ML20076K800

Safety Evaluation Supporting Amend 201 to License DPR-49

ML20076K800
Person / Time
Site:	Duane Arnold
Issue date:	10/26/1994
From:	Office of Nuclear Reactor Regulation
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NUDOCS 9411020120
Download: ML20076K800 (45)

Text

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?t UNITED STATES 1I hlI E NUCLEAR REGULATORY COMMISSION

'f WASHINGTON, D.C. 20666 4001

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w, SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 201 TO FACILITY OPERATING LICENSE NO. DPR-49 IES UTILITIES INC.

CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331

1.0 INTRODUCTION

By application dated March 27, 1992, IES Utilities Inc, formerly known as Iowa Electric Light and Power Company, requested an amendment to the Duane Arnold Energy Center facility operating license.

The proposed amendment requested revision of the Technical Specifications (TS) limiting conditions for operation (LCOs) and surveillance requirements (SRs) for primary containment integrity, secondary containment integrity and other systems and equipment of TS Section 3.7 " Containment Systems" to improve their clarity and consistency with the Standard Technical Specifications (STS). The staff's technical assistance contractor reviewed the application and provided a Technical Evaluation Report (TER) which was forwarded to the licensee by letter dated November 12, 1993. A copy of the TER is attached. The TER identified deficiencies which the staff agreed should be addressed by the licensee prior to issuance of an amendment.

By letter dated January 6, 1994, the licensee responded to the deficiencies cited in the Attachment.

In a subsequent letter dated March 30, 1994, the licensee advised the staff that a revised application was being prepared that would not only incorporate changes resulting from the deficiencies cited in the TER, but would add additional changes.

The licensee subsequently, by letter dated May 27, 1994, submitted a revised application.

The staff has reviewed the TER and concurs with the contractor's conclusions regarding acceptability of the changes proposed in the March 27, 1992, application.

Section 2.0 below is limited to discussion and evaluation of: (a) the licensee's response to the deficiencies, and (b) the additional changes.

2.0 Discussion And Evaluation 2.1 Deficiencies Cited in TER This section discusses the discrepancy items identified in the attached TER.

2.3.1 Secondary Containment Neaative Pressure Deficiency cited in TER: Section 6.5 of the DAEC Updated Final Safety Analysis Report (UFSAR) states that the secondary containment is maintained at a pressure of -k"w.g. (%-inch of water, gauge negative) during normal operation.

The TER noted that there is no requirement in either the existing 9411020120 941026 DR ADOCK 05000331 PDR

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_g.

- TS or proposed TS to periodically verify the negative pressure during operation. The TER also noted.that the TS do not specify or require periodic surveillance testing to verify standby gas treatment system (SGTS) capability to achieve -k"w.g. pressure within a specific drawdown time limit.

Section 50.36 of 10 CFR requires that Limiting Conditions for Operation (LCO) and Surveillance Requirements (SRs) be specified in TS for equipment required for safe operation.

Licensee Response: The licensee responded that a -k" w.g. pressure, and a specific drawdown time are not design or licensing basis requirements for the DAEC facility.

Staff Evaluation: The TS for facilities having a secondary containment for which a fission product control capability is credited in the analyses of radiological consequences of design basis accidents typically include surveillance test requirements to periodically ensure the operability of the equipment needed to establish and maintain a negative pressure in the secondary containment. The purpose of a negative secondary containment pressure is to preclude ex-filtration.

Ex-filtration is the direct release of primary containment fission product leakage without cleanup by the SGTS HEPA and charcoal filtration equipment.

Radiological dose consequence calculational methodology does not credit the secondary containment fission product control function during periods when the pressure is positive with respect to outside pressure.

DAEC is one of a group of early BWR facilities, whose design and licensing bases, are not typical of similar, but later facilities.

For these early BWRs, the secondary containment is normally maintained at a negative pressure, and, in the event of a accident, it is assumed that the negative pressure is maintained during the period when the secondary containment isolates, and the SGTS begins operating. The DAEC radiological dose models for these facilities do not assume a period of secondary containment ex-filtration and the TS do not include either: (1) a surveillance requirement for periodic verification of secondary containment negative pressure during normal operation, or (2) a requirement that drawdown be demonstrated within a specific, analytically-based time interval during SGTS testing. The question arose as to whether the proposed DAEC amendment should be denied, because the proposed changes would not fully upgrade the secondary containment surveillance requirements to current standards.

Although the staff found that the proposed changes would not fully upgrade the existing surveillance requirements, the staff recognized that issues relating to the improvement of TS have already been addressed.

Licensees of earlier facilities, such as DAEC, are being encouraged to upgrade the TS of their facilities by voluntarily submitting improved TS amendment requests (Ref: " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," 58 FR 39132 Published July 22, 1993). Accordingly, additional SGTS surveillance test requirements that w'ould: (1) demonstrate a drawdown time capability during SGTS surveillance testing, and (2) periodically verify, during normal operation, that the secondary containment is being maintained at -0.25 "w.g. subatmospheric

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pressure, need not be included as part of this amendment. The staff, therefore, finds the licensee's response acceptable.

2.1.2 Secured Check Value i

Deficiency Cited in TER: The TER noted that the proposed Bases for new TS Sections 3.7.B and 4.7.8 identify the use of "a check valve inside primary

' containment with flow through the valve secured," as an isolation barrier is not consistent with the associated LCO.

i Licensee Response: The licensee replied that the LCO, including an associated footnote, would be revised to delete text identifying the specific methods of isolating penetrations, and that such information would be specified in the BASES only.

The licensee's revised May 27, 1994, application eliminates the inconsistency by deleting text from the LCO that would describe how a i

p'enetration is to be isolated.

The reader must thus defer to the TS Bases for this additional information.

Staff Evaluation: The revised application resolves the inconsistency, allowing use of a " check valve inside containment with flow through the valve secured," as a means of isolating an open containment penetration in the event one or more of its isolation valves becomes inoperable.

The staff considers a check valve inside containment to be an acceptable isolation barrier, if it is

-i provided with means for positive closure. The use of additional descriptive text provided in TS Bases or Definitions (or in the UFSAR), is an acceptable means of clarifying specific TS cperability requirements.

The staff concludes that the licensee's response is acceptable, and the TER discrepancy is resolved.

L 2.1.3 Periodic Testina Of HEPA Filter Air Flow Distribution Deficiency Cited in TER: The licensee's proposed TS change added a requirement to perform an air distribution surveillance test following each complete or partial replacement of an HEPA filter bank or any structural maintenance on the HEPA filter housing, and deleted a requirement for annual periodic testing. The application did not include changes to the associated Bases needed for consistency.

Licensee Response: The revised application includes proposed changes to the Bases to make them consistent with the proposed changes to the SR.

Staff Evaluation: As indicated in the TER, the replacement of the requirement for an annual airflow distribution test by a requirement for an airflow distribution test following each complete or partial replacement of a HEPA filter bank or any structural maintenance on the filter housing is acceptable.

The licensee has proposed consistent SR and Bases changes.

The staff concludes that the licensee's response is acceptable, and the TER discrepancy is resolved.

2.2.3 Reouirement For Drywell Vacuum Breakers To Be Closed While Performina Their Intended Function Additional TS Change Added to Revised Application:

TS 3.7.E.3 presently requires that the drywell vacuum breakers be closed at all times during the applicable modes of operation. An additional proposed change would provide an exception for occasions when a vacuum breaker opens in the performance of its intended function.

Staff Evaluation: Occasionally, during normal plant operations such as inerting or pressure adjustment, a vacuum breaker may be subjected to AP conditions for which it is intended to open.

Such occasion need not invoke entry into the required action statement and associated reports and notifications, since no malfunction or degradat10n of safety systems has occurred. The proposed change is therefore acceptable.

2.2.4 M1thods Of Isolatina Secondary Containment Automatic Isolation Dampers Additional TS Change Added to Revised Application:

TS 3.7.K.2 would be revised to delete specific details on methods to isolate secondary containment penetrations.

The information would be provided in the Bases only.

Staff Evaluation: This change is being made for consistency with 2.1.2 above.

In 2.1.2 above, the staff concludes that specific information on means to isolate a primary containment penetration may be identified in the TS Bases, in lieu of in the LCO.

This change is similarly acceptable for secondary containment isolation.

2.2.5 Editorial Correction Additional TS Change Added to Revised Application:

TS 4.7.L.1,a states:

Annually it shall be demonstrated that pressure drop across the combined high efficiency and charcoal filters is less than 11 inches or water in the flow range of 3600 to 4000 cfm.

The licensee proposes to change it to read:

Annually it shall be demonstrated that pressure drop across the combined high efficiency and charcoal filters is less than 11 inches of water in the flow range of 3600 to 4000 cfm.

Staff Evaluation: The proposed change is a typographical correction only.

It would have ho effect on the associated LC0 or SR and is therefore acceptable.

2.2.6 Secondary Containment Isolation Devices Additional TS Change Added to Revised Application:

In the 3/4.7.K Bases, references to "SCIVs" would be changed to " secondary containment isolation valves / dampers."

Staff Evaluation: The proposed change would bring the Bases terminology into consistency with the LC0/SR terminology with no effect on actual operability and surveillance requirements of the associated safety systems. The change is therefore acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Iowa State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

S This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes a surveillance requirement.

The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (59 FR 34665). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR Sl.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principsi Contributor:

W. Long Date: October 26, 1994

Attachment:

Technical Evaluation Report prepared by SCIENTECH, Inc.

