ML061990634

RAI, Proposed Amendment to Revise the Limiting Condition for Operation 3.10.1

ML061990634
Person / Time
Site:	Duane Arnold
Issue date:	07/24/2006
From:	Spaulding D NRC/NRR/ADRO
To:	Vanmiddlesworth G Nuclear Management Co
D. Spaulding LPL3-1 X2928
References
TAC MD0293
Download: ML061990634 (6)

Text

July 24, 2006 Mr. Gary Van Middlesworth Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED AMENDMENT TO REVISE THE LIMITING CONDITION FOR OPERATION (LCO) 3.10.1 (TAC NO. MD0293)

Dear Mr. Van Middlesworth:

Your letter of March 1, 2006, submitted a proposed amendment to revise the limiting condition for operation 3.10.1, to allow ancillary testing to occur during the evolutions associated with performing the American Society of Mechanical Engineers Code Class I leak test of the reactor pressure vessel, at the Duane Arnold Energy Center.

We are reviewing this information, and find that we need additional information as shown in the enclosed request for additional information (RAI). I discussed this RAI with Tony Browning of your organization on July 18, 2006, and he agreed to respond within 30 days of receipt of this RAI. Please contact me at (301) 415-2928 if you have questions.

Sincerely,

/RA/

Deirdre W. Spaulding, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

RAI cc w/encl: See next page

Mr. Gary Van Middlesworth July 24, 2006 Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, Iowa 52324-9785

SUBJECT:

DUANE ARNOLD ENERGY CENTER - REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED AMENDMENT TO REVISE THE LIMITING CONDITION FOR OPERATION (LCO) 3.10.1 (TAC NO. MD0293)

Dear Mr. Van Middlesworth:

Your letter of March 1, 2006, submitted a proposed amendment to revise the limiting condition for operation 3.10.1, to allow ancillary testing to occur during the evolutions associated with performing the American Society of Mechanical Engineers Code Class I leak test of the reactor pressure vessel, at the Duane Arnold Energy Center.

We are reviewing this information, and find that we need additional information as shown in the enclosed request for additional information (RAI). I discussed this RAI with Tony Browing of your organization on July 18, 2006, and he agreed to respond within 30 days of receipt of this RAI. Please contact me at (301) 415-2928 if you have questions.

Sincerely,

/RA/

Deirdre W. Spaulding, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

RAI cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsNrrPMDSpaulding RidsNrrLATHarris RidsNrrDorlLple RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn3MailCenter RidsNrrDorlDpr ALewin JGilmer TBoyce ADAMS Accession Number: ML061990634 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC NAME DSpaulding THarris LRaghavan DATE 07/21/06 07/20/06 07/24/06 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED AMENDMENT TO REVISE THE LIMITING CONDITION FOR OPERATION (LCO) 3.10.1 DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331

1. LCO 3.10.1 Rev 3.1a would allow testing in Mode 4 with average reactor coolant temperature drifting greater than 200 F as a result of decay heat. Primary containment requirements are relaxed in LCO 3.10.1 Rev 3.0 with the reasoning in the technical specification (TS) Bases that average reactor coolant temperature is greater than 200 F as a result of testing and not due to significant decay heat. Please explain why it is acceptable to be in Mode 4 (with average reactor coolant temperature greater than 200 F) vice Mode 3 with the presence of decay heat contributing to an increase in the average reactor coolant temperature.

2. LCO 3.4.7 RCS Specific Activity, is normally not required in Mode 4 because the reactor is normally not pressurized. Please provide justification for not including LCO 3.4.7 under LCO 3.10.1 Rev 3.1a requirements when in Mode 4 with average reactor coolant temperature greater than 200 F.

3. The Bases for TS 3.10.1 Rev 3.1a discusses conducting other unnamed testing while the TS 3.10.1 Rev 3.1a specifically mentions conducting only inservice leak or hydrostatic tests and control rod scram time tests. Please elaborate on the intent of the TS and Bases as written with regards to other testing.

4. The use of the verbiage as a consequence of in the LCO under TS 3.10.1 Rev 3.1a could result in steady state Mode 4 with reactor coolant temperature > 200 F even though testing is over and no longer being conducted. This seems to be the reasoning for eliminating the statement in the Bases for TS 3.10.1 Rev 3.0 which states that normal Mode 4 requirements are in effect immediately prior to and immediately after LCO 3.10.1 operations. Please elaborate on what would require returning to normal Mode 4 requirements after testing is completed.

ENCLOSURE Duane Arnold Energy Center cc:

Mr. J. A. Stall Regional Administrator, Region III Senior Nice President, Nuclear and Chief U.S. Nuclear Regulatory Commission Nuclear Officer Suite 210 Florida Power & Light Company 2443 Warrenville Road P. O. Box 14000 Lisle, IL 60532-4351 Juno Beach, FL 33408-0420 Mr. M. S. Ross Mr. M. Warner Managing Attorney Vice President, Nuclear Operations Florida Power & Light Company Support P. O. Box 14000 Florida Power & Light Company Juno Beach, FL 33408-0420 P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. R. E. Helfrich Senior Attorney Mr. D. A. Curtland Florida Power & Light Company Plant Manager P. O. Box 14000 Duane Arnold Energy Center Juno Beach, FL 33408-0420 3277 DAEC Rd.

Palo, IA 52324-9785 Mr. W. E. Webster Vice President, Nuclear Operations Mr. R. S. Kundalkar Florida Power & Light Company Vice President, Nuclear Engineering P. O. Box 14000 Florida Power & Light Company Juno Beach, FL 33408-0420 P. O. Box 14000 Juno Beach, FL 33408-0420 John Bjorseth Site Director Daniel McGhee Duane Arnold Energy Center Utilities Division 3277 DAEC Road Iowa Department of Commerce Palo, IA 52324 Lucas Office Buildings, 5th Floor Des Moines, IA 50319 Steven R. Catron Manager, Regulatory Affairs Chairman, Linn County Duane Arnold Energy Center Board of Supervisors 3277 DAEC Road 930 1st Street SW Palo, IA 52324 Cedar Rapids, IA 52404 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 Palo, IA 52324