View source for NG-92-5179, Request for TS Change RTS-249 to License DPR-49,adding TS 3.0 & 4.0,corresponding Bases & Modifying Existing Specs Consistent W/New Requirements Denoting Applicability of LCOs & Srs,Per STS & GLs 87-09 & 89-14

{{Adams
| number = ML20127A334
| issue date = 12/31/1992
| title = Request for TS Change RTS-249 to License DPR-49,adding TS 3.0 & 4.0,corresponding Bases & Modifying Existing Specs Consistent W/New Requirements Denoting Applicability of LCOs & Srs,Per STS & GLs 87-09 & 89-14
| author name = Franz J
| author affiliation = IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
| addressee name = Murley T
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000331
| license number = 
| contact person = 
| document report number = GL-87-09, GL-87-9, GL-89-14, NG-92-5179, NUDOCS 9301110257
| package number = ML20127A339
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 20
| project = 
| stage = Request
}}

=Text=
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Iowa Electric Light and Power Company JOHN l'. FR ANZ. JR.                        NG-92-5179 su e msmv. aux.                      December 31, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation RU.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C.               20555

==Subject:==
Duane Arnold Energy Center Docket No:             50-331 Op License No: -DPR-49 Request for Technical Specification Change (RTS-249):. Addition of Technical Specifications 3.0 and 4.0 and Bases

==Reference:==
Letter, J. Franz to T. Murley; Request for Technical Specification Change (RTS-197); Dec. 4, 1992; NG-92-5326 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) hereby requests revision of the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).
                                                                ~
The proposed change adds Technical Specifications 3.0.and 4.0, corresponding Bases, and modifies existing specifications consistent with these new requirements denoting the applicability                                      ,
j of Limiting' Conditions for Operations and Surveillance                                             R Requirements. The proposed change is consistent with the requirements denoted in the Standard Technical Specifications and Generic Letters 87-09 and 89-14.
The application has been reviewed by the DAEC Operations Committee and the DAEC Safety Committee.' Pursuant to-the                                                .
requirements of 10'CFR 50.91, a-copy of this submittal, including 1                                 1 the analysis which concludes that there are no significant hazards considerations, is being forwarded to our appointed state official.
We ask that your approval of this. request be subsequent to your                                      i approval.of our referenced RTS-197. Should you have any-questions regarding this matter, please contact this office.
9301110257 921231 PDR       ADOCK 05000331                                                                         (}
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* Cettar Itaysts, Iowa 524cg e 339:3g344;y ,j
                                                                                                            }t'

                                                                                                      'i e- la :
Dr. Thomas E. Murley.
:NG-92-5179'
                            ~
: December 31, 1992
        .Page 3 This-letter is trueLand accurate to the-boat of my knowledge and                               .
belief.
IOWA ELECTRIC LIGHT'AND.-POWER COMPANY-                   .
By           O                      I John F. Franz        v Vice President, Nuclear
* State of Iowa (County) of Linn-Signed and sworn to before me on this             (-  )     day of        (bf fD Xf  ,--
1992, by. ,    DIl VI d      ,
___                  [!        -
f)OYl 7l{.;f ful 3 l( h_ ' key                             '
Notary Public;         6nd-f~or Lhe Stdte of Iowa
( glMtY        MICHELE O'NEALI
                 %f@'3"[fpys fi-(ll,,0
                                             -Commission Expires JFF/JMD/pjv~
         -Attachments:         1)-    Evaluation of Change Pursuant'to.10 CFR 50.92.
: 2)     Proposed. Change'.RTS-249lto the Duane Arnold Energy Center Technical Specifications-
: 3)    -Environmental Consideration
: 4)     Safety Assessment-:
cc:   M. Davis.
L. . Liu w/o attachments L. Rootw/o attachments
                .R. McGaughy ' w/o_ attachments R. Pulsifer (NRC-NRR)
* A~..Bert Davis'(Region III)
NRC Resident = Of fice S. Brown (StateLof Iowa)
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RTS-249                                                       Attachment 1 to NG-92-5179 Page.1 i                        EVALUATION OF CHANGE PURSUANT TO 10 CFR 50.92
!'                                                                                          -l a
i j          Background In 1991, an independent evaluation of the Technical Specifications
't         (TS) for the Duane Arnold Energy Center (DAEC) was completed. This evaluation was performed as part of the DAEC TS Improvement Program and included comparisons of the DAEC TS with TS from peer plants, the 4 -        Standard Technical Specifications (STS) (NUREG-0123), and the: draft i          Improved Technical Specifications (ITS) INUREG-1433).         The purpose of ji this proposed change-is.to (1) add Technical Specification Sections 3.0 and 4.0 and corresponding Bases and (2) modify existing                       .
;_         specifications consistent with these new requirements denoting the j          applicability of Limiting Conditions for Operations and Surveillance Requirements.
I i          The proposed Technical Specifications 3.0 and 4.0 and corresponding J          Bases were developed from Sections 3.0 and 4.0 of the STS as modified to the DAEC TS and plant specific nomenclature. Deviations to the STS E          or use of plant specific nomenclature are; discussed herein. The addition of these requirements also reflect the_ changes denoted-in         _.
Generic-Letters 87-09 (" Sections 3.0 and 4.0 of the Standard Technical.
Specifications (STS) on the Applicability of Limiting Conditions for l          Operation and Surveillance Requirements" - June :4, '1987) and 89 F          ("Line-item Improvements in Technical Specifications-- Removal of the 3.25 Limit on Extending Surveillance-Intervals"        -
August 21, 1989).
Specifically, the incorporation of Generic Letters 87-09 and 89-14 modify the requirements denoted in the STS (NUREG-0123,_ General' Electric -_STS (BWR/5)).and are discussed herein. DAEC previously incorporated Generic Letter 89-14 changes _as they applied to_DA.EC TS in Amendment No. 173 to our operating license.t The_ incorporation of Generic Letter 89-14'in this submittal refers only to.its effect on the new DAEC TS being added. Also-discussed.herein are various changes.to existing specifications which must be modified asLthe result of the addition of theJnew requirements denoted in-Specifications 3.0 and 4.0.
Iowa Electric Light and Power Company, Docket No.         50-331-Duane Arnold Energy Center, Linn County, _ Iowa Date of Amendment Request:      ' December 31, 1992
  .-                                                                                       4

