ML20137H534
| ML20137H534 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 03/28/1997 |
| From: | Peveler K IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | Collins S NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NEP-96-0063, NEP-96-63, NUDOCS 9704020272 | |
| Download: ML20137H534 (15) | |
Text
. -
IES Utilities Inc.
c 200 First Street SE.
~
PO. Box 351 Cedar Rapids, LA 52406-0351 Telephone 319 398 4411 UTILITIES March 28,1997 -
NEP-96-0063 Mr. Samuel J. Collins, Director Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn.: Document Control Desk '
Mail Station PI-37 Washington, DC 20555-0001 l
Subject:
Duane Arnold Energy Center Docket No: 50-331 -
Op. License No: DPR-49 Proposed Revision to Emergency Action Levels
Reference:
Letter from L. Heckert (IES) to W. Russell (NRC) dated September 15,1995, NEP-95-0184 File:
A-221
Dear Mr. Collins:
In the referenced letter, IES Utilities submitted a Duane Arnold Energy Center (DAEC) i proposed revision to the Emergency Action Levels for NRC review and approval. This submittal incorporates the guidelines contained in NUMARC/NESP-007," Methodology for Development of Emergency Action Levels (EALs)."
On March 10,1997, a conference call was conducted between NRR staff and IES Utilities Emergency Planning staff. As a result of this discussion, we are providing additional clarification on specific EAL basis information. (Attachment)
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Mr. Samuel J. Collins.
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NEP-96-0063:
y March 28,1997
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. Page 2 i
i Should you have any questions regarding this matter, please contact Larry lieckert at -
l 319-851-7016 or my office at 319-851-7801.
I t
i
'l Sincerely,-
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it
?t Kenneth E. Peveler j
Manager, Regulatory Performance KP/kd 3
Attachment i
cc:
G. Kelly (NRC-NRR)
A. B. Beach (Region 111)
[
NRC Resident Office
'p.
DOCU i
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f
Duane Arnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev.2 (forNRCreview)
PAGE S-5 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE:TBD SU4 Fuel Clad Degradation EVENTTYPE: Coolant Activity OPERATING MODE APPLICABILITY: All EXAMPLE EMERGENCY ACTION LEVELS: (1 or 2)
- 1. (Site-Specific) < valid > radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.
- 2. (Site-Specific) coolant sample acdvity value indicating fuel clad degradation greater than Technical Specification allowable limits.
There are no significant deviations from the generic EALs. These EALs are precursors ofmore serious fuel clad degradation and are thus considered as indicating a potential degradation ofthe level ofsafety of the plant. Thus, it is possible to be operating within Technical Specification LCO Action Statement time limitsfor iodine spikes and make a declaration ofan Unusual Event. DAEC mode applicability for these EALs are consistent with the Tech Specs.
EAL 1 addresses valid pretreat rad monitor exceeding (RM-4104) above 4E+3 mR/hr. The calculation supporting this value is described below. Valid means that the pretreat rad monitor readmg is determined to be operable in accordance with the Technical Specifications or has been verified by other independent i
methods such as indications displayed on the control panels, reports from plant personnel, or coolant sampling results. This reading would be displayed on Control Room panels IC-02 and IC-10 on pretreat rad recorder RR-4104.
1 As specified in the generic methodology, DAEC EAL 2 addresses coolant samples exceedmg technical specification 3.6.B.I.a, coolant activity less than or equal to 1.2 Ci/ml dose equivalent I-131.
j Radiological Engineering Calculation 94-014A and UFSAR Table 15.4-1 were reviewed to determine a suitable EAL threshold for the pretreat rad monitor reading corresponding to the Tech Spec 3.6.B.I.a coolant activity limit of 1.2 Ci/ml of dose equivalent 1-131. Using the condenser noble gas source term for the control rod drop accident of 2.38 E +06 Curies shown on UFSAR Table 15.4-1 and the condenser free volume of 55,000 cubic feet, an initial noble gas concentration in the condenser offgas line is determined. Because the offgas flow rate is very small (about 50 standard cubic feet per minute) compared to the total condenser free volume, dilution of the condenser noble gas concentration due to offgas flow is
Duane Arnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev.2 (forNRCreview)
PAGE S-17 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE: TBD SA3 Inability to Maintain Plant in Cold Shutdown EVENT TYPE: Inability to Maintain Shutdown Conditions OPERATING MODE APPLICABILITY: Cold Shutdown, Refuel EXAMPLE EMERGENCY ACTION LEVEL:
- 1. Loss of < decay heat removal systems required > to maintain cold shutdown AND Temperature increase that either:
Exceeds Technical Specification cold shutdown temperature limit OR Results' in uncontrolled temperature rise approaching cold shutdown technical specification limit.
e DAEC EALINFORMATION:
Under the conditions of concem for EAL 1, AOP 149, Loss of Decay Heat Removal, would be entered i
under Tab 1, Loss of Shutdown Cooling. Indications / alarms related to loss of shutdown cooling are displayed on control room panels 1C03 and 1C05 and are listed in the procedure under " Probable i
Indications." The procedure requires that shutdown cooling be re-established.