Technical Evaluation Report Prepared By SCIENTECH, Inc, Related to Request for Technical Specification Change IOWA ELECTRIC LIGHT AND POWER COMPANY CENTRAL IOWA POWER COOPERATIVE CORN BELT POWER COOPERATIVE DUANE ARNOLD ENERGY CENTER DOCKET NO, 50 331 INTRODUCTION By letter dated March 27,1992, Iowa Electric Light and Power Company, the licensee, requested changes to the Technical Specificadons (TS) for the Duane Amold Energy Center (DAEC). On August 13,1993, SCIENTECH, Inc. was tasked by the NRC to review the requested changes to the DAEC TS and prepare a Technical Evaluation Report (TER). A draft TER was provided to the NRC for review on September 29,1993. The report was finalized following discuss 5ns with the NRC staff on October 13,1993.

DISCUSSION a

The changes requested by the licensee would revise the limiting conditions for operation and the surveillance mquirements for primary containment integrity, secondary containment intecrity, and associated systems and equipment addressed in section 3.7 of the DAEC Technical Specifications, to improve their clarity and consistency with the Standard Technical Specifications (STS). The requested changes also would add limiting conditions for operation and surveillance requirements for drywell average air temperature and secondary containment automatic isolation dampers to the existing TS.

The requested changes resulted from an 'indepenuent evaluation of the DAEC TS completed in 1991, conducted as part of DAEC TS Improvement Program, which included comparisons of the DAEC TS with TS from peer plants, Standard Technical Specifications, and the draft Improved Technical Specifications (NUREG-1433). 'Ihis evaluation identified a number ofimprovements that should be made to the DAEC TS, including the addition of specifications related to the drywell temperature and secondary containment

. ATTACHMENT

1 i

isoladon dampers. For comparison with the Standard Technical SpeciScations, the, licensee used the Technical Specifications issued by the NRC for the Hope Creek Generadng Station (NUREG-1202) in July 1986. These are the latest TS issued by the STC for an operating BWR-4 plant and comparison of t'. DAEC TS to the Hope Creek TS is acceptable to the NRC staff. Accordingly, we have used NUREG-1202 as an example of the STS for comparison with the DAEC TS.

EVALUA' HON We have performed an item by item evaluation of each of the changes requested by the licensee. The results are presented in the enclosum. A large number of the changes are administrative or editorial in nature, resulting from a reorganization of the TS Section 3.7 material to track more closely the organizadon of the STS. These have no effect on plant safety. A number of proposed changes would result in no change or no change in intent from the existing limiting conditions for operation, action statements, and surveillance requirements of the DAEC TS; they merely move these requirements into the revised organizational format for Section 3.7, and do not impact plant safety. In many instances, where plant-specific considerations allow, the proposed changes would incorporate the limits of the STS in place of those in the exisdng DAEC TS. Finally, there are several instances where the proposed changes are not in accord with either the STS or the existing DAEC TS. In these cases, we have analyzedde changes and found them to be acceptable.

However, in several instances, as noted in this TER and the evaluation matrix, we have identined shortcomings which we believe the licensee should be urged to correct.

1 For purposes of shorthand identification of the types of changes, the enclosure indicates for each change the assigned review category or categories. These review categories are defined as follows :

1.

Administradve/ editorial change and therefore acceptable.

l 2.

No change from the intent of the existing TS. Does not result in a decrease in safety from the existing TS and therefore acceptable.

3.

Consistent with the STS and therefore acceptable.

f 4

Not in accordance with the STS or the existing DAEC TS, but has been analyzed and found acceptable.

5.

Unacceptable without additional justification.

1 2-r.-.m e

~"

A problem adses when attempting to compare the DAEC TS with the STS due to variations in the definitions of Operadonal Conditions. These differences are compared in the following table:

Operational Condition Definniomi Standard Tech Specs Duane Arnold Power Operation -

Reactor Power Operation Mode switch in RUN position Mode switch in STARTUP or RUN Reactor coolant at any temperature Reactor critical and above 1% rated power Startup Hot Standby Condition Mode switch in STARTUP / HOT Mode switch in STARTUP / HOT STANDBY STANDBY Reactor coolant at any temperatum Reactor coolant temperature >212*F Reactor pressure <1055 psig Hot Shutdown Hot Shutdown Mode switch in SHUTDOWN Reactorin SHUTDOWN mode Reactor coolant >200*F Reactor coolant >212*F Cold Shutdown Cold Condition Mode switch in SHUTDOWN Reactor coolant 5212*F Reactor coolant 5200*F Refueling

' Cold Shutdown Mode switch in SHUTDOWN or Reactorin SHUTDOWN mode REFUEL Reanor coolant $212*F Reactor coolant 5140*F Reactor vessel vented to atmosphere When attempting to adjust the DAEC TS to the STS format, these variations in definitions of the operating condidons msult in specified temperature limits for DAEC that are slighdy

' higher than the limits specified in the STS. However, the 212*F used by DAEC has been previously reviewed and approved by the NRC staff, and there is no justification caused by this requested change for reducing this to the 200*F value used in the STS.

In each instance, the proposed changes would result in TS which are as good as or better than the existing DAEC TS. The addition of requirements mgarding the drywell average air temperature and secondary containment isolation dampers are distinct improvements from the exisdng TS. The licensee's letter states that as of the dme of the submittal of the request, an acceptable method of performing surveillance testing for actuation times on the 3

secondary containment isoladon dampers had not been developed, but that a test was'urider development and would be submitted as a separate request at a later date. While the absence of a suitable surveillance test for the isolation damper actuation times mpresents a deficiency in the proposed TS, we do not view it as critical at this juncture. The addition of requirements in the mvised TS on the secondary containment isolation dampers is a considerable improvement in and ofitself. He surveillance test can be added later.

However, the licensee should be encouraged to remedy this deficiency at an early date.

In addition, we have identified the following deficiamies which are not cause for rejection of the proposed TS change, but which we believe should be corrected by the licensee at an early date.

1. While the DAEC FSAR Section 6.5 states that the secondary containment is maintained at a negative 1/4-inch of water pressure during normal operadon, there is no requirement in either the existing or proposed TS to periodically verify this negative pressure. Further, the TS do not specify or require tesdng to verify the maximum time for SGTS operation to achieve the 1/4-inch of water vacuum in secondary containment. These are shortcomings in the TS which the licensee should be urged to correct.

2. The Bases for new TS sections 3.7.B;md 4.7.B include an added discussion of the actions to t : taken in the event that one or more primary contamment isolation valves are inoperable. In general, this is an improvement. However, the discussion includes use of "a check valve inside primary containment with flow through the valve secured" as an acceptable isolation barrier. These words are not consistent with TS 3.7.B and should be corrected.

3. The Bases for Section 3.7.L and 4.7.L in the proposed revised TS, which have not been changed from the Bases of the existing DAEC TS, state that "... air distribution (across the HEPA filter bank) should be determined annually..." However, proposed revised TS 4.7.L.I.c requires an air distribution demonstration to be performed "after each complete or partial replacement of a HEPA filter bank or after any structural maintenance on the system housing." The Bases should be revised to suppon the revised requirement for the air flow demonstration.

4

CONCLUSION Overall, we conclude that the revised TS Section 3.7 would be a distinct improvement over the existing DAEC TS. The revised TS would track the STS more closely and would be more precise and easier to understand. We recommend that the NRC accept the requested changes to the DAEC TS and give consideration to the three deficiencies discussed above.

a

Enclosure:

Evaluation Matrix -- Proposed Changes to DAEC Technical SpeciDcations Revisions to Section 3.7 (RTS 246) 5

EVALUATION MATRIX PROPOSED CilANGES TO Tile DAEC TECIINICAL SPECIFICATIONS CONTAINMENT SYSTEMS Section _ 3.7 (RTS 246)

Prepared By:

SCIENTECH, Inc.

Contract Number NRC-03-93-031 Task Order Number 93-06 s

u rw

DilANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAl, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS I TS Page Review N o.

Proposed Change Evaluation of the Proposed Change Categon iii ne Table of Contents has been revised to renect that This is an administrative change to conform the Table 1

Section 3.7, " Containment Systems," has been of Contents for Section 3.7 to the revised contents of renamed " Plant Containment Systems." Subsections A-the section as proposed by this requested change. It D have been deleted and replaced wah subsections A-does not affect plant safety and is therefore acceptahic.

M which correspond to the revision to TS section 3.7.

De Surveillance Requirements and page numbers have also been revised accordingly.

vi In the List of Tables, the page at which Table 4.7-1 Revised pagination to reflect the proposed changes I

appears has been revised to correspond to the results in Table 4.7-1 appearing on a different page.

pagination of TS section 3.7.

His is an administrative change and is acceptable.

1.0-4 Definition'15 " Primary Containment Integrity", has This proposed change would bring the DAEC 2

heen revised to be more consistent with STS dqnnition definition of Priniary Containment Integrity more 1.31, " Primary Containment Integrity", Subspction a.

nearly into conformance with the Standard Technical and c. of previous TS definition 15 have been replaced Specifications (STS) definition. Adoption of this with new subsection a. which is identical to subsection revised definition would not result in any relaxation of

a. of STS definition 1.31 except for specific the requirements for closure of primary containment discussions of the PCIV Table (which have been penetrations from that mquired by the existing DAEC relocated to an Administrative Procedure) and Technical Specifications (TS), and would not result in incorporation of a statement allowing the valves to be any decrease in the integrity of the primary opened to perform necessary operational activities. containment. He change is, therefore, acceptable.

