not involve a significant j reduction in the margin of safety.

h Based upon the above, we have' determined that the proposed amendment will not involve a f sigmficant hazards consideration.

.t

. Local Public Document Room Location: Cedar Rapids Public Library,500 First Street SE, Cedar Rapids, Iowa 52401 4

1

] Attornev for Licensee: Jack Newman, Al Gutterman; Morgan, Lewis & Bockius,1800 M Street ,

NW, Washington, D.C. 20036-5869  ;

3 1

4

s. k i'

4 L

F t

l J

I i

2 i

l 1

l l

'l l

Attachment I to NG-97-0846.

Page 5 of 5 DAEC Nonencloture So f e t y L. nit Sof ety Lim.t Anotytic Limit Anotytic Lin t 1

1

, C s

i A

I Allowoble Volve Limiting Tr p Point '

f for Oper a tion g STP As-F ound I Tolerance E Tr.p Se tpo.nt LimitinD Surety Systen Set t.ng. Tr.p Level Se t ting, Non.not Te p D Se t point Narnal 4

l A Allowanc e Descr. bed .n Porograph 4.31

! B Attowonce Descr. bed in Pcrogroph 4.3 2

! C Regen Vhere Channet May Be Dettored inoperable

l. . . D. Piont Operu t:ng Morg n >

l E Reg.on of Col. oration Toterance (Acceptabte As-Lef t Cons.t.on) Desce. bed in Porograph 431

[ Figure 1 Sa f e t y-Relc.ted Se tpoint j Relationships j (Reproduced from I S A- S 6 7.0 4 -199 4 )  :

d i

l 4

e 4

I 1

i t

- . , - . . . . - - - . . . . . . . - - - - - - - ~ - - - - - - - . - - . ~ . - - - - - - , , , - ~ - - - - - .