IES Utikties Inc.

* 200 Fwst Street S.E.'* PO. Box 351.,

Cedar Rapids, IA 52406-0351.

Telephone 319 398 8162

Fax 319 398 8192

UTIUTIES . , , , , , , , , , , , , _

Vce President, Nuclear

May 9,1997NG-97-0847

OfSce ofNuclear Reactor RegulationU. S. Nuclear Regulatory CommissionAttn: Document Control DeskMail Station PI-37Washington, DC 20555-0001

Subject: Duane Amold Energy CenterDocket No: 50-331Op. License No: DPR-49Request for Technical Specification Change (RTS-292): Revision toDefmition of Limiting Conditions for Operation.

Reference: G. Kelly (NRC) to IES Utilities Inc., " Summary of March 20,1997Meeting on Technical Specification Setpoints and the Pra.:tice of NotEntering Limiting Conditions for Operation (LCO) Action StatementsDuring Certain Surveillances," April 3,1997.

File: A-ll7

Dear Sir (s):

In accordance with the Code of Federal Regulations, fitle 10, Sections 50.59 and 50.90,IES Utilities Inc. hereby requests revision to the Technical Specifications (TS) for theDuane Arnold Energy Center (DAEC).

The proposed TS amendment would revise the definition of Limiting Conditions forOperation (LCO) to address the situation when systems, components, etc. are removedfrom service or otherwise made inoperable during secondary modes of operation, withoutrequiring entry into the LCO actions This is the current operating practice at the DAECand is supported by the plant design and licensing basis, as discussed in the referencedmeeting with the Staff. Within the dermition of LCO, such secondary modes are alsobeing defined consistent with the DAEC design and licensing basis. As compensatorymeasures during such secondary modes of operation, criteria are established within thedefinition of LCO that ensure the plant is operated consistent with the original designbasis assumptions, f

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An IES Industnes Compey .

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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 >

Ilazards Consideration, is being forwarded to our appointed state official pursuant to 10i CFR Section 50.91,'

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Should you have any questions regarding this matter, please contact this office.

This Ictter is true and accurate to the best of my knowledge and belief

IES UTILITIES INC. f

By_ inu| jjs, Y trct T$ ;

'lohjfF.' Franz' ' "#

Vice President, Nuclear

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State ofIowa(County) of Linn

Signed and sworn to before me on this W day of A1&/_. ,1997,

by (Ash / dPOnnnn)/ Vr'mnd

} Afb |b) f00 .

Nota /y Public in and for the/ State ofj6wa

f|8 -99Commission Expires )

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

2) Proposed Change RTS-292 to the DAEC Technical Specifications J

3) Safety Assessment 1

4) Environmental Consideration

JFF/RAB/rabN.\lowa\Liecmingug\97-0847

cc: R. BrowningL. Root

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G. Kelly (NRC-NRR)A. B. Beach (Region 111)P. Baig (State ofIowa) !NRC Resident Office )Docu i

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RTS-292 Attachment I to.

NG-97-0847.

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EVALUATION OF CIIANGE PURSUANT TO 10 CFR SECTION 50.92

Background;

in a meeting with the NRC Staff on March 20,1997, we explained the DAEC's policy of notentering Limiting Conditions for Operation (LCO) actions for equipment removed from serviceduring so-called " secondary modes of operation," such as surveillance testing, ir, thisequipment is not in its nonnal standby readiness mode. This policy has also been the subject ofprevious communications with the Staff (Ref. September 22,1994 Meeting and IES letters NG-94-4017, dated November 30,1994 and NG-95-0815, dated March 10,1995) on the GenericLetter 89-10 Program for motor-operated valves. In these previous communications we haveprovided the Staff with the original design and licensing basis information that supports thispolicy. The fundamental premise of this original basis information is that LCO actions are onlyintended to be entered when equipment is removed fmm service for maintenance (eithercorrective or preventative), not when taken out of service for testing or other allowed secondarymodes of operation (Ref. General Electric reports APED-5736: fluideline for Determining SafeIc;t Intervals and Repair Times for Engineered Safeguards , and NEDO-10739: Methods forCalculating Safe Test Intervals and Allowable Renair Times for Engineered Safeguard Systems),This was determined to be acceptable because the time in such secondary modes of operation(iz, the safe test interval) is very short in duration, especially when compared to the allowablerepair time for maintenance (ir, LCO time); and, that redundant systems, trains, etc. would notbe removed from service simultaneously. |

As a follow-up to the March 20,1997 meeting, we agreed to incorporate the existing |administrative controls used to assure that operation in such secondary modes was consistent |

with the above design and !icensing basis into the DAEC Operating License. Such controls willIbe applied uniformly to ali 15-required equipment during secondary modes of operation that

preclude that equipnnnt from performing its intended safety function. The enclosed changerequest is intended to fulfill that agreement.