Subsection d. of previous TS definition 15 has been re-designated as subsection c.

l l

Oe l':y'e i 1

DUANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAI. SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 1.0-4 Definition 16, " Secondary Containment Integrity", has This proposed change wocid bring the DAEC 2

been revised for clarity and to be more consistent with definition of Secondary Containment Integrity more STS definition 1.38, " Secondary Containment nearly into conformance with the STS definition.

Integrity". Subsection c. of previous TS definition 16 Adoption of mis revised definition would not result in has been replaced with subsection a. of previous TS any relaxatit n of the requirements for closure of definition 1.38 except for the discussion of a secondary secondary containment penetrations from that required containment isolation valve / damper table. De list of by the existing DAEC TS, and would not result in any applicable valves / dampers wi'l be located in an decrease in the integrity of the secondary containment.

Administrative Procedure.

Additionally, a note De change is, therefore, acceptahic.

allowing the valves / dampers to ne opened to perform operational activities has been added. The term

" OPERABLE" has been capitalized in subsections b.

and c. to denote that it is a term defined in TS section 1.0.

3.1-3 The reference to specification 3.7.B in TS'section Page 3.2-3 was changed by Amendment 196 to the NA 3.2.D.2," Reactor Building isolation and Standby Gas DAEC TS, issued April 14, 1993, after this Treatment System," has been changed to section 3.7.

amendment request was submitted t y the licensee. This His more general reference reflects the re-organization requested change, therefore, is no Icnger applicable.

of TS section 3.7.

3.5-10a The reference to specification 3.7.A.I in TS section This proposed change is administrative in nature and 1

3.5.G.4 has been changed to section 3.7. This more merely reflects the revisions in the organization of general reference reflects the re-organization of TS Section 3.7. It has no impact upon plant safety. It is, section 3.7.

therefore, acceptable.

3.5-16 The reference to section 3.7.A.! in the Bases to TS This proposed change is administrative in nature and I

sections 3.5.B and 3.5.C has been changed to section merely reHects the reorganization of Section 3.7 of the 3.7. This more general reference reflects the re-DAEC TS that would result from this amendment organization of TS section 3.7.

request. It is, therefore, acceptable.

IWe2

DUANE ARNOLD ENERGY CENTER (DAEC)

TECllNICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-1 The title of TS section 3.7.A has been changed from Ris change is administrative in nature and is necessary I

" Primary Containment" to " Primary Containment to accommodate the revised organization of Section Integrity."

3.7. It does not affect plant safety and it is, therefore, acceptable.

3.7-1 Revised TS section 3.7.A.I contains the Primary This is an administrative and editorial change that I

Containment LCO previously located in TS section moves the LCO for primary containment integrity from 3.7.A.2. The reference to section 3.7.D.2 has been its position in the existing DAEC TS to a new position revised to 3.7.B.2. The term, " Primary Containment in Section 3.7 and adds capitalization to tae term Integrity" has been capitalized to denote that it is a term " Primary Cortainment integrity" to indicate that it is defined in TS section 1.0.

defined in Section 1. No changes am made to the LCO itself, and the change is, therefore, acceptable.

3.7-1 De specifications in previous TS section 3.7A. I are This is an administrative change necessitated by the I

now located in TS section 3.7.G.

reorganization of Section 3.7. The movement of the specifications to the new position does not affect plant safety and is acceptabic.

3.7-1 New TS section 3.7.A.2 specifies what actions are to De movement of the LCO is administrative in nature I,3 he taken when the requirements of Primary and is acceptable. The change to the LCO conforms Containment Integrity are not met. The actions the DAEC TS to the STS, results in a more precise (previously located in TS section 3.7.A.8) have been statement of the requirements for maintaining Primary revised and are now consistent with the actions of STS Containment Irnegrity, and does not in any way relax section 3.6.1.1.

the requirements provided by the existing DAEC TS.

He changes are, therefote, acceptable.

3.7-1 The title of TS section 4.7.A has been changed from his is an administrative change, conforming the title to i

" Primary Containment" to " Primary Containment its counterpart in Section 3.7.A. It does not affect Integrity."

plant safety and is, therefore, acceptable.

Ibge 3

DilANE ARNOLD ENERGY CENTER (DAEC)

TECIINICAI. SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-1 Revised TS section 4.7.A.I contains the Primary This is an administrative and editorial change that i

Containment Integrity surveillance requirements moves the surveillance requirements to verify primary previously located in TS section 4.7.A.2. The term, containment integrity from their position in the existing

" Primary Containment Integrity" has been capitalized to DAEC TS to a new position in Section 4.7.A.1 and denote that it is a tenn defined in the TS section 1.0.

adds capitalization to the term " Primary Containment Integrity" to indicate that it is defined in Section 1.

Here are no changes to the surveillance requirements themselves. The change is, therefore, acceptable.

3.7-I The subtitle of TS section 4.7.A.I.a. " Type A Test" is His is an eJitorial change and is acceptable.

I no longer underlined.

3.7-1 In TS section 4.7.A.I.a. (1), the reference to TS This is an administrative change necessitated by the I

section 4.7.A.2.a. (9) has been revised to 4.]. A.I.a.

revised organization of Section 3.7. He existing TS (8).

erroneously references 4.7.A.2.a. (9) instead of 4.7.A.2.a. (8). This change corrects the reference in the revised TS to 4.7.A.I.a. (8). The changes are, therefore, acceptable.

3.7-2 Re underlining of subtitles of TS sections 4.7.A.I.a. Dese are editorial changes and are acceptable.

1 (7)- 4.7.A.1.a. (9) and 4.7.A.I.h has been deleted.

3.7-2 In TS section 4.7.A.I.a. (9), the reference to TS These are administrative changes to conform to the I

section 4.7.A.2. (a) (8) has been revised to 4.7.A.I.a.

revised organization of Section 3.7 and are acceptable.

(8). The reference to TS section 4.7.A.2. (d) bas been revised to 4.7.A.I.d.

3.7-3 De underlining of subtitles of TS sections 4.7.A.I.b. These are editorial changes only and are acceptahic.

1 (1), 4.7. A. I.b.

(2), 4.7. A. I.c, 4.7. A. I.d, and 4.7.A.I.d. (1) has been deleted.

3.7-4 The underlining of subtitles of TS sections 4.7.A.I.d. Rese are editorial changes only and are acceptahic.

1 (2). 4.7. A.I.d. (4) has been deleted.

l' ace.

DilANE ARNOI D ENERGY CENTER (DAEC)

TECIINICAI, SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-7 The note denoted by "*" has been deleted due to the This is an administrative change necessitated by the I

changes to TS section 3.7.B.2. The note denoted by revised wording of proposed Section 3.7.B.2.h. It has

"* *" has been changed to "*."

no affect on plant safety and is acceptable.

3.7-7 TS section 4.7.B. has been changed from " Standby This is an administrative change necessitated by the I

Gas Treatment System" to " Primary Containment proposed change in the title of Section 3.7.B. Itis Power Operated Isolation Valves "

acceptable.

3.7-7 TS section 4.7.B.I contains the Primary Containment These surveillance requirements are moved without i

Power Operated Isolation Valve surveillance change in content to the new location. His change is requirements previously located in TS section 4.7.D. I.

administrative in nature and is acceptable. He change The note previously denoted by "*" has been changed in reference to the footnotes avoids possible confusion to "#."

The note previously denoted by "**" has been with the footnote to Section 3.7.B.2.b and is editorial changed to "##."

in nature. It is acc( plable.

3.7-7 in the note denoted by "#", the reference to T'S section This is an administrative change necessitated by the 1

4.7.D.I.a has been revised to 4.7.B.I.a.

morganization of the material in Section 3.7.

Itis acentable.

3.7-7 In the note denoted by "##", the reference to TS section This is an administrative change necessitated by the 1

4.7.D.I.b has been revised to 4.7.B.I.h. The word reorganization of the material in Section 3.7. Itis

" suction" has been capitalized.

acceptable. In the proposed revised TS, the word

" suction" has not been capitalized as stated in the amendment request. Ilowever, this does not affect the acceptability of the proposed change.

3.7-8 TS section 3.7.B.2.c (formerly section 3.7.D.2.c) has The proposed revision clarifies the wording of this 2, 3 been revised to be consistent with action a.3 of STS section and brings it into conformance with the section 3.6.3. The footnote "**" has been changed to wording of the STS. There is no change to the requirement of the LCO. It is, therefore, acceptable.

l' age 6

DUANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAI, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review N o.

Proposed Change Evaluation of the Proposed Change Category 3.7-8 In TS section 3.7.B.3 (formerly 3.7.D.3), the The changes in the referenced TS sections are made to I, 2, 3 references to TS sections 3.7.D.1 and 3.7.D.2 have accommodate the revised organization of Section 3.7, been revised to 3.7.B.1 and 3.7.B.2 respectively. The and are acceptable. The revised wording of the requirement to "be in the Cold Shutdown condition requirement novides a more precise description of within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" has been changed to "be in at least what is required, conforms the wording to the STS IlOT SIIUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and COLD requirement, and does not result in any decrease in the SilVTDOWN in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

These protection afforded to the primary containment shutdown requirements are consistent with the other integrity. It is, theitfore, acceptable.

shutdown requirements of this chapter.

3.7-8 The note denoted by "*" has been added and is The addition of this footncte is an administrative I

identical to the note on TS page 3.7-7.

change necessitated by a page change for 3.7.B.2.c. It represents no change from the requirement of the existing TS, and it is, therefore, acceptable.

3.7-8 TS sections 3.7.B.4, " Purging," and TS'section This is an administrative change to accommodate the 1, 2 3.7.B.4.a contain the requirements previously located revised organization of Section 3.7.