The procedure provides curves of maximum water heat up rates which provide an upper bound of the heatup until an estimated time to boil calculation can be completed by Engineering.
The DAEC EAL is written to imply a RCS temperature rise above 212 F that is not allowed by plant procedures. This corresponds to the inability to maintain required temperature conditions for Cold Shutdown. " Uncontrolled" means that system temperature increase is not the result of planned actions by the plant staff. The wording is also intended to eliminate minor cooling interruptions occurring at the transition between Hot Shutdown and Cold Shutdown or temperature changes that are permitted to occur during establishment of altemate core cooling so that an unnecessary declaration of an Alert does not occur. 'Ihe uncontrolled temperature rise is necessary to preserve the anticipatory philosophy of NUREG-0654 for events starting from temperatures much lower than the cold shutdown temperature limit.
r e
Duane Amold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev.2 (forNRCreview)
PAGE S-18 of 33 i
SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE:TBD i
J
REFERENCES:
i i
- 1. Abnormal Operating Procedure (AOP) 149, Loss of Decay Heat Removal
- 2. DAECTechnicalSpecifications
- 3. Surveillance Test Procedure (STP) 46A003, Heatup and Cooldown Rate Log
- 4. NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the i
UnitedStates, September 1993
- 5. NUMARC Methodologyfor Development ofEmergency Action Levels NUMARC/NESP-007 Revision 2 Questions andAnswers, June 1993 r
1 I
lE3 v: ees Wc.
200 '<rst Stet 5 E F O S~w 351 Cecy Hapods. IA 52406 4361
,emorwoe 319 398 4411 UTILITIES March 28,1997 NEP-96-0063 Mr. Samuel J. Collins, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station PI-37 Washington, DC 20555-0001
Subject:
Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Proposed Revision to Emergency Action Levels
Reference:
Letter from L. Heckert (IES) to W. Russell (NRC) dated September 15,1995, NEP-95-0184 File:
A-221
Dear Mr. Collins:
In the referenced letter. IES Utilities submitted a Duane Arnold Energy Center (DAEC) proposed revision to the Emergency Action Levels for NRC review and approval. This submittal incorporates the guidelines contained in NUMARC/NESP-007. " Methodology for Development of Emergency Action Levels (EALs)."
On March 10,1997, a conference call was conducted between NRR staff and IES Utilities Emergency Planning staff. As a result of this discussion, we are providing additional clarification on specific EAL basis information. (Attachment)
An rES Indrstres Campyy
Mr. Samuel J. Collins NEP-96-0063 March 28,1997 Page 2 Should you have any questions regarding this mat:er, please contact Larry Heckert at 319-851 7016 -or my office at 319-851-7801.
Sincerely, t
c Kenneth E. Peveler Manager, Regulatory Performance KP/kd Attachment j
l cc:
G. Kelly (NRC-NRR)
A. B. Beach (Region III) i NRC Resident Office i
DOCU i
i i
1
Duane Arnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-5 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE:TBD i
i SU4 Fuel Clad Degradation EVENTTYPE: Coolant Activity OPERATING MODE APPLICABILITY: All EXAMPLE EMERGENCY ACTION LEVELS: (1 or 2)
~
1 (Site-Specific) < valid > radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.
- 2. (Site-Specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.
i There are no significant deviations from the generic EALs. These EALs are precursors ofmore serious l
fuel clad degradation and are thus considered as indicating a potential degradation ofthe level ofsafety of the plant. Thus, it is possible to be operating within Technical Specification LCO Action Statement time limitsfor iodine spikes and make a declaration ofan Unusual Event. DAEC mode applicability for these EALs are consistent with the Tech Specs.
EAL 1 addresses valid pretreat rad monitor exceeding (RM-4104) above 4E+3 mR/hr. The calculation
)
supponing this value is described below. Valid means that the pretreat rad monitor reading is determined j
to be operable in accordance with the Technical Specifications or has been verified by other independent j
methods such as indications displayed on the control panels, reports from plant personnel, or coolant l
sampling results. This reading would be displayed on Control Room panels 1C-02 and 1C-10 on pretreat rad recorder RR-4104.
