ML20212H212

Forwards Request for Addl Info Re 990412 Licensee Request to Revise DAEC TS SR 3.6.1.3.7 to Allow Representative Sample of Reactor Instrumentation Line EFCV to Be Tested Every 24 Months,Instead of Testing Each EFCV Every 24 Months

ML20212H212
Person / Time
Site:	Duane Arnold
Issue date:	09/27/1999
From:	Mozafari B NRC (Affiliation Not Assigned)
To:	Protsch E IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
References
TAC-MA05421, NUDOCS 9909300243
Download: ML20212H212 (5)

Text

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September 27, 1999 L Mr. Eliot Protsch President IES Utilities Inc.

200 First Street, SE '

P.O. Box 351 ->

Cedar Rapids, IA 52406-0351

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON TECHNICAL SPECIFICATION CHANGE REQUEST REGARDING EXCESS FLOW CHECK VALVE

' SURVEILLANCE REQUIREMENTS AT DUANE ARNOLD ENERGY CENTER (TAC NO. MA05421)

I

Dear Mr. Protsch:

l in a letter dated April 12,1999, IES Utilities (the licensee) submitted a request to revise Duane Arnold Energy Center (DAEC) Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.3.7 to allow a representative sample of reactor instrumentation line excess flow control valves (EFCV) to be tested every 24 months, instead of testing each EFCV every 24 months.

The NRC staff has reviewed the licensee's submittal regarding the EFCV surveillance requirement for DAEC, and has determined that additional information is necessary to complete our review.

Your timely response to the enclosed request for additional information (RAl) will assist us in meeting your schedule. This RAI and the schedule have been discussed with Kenneth Putnam of your staff. If you have any questions regarding this issue, please contact me at your earliest convenience at 301-415-2020. I Sincerely, .

. On. .ginalsigned by: k* ($i Brenda L. Mozafari, Project Manager, Section 1 Project Directorate ill l Division of Licensing Project Management i Office of Nuclear Reactor Regulation  !

Docket No. 50-331 DISTRIBUTION: j Docket File PUBLIC JHannon PD31r/f

Enclosure:

As stated GGrant, Rlli JZwolinski/SBlack JPulsipher GHubbard (SPLB) OGC ACRS Slee (SPSB) cc w/ encl.:._See next page l DOCUMENT NAME:0:\PDlli-1\DUANEARN\RAl-EFCV.WPD OFFICE PM:PD31 E LA:PD31 E SC:PD31 E NAME BMozafari EBamhill W CCraigNU('

c DATE 9/2 7/99 9lAff99 9/Y]/99 OFFICIAL RECORD COPY [

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3?0051 9909300243 990927 PDR ADOCK 05000331 P PDR

l,, September 27, 1999 lv ,

Mr. Eliot Protsch -

i L  : President j

IES Utilities Inc.

200 First Street, SE ,

P.O. Box 351 Cedar Rapids, IA 52406-0351-

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON TECHNICAL SPECIFICATION CHANGE REQUEST REGARDING EXCESS FLOW CHECK VALVE SURVEILLANCE REQUIREMENTS AT DUANE ARNOLD ENERGY CENTER

. (TAC NO. MA05421)

Dear Mr. Protsch:

In a letter dated April 12,1999, IES Utilities (the licensee) submitted a request to revise Duane f

Amold Energy Center (DAEC) Technical Specification (TS) Surveillance Requirement (SR) l 3.6.1.3.7 to allow a representative sample of reactor instrumentation line excess flow control valves (EFCV) to be tested every 24 months, instead of testing each EFCV every 24 months. i The NRC staff has reviewed the licensee's submittal regarding the EFCV surveillance  !

requirement for DAEC, and has determined that additional information is necessary to comp!ete  !

our review.

l Your timely response to the enclosed request for additional Wrmation (RAI) will assist us in meeting your schedule. This RAI and the schedule have b6 n discussed with Kenneth Putnam of your staff. If you have any questions regarding this issue, please contact me at your earliest convenience at 301-415-2020.

Sincerely,

_ Originalsigned by:

Brenda L. Mozafari, Project Manager, Section 1 Project Directorate 111 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-331 DISTRIBUTION:

Docket File PUBLIC JHannon PD31r/f

Enclosure:

As stated. GGrant, Rlli JZwolinski/SBlack JPulsipher GHubbard (SPLB) OGC- ACRS Slee (SPSB) cc w/ encl.: See next page i 1

DOCUMENT NAME:0:\PDill-1\DUANEARNiRAI-EFCV.WPD I OFFICE PM:PD31 E LA:PD31 E SC:PD31 E NAME BMozafari EBarnhill W CCraig' U l' t DATE 9 /2 7/99 9 @ 99 9/ O /99 OFFICIAL R$ CORD COPY i

,, ,;c9  %,

4"E 4. UNITED STATES a$ g ,g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565 4001

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• September 27, 1999 Mr. Eliot Protsch President IES Utilities Inc.