There is no in TS section 3.7.A.9. The underlining of the subtitle change to the requirement from th; t in the existing TS of TS section 3.7. A.9 has been deleted.

and it is, therefore, acceptable.

3.7-9 The title of TS section 3.7.C has been changed from Ris is an administrative change to accommodate the I

" Secondary Containment to "Drywell Average Air revised organization of Section ' ~ It is acceptable.

Temperature."

ISge 7

DUANE ARNOLD ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS 1

a TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-9 TS section 3.7.C.1 is a new specification for drywell This new specification makes the DAEC TS conform 4

average air temperature that is consistent with the more closely to the STS by the addition of an LCO on drywell average air temperatute LCO contained in STS drywell temperature. The temperature limit is set at 3.6.1.7. De specified applicability, however, is the 135'F, which is the same as the STS temperature limit, same as specified in TS section 3.7.A.I. " Primary and is the temperature used in the DAEC Design Basis Containment Integrity" (without the exception for low Accident calculations. De LCO is applicable when the power physics testing).

reactor is critical or when fuel is in the reactor vessel and the reactor tearperature is above 212*F. The comparable STS requirement is that the drywell temperature LCO is applicable during Operational Conditions 1, 2 and 3.

Operational Condition 3 specifies a reactor temperature >200*F. The proposed DAEC LCO thus is not quite as tight as the LCO for the STS. Ilowever, the DAEC LCO applicability for control of drywell temperature is the same as the DAEC l

LCO applicability for control of primary containment integrity, which previously has been reviewed by the staff and found acceptable. There is no trason to have tighter controls on drywell temperature applicability than on primary containment integrity. Dus, since this i

is an added requirement not present in the existing TS; since it conforms closely to the STS requirement, varying only in the specified reactor. coolant temperature above which the LCO is applicable; and since its applicability is the same as for the previously approved applicability for primary containment integrity controls, we find the change acceptable.

3.7-9 TS section 3.7.C.2 contains the action statement for This action statement conforms the DAEC TS to the Specification 3.7.C.I. These actions are identical to action statement of the STS and is acceptable.

3 ','

the actions required by STS section 3.6.1.7.

15cc R

~-

DllANE ARNOLis ENERGY CENTER (DAEC)

TECilNICAl, SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Ch:mge Evaluation of the Proposed Change Category 3.7-9 The title of TS section 4.7.C has been changed from This is an administrative change to conform the section i

" Secondary Containment" to "Drywell Average Air title to the title its counterpart Section 3.7.C. It is Temperature."

acceptable.

3.7-9 TS section 4.7.C.I contains drywell average air The specified surveillance requirements are the same as 4

temperature surveillance requirements similar to the those contained in the STS except that the locations for survei; lance requirements of STS section 4.6.1.7. He sampling to determine volumetric average drywell reference to volumetric average contained in the STS temperature are not specified. The Bases for Section surveillance requirement is located in the Bases to 3/4.7.C discuss sampling at various elevations in the DAEC TS section 3.7.C.

drywell to obtain a volumetric average. Sample points are not specified, but the stated intent is similar to that of the STS. Since the requirement for a drywell temperature limit is an added requirement that will enhance plant safety, we find this change acceptable.

3.7-10 The title of TS section 3.7.D has been changed from This is an administrative change to accommodate the i

" Primary Containment Power Operated Isoiation revised organization of Section 3.7. It is acceptable.

Valves" to " Pressure Suppression Chamber - Reactor Building Vacuum Breakers".

3.7-10 TS section 3.7.D.1 contains the LCO for the Pressure This LCO has been modified to correspond to the 1,3 Suppression Chamber - Reactor Building Vacuum werding of the STS. The intent of the LCO has not Breakers previously located in TS section 3.7.A.3.a. changed from that of the existing TS. He change is an This section has been revised to be consistent with STS improvement and is, therefore, acceptable. The section 3.6.4.2 " Reactor Building - Suppression relocation of the setpoint specification to Section Chamber Vacuum B reakers".

The specified 4.7.D.3 is consistent with the organization of the TS applicability is the same as required in current TS and is acceptahic. Capitalization of the term " primary section 3.7.A.3.a. De setpoint specified in present TS Containment integrity" has no affect on plant safety and section 3.7.A.3.a has been relocated to surveillance is acceptable.

requirement 4.7.D.3. The term, Primary Containment Integrity, has been capitalized.

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3 3

DtlANE ARNOLD ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-10 TS sections 4.7.D.2 and 4.7.D.3 contain the Pressure The relocation of these surveillance requirements ir[

2,4 Suppression Chamber Reactor fluilding Vacuum consistent with the revised organization of TS Section Breakers surveillance acquirements previously located 3/4.7 and is acceptable. The requirement of the new in TS section 4.7. A.3.a.

These surveillance TS Section 4.7.D.2 to verify operability of each requirements have been revised as follows:

vacuum breaker assembly valve once per quarter by cycling the valve through one complete cycle, with TS section 4.7.D.2 now specines that the position concurrent verification of the operability of the valve indication shall be verified as part of the quarterly position indicators, is a more precise way of stating cycling test.

the intent of existing TS 4.7.A.3.a. and is acceptable.

The requirement of Section 4.7.D.3 for quarterly TS section 4.7.D.3 now specines that the opening verification of the differential opening pressure for the setpoint of s L.5 psid shall be demonstrated. This vacuum breakers is an improvement to the requirement setpoint was previously located in TS section of the existing TS Section 3.7. A.3.a and is acceptable.

3.7. A.3.a.

De STS require monthly surveillance intervals for the vacuum breaker valves, while the proposed DAEC TS require quarterly surveillance imerv.ds. Thus, the proposed DAEC requirements do not meet the STS requirements. Ilowever, they are the same as required by the existing DAEC TS which the staff has previously reviewed and found to be acceptah!c. The quarterly surveillance intervals are, therefore, acceptahic.

3.7-11 The title of TS section 3.7-E has been changed from This is an administrative change to accommodate the i

" Main Steam isolation Valve Leakage Control System revised organization of Section 3.7. It is acceptable.

(MSIV-LCS)" to "Drywell - Pressure Suppression Chamber Vacuum Breakers".

~.

l l

Page II I

DUANE ARNOLD ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-11 TS section 3.7.E.1 contains the LCO for the Drywell - This LCO has been modified to correspond to the 3, 4 Pressure Suppression Chamber Vacuum Hreakers wording of the STS. The applicability of the LCO is previously located in TS section 3.7.A.4.a.

This the same as is required by the existing TS which, as section has been revised to be consistent with the discussed earh. in the evaluation for Section 3.7.C.I.

Suppression Chamber - Drywell Vacuum Breaker LCO is nearly identital to the applicability requirements of contained in STS 3.6.4.1. The specified applicability, the STS and is acceptable. Deletion of the words however, is the same as required in current TS section "except during testing" strengthens the LCO and is 3.7.A.4.a except that the reference to "except during consistent with the STS u hich has no such exception.

testing" has been deleted. "Prunary Containment Capitalization of " primary containment integrity" has Irtegrity" has been capitalized.

no affect on phnt safety. In sum, this proposed change strengthens the LCO and is acceptahic.

3.7-11

'S sections' 3.7.E.2 - 3.7.E.4 contain the action ne action statements of TS sections 3.7.E.2 through 2, 3 statements for specifications 3.7.E.1. These ac(ions. 3.7.E.4 apply the requirements of the STS to the previously located in TS sections 3.7.A.4.b - DAEC LCO with one exception. The STS specifies 3.7.A.4.d. have been revised to be consistent with the that with one of the vacuum breaker position indicators actions of STS section 3.6.4.1. Specifically:

inoperable, verification that the vacuum breaker is De actions of TS section 3.7.E.2 are identical to closed is determined by confirming the ability to maintain a 0.5 psi AP across the breaker for one hour action a. of STS section 3.6.4.1.

without makeup. The DAEC-specific method for De actions of TS section 3.7.E.3 ire identical to verification that the vacuum breaker is closed is to action b. of STS section 3.6.4.1.

verify that the total drywell to suppression pool bypass area is less than 0.2 ft 2. This is in the existing TS and De actions of TS section 3.7.E.4 are identical to is applied to the revised TS in lieu of the STS method.

action c. of STS section 3.6.4.1 with the following His does not represent a reduction in safety from that exception. The actions of TS section 3.7.E.4.b are afforded by the existing TS and is acceptable. Overall, DAEC-specific and were previously located in TS the revised TS regarding the Drywell - Pressure section 3.7.A.4.b. He specified time limits, Suppression Pool Vacuum Breakers represents a however, are in accordance with the time limits of considerable improvement over the existing TS and is action C.2 of STS section 3.6.4.1.

acceptable.

Page 12

Dti/ E ARNOI.D ENERGY CENTER (DAEC)

TEC11NiCAl, SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7 11 The title of TS section 4.7.E has been changed from Dis is an administrative change to accommodate the i

" Main Steam Isolation Valve leakage Control System" revised organization of Section 3.7. It is acceptable.

to "Drywell - Pressure Suppression Chamber Vacuum Breakers".

3.7-11 TS section 4.7.E.I is a new surveillance requirement his new surveillance requiremer.t. confomiing to the 3

and is consistent with STS section 4.6.4.1.a.

STS, represents an improvement from the existing TS and is acceptable.

D 8

t 85

• 4 l

DUAWE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CIIANGE (RTS-24(.)

REVISIONS TO TS SECTION 3,7 -- CONTAINMENT SYSTEMS TS Page Review N o.