1 l
As specified in the generic methodology, DAEC EAL 2 addresses coolant samples exceeding technical j
specification 3.6.B.I.a. coolant activity less than or equal to 1.2 Ci/ml dose equivalent I-131.
i i
Radiological Engineering Calculation 94-014A and UFSAR Table 15.4-1 were reviewed to determine a suitable EAL threshold for the pretreat rad monitor reading corresponding to the Tech Spec 3.6.B.I.a coolant activity limit of 1.2 Ci/ml of dose equivalent I-131. Using the condenser noble gas source term for the control rod drop accident of 238 E +06 Curies shown on UFSAR Table 15.4-1 and the condenser fm volume of $5,000 cubic feet, an initial noble gas concentration in the condenser offgas line is determined. Because the offgas flow rate is very small (about 50 standard cubic feet per minute) compared to the total condenser free volume, dilution of the condenser noble gas concentration due to offgas flow is
Duane Arnold Energy Center 3
EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-17 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE: TBD i
l SA3 Inability to Maintain Plant in Cold Shutdown EVENT TYPE: Inability to Maintain Shutdown Conditions
+
OPERATING MODE APPLICABILITY: Cold Shutdown, Refuel EXAMPLE EMERGENCY ACTION LEVEL:
- 1. Loss of < decay heat removal systems regtured> to maintain cold shutdown AND Temperature increase that either:
Exceeds Technical Specification cold shutdown temperature limit OR Results' in uncontrolled temperature rise approaching cold shutdown technical specification limit.
Under the conditions of concern for EAL 1. AOP 149, Loss of Decay Heat Removal, would be entered i
under Tab 1, Loss of Shutdon Cooling. Indications / alarms related to loss of shutdown cooling are displayed on control room panels IC03 and IC05 and are listed in the procedure under " Probable
)
Indications." The procedure requires that shutdown cooling be re-established.
The procedure provides curves of maximum water heat up rates which provide an upper bound of the heatup until an estimated time to boil calculation can be completed by Engineering.
The DAEC EAL is written to imply a RCS temperature rise above 212 'F that is not allowed by plant procedures. This corresponds to the inability to maintain required temperature conditions for Cold Shutdown. " Uncontrolled" means that system temperature increase is not the result of planned actions by the plant staff. The wording is also intended to eliminate minor cooling interruptions occurring at the i
transitien between Hot Shutdown and Cold Shutdown or temperature changes that are permitted to occur during establishment of attemate core cooling so that an unnecessary declaration of an Alert does not occur. The uncontrolled temperature rise is necessary to preserve the anticipatory philosophy of NUREG-0654 for i. vents starting from temperatures much lower than the cold shutdown temperature limit.
1 l
=
Duane Arnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-18 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE: TBD
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 149, Loss of Decay Heat Removal
- 2. DAECTechnicalSpecifications
- 3. Stuveillance Test Procedure (STP) 46A003, Heatup and Cooldown Rate Log
- 4. NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the UnitedStates, September 1993
- 5. NUMARC Methodologyfor Development ofEmergency Action Levels NUMARC/NESP-OO7 Revision 2 Questions andAnswers, June 1993 x
iCS unte; toc.
- % r ru Stwt S F e
P O do. 357 Ceny Racias. IA 52JLM 0J31 Terle pf %nt.,31) 398 4411 UTILITIES March 28,1997 NEP-96-0063 Mr. Samuel J. Collins, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Mail Station Pl-37.
Washington, DC 20555-0001
Subject:
Duane Amold Energy Center Docket No: 50-331 -
Op. License No: DPR-49 Proposed Revision to Emergency Action Levels
Reference:
Letter from L. Heckert (IES) to W. Russell (NRC) dated September 15,1995, NEP-95-0184 File:
A-221 l
i
Dear Mr. Collins:
In the referenced letter, IES Utilities submitted a Duane Amold Energy Center (DAEC) proposed revision to the Emergency Action Levels for NRC review and approval. This submittal incorporates the guidelines contained in NUMARC/NESP-007," Methodology for Development of Emergency Action Levels (EALs)."
On March 10,1997, a conference call was conducted between NRR stafT and IES Utilities Emergency Planning staff. As a result of this discussion, we are providing additional clarification on specific EAL basis information. (Attachment) i An E S Ine nie 1 Cyr,v v
Mr. Samuel J. Collins NEP-96-0063 March 28,1997 Page 2 Should you have any questions regarding this matter, please contact Larry Heckert at 319-851-7016 or my office at 319-851-7801.