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           ~RTS-249                                                     Attachment 3 to NG-92-5179 ENVIRONMENTAL CONSIDERATION-10 CFR 51.22(c)(9) identifies certain licensing and regulatory' actions which are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating licenso 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 effluent that.may be. released offsite; and (3)_
result in an increase in individual or cumulative occupational radiation exposure. Iowa Electric Light and Power has reviewed this        ,
request and determined that the proposed' amendment meets the eligibility criteria for categorical exclusion set forth in 10: CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), ao environmental impact              '
statement or environmental assessment need be prepared,in connection with the issuance of the amendment. The basis for this determirition L           follows:
Basis l
The change meets the eligibility critoria for categorical exclusion set torth in 10 CFR 51.22(c)(9) for the following reasons:
j           1. As demonstrated in Attachment'1, the proposed amendment does not l                 involve a significant hazards consideration.
1
: 2. The proposed change to incorporate the requirements of Standard          ,
Technical Specifications (STS) 3.0.and 4.0, corresponding STS 3.0 and 4.0 Bases, and to modify existing specifications consistent with the Specifications 3.0_and 4.0 have no effect on the types or amounts of effluent released offsite.
: 3. The. proposed _ change to incorporate the' requirements of Standard' Technical Specifications (STS)-3.0-and 4.0, corresponding STS 3.0 and 4.0 Bases, and to modify existing specifications < consistent with the Specifications 3.0 and 4.0 have no effect on individual or cumulative occupational radiation exposure.
L l
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RTS-249                                                         

==Attachment:==
4 to NG-92-5179-Page 1                           ,
S_AFETY ASSESSMENT-Introduction By {{letter dated|date=December 31, 1992|text=letter dated December 31, 1992}}, Iowa Electric Light and Power _-
Company-(IELP) submitted a_ request _for revision of the Technical Specifications, Appendix A to Operating License No. DPR-40, for the
:        Duane Arnold -Energy Center (DAEC).            The proposed change would DAEC- Technical incorporate       en ' Applicability     section     into Specifications (DAEC TS)           similar   to-  that     found-         in Standard Technical-     Specifications        (STS)     and       Improved           Technical Specifications (ITS).
Assessment As part- of       the DAEC TS      Improvement Program,_ an ' independent -
evaluation of the DAEC TS was performed. This included comparisons of the DAEC TS w! .h Technical- Specifications from peer plants, STS, and draft ITS.
IELP determined from the evaluation that the addit. ion of - an
 ,          -Applicability section, based upon STS 3.0/4.0, should be-added'to DAEC TS. This new section would be similar-to those found in-STS and ITS and would ' reflect ' current DAEC operating philosophy that is already enforced'by plant procedures.           The_ statements included in                     =;
the Applicability section are administrative in nature and do'not 4
reflect any changes. to physical - plant equipment, - operation or surveillance practices.
The deviations from STS wording in .: .0/4.0 are justifiable. as 'they are either based upon later NRC guidance (e.g. , GL 87-09, GL 89'14                             '
l            or ITS), previously-approved changes on other dockets or are necessary for        internal    consistency     with     existing          DAEC   TS
!            nomenclature and format.
6 The exceptions which are taken within individual' DAEC. TS to the provisions of various 3.0/4.0 specifications are deemed to be acceptable as-they are similar to exceptions taken'in' standard-format TS for plants similar-to the DAEC..
Based on 'the above evaluation, we conclude that the proposed-Technical Specification changes are acceptabic.
I k                                          __          .       -  __      . _ __ __         . _  . . _ _