Proposed Change Evaluation of the Proposed Change Ca'n 33-11 TS sections 43.E.2 - 43.E.4 contain the Drywell - Relocation of the surveillance requirements is an 1

Pressure Sup[:ression Chamber Vacuum Breaker administrative change necessitated by the revised surveillance requirements previously located in TS organization of Section 3.7, and is acceptable.

sections 43. A.4.a - 4.7.A.4.d.

Tisese surveillance requirements have been revised as follows:

TS section 4.7.E.2 has been reworded for clarity The rewording of this surveillance requirement is an I, 2, 4 and now specifies that the r " lion indication shall editorial ch 1ge to improve clarity, while the addition be verified as part of the cy

. test. His of the requirement to verify position indication is an surveillance requirement v. neviously located in improvement to the existing TS. This change is TS section 4.7.A.4.a.

acceptable.

TS section~ 43.E.3 contains the inspection Deletion of the requirement to immediately exercise all i I,4 requirement previously located in TS section OPERABLE vacuum breakers and at 15-day intervals 43.A.4.c. De requirement to exercise all thereafter upon discovery of an inoperable vacuum OPERABLE vacuum breakers upon identification breaker represents an improvement in safety in that it of a vacuum breaker which is inoperabic for eliminates the need for unwarranted wear of the opening (also located in previous TS section OPERABLE e 43.A.4.c) has been deleted. De asterisk "*" has human error.quipment and decreases the possibility of The monthly cycle tests of the also been deleted.

OPERABLE vacuum breakers is sufficient to assure their continuing operability. Deletion of the asterisk is an editorial change and is acceptable.

Re surveillance rcquirement for determining This change in the location of the requirement to 2

Drywell - Pressure Suppression Chamber bypass monitor bypass leakage does nat affect the intent of the leakage previously located in TS section 4.7. A.4.b existing DAEC TS and is acceptable.

has been deleted. His surveillance requirement is already part of the actions specified in TS section 3.7.E.4.b.

TS section 4.7.E.4 contains the test requirement Relocation of the test requirement does not affect the 2

previously beated in TS section 4.7.A.4.d. The intent of the existing DAEC TS and is acceptable. Test details of this test have been deleted.

details are not needed in the TS.

ISge 14

DUANE ARNOLD ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS T5 Page Review N o.

Proposed Change Evaluation of the Proposed Change Category 3.7-11 De note "*" at the bottom of the page has been Dis footnote explained a previous amendment change.

I deleted.

Its deletion is editorial in nature and does not affect the TS rettuirements. The change is acceptahic.

3.7-12 The title of TS section 3.7.F has been changed from Dis is an administrative change to accommodate the i

" Mechanical Vacuum Pump" to " Main Steam Isolation revised organization of Section 3.7. It is acceptable.

Valve leakage Control System (MSIV-LCS)".

3.7-12 TS section 3.7.F.1 contains the LCO for the MSIV-Relocation of the LCO is an administrative change to I

LCS previously located in TS section 3.7.E.8 The accommodate the revised organization of Sectio,3.7.

reference to TS section 3.7.E.2. has been revised to it is acceptable.

3.7.F.2.

3.7-12 TS section 3.7.F.2 contains the actions previotply Relocation of this action statement is an administrative 1, 3, 4 located in TS section 3.7.E.2. The statement allovymg change to accommodate the revised organization of operation for 30 days after one MSIV-LCS is Section 3.7, and is acceptable. The addition of the inoperable "provided all active components of the other words " verified to be" allows the og crators to rely MSIV-LCS subsystems are OPERABLE" has been upon the periodie (monthly) tests of t ie other MSIV changed to " verified to be OPERABLE".

components to verify operability rather than require potentially non-conservative, conditional surveillance testing of these components, which could result in equipment failure due to the testing and introduce the added possibility of human error. This verification of operability is consistent with the requirements of STS Section 4.4.7 for the MSIVs. Elimination of this additional testing does not substantially decrease the I

assurance of operability of the redundant MSIV components, and is acceptable.

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DilANE AltNOI.D ENERGY CENTER (DAEC)

TECilNICAI. SI'ECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Iteview No.

Proposed Change Evaluation of the Proposed Change Category 3.7-13 TS section 3.7.G " Suppression Pool lxvel and This is an administrative change to accommodate the 1, 3, 4 Temperature" has been added. This new TS section revised organization of Section 3.7. It is acceptable.

contains the suppression pool level and temperature Addition of the requirement for suppression pool requirements previously located in TS section 3.7.A.I. operabilit) to the LCO is an enhancement to the The LCO now specifies that the suppression pool shall existing DA3C TS and is acceptable.

he OPERABLE. The applicability of the suppression pool level and temperature limits has been revised to Deletion of the requirement to maintain the limits on delete references to " work is bcing done which has the suppression pool water volume when " work is being potential to drain the vessel",

done which has the potential to drain the vessel" has no impact en plant safety during periods of reactor operation since such work is accomplished only during shutdown periods. The revised TS is consistent with the STS which requires suppression pool operability only during Operational Conditions I, 2 and 3.

Existing DAEC TS 3.5.G.4.d requires that, during a refueling outage, operations that have the potential for draining the reactor vessel will be suspended whenever the water level in the suppression chamber falls below the minimum. This is consistent with STS section 3.13.b.l. Thus, we find deletion of the words " work i

is being done which has the poten'ial to drain the vessel" acceptable.

l l

I' age 17

D11ANE ARNOLD ENERGY CENTER (DAEC)

TECllNICAI, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7.13 TS section 3.7.G.1, " Suppression Pool Level",

Relocation of the suppression pool level requirements I,3 contains the LCO for Suppression Pool Level is an administrative change to accommodate the revised previously located in TS sections 3.7.A.I.a and organization of Section 3.7. The revisions to the 3.7.A.I.b. This section has been revised for clarity wording improve the clarity and conform the wording and to be consistent with STS section 3.6.2.1.

to the STS formal The changes are acceptable.

Specifically:

The wording format now follows the STS wording TS section 3.7.G.I.a is consistent with STS section format. There are no changes to the maximum and 2, 3 3.6.2.1.a.l. A reference to indicated suppression minitam specified water levels. Addition of the pool water level (in percent) has been added.

percentages of suppression pool volume to the water level limits adds information not previously provided.

"Ihese changes are acceptable.

This action statement is not present in the existing TS section 3.7.G.I.b is consistent with action a. of DAEC TS. It is an improvement, consistent with the 3

STS section 3.6.2.1. A reference to indichted STS, and is acceptable.

suppression pool water level has been added.

Ibge IX

DilANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO 'IS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-13 TS section 3.7.G.2, " Suppression Pool Temperature" Relocation of the suppressio, pool temperature 1, 3 contains the LCOs for suppression pool temperatures requirements is an administrative change to previously located in TS section 3.7.A.I.c.

This accommodate the revised organizatien of Section 3.7.

section has been revised for clarity. The specified De revisions to the wording improve the clarity and limits and actions are consistent with STS section conform the wording to the STS format. He changes 3.6.2.1. Specifically:

are acceptable.

TS section 3.7.G.2.a specifies the normal This is the same temperature limit specified in the 2

suppression pool temperature limit previously existing DAEC TS. It is acentable, located in TS section 3.7.A.I.c. (1). This temperature limit is consistent with the normal temperature limit specified in STS section 3.6.2.1.a.2.

TS section 3.7.G.2.b is a new LCO which specffies This LCO is tiot present in the existing DAEC TS, 2, 4 what actions are to be taken when average which are silent regarding actions to be taken when the suppression pool water temperature is > 95 'F but pool temperature is >95'F but <l10'; and testing is

< 110 *F during operation and not performing not in progress which adds heat to the pool. The testing which adds heat to the pool. Rese actions 110'F upper limit is allowed by the existing DAEC TS.

am consistent with action b. of STS section 3.6.2.1 This change is an improvement le the TS and is and STS section 4.6.2.1.b.2.a.

acceptable.

TS section 3.7.G.2.c contains the suppression pool This LCO amplifies the requirements stated in the 2,4 water temperature limits during the perfonnance of existing DAEC TS by specifying the actions to be taken testing which adds heat to the suppression pool if the temperature exceeds 105'F during testing which previously located in TS section 3.7.A.I.c. (2).

adds heat to the pool. De actions are consistent with This limit and the specified actions are consistent the STS and am acceptable.

with STS section 3.6.2.1.a.2. (a) and action b.l.

of STS section 3.6.2.1. The requirement to verify temperature is < 110 'F once/hr has been added as an additional conservatism and is consistent with STS section 4.6.2.1.b.2.a.

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DtlANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAl, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7 14 TS section 3.7.G.2.d contains the suppression pool The requirement to scram the reactor if the suppression 2, 4 water temperature limits and actions previously located pool average water temperature exceeds 110'F is the in TS section 3.7.A.I.c. (3). These limits and actions same as in the existing DAEC TS and is acceptable.

are consistent with action b.2 of STS section 3.6.2.1.

'Ihc condition for resumption of power operation (pool The requirement for resuming power operation temperature equal to or less than 95'F) is adequately previously included in TS section 3.7.A.I.c. (3) is stated in TS Section 3.7.G.2.a. Therefore, deletion of adequately covered by revised TS section 3.7.G.2.a this portion of the requirements from the existing TS is and has been deleted.

acceptable.

3.7-14 TS section 3.7.G.2.c contains the suppression pool Relocation of the suppression pool water temperature I, 3, 4 water temperature limit and actions previously located limit requirement is an administrative change to in TS section 3.7.A.I.c.(4). This limit and specified accommodate the revised organization of Section 3.7.

action have been reworded to be consistent with action The revisions to the wording improve the clarity and b.3 of STS section 3.6.2.1.

conform the wording to the STS format. These changes are acceptable. The deletion of the phrase, "during reactor isolation conditions," make the requirement more restrictive and is therefore acceptable.

