ML20080E426

Safety Evaluation Supporting Amend 206 to License DPR-49

ML20080E426
Person / Time
Site:	Duane Arnold
Issue date:	01/06/1995
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20080E425	List: ML20080E421 ML20080E426
References
NUDOCS 9501130208
Download: ML20080E426 (6)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 206 TO FACILITY OPERATING LICENSE NO. DPR-49 IES UTILITIES INC.

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

1.0 INTRODUCTION

In its letter dated July 29, 1994, IES Utilities Inc., the licensee, proposed that Facility Operating License DPR-49 be amended to revise the Duane Arnold Energy Center Technical Specifications (TS). Specifically, the proposed amendment would change TS 4.6.G.1, " Structural Integrity," which specifies the surveillance requirements for implementation of the regulations for inservice inspection (ISI) and inservice testing (IST).in accordance with 10 CFR 50.55a.

The proposed change is consistent with the revised standard technical specifications for General Electric BWR/4 Plants (NUREG-1433). The licensee has also proposed to add TS 4.6.G.3 which states that TS Definition 26,

" Surveillance Frequency," will be applicable to the performance of ISI and IST.

2.0 EVALUATION The regulations for nuclear industry codes and standards are stated in 10 CFR 50.55a. By rulemaking published June 12, 1971, effective July 12, 1971,10 CFR 50.55a was issued to establish minimum quality standards for the design, fabrication, erection, construction, testing, and inspection of certain systems and components of boiling and pressurized water-celed nuclear power reactor plants by requiring conformance with appropriate indastry codes and standards. The regulations have been revised a number of times since first promulgated, including adding design requirements for assuring access for inspection and testing.

Before March 15, 1976, the regulations contained no requirements for IST of pumps and valves.

The ASME Code first included Subsections IWP and IWV to Section XI in the Sumner 1973 Addenda. The rules effective March 15, 1976 (41 Federal Reaister 6256, published February 12, 1976), required that an operating license for a utilization facility be subject to the conditions specified in 10 CFR 50.55a(g), which included requirements for the ISI of components, and the new IST of pumps and valves.

The regulations provide for alternatives to the requirements, if compliance would result in hardship without a compensating increase in the level of quality and safety, or if the proposed alternatives would give an acceptable

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l level of quality and safety. Also, because a number of plants were designed prior to the inservice inspection and testing requirements were imposed, and therefore, may not have included all the necessary access provisions, the regulations provide for relief from Code requirements, if a licensee determines that conformance is impractical for its facility. These provisions are stated in 10 CFR 50.55a, paragraphs (a)(3)(1), (a)(3)(ii), (f)(6)(1), and (g)(6)(1).

After publishing the rules that took effect March 15, 1976, the NRC issued letters to licensees informing them of the rule change and recommending that they propose technical specification changes for both ISI and IST with the following standard statements:

The following language should be substituted, as appropriate, into the Technical Specifications where existing surveillance requirements are superseded by ASME Section XI inservice inspection and testing requirements:

a.

Inservice inspection of ASME Code Class 1, Class 2, and Class 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code, and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the NRC l

pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

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Inservice testing of ASME Code Class 1, Class 2, and Class 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR 50, Section 50.55a(g)(6)(i).

In the letters issued to then current operating plants, the NRC further discussed the regulation which, at that time, required updates of the l

inservice inspection programs at 40-month intervals and the IST programs at 20-month intervals.

The NRC suggested that licensees submit requests for relief from ASME Code requirements, as far in advance as possible of the start of any 20-month period for testing pumps and valves, but at least 90 days l

before that period (these inspection and testing periods were later changed to 120-month intervals for both ISI and IST). The NRC stressed the need to incorporate 10 CFR 50.55a(g) by reference in technical specifications (1) to avoid duplication of requirements, (2) to alleviate the need for technical specification changes, whenever a testing program is updated, and (3) to simplify the process for obtaining relief from impractical ASME Code requirements.

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. The NRC discussed relief requests as follows in the letters to licensees

I Generally, the licensee will know well in advance of the beginning i

of any inspection period, whether or not a particular ASME Code requirement will be impractical for his facility.