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       ,~       s
.                     RTS-249                                                                              Attachment 1 to       )
                                                                                                        'NG-92-5179 Page-2 i
Description of Amendment Request:                                                                          l The proposed change adds Technical Specification Sections 3.0 and 4.0 and corresponding 3.0 and 4.0 Bases consistent with the requirements denoted in the STS and Generic Letters 87-09 and 89-14. The proposed change also modifies existing specifications consistent with the addition of these new requirements to the DAEC TS. The addition of Specifications 3.0.A, 3.0.B, 3.0.C, and 3.0.D establish the general requirements applicable to Limiting Conditions for Operation (LCO).
The addition of Specifications 4.0.A, 4.0.B, 4.0.C, and 4.0.D establish the general requirements applicable to Surveillance Requirements.
Specification 3.0.A and Bases The proposed Specification 3.0.A, consistent with the STS Specification 3.0.1, establishes the applicability within each j                     individual specification as the requirement for when conformance to the LCO is required for safe operation of the facility. The action                                        .
requirements establish those remedial measures that must be taken
!                     within specified time limits when the requirements of an LCO are not 1
met.
~
The proposed Specification 3.0.A and Bases differs from that of STS Specification 3.0.1 and Bases by the following:                                                           ,
;                                           The reference to " Applicability statement" was revised due to the fact that the DAEC TS are of custom format and as such do
!                                  not have a specific " Applicability" section for each Individual
;                                  LCO as. typically denoted in the standard format Technical l                                  Specifications. For the DAEC TS, the applicability of each
!                                   individual LCO.is denoted within its~. individual specification.
l                                            The references to " OPERATIONAL CONDITIONS or other conditions" were modified to. reflect that the.DAEC TS-are of custom format and as such do not use modes of operation to define l
LCO applicability as typically denoted in the standard format
                                   ' Technical Specifications.               For the DAEC TS,_the. applicable condition is denoted within its individual specification.
l These proposed changes do_not change or modify the intent of the requirements denoted in the STS. These_ changes only clarify specific differences in the format that exist between the DAEC TS-(custom format) and the STS (standard format).
i
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            ,      e
.                        RTS-249                                                                              Attachment 1- to
.                                                                                                             NG-92-5179                 '
Page 3-Specification 3.0.B and Bases The proposed Specification 3.0 B and Bases, consistent with the STS Specification 3.0.2 and Bases, establishes that noncompliance withta specification exists when the requirements of the-LCO.are not met and the associated action requirements have not.been implemented within 4                        the specified time interval. The purpose of this specification is to clarify that (1) implementation of the action requirements within the specified time interval constitutes compliance with a specification                                             ,
and (2) completion of the remedial measures of the action requirements is not required when compliance with an LCO is restored within the time interval specified in the associated action requirements.
Specification 3.0.C and Bases The proposed Specification 3.0.C and Bases, consistent with the STS
                        ' Specification 3.0.3 and Bases, establishes the shutdown action requirements that must be implemented when an LCO is not met-and the l                        condition is not specifically addressed by the associated action requirements. The purpose of this specification is to delineate the time limits for placing the unit in a safe shutdown condition when
!                        plant operation cannot be maintained within the limits for safe
[
operation defined by the LCO and its action requirements.
The proposed Specification 3.0.C and Bases dif fers from that of STS Specification 3.0.3 and Bases by the following:
l                                                               The STS phrase "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, ... " would be revised to "When an LCO is not met and the associated ACTIONS are not met or an associated ACTION is not provided, ..." This provides clarification that-the conditions which must exist for the requirements of Specification 3.0.C to become applicable are when the associated ACTIONS are not met-or when no associated ACTION is denoted.                  This proposed clarification is consistent with the clarifications provided in the -Improved Technical Specifications.
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Attachment 1 to b
RTS-249                                                                             l F                                                                         NG-92-5179              ;
Page 4                 j i                          The STS phrase "Where corrective measures are completed that           I permit operation under the ACTION requirements,-the ACTION may be taken in accordance with the_specified time limits as measured
'                    from the time of failure to meet the Limiting Condition for Operation." would be revised to "Where corrective measures are               ;
completed that pecmit operation in accordance with'the LCO or
[                    ACTIONS, completion of the actions required by Specification
,                    3.0.C is not required." This provides clarification and consistency with the revisions to Specification 3.0.C denoted above. The addition of "... LCO or ACTION..." providas clarification.that an " associated ACTION" may not be denoted.
This proposed clarification is consistent with the clarifications
!                    provided in the Improved Technical Specifications.
The STS phrase " Exceptions to these requirements are stated 4
in the individual Specifications." would be revised to
                     " Exceptions to this Specification are stated in the individual Specificaticns." This provides clarification that the exceptions
 ;                   were to the requirements denoted in Specification 3.0.C.       This ensures the appropriate' understanding of the use of Specification 3.0.C and clarifles what the statement " Specification 3.0.C is not applicable." means when stated in an ACTION. This proposed
:                    clarification is consistent with the clarifications provided in l                    the Improved Technical Specifications.
* The references to " OPERATIONAL CONDITIONS or other
{                    conditions" were modified to reflect that the DAEC TS are of custom format and as such do not use modes of operation to define LCO applicability as typically denoted in the standard format Technical Specifications. For the DAEC TS, the applicable condition is denoted within its individual specification.
The STS words " POWER OPERATION" would be revised to " REACTOR POWER OPERATION" for consistency with DAEC plant specific nomenclature.
:             These proposed changes do not change or modify-the intent of the requirements denoted in the STS. These changes only (1) clarify specific differences in the format that exist'between the DAEC-TS (custom format) _and the STS-(standard format), (2) provide clarity in the specification consistent with the Improved Technical i             Specifications, or (3) provide consistency with DAEC plant specific nomenclature.
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  , __--_.                         __       - .-. - - - . -              _ _ - - _ _ -               _ _ . - _ -     .~
1 RTS-249                                                                   Attachment 1 to                    ,
NG-92-5179 Page 5                              j Specification 3.0.D and Bases The proposed Specification 3.0.D is consistent with the requirements denoted in the STS Specification 3.0.4 and is modified, in part, by                                          ,
the more recent guidelines established in Generic Letter 07-09. The                                          ,
proposed Specification 3.0.D establishes limitations on a change in operational conditions when an LCO is not mot. It precludes placing the facility in a higher condition of operation when the requirements for an LCO are not met and continued noncompliance to these conditions would result in a shutdown to comply with the action requirements if-a change in conditions were permitted.           The purpose of this specification is to ensure that facility operation is not initiated or that higher conditions of operation are not entered when corrective action is being taken to obtain compliance with a specification by restoring equipment to OPERABLE status or parameters to specified limits.
The modification of the STS Specification 3.0.4, consistent with
!            Generic Letter 87-09, ensures consistency with operational requirements for plant systems. The STS Specification 3.0.4 currently                                        ,
denott          his inconsistency by irohibiting plant startup with-
:            Inoper          e equipment though continued power operation would be permits           with the same equipment in an inoperable condition. The NRC staff concluded in Generic Letter 87-09 that STS Specification _
3.0.4 unduly restricted facility operation when conformance to-the Action Requirements provided an acceptable level of safety for continued operation. For an LCO that has Action _ Requirements permittin_g continueo operation for an unlimited period of-time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those. Action Requirements.                                  The      '
restriction on a change in operational modes or other specified                                       _
conditions should apply only where the Action Requirements establish a-specified interval in which the LCO must be met or a shutdown of the facility would be required. The NRC staff. concluded that as a consequence of the modifications by Generic Letter 87-09=to                                                  .
Specification 3.0.4, exceptions may be made for individual i            specifications if a mode change would be precluded by Specification 3.0.4.        Specifically, some specifications do not satisfy the provisions under which mode changes are permitted by Specification-3.0.4. _The NRC staff position was_that the. modifications by Generic Letter 87-09 to Specification 3.0.4._should:not result _in more' restrictive requirements for individual specifications.
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RTS-249                                                                         Attachment 1 to NG-92-5179 Page 6 The proposed Specification 3.0.D and Bases differs from that of the modified STS Specification 3.0.4 and Bases by the following:
The STS phrase " Entry into an OPERATIONAL CONDITION or other specified condition shall not be made when the conditions for the-Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval.              Entry into an OPERATIONAL CONDITION or other specified condition may be made in accordance with the ACTION
,                                                requirements when conformance to them_ permits continued-operation of the facility for an unlimited period of time." would be revised to "When an LCO is not met, entry into a specified condition shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition for an unlimited period of time." This provides clarification and is consistent with Generic Letter 87-09 guidance. This change also provides consistency for use of proposed Specification 3.0.D, since it is the permitting of continued operation for an unlimited period of time, not the requirement to shutdown, that determines the applicability of proposed Specification 3.0.D. This proposed clarification is also                                                             '
consistent with the clarifications provided in the Improved Technical Specifications.
The references to " OPERATIONAL CONDITIONS or other conditions" were modified to reflect that the DAEC TS are of                                                         ,
custom format and as such do not use modes of operation to define LCO_ applicability as typically denoted in the standard _ format Technical Specifications.                For the DAEC TS, the applicable; condition-is denoted within its individual specification.
The STS phrase "Ercoptions to these requirements are stated in the individual Specifications." would be revised to
                                                  " Exceptions to this Specification are stated _in the individual Specifications." This provides clarification that the exceptions were to the requirements denoted in-Specification 3.0.D.                                     This ensures the appropriate understanding of the use of; Specification 3.0.D and clarifies what the seatement " Specification 3.0.D is not applicable." means when stated in an ACTION. This proposed clarification is consistent with the_ clarifications provided in                                                   '
                                               - the Improved Technical _ Specifications.
I.                                These proposed changes do not change or modify the intent of the requirements denoted in the STS. These changes only (1) clarify _
specific differences-in the format that exist between the DAEC TS (custom format) and the STS (standard format), or (2) provide. clarity in the specification-consistent with Generic Letter 87-09 and the-1                                  Improved Technical Specifications.
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RTS-249                                                    Attachment 1 to NG-92-5179 Page 7 Specification 4.0.A and Bases The proposed Specification 4.0.A, consistent with the STS Specification 4.0.1, establishes the requirement that surveillances-must be performed during the operational conditions for which the requirements of the LCO apply unless otherwise stated in-an' individual Surveillance Requirement. The purpose of this specification is to ensure that surveillances are performed to verify _the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a specified condition for which the associated LCO are applicable.
The proposed Specification 4.0.A and Bases differs from that of STS Specification 4.0.1 and Bases by the following:
The references to " OPERATIONAL CONDITIONS or other conditions" were modified to reflect that the DAEC TS are of custom format and as such do not use modes of operation to define LCO applicability as typically denoted in the standard format          ;
Technical Specifications. For the DAEC TS, the applicable-condition is denoted within its individual. specification.
The STS phrase "... In an individual' Surveillance Requirement" was deleted for clarity.; The custom format that exists in the DAEC TS could allow for conditional surveillances to be described in the specific LCO. Therefore, the proposed clarification "...unless otherwise stated." would apply.to both Surveillance Requirements and LCO's.
These proposed changes do not change or modify the intent of_the requirements denoted in the STS.      These changes only clarify specific differences'in the format-that exist between the DAEC TS (custom             '
format) and the STS (standard format).
Specification 4.'O.B and Bases The proposed Specification 4.0.8_is consistent with the requirements denoted.in the STS 4.0.2_and is modified-by_the more recent guidelines established in Generic Letter 89-14. :The_ proposed Specification'4.0.B establishes the-limit for which the specified time interval-for            -;
Surveillance Requirements.may-be extendea._ The-purpose of this specification is to permit an allowable extension of-the normal-surveillance interval to facilitate surveillance' scheduling and-consideration of plant operating conditions that may not be suitable toriconducting the surveillance; e.g., transient conditions or other
       - ongoing surveillance or-maintenance activities.
l l-1:
I