3.7-15 TS section 3.7. H. " Containment Atmosphere Relocation of the containment atmosphere dilution i

Dilution," has been added. This new TS section requirements is an administrative change to contains the containment atmosphere dilution accommodate the revised organization of Section 3.7.

requirements previously located in TS section 3.7.A.6.

It is acceptable.

l l

l t' age 21

DilANE ANNOI.D ENERGY CENTER (DAEC1 TECilNICAl, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTA!NMENT SYSTEMS -

'lS Page l Review No.

Proposed Change Evaluation of the Proposed Change l Category 3.7-15 TS section 3.7.11.1 contains the requirements De revision of the applicability statement to specify 1, 3. 4 previously located in TS section 3.7.A.6.a.

The that the CAD system need be OPERABLE only when applicability has been revised to specify that the the containment is required to be inerted is a relaxation containment atmosphere dilution system is only of the requirement in the existing DAEC TS, but the required to be operable when the primary containment resulting appliubility is consistent with STS 3.6.6.2 is required to be inerted. De tenn " operable" has been for when the containment must be incited. There is no c;:pitalized. Additionally, the requirement to take the need for the CAD system to be operable when the reactor "out of power operation" has been revised to containment is not required to be inerted. Derefore, l

"be ia at least ilOT SilUTDOWN within the next 12 this relaxation of the requirement in the existing TS is hours and in COLD SilUTDOWN in the following 24 acceptahic. Capitalization of "operabic" is an editorial hours" to be consistent with the other shutdown change and is acceptahic. Replacement of the vague requirements of this chapter.

requirement to "take the reactor out of power

?

operation" with the specified times to be in ilOT SilUTDOWN and COLD SilUTDOWN will provide the operators with firm guidance as to what is required.

The time requirements are consistent with terminology used in the STS and with other action statements related to the primary containment and are acceptabic, t

3.7-15 TS section 3.7.11.2 contains the requirements De basic requirement for the minimum volume of N 2

2, 4 previously located in TS section 3.7.A.6.b.

The to be available, and the need to restore this volume requirement to take the reactor "out of power within 7 days if the specification cannot be met, are operation" has been revised to "bc in at Icast ilOT unchanged from the existing TS and are acceptable.

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 in COLD Replacemer.1 of the vague requirement to "take the SilUTDOWN in the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" to be reactor out of power operation" with the speciGed times consistent with the other shutdown requirements of this to be in llOT SiltJIT)OWN and COLD SHUTDOWN chapter.

will provide the operators with firm guidance as to what is required. De time requirements are consistent with terminology used in the STS and with odn action statements related to the prituary containment ad are acceptabic.

l m 22

~

DUANE ARNOI.1) ENERGY CENTER (I)AEC)

TECIINICAI, SI'ECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-15 TS section 3.7.11.3 contains the requirements His proposed change is identical to the wording of the 2

previous 1rjocated in TS section 3.7.A.6.c.

cxisting DAEC TS and is acceptahic.

3.7-15 TS section 4.7.11., " Containment Atmosphere This is an administrative change to accommodate the i

Dilution", has been added. This new TS section revised organization of Section 3.7. It is acceptable.

contains the containment atmosobe g dilution surveillance requirements previously '

.ted in TS section 4.7.A.6.

3.7-15 TS section 4.7.11.1 contains the surveillance This surveillance requirement is unchanged frota the 2

requirements previously located in TS section requirement in the existing DAEC TS and is accep.able.

4.7. A.6.a.

3.7-15 TS scciion' 4.7.11.2 contains the surveillance This surveillance requirement is unchanged from the 2

requirements previously located in TS se,ction requirement in the existing DAEC TS and is acceptahic.

4.7. A.6.b.

3.7-15 TS section 4.7.11.3 contains the surveillance This surveillance requirement is unt hanged from the 1, 2 requicements previously located in TS section requirement in the existing DAEC TS md is acceptable.

4.7.A.6.c. The reference to TS section 4.7.A.6.a has Revision of the reference is an administrative change to been revised to 4.7.11.1.

accommodate the revised organization of Section 3.7 and is acceptable.

Page 23

DUANE ARNot.D ENERGY CENTER (DAEC)

TECIINICAl SPECIFICATION CllANGE (RTS-246)

(

REVISIONS TO TS SECTION 3.T -- CONTAINMENT SYSTEMS xw

'lS Page No.

Proposed Change Evaluation of the Proposed Change Category Review 3.7-16 TS section 4.7.1, " Oxygen Concentration," has been De movement of the requin ment to the new location is I, 3, 4 added. This new TS section contains the oxygen an administrative change and is acceptabic. Addition of concentration surveillance requirements previously the requirement to verify the oxygen concentration located in TS section 4.7.A.S. The frequency of the within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after placing the mode switch in RUN surveillance however, has been revised to be consistent is a new requirement, comparabic to the STS with STS section 4.6.6.2.

requirement, and consistent with the proposed new LCO 3.7.1.2.

It is acceptahic.

The chenge in surveillance frequency from twice weckly to once every 7 days is consistent with the STS surveillance requirement, and is acceptable.

3.7-17 TS section 3.7.3, %condary Containment" has been His is an administrative change to accommodate the 1

added. This new TS section contains requirements previously located in TS section 3.7.C.

revised organization of Section 3.7. It is acceptable.

3.7-17 TS section 3.7.J.2 contains the requirem6nts His is an administrative change to accommodate the I

previously located in TS section 3.7.C.2. 'The reference to TS section 3.7.C.1 has been revised to mvised organization of Section 3.7. It is acceptable.

3.7.J.l.

3.7-17 TS section 3.7.J.2.c has been revised to be consistent De change in the shutdown requirement pmvides for a 4

with the other shutdown requirements of this chapter.

more orderly shutdown, is consistent with the shutdown requirements elsewhere in this section, and is acceptabic.

3.7-17 TS section 4.7.J. " Secondary Containment' has been his is an administrative change to accommodate the I

added. This new TS section contains surveillance revised organization of Section 3.7. It is acceptable.

re luirements previously located in TS section 4.7.C.

4 Page 25

1)llANE AltNOI.1) ENlt.HGY CENTE!t (1)AEC)

TECIINICAI SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS IS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 13.7-17 TS section 4.7.J.I has been revised to delete all 'Ihis is an administrative change, deleting material that 1,4 mention of historical testing previously described in TS no longer is applicable to the operation of the DAEC.

sections 4.7.C.I.a and 4.7.C.I.h.

It does not affect current plant operations and is acceptabic.

3.7-17 TS section 4.7.J.l.a contains the surveillance The relocation of the surveillance requirement is an I,4 requirements previously located in TS section administrative change and is acceptable. The change in 4.7.C.I.c. He reference to calm wind conditions as < the definition of calm wind speed from 5 mph to 15 5 mph has been revised to < 15 mph.

A new mph is based upon the licensce's engineering discussion of what constitutes calm wind conditions evaluation of the effect of wind speeds on the has been added to the Bases to TS section 3.7.L.

secondary containment manometer readings. The change is conservative in that it requires that secondary containment vacuum he maintained o ter a wider range of wind speeds. It is. therefore, acceptable.

3.7-17 Previous TS section 4.7.C.I.d has been deleted.*This Deletion of this requicement does not materially affect 4

type of verification testing is not required by STS.

plant safety and it climinates unnecessary operation of the SGTS. Most violations of secondary containment are temporary and minor in nature (open doors, penetrations, etc.) and are readily correctable after identification. They do not demand a test to verify the capability of maintaining a vacuum after the violation has been corrected.

Any modifications to the secondary containment boundary which could result in a change in secondary containment operability are subjected to post-modification testing which would confirm the operability of the secondary containment.

De change is, therefore, acceptable.

l Page 26

DllANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAI, SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS

'IS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-17 (Continued)

While there is no requirement in the STS to verify secondary containment integrity after identiGcation of a violation. STS 'iclion 4.6.5.1 does require periodic veriGcation of reactor building negative pressure and closure of secondary containment penetrations, doors, hatches, and blowout pancis. DAEC FSAR Section 6.5 states that the secondary containment is maintained at a 1/4-inch of water vacuum during normal operation, but neither the existing or the proposed DAEC TS require periodic ver6 cation of the secondary containment pressure. While this requested TS change does not justify adding such a requirement to the TS, this is a shortcoming that the licensee should be urged to correct.

Neither the existing nor the proposed TS state a time limit for the SGTS to reduce the secondary containment pressure to a negative 1/4 inch of water. Since the negative pressure in secondary containment is maintained during normal operation, this should not be a problem. Ilowever, upon loss of offsite power and transfer to emergency power, this could become a facter. The STS allow a 375 second time period to establish the negative pressure based upon the results of accident analyses. While this requested TS change does not provide justification for adding a time limit for operation of the SGTS to reduce the secondary containment pressure to the negative 1/4-inch of water, this is a shortcoming that the licensee should be urged to correct.

l' age 27

DUANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAI, SI ECIFICATION CllANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Category

.k 3.7-18 TS section 3.7.K.," Secondary Containment Automatic Dis is a new requirement, not present m the existing 3

Isolation Dampers", has been added.

These DAEC TS. As such, it is an improvement to the requirements were not previously included in the existing TS, consistent with the STS, and is D AEC TS. The requirements of TS section 3.7.K.I acceptabic.

are consistent with the requirements of STS section 3.6.5.2. Specifically:

TS section 3.7.K.1 is consistent with STS This requirement is consistent with the intent of the 3,4 3.6.5.2. The applicability however,is DAEC-STS, but is tailored to be specific to DAEC. It is an specific and the list of applicable valves / dampers is improvement to the existing TS and is acceptable, not included in the TS but will be incorporated into an administrative procedure.