Thus, the licensee should request relief from ASME Code requirements, as far as possible, in advance of, but not less than 90 days before, the start of the inspection period.

Early submittals are particularly important for the first 40-month inservice and 20-month pump and j

valve testing period, because they will enable the NRC staff to i

evaluate the information received from all licensees and determine, which ASME Code requirements may be generally impractical for various classes of plants.

Early submittals, will 4

thereby facilitate earlier feedback to licensees regarding the acceptability of their requests.

1 The NRC staff recognizes that it will not be possible, in all i

cases, for a licensee to determine, in advance, that any particular ASME Code requirement will be impractical for his facility.

In cases where, during the process of inservice testing, certain requirements are found to be impractical, due to unforeseen circumstances, the licensee may request relief at that time. These occurrences are not expected to be many, and are i

expected to result in only minor changes to an inservice testing program.

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All relief from ASME Code requirements that are determined to be impractical for a facility will be granted in the form of a letter, within the provisions of 650.55a(g)(6)(i).

This written i

relief should be incorporated into the document describing the inservice inspection and testing program retained by the j

licensee...the written relief itself will not become an explicit i

part of the facility license...

During development of the revised standard technical specifications, the NRC approved a change from the ISI and IST surveillance requirements, as originally proposed in the 1976 letters to licensees.

The standard technical specification change corrected what appeared to be a more restrictive limitation than the regulator;, requirements of 10 CFR 50.55a in prohibiting the licensee from implementing relief for impractical Code requirements, before obtaining approval from the NRC. The administrative section of the revised standard techrical specifications include", the followirg applicable requirements for the ISI and IST programs:

5.7.2.11 Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports.

The program shall include the following:

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f Provisions'that inservice' inspection of ASME Code-

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Class 1, 2, and 3 components shall:be performed in accordance with Section XI of the' ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a -

5.7.2.12 Inservice Testing Program j

This program provides controls for inservice testing of: ASME Code Class 1, 2, and 3 components including applicable supports. The program shall include the following:

a.

. Provisions that inservice. testing of ASME Code j

Class 1, 2, and 3 pumps, valves,- and snubbers shall be i

performed in accordance with Section XI of the ASME-l Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;...

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The revised standard technical specifications reflect the position that the licensee must establish and. implement-the program in accordance' with i

10 CFR 50.55a. For preparing an updated ISI or IST program, the regulations i

allow a licensee, up to a full year, after the beginning of the updated l

interval, to obtain NRC approval of relief from those Code requirements that l

the licensee has determined are~ impractical for its facility and are not..

i included in the revised ISI or IST program.

The regulations state that the l

need for relief be demonstrated to the satisfaction of the Commission, no later.than 12 months from the interval start date.

If later in the interval, i

l a licensee finds a specific need for relief,.the request should be submitted i

for NRC approval 'after identification of the impractical requirement.

The licensee proposes to delete the phrase "except where specific written i

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relief has been granted by the Commission pursuant to 10 CFR 50, Section.

l 50.55a(g)(i)." The revised technical specification will.also eliminate the reference to "Section 50.55a(g)" and reference "Section-50.55a" to ' reflect the separation between ISI and IST,'that was effective in the most recent i

rulemaking to Section 50.55a. ' Requirements for IST, are.now addressed-in~

Section 50.55a(f) while requirements for ISI remain in Section 50.55a(g). The bases for the technical specification have been changed accordingly.

Technical Specification 4.6.G.1 will read as follows.

i Inservice inspection of ASME Section XI Code Class -1, Class 2, and-

.j Class 3 components and inservice testing of ASME Code' Class 1, t

Class 2, and Class 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code ard applicable Addenda as required by 10 CFR 50, Section 50.55a.

For 120-month updated programs, relief requests should be submitted prior to the interval start date to allow a period for NRC review twelve months after the interval start date (i.e., submit the updated program three to six months prior to the start date, or earlier). Upon determining an impractical

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- requirement and not including that requirement in the revised inservice test or inspection program, the licensee must follow the r=auirements of 10 CFR 50.55a(f)(5)(iv) or (g)(5)(iv), as applicabl:.

lite change to the specification does not allow the licensee to implement alternative testing under 10 CFR 50.55a, paragraphs (a)(3)(i) and (a)(3)(ii), until the NRC has determined that such alternatives are authorized, and has issued a safety evaluation to the licensee. However, this technical specification change will enable licensees to avoid situations where compliance with the current technical specifications cannot be achieved, for the period between preparation and submittal of a relief request as part of a revised inservice test or inspection program during the first 12 months of the program, and when the NRC has issued a safety evaluation and granted the relief. This situation could occur at the beginning of a new iiterval.