RTS-249                                                                                                     Attachment 1 to             .
NG-92-5179 Page 8                      ;
i The modification of the STS Specification 4.0.2, consistent with Generic Letter 89-14, reflects the removal of the 3.25 limit on extending surveillance intervals. The intent of the 3.25 11mit was                                                        to           1 preclude routine use of the provision for extending a surveillance interval by 25 percent. The NRC staff concluded in Generic Letter 89-                                                                   l 14 that the 3.25 limitation on extending surveillances has not been a                                                                   e practical limit on the use of the 25 percent allowance for extending surveillances that are performed on a refueling outage basis. The NRC staff also concluded that the safety benefit of allowing the use of the 25 percent allowance to extend a surveillance interval would outweigh any benefit derived by limiting three consecutive surveillance intervals to the 3.25 limit. The incorporation or Generic Letter 89-14 will, therefore, remove an unnecessary restriction an extending surveillance requirements and will result in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements. The removal of the 3.25 limit will provide greater flexibility in the use of the provision for extending surveillance intervals, reduce the administrative burden                                                                      ,
associated with its use, and have a positive effect on safety.                                                                          ,
Specification 4.0.C and Bases                                                                                                           ,
The proposed Specification 4.0.C is consistent with the requirements denoted in the STS Specification 4.0.3 and is modified by the more recent guidelines established in Generic Letter 87-09. The proposed Specification 4.0.C establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined inr the provisions of Specification 4.0.B, as a condition that constitutes a failure to meet the OPERABILITY requirements for an LCO.
The modification of the STS Specification 4.0.3, consistent with i
Generic Letter 87-09, ensures the flexibility to perform a missed
(                     surveillance in a reasonable period of time.                                         The STS Specification 4.0.3 currently denotes that failure to perform a surveillance i                     requirement results in the failure to demonstrate that a structure, system, or component is operable and, therefore, would require a plant shutdown.            If an immediate attempt to perform the missed surveillance were made in order to prevent the plant shutdown,--the quality of plant control could be degraded. The incorporation of Generic Letter 87-09 L                     permits up to a 24-hour delay in implementing Action Statement                                                                          .
requirements for the completion of the missed Surveillance Requirement. The NRC staff concluded in Generic Letter 87-09 that it was overly conservative to assume that systems or components were                                                                       ;
inoperable when a Surveillance Requirement had not been performed.
The NRC staff position was that the opposite was in fact the case; in that the vast majority of surveillances demonstrate that systems or components are operable. When a surveillance is missed, it is primarily a question of operability that has not been verified by the                                                                   .
performance of the required surveillance. The NRC staff also                                                                            .
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RTS-249                                                                     Attachment I to NG-92-5179 Page 9 1
concluded that because the allowable outage time limits of some Action Requiremonta did not provide an appropriate timo limit for performing 4                               a missed surveillance before shutdown requirements woro invoked, a 24-                                                  ,
j                               hour time limit would allow a delay of the required actions to permit the performance of the missed surveillance.           The 24-hour time limit 1
was based on considerations of plant conditions, adequate planning, 4
availability of personnel, the timo required to perform the                                                             :
survoillance, and the safety significance of the delay in completion-of the surveillance. The NRC staff concluded that the 24-hour timo limit would balanco the risks associated with an allowance for completing the survoillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with Action RequJrements before the surveillanco can be completed.
The proposed Specification 4.0.C Bases differs from that of STS Specification 4.0.3 Bases by the following:
The proposed Specification 4.0.C Bases is additionally                                                        i modified to clarify what constitutos a reportable event for missed surveillances. The proposed clnrifications denote that "any reports required by 10 CFR 50.73 shall be determined based upon the length of time the surveillanco interval has boon                                                         ,
exceeded, and the corresponding LCO? ACTION time requirements."
This is consistent with the current IELP practice for reportability determinations and is consistent with apacifications recently approved by the NRC on the Limerick Generating Station, Units 1 and 2 docket.
This proposed change does not change _or modify the intent of the requirements denoted in the STS.                                                                                        ;
Specification 4.0.D and Bases The proposed Specification 4.0.D is consistent with the requirements denoted in the STS 4.0.4 and is modified by the more recent guidelines established in Generic Letter 87-09. The proposed Specification 4.0.D establishes the requirement that all applicable surveillances must be met beforo entry into an operational condition _or other condition _of operation specified in the Applicability statement.- The. purpose of                              -
this-specification is to ensure:that system and component operability:
requirements or parameter limits are met before entry into an operational condition or other_speciflod condition for which these systems and components ensure safe operation of the facility.
          ,.-a.   <  r,-,.--.                ,wr .-r,,,,,, , ,,m.m,                    ,.-m.y-,w,-         --,r.,-e,---,-y, e,,,,   , e w - - - - , w--