Sincerely, Kenneth E. Peveler Manager, Regulatory Performance KP/kd Attachment cc:
G. Kelly (NRC-NRR)
A. B. Beach (Region 111)
NRC Resident Office DOCU
Dhane A'rnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-5 of 33 j
SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE: TBD SU4 Fuel Clad Degradation EVENT TYPE: Coolant Activity OPERATING MODE APPLICABILITY: All EXAMPLE EMERGENCY ACTION LEVELS: (1 or 2)
- l. (Site-Specific) < valid > radiation monitor reading 5 indicating fuel clad degradation greater than Technical Specification allowable limits.
- 2. (Site-Specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.
'lhere are no significant deviations from the generic EALs. These EALs are precursors ofmore serious fuel clad degradation and are thus considered as indicating a potential degradation ofthe level ofsafety of the plant. Thus, it is possible to be operating within Technical Specification LCO Action Statement time limitsfor iodine spikes and make a declaration of an Unusual Event. DAEC mode applicability for these EALs are consistent with the Tech Specs.
EAL 1 addresses valid pretreat rad monitor exceeding (RM-4104) above 4E+3 mR/hr. The calculation supporting this value is described below. Valid means that the pretreat rad monitor reading is determined to be operable in accordance with the Technical Specifications or has been verified by other independent methods such as indications displayed on the control panels, reports Sem plant personnel, or coolant sampling results. 'Ihis reading would be displayed on Control Room panels IC-02 and IC-10 on pretreat rad recorder RR-4104.
As specified in the generic methodology, DAEC. EAL 2 addresses coolant samples exceeding technical specification 3.6.B.I.a. coolant activity less than or equal to 1.2 Ci/ml dose equivalent I-131.
Radiological Engineering Calculation 94-014A and UFSAR Table 15.4-1 were reviewed to determine a suitable EAL threshold for the pretreat rad monitor reading corresponding to the Tech Spec 3.6.B.I.a coolant activity limit of 1.2 pCi/ml of dose equivalent I-131. Using the condenser noble gas source term for the control rod drop accident of 2.38 E +06 Curies shown on UFSAR Table 15.4-1 and the condenser l
free volume of 55,000 cubic feet, an initial noble gas concentration in the condenser offgas line is i
determined. Because the offgas flow rate is very small (about 50 standard cubic feet per minute) compared to the total condenser free volume, dilution of the condenser noble gas concentration due to offgas flow is
Duane Arnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-17 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE: TBD SA3 Inability to Maintain Plant in Cold Shutdown EVENT TYPE: Inability to Maintain Shutdown Conditions OPERATING MODE APPLICABILITY: Cold Shutdown, Refuel EXAMPLE EMERGENCY ACTION LEVEL:
- 1. Loss of < decay heat removal systems required > to niaintain cold shutdown AND Temperature increase that either:
Exceeds Technical Specification cold shutdown temperature limit j
OR Results' in uncontrolled temperature rise approaching cold shutdown technical specification limit.
Under the conditions of concem for EAL 1, AOP 149, Loss of Decay Heat Removal, would be entered under Tab 1, Loss of Shutdown Cooling. Indications / alarms related to loss of shutdown cooling are displayed on control room panels IC03 and IC05 and are listed in the procedure under " Probable Indications." The procedure requires that shutdown cooling be re-established.
i The procedure provides curves of maximum water heat up rates which provide an upper bound of the heatup until an estimated time to boil calculation can be completed by Engineering.
The DAEC EAL is written to imply a RCS temperature rise above 212 F that is not allowed by plant procedures. This corresponds to the inability to maintain required temperature conditions for Cold Shutdown. " Uncontrolled" means that system temperature increase is not the result of planned actions by the plant stafE The wording is also intended to eliminate minor cooling interruptions occumng at the transition between Hot Shutdown and Cold Shutdown or temperature changes that are permitted to occur 4
during establishment of altemate core cooling so that an unnecessary declaration of an Alert does not occur. The uncontrolled temperature rise is necessary to preserve the anticipatory philosophy of NUREG-0654 for events starting from temperatures much lower than the cold shutdown temperature limit.
.~
. o Duane A'rnold Energy Center EMERGENCY ACTION LEVEL BASES DOCUMENT Rev. 2 (for NRC review)
PAGE S-18 of 33 SYSTEM MALFUNCTION CATEGORY EFFECTIVE DATE:TBD
REFERENCES:
- 1. Abnormal Operating Procedure (AOP) 149, Loss of Decay Heat Removal
- 2. DAECTechnicalSpecifications
- 3. Surveillance Test Procedure (STP) 46A003, Heatup and Cooldown Rate Log
. 4. NUREG 1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the
. UnitedStates, September 1993
- 5. NUMARC Methodologyfor Development ofEmergency Action Levels NUMARC/NESP-007 Revision 2 Questions and Answers, June 1993 I
l i
a M-
-,