Following implementation of the TS change, when a Code requirement is practical, but an alternate method is requested, approval from the NRC is required before implementing the alternative method of testing (1) proposed to achieve levels of quality and safety equivalent to those of the Code method or (2) proposed to avoid an undue hardship without, yielding a compensating increase in the level of quality and safety. Additionally, for IST, the licensee may use the guidance in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," for alternatives, that the staff has determined are acceptable for implementation.

In the letter dated July 29, 1994, accompanying the amendment application, the licensee discussed the guidance in draft NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants." Draft NUREG-1482 was published for comment in consideration of publishing the report in final form to give guidance on IST issues. The staff is evaluating the comments received and has not published the report in the final form yet. Additional staff guidance, if any, on IST and ISI issues will be published in an appropriate document at such time as such guidance or recommendations are available.

However, notwithstanding any guidance or recommendations published by the staff, NRC requirements regarding the ASME Boiler and Pressure Vessel Code are as set out in the regulations at 10 CFR Section 50.55a.

The licensee has also proposed to add TS 4.6.G.3, " Surveillance Frequency,"

which states that the provision of TS Definition 26, " Surveillance Frequency,"

are applicable to the performance of ISI and IST. This would allow the licensee to extend the ISI and IST surveillance frequencies to 25% of the surveillance interval.

Definition 26 in the TS states, that this provision is not intended to be used repeatedly as a convenience to extend non-outage related surveillance intervals. This change is consistent with language in the General Electric BWR/4 Standard Technical Specifications Section SR 3.0.2.

The extension facilitates the scheduling of surveillance activities and allows surveillances to be postponed when plant conditions are not suitable for conducting a surveillance, for example, under transient conditions or other ongoing surveillance or maim enance activities. The use of the allowance to extend surveillance interva!,, can also result in a significant safety benefit for surveillances that are 'erformed on a routine basis, during plant 4

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operations to accommodate operating conditions, that 'are not suitable for

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I performing the surveillance.

Based on these reasons, the change is acceptable-l l

for implementation.

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'2.1 TECHNICAL CONCLUSION t

4 The proposed changes to the~ Duane Arnold Energy.. Center TS 4.6.G.1 and the i

1 associated bases are acceptable. The proposed addition of TS 4.6.G.3. is also i

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-acceptable.

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3.0-STATE CONSULTATION, 4

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'In accordance with the Commission's regulations, the Iowa State official was.

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notified of the proposed issuance of the amendment. The State official had no-j, comments.

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4.0' ENVIRONMENTAL CONSIDERATIONS j

This amendment changes a requirement'with respect to ins'allation or use of a f

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facility component located within the restric'.ed area as defined in 10 CFR l

j Part 20 and changes' surveillance requirements. The staff has determined that j

the amendment involves no.significant increase $n the amountK and'no significant change in the types, of any effluent that may be.reicted biisite, j

and that there is no significant increase in indiv1Aal: or cumulative l

l occupational radiation exposure. The Commission has pretously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public' comment. on such f bding.

1 (59 FR 45026). Accordingly, the amendment meets the eligibility criteria for j

categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR l

51.22(b), no environmental impact statement or environmental assessment' need be prepared in connection with the issuance of.the amendment.

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5.0 CONCLUSION

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The staff has concluded, based on the considerations discussedLabove, that:

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(1) there is reasonable assurance that the health and safety of-the public l

will not be er: dangered by operation in the proposed manner,- (2)'such j

activities will be conducted in compliance with the Commission's.. regulations, j

and (3) the issuance of the amendment will not be inimical to the common i

defense and security or to the health and safety of the public.

i Principal Contributor: J. Colaccino

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j Date: January 6, 1995 i

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