RTS-249                                                             Attachment 1 to NG-92-5179 Page 10 The modification of the STS 4.0.4, consistent with Generic Letter 87-09, ensures that Specification 4.0.4 does not conflict with                          ;
Specification 4.0.3 to prevent passage through or to operational                     i conditions as required to comply with Action Statement requirements.                 i Conversely, the change ensures that Specification 4.0.3 could not prevent entry into a mode for which a surveillance is-required to demonstrate operability when that surveillance can only be performed in that particular mode. The NRC staff concluded in Generic Letter 87-09 that the potential for a plant upset and challenge to safety systems is heightened if surveillances are performed during a shutdown to comply with Action Requirements and, therefore, it is not the intent of Specification 4.0.4 to prevent passage through or to operational conditions as required to comply with Action Requirements and should not apply when mode changes are imposed by Action                        ,
Requirements.
The proposed Specification 4.0.D and Bases differs from that of STS 4.0.4 and Bases by the following:
The STS phrase "... the applicable surveillance interval
          ... " will be revised to "... the allowed surveillance interval, defined by Specification 4.0.B, ...." The reference to Specification 4.0.B was added for clarification. The phrase is also consistr,nt with the statement in Specification 4.0.C.
The references to " OPERATIONAL CONDITIONS or other conditions" ucre modified to reflect that the DAEC TS are of custom format and as such do not use modes of operation to define LCO applicability as typically denoted in the standard-format Technical Specifications. For the DAEC TS, the applicable condition ic denoted within its individual specification.
The proposed Specification 4.0.D Bases is additionally modified to be consistent with DAEC TS format. The STS words
         "...in the Applicability statement." would be deleted because the DAEC TS are currently not structured in the STS format containing specific " Applicability statements."
These proposed changes do not change or modify the intent of the                    +
requirements denoted in the STS. These changes only clarify specific differences in the format.that exist between the DAEC TS (custom-format) and the STS (standard format).
Definition      " Action" The proposed definition ACTION is being added and is consistent with that of the STS definition 1.1.