200 First Street, SE P.O. Box 351 Cedar Rapids, IA 52406-0351 GUBJECT: REQUEST FOR ADDITIONAL INFORMATION ON TECHNICAL SPECIFICATION CHANGE REQUEST REGARDING EXCESS FLOW CHECK VALVE SURVEILLANCE REQUIREMENTS AT DUANE ARNOLD ENERGY CENTER (TAC NO. MA05421)

Dear Mr. Protsch:

In a letter dated April 12,1999, IES Utilities (the licensee) submitted a request to revise Duane Arnold Energy Center (DAEC) Technical Specification (TS) Surveillance Requirement (SR) 3.6.1.3.7 to allow a representative sample of reactor instrumentation line excess flow control valves (EFCV) to be tested every 24 months, instead of testing each EFCV every 24 months.

1 The NRC staff has reviewed the licensee's submittal regarding the EFCV surveillance 1 requirement for DAEC, and has determined that additional information is necessary to complete our review.

Your timely response to the enclosed request for additional information (RAI) will assist us in meeting your schedule. This RAI and the schedule have been discussed with Kenneth Putnam of your staff. If you have any questions regarding this issue, please contact me at your earliest convenience at 301-415-2020.

Sincerely, Brenda L. Mozafari, Pr ect Manager, Section 1 Project Directorate til Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

As stated cc w/ encl.: See next page

i Mr. Eliot Protsch Duane Amold Energy Center IES Utilities Inc.

l' cc:

l Jack Newman, Esquire -

1 Al Gutterman, Esquire '

l Morgan, Lewis, & Bockius 1800 M Street, NW.

Washington, DC 20036-5869 Chairman, Linn County Board of Supervisors Cedar Rapids, IA 52406 l

lES Utilities Inc.

ATTN: Gary Van Middlesworth i Plant Superintendent, Nuclear 3277 DAEC Road l

.Palo, IA 52324 John F. Franz, Jr.

! Vice President, Nuclear Duane Amold Energy Center 3277 DAEC Road Palo,IA 52324 Ken Peveler Manager of Regulatory Performance l

Duane Arnold Energy Center i

3277 DAEC Road Palo,IA 52324 U.S. Nuclear Regulatory Commission Resident inspector's Office Rural Route #1 Palo,IA 52324 Regional Administrator, Rlli  !

U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle,IL 60532-4531 Daniel McGhee Utilities Division Iowa Department of Commerce Lucas Office Building,5th floor Des Moines,IA 50319 l

I I

1 b l l

l REQUEST FOR ADDITIONAL INFORMATION REGARDING EXCESS FLOW CHECK VALVE SURVEILLANCE REQUIREMENTS FOR THE DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331  !

l

1. You have proposed a 10-year test interval for Excess Flow Check Valves (EFCVs), and I have primarily referred to Option B of Appendix J to 10 CFR Part 50, as the model for i

doing this. However, you have neglected to address the fact that the NRC staff, through  :

Regulatory Guide (RG) 1.163, limits containment isolation valve testing intervals to a maximum of 5 years. By licensees' requests, the RG has been incorporated by reference into the Technical Specifications (TS) of every plant that is using Option B of Appendix J. Thus, the 5-year interval is a requirement for every plant using Option B l

l Insofar as your justification for a 10-year test interval is, for the most part, that it is like l

l Option B of Appendix J, provide additional justification for your proposed interval that is longer than the 5-year interval used for Option B of Appendix J.

2. Under the Appendix J, Option B, program, if a component on an extended test interval fails a test, it musi be returned to the nominal test interval until subsequent testing re- J l

establishes its reliable performance. In other words, if it doesn't continue to perform '

well, it gets tested more often. Your proposal has no similar well-defined feedback j mechanism for EFCVs. There is only the following:

EFCV test failures will be evaluated to determine if additional testing in that test interval is warranted to ensure overall reliability is maintained. (From the l proposed DAEC Bases) l The risk-informed IST Regulatory Guide, RG 1.175, also specifies the need for a feedback mechanism.

Justify the absence from your proposal of an explicit, well-defined performance feedback mechanism that requires increased testing when valves fail their tests, or add such a mechanism to your proposal. l

3. The proposed Duane Arnold TS says "a representative sample" of EFCVs will be tested every 2 years. The " representative sample" is not defined. Your proposed Bases, which, you are careful to point out, are not part of your proposed license amendment i and are included for information only, say you will test 20% of the valves each refueling l outage and thus test all of them in a 10-year period. In fact, the proposed TS would l l allow you to test less than 20% each time, and the concept of " representative" could l l change with time to exclude certain valves that were problems (e.g., repeat leakers, hard to access). The point is not that these things will actually happen, but that the proposed TS contain virtually no actual requirements.

1 Justify the absence of more specific requirements in the proposed TS, or add specific requirements to the proposed TS.

t l