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

DRane Arnold Energy Center. I inn County. Iowa |Date of Amendment Reauest: May 9,1997

Descrintion of Amendment Reouest:

The proposed TS amendment would revise the definition of LCO to address the situation whensystemt, components, etc. are removed from service or otherwise made inoperable duringsecondary modes of operation, without requiring entry into the LCO actions. Within thedefinition of LCO, such secondary modes are def'med as " conditions or states other than theprimary safety function." Some examples of such secondary modes of operation are surveillancetesting of systems, torus cooling mode (test line-up) of Residual lleat Removal system, and useof fligh Pressure Coolant injection system or Reactor Core Isolation Cooling system in test line-up for reactor pressure control during transients. These modes require them to be placed in a line-up or configuration that is difTerent from their normal, standby readiness configuration. While

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RTS-292 Attachment I to.

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these systems are generally " functional" during such secondary modes, they do not strictly meetthe TS dermition of OPERABILITY, as they will not respond as assumed in the safety analysis(ca:,., slower response time, less than assumed flow, etc.) It is important to note that maintenanceactivities are not considered to be secondary modes of operation, as the system undergoing

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maintenance is not, in general, " functional" during those activities, k, easily and/or promptly,

retumed to the safety function line-up or configuration. Therefore, they are purposefullyexcluded from this definition.

As compensatory measures during such secondary modes of operation, criteria are establishedwithin the definition of LCO that ensure the plant is operated consistent with the original designbasis assumptions. The criteria establish the administrative controls that ensure that the plant isunder the control of the operators, k, use pre-approved plant procedures, limit the amount oftime in such secondary modes, and ensure that a loss-of-function is not inadvertently created.

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(Note: for some systems, surveillance testing will create a loss-of-function. For example, bydesign, Standby Liquid Control System has shared components between the two subsystems.Consequently, when testing causes a loss-of-function, the above criteria are applied to bothsystems, trains, etc.). If these criteria are not met, then the L.CO will be entered and those actionswill be taken in the specified time period.

Basis for Proposed No Significant iia 7;irds Consideration:>

The Commission has provided standards (10 CFR Section 50.92(c)) for determining whether asignificant hazards consideration exists. A proposed amendment to an operating license for afacility involves no significant hazards censideration if operation of the facility in accordancewith the proposed amendment would not (1) involve a significant increase in the probability orconsequences of an accident previously evaluated; (2) create the possibility of a new or differenti.ind of accident from any accident previously evaluated; or (3) involve a significant reduction ina margin of safety.

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Aller reviewing this proposed amendment, we have concluded:

1) The proposed TS amendment will not significantly increase the probability or consequencesof any previously evaluated accidents.

The proposed change merely adds criteria to the TS that are consistent with the originaldesign and licensing basis assumptions. Operation in secondary modes of operation (such assurveillance testing, torus cooling mode (test line-up) of Residual IIcat Removal system, anduse ofliigh Pressure Coolant Injection system or Reactor Core Isolation Cooling system intest line-up for reactor pressure control during transients) is assumed in the safety analysisreport (Ref. UFSAR Section 6.3.4.2.1 and 7.3.4.2). Because no changes in actual equipmentoperation or testing are being made as part of this change, the probability of any event whici.could be induced by such operation or testing is not increased. Also, the change will ensurethat the time such equipment is removed from service is kept very short in duration, eitherthrough the existing TS Allowed Outage Time (AOT) notes or administratively by

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procedures. This is consistent with the assumption that the time in such secondary modes of

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operation (k, safe test interval) is much shorter than the allowable repair time (k, LCOtime). Therefore, the proposed change will not significantly increase the probability of anypreviously evaluated accident.

The uniform application of the new TS criteria will further ensure that the plant remainswithin the original design and licensing basis assumptions for equipment removed fromservice during secondary modes of operation. In particular, in the special case where testingalso removes the redundant system, train, component, etc., from service, these criteria ensurethat both affected systems, trains, etc., are properly controlled This is acceptable because thetime in such secondary modes of operation is very short in duration, such that the impact onoverall availability / reliability is insignificant. Therefore, the consequences of any previouslyanalyzed accident are not significantly increased by this change.

2) The proposed changes will not add a new or different kind of accident because the plant willnot be operated in a different way. Operation in secondary modes has been previouslyevaluated and found to be acceptable (Ref. General Electric reports APED-5736: Guidehaefor Determining Safe Test Intervals and Renair Times for Engineered Safeguards , andNEDO-10739: Methods for Calculatine Safe Test Intervals and Allowable Renair Times forEngineered Safeguard Systems.) The proposed change increly adds criteria to the TS that areconsistent with the assumptions contained within these evaluations. Consequently, no new ordifferent accidents are postulated as a result of this proposed change.

3) Because the criteria being added to the TS enforce the assumptions of the evaluations thatform the basis of t.c aisting TS (Ref. TS Bases 4.1,4.2, and 3.5), the proposed change willnot result in a significant reduction in any margin of safety.

Based upen the above, we have determined that the proposed amendment will not involve asignificant hazards consideration.

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

Attorrwv for Licensee: Jack Newman, Al Gutterman; Morgan, Lewis & Bockius,1800 M StreetNW, Washington, D.C. 20036-5869

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