RTS-249                                                           Attachment 1 to NG-92-5179 Page 11 Definition - " Surveillance Frequency" The definition SURVEILLANCE FREQUENCY is being deleted. The definition is redundant with the new proposed Specification 4.0.B.
Definition - " Frequency Notation" The proposed definition FREQUENCY NOTATION is being enhanced consistent with that of STS definition 1.16. The proposed change also adds specific surveillance interval frequencies for inservice inspection and testing of ASME Code Class 1, 2, and 3 components.
These requireme'ts are consistent with the requirements contained in STS Specificativa 4.0.5.
Non-Applicabilities to Specification 3.0.C Specifications 3.10.B.1, 3.14.A, and 3.14.B require an exception to the provisions of Specification 3.0.C. These specifications denote an applicability "at all times" and maintain Action Requirements consisting of remedial measures to be taken. The proposed changes to these specifications are consistent with exceptions to Specification 3.0.3 denoted in the STS.
Non-Applicabilities to Specification 3.0.D Table 3.1-1, Note 1; Table 3.2-A, Note 2; Table 3.2-B, Note 1; 3.2.D.1; Table 3.2-D; Table 3.2-F, Note 1; 3.3.A.2; and 3.7.D.2 require an exception to the provisions of Specification 3.0.D. These             -
exceptions are being added to clarify that a mode change would not be precluded by specification 3.0.D. These specifications do not satisfy the provisions under which modo changes are permitted by Specification 3.0.D as discussed above in " Specification 3.0.D and Bases." The proposed changes to these specifications are consistent with exceptions to Specification 3.0.4 denoted in the STS.
Non-Applicabilities to Specification 4.0.B Table 4.6.H-1 and Specifications 4.7.A.2.d.1); 4.7.A.2.d.2)a);
4.7.A.2.d.2)b); 4.7.A.2.d.3); and 4.7 A.2.e require an exception to the provisions of Specification 4.0.B. These specifications require surveillance testing either (1) at intervals which have extension allowances denoted within the specification or (2) at intervalc which are mandated by the Code of Federal Regulations that specify no extension allowances. The proposed changes to these specifications are consistent with exceptions to Specification 4.0.2 denoted in the STS.

RTS-249                                                                                                             Attachment 1 to NG-92-5179 Page 12 Non-Applicabilities to Specification 4.0.D TS Table 4.1-1 and Specifications 4.5.D; 4.5.E; 4.6.D.3; 4.12.A; 4.12.B; and 4.12.C require an exception to the provisions of Specification 4.0.D. These specifications require associated surveillance testing which can only be performed after entry into the                                                            _
applicable mode. The proposed changes to these specifications are consistent with exceptions to Specification 4.0.4 denoted in the STS.
For Specifications 4.5,D; 4.5.E; and 4.6.D.3; a limit of 12 hours is provided to ensure that these surveillances are performed within a reasonable time-frame once the modo is entered. A conditional action statement is provided to clarify that if OPERABILITY is not
-                            successfully demonstrated within the 12-hour period, action would be taken to reduce the reactor steam dome pressure to less than the pressure specified for the applicable condition (150_psig for Specification 4.5.D and 4.5.E; 100 psig for specification 4.6.D.3) within the following 72 hours.                                             The time limit of 72 hours provides a sufficient amount of time for remedial measures to be.taken prior to placing the plant in the non-applicable mode.                                                             This conditional action statement is consistent with specifications recently approved by the NRC on the Limerick Generating Station, Units 1 and 2 docket. The addition of this conditional action statement to the 4.0.D exceptions only clarifles actions which would otherwise have to be interpreted by the operators. A limit of 12 hours for completing surveillances is also given for certain trip functions listed in Table 4.1-1. This assures required surveillances will be completed in an appropriate time frame in cases-where actions are not being taken to immediately proceed to a shutdown condition.
Specification 4.6.G and Bases Specification 4.6.G and Bases has been revised to incorporate STS                                              -
Specification 4.0.5 and. Bases which establishes the_ inservice inspection and inservice testing requirements. This specification, as proposed, establishes the requirement that inservice inspection of I.                            ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with a periodically updated version of Section XI of.the-ASME Boiler and Pressure Vessel Code and Addenda as-required by_10_CFR 50.55a.                   This specification also clarifies the._frequenciesLfor                                                    _           ___
performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This ensures consistency in surveillance intervals throughout the Technical Specifications and removes any ambiguities relative to the frequencies for performing the required inservice inspection and testing- activities. The proposed changes are
,                             consistent with-the requirements contained in STS Specification 4.0.5.
The proposed changes to Specification-4.6.G and to Specification'l.0 y,_,-h . 9
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RTS-249                                                                    Attachment 1 to NG-92-5179 Page 13 (Frequency Notation) are in lieu of a new specification in the 3.0/4.0 section of the DAEC TS similar to STS Specification 4.0.5. Due to the fact that the DAEC TS already established inservice inspection and inservice testing requirements in Specification 4.6.G prior to this
,                                 submittal, relocating these requirements to a new specification (3.0/4.0) would require extensive surveillance procedure changes.
While these surveillance procedure changes would be administrative in nature, they would be required to ensure a consistent referencing between the surveillance procedures and the corresponding DAEC TS.
Consequently, we have chosen to leave these requirements'in Specification 4.6.G.
Basis for Proposed No Significant Hazards Consideration The Commission has provided standards (10 CFR 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 different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
In reviewing the proposed request for Technical Specification change, wo have concluded:
(1)            The proposed change will not increase _the probability or consequences of an accident previously evaluated. The change provides specific applicability requirements to both the Limiting Conditions for Operation and the Surveillance Requirements. The proposed change incorporates only those applicability requirements and exceptions denoted in the Standard Technical Specifications as modified by Generic Letters 87-09 and-89-14, the Improved Technical Specifications (NUREG-1433), or DAEC plant specific terminology which is_ considered administrative in l
nature. Invoking the proposed applicability requirements, and thus the administrative requirements imposed on the systems, subsystems, trains, components, or devices, better ensures that these systems,_ subsystems,_ trains, components, or devices will be available to mitigate the consequences of_an-accident or transient event. Further, the proposed change _does not= affect any accident or safety analysis event initiator _as analyzed-in the Final Safety Analysis Report, nor involve any modification to l                                                  equipment.
(2). The proposed change will not create the possibility of a new or l                                                  different kind of accident from any accident prevlously
[                                                  evaluated. The proposed change does not affect any equipment I                                                  design or configuration and, therefore, no new or different types
  -- ,-                                                                                          a--