TS section 3.7.K.2 (including sub items a., b., This new requirement, not present in the existing 3.4 and c) are consiste.it with actions a., b., and c., of DAEC TS, conforms the revised TS to the STS STS sections 3.6.5.2. A note, however, has licen requirements with the exception of the note allowing added to TS section 3.7.K.2.c.

This note is intermittent opening of the isolated penetrations under consistent with the note for closed / isolated primary administrative control. His exception is the same as is containment isolation valves.

allowed for the primary containment is alation valves in existing DAEC TS 3.7.D.2 and in proposed revised DAEC TS 3.7.B.2. There is no reason for this new requirement regarding secondary containment isolation dampers to be more restrictive than the requirement for the primary containment isolation valves. 11 is, therefore, acceptabic.

3.7-18 TS section 3.7.K.3 is consistent with the shutdown his action statement follows the format of, but is not 3, 4 action statement of STS section 3.6.5.2.

The as all-inclusive as, the STS in that it does not address requirement to suspend reactor building fuel cask and suspension of core alterations and operations with the irradiated fuel movement is consistent with TS section potential for draining the reactor vessel. Ilowever, it is 3.7.12.a.

a considerable improvement to the existing DAEC TS, and it is acceptabic.

l' age 28

DtlANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAL SI'ECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review No.

Proposed Change Evaluation of the Proposed Change Categog 3.7-18 TS section 4.7.K " Secondary Containment Automatic Dis is a new surveillance requirement, not present in 3, 4 Isolation Dampers", has been added. This surveillance the existing DAEC TS. It is consistent with de STS requirement was not pmviously required by DAEC TS. requirement for testing at least once per operating he surveillance requirement of TS section 4.7.K is cycle, but omits the STS requirement for verifying consistent with the surveillance requirements of STS isolation damper operating times and the requirement section 4.6.5.2 except that surveillance requirements a. for post-maintenance testing of the dampers. Still,it is and c. of STS section 4.6.5.2 are not included. (Post-an improvement over the existing TS and is acceptahic.

maintenance testing has not historically been included in DAEC TS.) Specifically:

TS section 4.7.K.1 is consistent with STS section This statement is partially truc, but the proposed 4

4.6.5.2.b.

surveillance requirement calls only for simulated initiation of the dampers, while the STS require verification that the dampers actuate to their isolaicd position on the test signal.

It is, however, an

~'

improvement over the existing TS and is acceptahic.

3.7-19 TS :cection 3.7.L. " Standby Gas Treatment System," His is an administrative change to accommodate the I

has teen added. This new TS section contains the revised organization of Section 3.7. It is, acceptable.

standby gas treatment system requirements previously located in TS section 3.7.B. The reference to TS section 3.7.B.3 has been revised to 3.7.L.3.

3.7-19 TS section 4.7.L Standby Gas Treatment System", has This is an administrative change to accommodate the I

been added. His new TS section contains the standby revised organization of Section 3.7. It is acceptable.

gas treatment system surveillance requirements previously located in TS section 4.7.H.

l I

1 l' age 29 I

1

DniANE ARNOI,D ENERGY CENTER (DAEC)

TECIINICAl, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS

'IS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-19 TS section 4.7.L t.b has been revised to require that The 22 kw requirement in the revised TS is more 4

the inict heaters of each train be capahic of an output of restrictive than the lI kw requirement in the existing at least 22 kw. Tbc previous TS requirement was lI TS. The licensee states that the 22 kw minimum is k w.

needed to assure that the assumed initial conditions for inlet to the SGTS can be met, but that the temperatun:

rise across the heaters at this heat rate still would be less than the 20'F maximum differential temperature specified in the UFSAR Section 6.5.3.3. The change,

herefore,is acceptable.

3.7-19 TS section 4.7.LI.c has been revised to require that The requirement to demonstrate air distribution after 4

the air distribution demonstration be performed "after "cach compicte or partial replacement of the HEPA cach complete or panial replacement of the llEPA filter filter bank or after any structural maintenance on the bank or afterany structural maintenance on the system system housing" is an improvement to the present housing." This test was previously required to be requirement for annual demonstration.

The performed annually.

requirement is consistent with ASME N510-1989,

" Testing of Nuclear Air Treatment Systems." Any changes to the now distribution would be expected to occur after changes are made to the filters or filter housing rather than on a time-dependent basis. The change, therefore, is acceptable.

3.7-19 in TS section 4.7.LI.g. the reference to TS section This is an administrative change to accommodate the 1

3.7.B.2.b. has been revised to 3.7.L.2.b.

revised organization of Section 3.7. It is acceptable.

3.7-19 in TS section 4.7.L2.a. the reference to TS section This is an administrative change to accommodate the 1

3.7.B.2 has been revised to 3.7.L.2.

revised organization of Section 3.7. It is acceptable.

Page 30 t

DllANE ARNOI.D ENERGY CENTER (DAEC)

TECilNICAI, SPECIFICATION CllANGE (RTS-246)

REVISIONS TO TS SECTION 3.7

-o CONTAINMENT SYSTEMS IS Page Review No.

Proposed Change livaluation of the Proposed Change Category I

3.7-21)

TS section 3.7.L.3 contains the requirements This is an administrative change to accommodate the I

previously located in TS section 3.7.11.3.

The revised organization of Section 3.7. It is acceptable.

wording has been revised for consistency.

Specifically:

The wording "IlOT SilUTDOWN within 12 This is an editorial change which clarifics the intent of I

hours" has been revised to 'llOT SIIUTDOWN the action statement. It is acceptable, within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />".

He wording " suspend fuct handling operations" This change makes the action statement for an 4

has been revised to " suspend reactor building fuct inoperabic SGTS comparable to the action statements cask and irradiated fuel movement." This wording for lack of secondary containment integrity or for is consistent with TS sections 3.7.J and 3.7.K.

incperability of the secondary containment isolation dampers. The revis:d words are more explicit, but may not be as all-ine.usive as the existing words, e.g.,

they could allow movement of fresh fuel to continue.

llowever, since the principal danger of radioactive release stems from movement of irradiated fuel or movement of the fuel cask, the net effect of the change with regard to safety is minimal. Since the safety impact is minimal and since the change conforms the action statement to the comparable statements for secondary containment integrity and for inoperability of the secondary containment isolation dampers, the change is acceptable.

3.7-21 TS section 3.7.M. " Mechanical Vacuum Pump" has His is an administrative change to accommodate the t

been added. This new TS section contains the revised organization of Section 3.7. It is acceptable.

mechanical vacuum pump requirements previously located in TS section 3.7.F.

3.7-21 In TS section 3.7.M.3, the references to TS sections. This is an administrative change to accommodate the 1

3.7.F.I and 3.7.F.2 have been revised to 3.7.M.1 and revised organization of Section 3.7. It is acceptable.

3.7.M.2.

Page 31

DilANE ARNOI.D ENERGY CENTER (DAEC)

TECIINICAI, SPECIFICATION CilANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS

'IS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-21 TS section 4.7.M. " Mechanical Vacuum Pump" has His is an administrative change to accommodate the I

been added. His new TS section contains surveillance revised organization of Section 3.7. It is acceptable.

n quirements previously located in TS section 4.7.F.

3.7-22 The Bases for TS sections 3.7.A and 4.7.A has been His is an editor.d change necessary to accommodate I, 2, 4 changed from " Primary Containment" to " Primary the revised org.ini7;ition of Section 3.7. The new Containment Integrity."

A discussion of the Bases for TS Sections 3.7.A and 4.7.A incorporate requirement to restore primary containmem within I those portions of the existing TS Bases that relate to hour in the event primary containmc.u is inoperabic has primary containment integrity and leak rate testing. The been added.

The Bases infmmation has been added discussion regarding the need to restore primary reorganized for clasity.

containment integrity within I hour is an impmvement. The changes are acceptahic.

3.7-24 De Bases for TS sections 3.7.B and 4.7.B. " Primary This is an administrative change to account for the 1

Containraent Power Operated Isolation Valves", revised organization of Section 3.7, and is acceptable.

contains the information previously located in Ifases section 3/4.7.A.8.

This information has 'bcen reorganized for clarity.

3.7-26 A discussion of the actions to be tak< n in the event that His discussion regarding the need for isolation and the 4

one or more primary containment isolation valves are method ofisolation ofinoperable PCIVs is generally an inoperable has been added to the Bases of section improvement. However, the words relating to use of 3.7.B. and 4.7.B.

"a check valve inside primary containment with flow through the valve secured' as an acceptable isolation barrier is not consistent with the TS 3.7.B and should be corrected.

3.7-26 He Bases for TS sections 3.7.C and 4.7.C "Drywell This is a new Bases section supporting the new TS 4

Average Air Temperature" has been added to provide Section 3/4 7.C. It provides the rationale for selecting additional information on this new specification.

the related LCO limits and surveillance frequency, and

, explains the need for Drywell temperature control.

l l' age 32

DUANE ARNOLD ENERGY CENTER (DAEC)

TECllNICAl, SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS

'lS Page lieview No.

Proposed Change Evaluation of the Proposed Change Category 3.7-27 The Bases for TS sections 3.7.D and 4.7.D. " Pressure This is an administrative change to account for the

1. 4 l

Suppression Chamber - Reactor lluilding Vacuum revised organization of Section 3.7, and is acceptable.

