ML20198P881

Application for Amend to License DPR-49,revising LCO for PCIVs in TS Section 3.7.B to Allow 72 Hours to Isolate Failed Valve Associated W/Closed Sys,Per NUREG-1433

ML20198P881
Person / Time
Site:	Duane Arnold
Issue date:	01/09/1998
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198P885	List: ML20198P887 NG-98-0016, Application for Amend to License DPR-49,revising LCO for PCIVs in TS Section 3.7.B to Allow 72 Hours to Isolate Failed Valve Associated W/Closed Sys,Per NUREG-1433
References
RTR-NUREG-1433 NG-98-0016, NG-98-16, NUDOCS 9801220280
Download: ML20198P881 (5)

Text

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IES Utdates Inc.

200 First Stmet S E.

, PO Ban 351 Cedar Rapds,IA b2406 c3bt Te+ phone 319 398 8162 Fax 319 398 8192 UTILITIES. ,, , ,,,

Vce Preckient, & clear Jamtary 9,1998 NG-98-0016 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37

- Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center Docket No: 50 331 Op. License No: DPR-49 Request for Revision to the Duane Arnold Energy Center Technical Specifications (RTS-297): Section 3.7.B

Reference:

10 CFR 50.90 File: A-117, T-23d in accordance with the Code of Federal Regulations, Title 10, Sections 50.59 and 50.90, IES Utilities hereby requests revisit Tecimical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

IES Utilities proposes to revise the limiting condition for operation (LCO) for primary containment isolation vdves (DCIVs) in TS Section 3.7.B. The proposed change is consistent with Revision 2 to Traveler TSTF-30 (approved by the NRC on October 1,

' 1997) for the Improved Standard Techrical Specifications for General Electric BWR/4 plants (NURF.G-1433). i f

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. NG.98-0016 January 9,1998 Page 2 This application has been reQwed by the DAEC Operations Committee and the Safety Committee. A copy of this submittal, along with the evaluation of No Significant llazards Consideration, is being forwarded to our appointed state official pursuant to 10 CFR Section 50.91.

Shoulc' "ou have any questions regarding this matter, please contact this office.

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

IES UTILITIES INC.

By 4 _M /

ohn F'. Fradz

[Vice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this, h day of huuim ,1998, Q~ A by m L m a b.udn .

p KATHRYN DJNLAP g

\ W C M SSCNO M S Notary Public in and for the Str.te ofIowa ktO2, cM N93 '

CComnh3 on i EApires Attachments: 1) Evaluation of Change Pursuant to 10 CFR Section 50.92

2) Proposed Change RTS-297 to the DAEC Technical Specifications

3) Safety Assessment

4) Environmental Consideration cc: C. Rushworth L. Root D. Wilson G. Kelly (NRC-NRR)

A. B. Beach (Region III)

P. Baig (State ofIowa)

NRC Resident Office Docu l

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Attachment I to '

,- NG-98-0016 Page1 JiVALUATION OF CllANGE PURSUANT TO 10 CFR SECTION 50.92 As discussed in LER 97-13 dated December 19,1997, when Contcol Building / Standby Gas Treatment System Instrument Air Compressors 1K3/4 are out-of-service, components supplied by these compressors are inoperable. Among the components supplied by these air compressors are the drywell well water cooling isolation valves, which are 10CFR50 Appendix A GDC 57 (Type "C") containment isolation valves.

Inoperable primary coniainmcat isolation valves (PCIVs) are covered by Technical Specification (TS) 3.7.B.2 which states "With one or more of the primary containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either: a. Restore the inoperable valve (s) to OPERABLE status, or b. Isolate each affected penetration flow path." TS 3.7.B.3 states "If Specifications 3.7.B.1, and 3.7.B.2 cannot be met, an orderly shutdown shall be initiated and the reactor shall be in at least ilOT SilUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD SilUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Although these Technical Specifications and accompanying Bases address the operability of primary containment isolation valves, it is appa ent that these requirements are more applicable to Type "A" or "B"(GDC 55 or 56) primary containment isolation valves which either interface directly with the reactor primary coolant system or the primary containment atmosphere. Further, the Technical Specification Bases for Section 3.7.B are explicit on the means that can be utilized to isolate a primary containment penetration with an inoperable containment isolation valve. These means do not acknowledge the intact closed loop of piping in the drywell as an acceptable means for isolation of penetrations with GDC 57 valves.