      - - . . ,         - - - _.- - .                                . . - . - . _ - .                                         _ . - . . - - - . - _ . . . . . - - . . - ~ . . . _ . _ . _ - - .
RTS-249                                                                                                                                                                                        Attachment 1 to
  !                                                                                                                                                                                                              NG-92-5179 Page-14 of failures are created. The proposed change will not create any new modes of operation, but ensures that appropriate administrative requirements are invoked (i.e. operability status of a system) prior to mode changes.
(3)              The proposed change will not involve a significant reduction in a margin of safety. The proposed change does not reduce the margin of safety becat se it has no impact on any safety analysis-                                                                                                                                          ,
assumption.                                 The proposed change is in fact-more-restrictive due                                                                                                      i to the additional administrative requirements imposed on the                                                                                                                                         l Limiting Conditions for Operation and Surveillance Requirements                                                                                                                                     l in each individual specification.                                                                                           The proposed change ensures                                              !
that each system, subsystem, train, component, or device denoted in the Technical Specifications is maintained with applicability requirements that are consistent with the Standard Technical Specifications and other regulatory guidance documents.
Therefore, the proposed license amendment is judged to involve no significant hazards consideration.
Local Public Document Room Location:                                                                                                          Cedar Rapids Public Library, 500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licensee:                                                                            Jack Newman, Kathloen H. Shea, Newman and Holtzinger, 1615 L Street NW, Washington, DC 20036 l
l I
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_ _ _ _ . _ _ . _ . _ _ _ _ _ . _ _ . . _ _ _ _ . _ _                                           _ . . _     _ . _       . -=- _ _ _ _ .._ _.
RTS-249                                                                        Attachment 2 to NG-92-5179 Page 1 PROPOSED CHANGE RTS-249 TO THE DUANE ARHOLD ENERGY CENTER TECHNICAL SPECIFICATIONS The holders of license DPR-49 for the Duane Arnold Energy Center .                                               ,
propose to amend Appendix A (Technical Specifications) to said license                                           l by deleting certain pages and replacing them with the attached, new                                            .j pages.              The List of Affected Pages is given below.                                                  ,
I List of Affected Pages                                                    l l
1                 3.2-45a+
11*               3.3                                                                              1.0-1             3.5-7 1.0-7             3.5-8 1.0-8            3.5-18 3.0-1             3.6-9*                                                i 3.0-2             3.6-11*                                                I 3.0-3            3.6-12*
3.0-4             3.6-13*                                                l 3.0-5             3.6-24*
3.0-6            3.6-29*                                                i 3.1-5+           3.7-6#                                               q 3.1-8+           3.7-7#
3.1-11+          3.7-19#
3.1-15+          3.10-2a 3.2-3+#          3.12-1 3.2-6+-          3.12-2 3.2-15+          3.12-3 3.2-19+          3.14-1 3.2-22+          3.14-2 3.2-45+.
Summary of Changes:
The following list of proposed changes is in the order that the changes appear in the Technical Specifications.
Page                             Description of Change The Table of Contents has been revised to reflect that
                                                                                           ~
i and 11 Section.3.0, " Applicability," has been added.              The                  _ . .
corresponding Surveillance Requirements and page number have_
also been added.
                                        +-              These pages are common to-RTS-186
                                        *-              These pages reflect changes'made by RTS-197
                                        #               These pages are common to RTS-246
_ _ _ _ _ _ _ _ _ - . . _ . _ . _ . _ . _ . . _ . ,_                          __ -  - _ _ _          _,c       -  ..      . _ , .      -,_