Breakers" contains the information previour!y located The added discussion regarding the need to restore in Bases section 3/4.7.A.3. This section has been operability of inoperable vacuum breakers explains the expanded to provide additional information specific to need for the action statements of TS Section 3.7.D and these vacuum breakers.

is a considerable improvement over the existing wording in the present Bases. It is acceptable.

3.7-28 He Bases for TS sections 3.7.E and 4.7.E. "Drywell-This is an administrative change to account for the

1. 4 Pressure Suppression Chamber V. ruum Breakers" revised organization of Section 3.7, and is acceptable.

contains the information previously located in Bases The added discussion regarding the need to rertore section 3/4.7.A.3. This section has been expanded to operability of inoperable vacuum breakers explains the provide additional infwmation specific to these vacuum breakers.

need for the action statements of TS Section 3.7.E and is a considerable improvement over the existing wording in the present Bases. It is acceptabic.

3.7-29 The Bases for TS section 3.7.F and 4.7.F ' Main This is an administrative change to account for the i

Steam Isolation Valve leakage Control System (MSIV-revised organization of Section 3.7, and is acceptabic.

LCS)" con,ains the information previously h>cated in Bases section 3/4.7.E.

3.7-30 The Bases for TS sections 3.7.G and 4.7.G, This is an administrative change to account for the 1, 4

" Suppression Pool Level and Temperature" contains revised organization of Section 3.7, and is acceptable.

the information previously h>cated in Bases sections The added discussion regarding the need for a 3/4.7. A.1, 3/4.7. A.5, and 3/4.7. A.8.

This maximum water volume in the suppression peal is an l

information has been reorganized for slarity.

improvement and is acceptabic.

Additional details regarding the bases for the muimum suppression pool volume and equivalent indicated

[

levels has been added.

4 Page 33

DUANE ARNOI.I) ENERGY CENTER (DAECl TECIINICAI, SI'ECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS

~IS Page Review No.

Proposed Change Evaluation of the Proposed Change Category 3.7-32 The requirement to maintain the suppression pool His is an editorial change to conform the Bases words I

temperature "below" the normal operating limit of 95 to the requirements of the TS. It does not change the

• F has been changed to "at os below" the normal intent of the wording in the present BASES and is operating limit oi95 'F. His change is consistent with acceptahic.

TS section 3.7.G.2.a.

3.7-33 He reference to Bases section 3.7.A.1 (previously Ris is an editorial change. De deleted reference is no i

located in the first paragraph of previous TS page 3.7-longer needed since the words from previous Bases 48a) has been deleted.

Section 3.7. A.1 are now incorporated in the new Bases section. De change is acceptable.

3.7-33 ne discussion of the daily suppression poollevel and The deleted discussion regarding daily volume and 4

temperature surveillance previously located in the first temperature checks of the suppression pool water are paragraph of the Bases section 3/4.7.A.4," trak Rate adequately covered in the revised Bases for Sections Testing" (but applicable to suppression pool level,and 3.7.G and 4.7.G. Inchision of this discussion would temperature) has been deleted. This mformatipn is be redundam. Therefore, this change is acceptahic.

redundant to the surveillance discussion already included in the Bases for section 3.7.G and 4.7.G.

3.7-34 The Bases for TS section 3.7.11 and 4.7.11, This is an administrative change to account for the i

" Containment Atmosphere Dilution" contains the revised organization of Section 3.7, and is acceptable.

information previously located in the Bases for sections 3/4.7.A.6.

3.7-35 The Bases for TS sections 3.7.1 and 4.7.1, " Oxygen This is an administrative change to account for the 1

Concentration", contains the information previously revised organization of Section 3.7, and is acceptable.

located in Bases section 3/4.7.A.2.

Page 34

D:34NE ARNOI.l> ENERGY CENTER (DAEC)

TECIINICAI. SFECIFICATION LilANGE (RTS 246)

REVISIONS TO TS SECTION 3.7 o-CONTAINMENT SYSTEMS

'lS Page Retiew Ne.

Proposed Change Evaluation of the Proposed Change Category 3.7-36 Additional information has been added to the Bases for This additional information is consistent with the 4

TS section 3.7.1 and 4.7.I stating that the CAD system requirement of revised TS Section 3.7.11 (which refers is not required to be operable during drywell to TS Section 3.71.1) and is acceptable. Contrary to inspections and when the containment is not inerted. the licensce's statement, there is no note added to TS This note is consistent with the note added to TS Section 3.7.I. Rather. the information apparently was section 3.7.1.

incorporated in the text of the TS. In any event, the additional information provided in the Bases supports the requirements of the TS and is acceptable.

3.7-36 De discussion of oxygen monitoring in the last This revision conforms the Bases

• wording to the TS 4

paragraph of the Bases for TS sections 3.7.1 and 4.7.I requirement, which was previously found acceptable, has been changed liom "twice a week" to "once per Therefore, this change is acceptahic.

weck". This corresponds to revised surveillance requirement 4.7.1.1.

3.7-36 nc Bases for TS sections 3.7.3 and 4.7.J. "Secondhry This is an administrative change to account for the 1

Containment" contains the information previohsly revised organization of Section 3.7, and is acceptable.

located in Bases section 3/4.7.A.7.

3.7-37 The Bases for TS sections 3.7.K and 4.7.K. This additional information explains the need for 4

" Secondary Containment Automatic Isolation controls on the operability of the secondary Dampers", has been added to provide additional containment automatic isolation dampers, supporting information on this new specification.

the new TS on this equipment. It is acceptabic.

3.7-38 The Bases for TS sections 3.7.L and 4.7.L. " Standby This is an administrative change to account for the I

Gas Treatment System" contains the information revised organization of Section 3.7, and is acceptabic.

previously contained in Bases section 3/4.7.A.7. The previous reference to TS section 3.7.B.3 has been changed to TS section 3.7.L3.

1 1

Page 35

DtJANE ARNOLD ENI?RGY CENTER (DAEC)

TECilNICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3.7 -- CONTAINMENT SYSTEMS TS Page Review N o.

Propmed Change Evaluation of the Proposed Change Category 3.7-39 The Bases for TS section 3.7.L and 4.7.L. " Standby nese revisions conform the discussion in the Bases to 4

Gas Treatment System", has been revixd to c!arify the the requirements of the proposed revised TS and are in-place and laboratory tests performed on the system. acceptabic. The corresponding numbers presented in Specifically, the previous reference to "less than I the present Bases Section 3/4.7.A.7 are in crTor.

percent bypass leakage" for the charcoal absorbers has been changed to "s 0.1 percent bypass leakage" for the charcoal absorbers. This change is consistent with the requirements of TS sections 3.7.L.2.a. De discussion of laboratory carbon sample test results previously described a radioactive methyl iodide removal efficiency of "at least 99.9 percent for expected accident conditions." This has been changed to "at least 99% for expected accident conditions." This change is consistent with the requirements of TS section 3.7.L2.b.

)

3.7.39 None The Bases for Section 3.7.L and 4.7.L. carried 4

forward from the Bases of the existing DAEC TS, state that "Ilcater capability, pressure drop, and air distribution should be determined annually to show system performance capability." flowever, proposed revised TS 4.7.L.I.c now requires a'. iir distibution demonstration to be performed "after each complete or partial replacement of the llEPA filter bank or after any structural maintenance on the system housing," in lieu of the requirement in existing DAEC TS 4.7.B.I.c for an anne.nl demonstration of the air flow distribution.

The proposed revised Bases thus needs to be modified to state that air flow distribution is determined following complete or partial replacement of the flEPA filter bank and after any structural maintenance on the system housing instead of the annual determination.

Ibge 36 l

DilANE ARNOLD ENERGY CENTER (DAEC)

TECllNICAL SPECIFICATION CIIANGE (RTS-246)

REVISIONS TO TS SECTION 3,7 -- CONTAINMENT SYSTEMS TS Page No.

Proposed Change Evaluation of the Proposed Change Category Review 3.7-40 The description of standhv gas treatment system De change conforms the wording in the Bases to the 4

(SGTS) inlet heater capacity in Hases section 3.7.L and requirement of the revised TS 4.7.L.I.b and is 4.7.L has been revised from 11 kw to 22 kw. This acceptable.

change is consistent with revised TS seethi 4.7.L.I.b.

3.7-40 A specific discussion of the engineering evaluation New TS 4.7.J.l.a requires the capability of 4

regarding the effects of differing wind speeds on SGTS testing has been added to the Ilases of TS maintaining a 1/4 inch water vacuum in the secondary sections 3.7.L and 4.7.L containment with wind speeds up to 15 mph. This additional discussion explains how the averaged manometer readings compensate for wind speeds up to 15 mph. The change adds clarification and is acceptable.

k

'3.7-41 The Bases 'for TS sections 3.7.M and 4.7.M This is an administrative change to account for the i

" Mechanical Vacuum Pump", contains the infonnation previously located in Bases sections 3.7.F and 4.7.F.

revised organization of Section 3.7, and is acceptahic.

3.7-42 Previous TS pagc number 3.7-49 has been renumbered This is an administrative change to account for the I

to page 3.7-42.

revised organization of Section 3.7, and is acceptable.

3.7-43 Previous TS page number 3.7-50 has been renumbered This is an administrative change to account for the I

to page 3.7-43.

revised organization of Section 3.7, and is acceptable.

3.7-43 Previous TS page 3.7-20 has been dcIcted.

De deleted page, inserted by Amendment 181, noted 4

that a series of tables had been deleted from the TS, which resulted in a number of pages no longer being used. With this revision to the TS, this note is no longer needed. This change, therefore,is acceptabic.

l l

t Ibge 37

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