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

Duane Amold Eneruv Center.1 inn County. Iowa Date of Amendment Reauest: January 9,1998 ,

Descrintion of Amendment Request:

The proposed amendment revises DAEC TS Section 3.7 Limiting Condition for Operation (LCO) for Primary Containment isolation Valves (PCIVs). TS Section 3.7.B is revised to allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to isolate a failed valve associated with a closed sy stem (General Design Criteria (GDC) 57, i.e., closed systems inside containment). The pioposed change is consistent with Revision 2 to Improved Technical Spec.fications Traveler TSTF-30 approved by the NRC on October 1,1997.

GDC-57 allows the use of a closed system in combination with a single containment isolation valve to provide two containment barriers against the release of radioactive material following an accident. As such, the use of a closed system is not different from isolating a failed containment isolation valve by use of a single valve. Currently, TS - Section 3.7.B does not allow the use of a closed system to isolate a failed containment isolation valve even though the closed system is subjected to a Type A containment

1 Attaci ment I to NG 98-0016

- Page 2 leakage test, is missile protected, and is seismic category I piping. A closed system also typically has flow through it during normal operation such that any loss ofintegrity could be continually observed through the leakage detection system within containment and system walkdowns for closed systems outside containment. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period provides the necessary time to perform repairs on a failed containwrjt isolation valve when relying on an intact closed system. Seventy-two hours is censidered appropriate given that certain valves may be located inside containment, the reliability of the closed system, and that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is typically provided for losing one train of redundancy throughout the .

NUREC 1433, liasis for proposed No Siunificant flazards Considerat i on:

The Commission has provided star.Jards (10 CFR Section 50.92(c)) for determining whether a significant hazards consideration exists. A proposed amendment to im operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amwndment would not (1) involve a significant increase in the probability or consequence : of an accident previously evaluated;(2) create the possibility of a new or diffen nt kind of accident from any accident previously evaluated; or (3) involve a significant reduct! a in a margin of safety.

Aller reviewing this proposed amendment, we have concludei

1) The proposed amendment will not involve a significant increase in the probability ar consequences of an accident previously evaluated.

This change extends the time to isolate single PCIV penetrations from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The time allowed to isolate the penetration is not assumed to be an initiator of any analyzed event. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period provides the necessary time to perform repairs on a failed containment isolation valve when relying on an intact closed system. Use of a closed system for isoh. tion is directly equivalent to isolating a failed containment isolation valve by use of a single valve. The closed systems are subject to a Type A containment leakage test, are missile protected, and are scismic Category 1 piping.

Allowing an additional 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> to isolate these penetrations will not significantly increase the consequences of an accident since the intact closed system provides adequate isolation. Also, the consequences of an event occurring during the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period are the same as those during the current 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period is consistent with NRC-approved Traveler TSTF-30, Revision ? Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

This change extends the time allowed to isolate single PCIV penetrations liom 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The additional 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> that the penetrations are not isolated will not create the

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Attachment I to NG-98-0016 Page 3 possibility of a new or different kind of accident. Use of a closed system for isolation is directly equivalent to isolating a failed containment isolation valve by use of a single valve. The closed systems are subject to a Type A containment leakage test, are missile protected, and are seismic Category 1 piping. This change will not physically alter the plant (no new or different type of equipment will be installed) The change in allowed out-of-service-time is consistent with the current safety analysis assumptions. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3). The proposed amendment does not involve a significant reduction in a marg:n of safety.

1 This change extends the time allowed to isolate single PCIV penetrations from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. During the additional time allowed, a limiting event would still be assumed to be within the bounds of the safety analysis assuming no single active failure. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period is censistent with NRC-approved Traveler TSTF-30, P: vision 2. Use of a closed system ior isolation is directly equivalent to isolating a failed containment isolation valve by use of a single valve. Therefore, this change does not involve a significant reduction in a margin of safety.

Based upon the above, the proposed license amendment is judged to involve no significant hazards considerations.

1,ocal Public Document Room I.ocation: Cedar Rapids Public ' brary,500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licensee: Jack Newman, Al Gutterman; Morgan, Lewis & Bo;kius,1800 M Street NW, Washington, D.C. 20036-5869

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