  -      . . - -             . . . ~ .           --              . . .          - -.    -.         ._..   ..   .._         . . .     . _ _
RTS-249                                                                                         Attachment 2 ton NG-92-5179 Page 2 Page                                         Description of Change 1.0-1                   Definition 4, " ACTION" has been added consistent with that of.the STS definition 1.1.
1.0-7                   Definition 26, " SURVEILLANCE FREQUENCY" has been deleted.
The definition is redundant with new Specification 4.0.B.
1.0-8                   Definition 27,                       FREQUENCY NOTATION" has been revised consistent with-that of the STS definition 1.16 and has incorporated specific surveillance interval frequencies for.
Inservice inspection and testing of ASME Code Class 1,c2,.
and 3 components. These requirements are consistent with
* the requirements contained-in STS Specification 4.0.5.
3.0-1                   Added STS 3.0 and-4.0, " Applicability," and' corresponding to                Bases to the DAEC TS. The addition of Specifications 3.0 A, 3.0-6                   3.0.B,.3.0.C, and 3.0.D establish the general-requirements-applicable to Limiting-Conditions-for operation. The addition of Specifications 4.0.A, 4.0 B,'4.0.C, and 4.0.D establish the general requirements applicable to.
Surveillance Requirements.
3.1-5                   Added a provision for the exception to specification 3.0.D                                        '
to. Table 3.1-1,-Note 1.
3.1-8                   Added exception to Specification 4.0.D to Table 4.1-1,.vla and
                                                    ~
Note 6, provided surveillances are-completed within 12 hours 3.1-11                  or actions are taken to proceed to shutdown.
3.1-15                  Added clarifying statement to TS.3.1 Bases concerning exception to Specification.3.0.D. Corrected typographical-error on " inadvertent."
3'.2-3                  Added a provision for the exception-to Specification 3.0.D to TS 3.2.D.1,                       MadeLeditorial change-to column headers-for consistency-3.2-6                   Added a provision for the exception to Specification.3.0.D to Table 3.2.A, Note 2.
3.2-15                 Added a provision for the exception to specification 3.0.D-
                                               ~
to Table 3.2-B, Note 1.
3.2-19                 Added a provision for the exception to Specification 3.0.D to Table 3.2-D.
3.2-22                 Added a provision for-the exception to Specification 3.0.D.
to Table 3.2-F, Note 1.
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l RTS-249                                                    Attachment 2 to NG-92-5179 Page 3 Page                  Description of Change 3.2-45  Added clarifying statement to TS 3.2 Bases concerning and    exception to Specification 3.0.D.
3.2-45a 3.3-3   Added a provision for the exception to Specification 3.0.D to TS 3.3.A.2. Made editorial change to column header for consistency.
3.5-7   Added a provision for the. exception to Specification 4.0.D to TS 4.5.D. Made editorial change to column header for consistency.
3.5-8   Added a provision for the exception to Specification 4.0.D to TS 4.5.E. Made editorial change to column 1 header for consistency.
3.5-18   Added a statement to TS 3.5 Bases clarifying the 12 hour and 72 hour time periods for demonstration of HPCI and RCIC operability.
3.6-9    Added a provision for the exception-to Specification 4.0.D to TS 4.6.D.3, 3.6-11   TS 4.6.G has been revised to incorporate the inservice to     inspection and inservice testing requirements denoted in STS.
3.6-12   Specification 4.0.5.      Paragraph 4.6.G.2 has been renumbered 4.6.G.5 and moved from page 3.6-11 to 3.6-12, 3.6-13   Added Note t' to Toole 4.6.H-1 to clarify applicebility of-Specification 4.0.B.
3.6-24   Added a statement to TS 3.6 Bases-clarifying the 12 hdur and 72 hour time periods for demonstration of relief valve operability.
3.6-29   TS 4.6.G Bases has been revised to incorporate the inservice inspection and inservice _ testing requirements denoted in STS Specification _4.0.5.
                                                             ~
3.7-6   -Added a provision _for the exception to Specification 4.0.B to TS 4.7.A.2.d.1),;4.7.A.2.d.2)a), and 4.7.A.2.d.2)b).
3.7-7    Added a provision for the exception to Specification 4.0.B to TS 4.7.A.2.d.3)1and 4.7.A.2.e.

e
:RTS-249                                                                      Attachment 2 to NG-92-5179
                                                                                        -Page_4 Page                 Description of Change 3.7-19   _Added a provision for the exception to specification 3.0.D to TS 3.7.D.2. Made editorial change to column header for-consistency.
3.10-2a   Added a provision for the exception to Specification 3.0.C to TS 3.10.B.1. -Made' editorial change to column header for
                     . consistency..
3.12-1   Added a provision for the exception to Specification 4.0.D1                          _
to TS 4.12.A. Made editorial change to column header for consistency.
3.12-2   Added a-provision for the exception to Specification 4.0.D.
to TS 4.-12.B. -Made editorial change-to-column header for-consistency.
3.12-3   Added a provision;for the exception to Specification 4.0.D to TS 4.12.C. Made editorial change to column header.for consistency.
3.14-1    Added a provision for the exception to Specification 3.0.C-to TS-3.14.A.
             -3.14-2   Added a provision for the exception to Specification 3.0.C.
to TS 3.14.B.
                                                                                                  ^
                                                  . _ _ . . _ . _ _ _ _ _   _2- . . . .}}