NG-95-0759, Application for Amend to License DPR-49,to Modify Pump & Valve Surveillance Criteria for LPCI & Core Spray Subsystems,Rhr Svc Water,Hpci,Esw & River Water Supply Systems

Application for Amend to License DPR-49,to Modify Pump & Valve Surveillance Criteria for LPCI & Core Spray Subsystems,Rhr Svc Water,Hpci,Esw & River Water Supply Systems

ML20080Q061
Person / Time
Site:	Duane Arnold
Issue date:	03/01/1995
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20080Q064	List: ML20080Q085 NG-95-0759, Application for Amend to License DPR-49,to Modify Pump & Valve Surveillance Criteria for LPCI & Core Spray Subsystems,Rhr Svc Water,Hpci,Esw & River Water Supply Systems
References
NG-95-0759, NG-95-759, NUDOCS 9503080233
Download: ML20080Q061 (9)

Text

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I UTILITIES INC.

L John F. Franz, Jr.

Vice President. Nuclear March 1,1995 l.

NG-95-0759 Mr. William T. Russell, Director l Ollice of Nuclear Reactor Regulation l U. S. Nuclear Regulatory Commission

! Attn: Document Control Desk -

l Mail Station PI-37 l Washington, DC 20555-0001 I

Subject:

Duane Arnold Energy Center

[

Docket No: 50-331 l Op. License No: DPR-49 Request for Technical Specification Change l

(RTS-274): " Revision of ECCS Pump and ~

Valve Tes_ ting Requirements"

References:

NUREG-1433, " Standard Technical Specifications, General Electric Plants, l BWR/4" File: A-117

Dear Mr. Russell:

In accordance with the Code of Federal Regulations, Title 10, Sections 50.59 and 50.90, f IES Utilities Inc. hereby requests revision to the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC).

i The proposed change will modify the pump and valve surveillance criteria for the Low l Pressure Coolant injection (LPCI) subsystem and Core Spray subsystem, as well as the Residual lleat Removal (RilR) Service Water, liigh Pressure Coolant Injection (IIPCI),

Emergency Service Water (ESW), and River Water Supply systems (henceforth referred to in the aggregate as 'the affected pumps and valves') from once every three (3) months to the frequency specified by the DAEC ASME Section XI Inservice Testing (IST)-

program.

This application has been reviewed by the DAEC Operations Committee and the DAEC Safety Committee. A copy of this submittal, including the analysis of no significant hazards consideration, is being forwarded to our appointed state oflicial pursuant to the requirements of 10 CFR 50.91.

Oene r n

• 9503080233 950301 PDR ADOCK 05000331 P PDR m!

General Office

• P.O Box 351

• Cedar Rapids. Iowa 52406'

• 319/398-4411 ,

kj An IES INDUSTRIES Company q w

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Mr. William T. Russell NG-95-0759 l March.1,1995 'I Page 2 I

. We hereby request that the proposed amendment be approved with an et ective date 30 -

- days after issuance to allow adequate time for implementation.

No new commitments are made by this letter, i 1

This letter is true and accurate to the best of my knowledge and belief.

IES UTILITIES INC.- ,

By _/ #

l [Johh F. Franz /

Vice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this day of ,1995, l' .b h YW l # v gh .

l 3

k a N'otary Pbblic in and for the State ofIowa l5 l gg& p[, gf&

3 Commidion Expires v..

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JFF/LS/pj N:Y1owaiicensingapjv\c-274. doc Attachments: 1) Evaluation of Change with Respect to 10 CFR 50.92

2) Proposed Change (RTS-274) to the Duane Arnold Energy Center Technical Specifications

3) Safety Assessment

4) Environmental Consideration cc: L. Sueper L.Liu B. Fisher L. Root S. Brown (State ofIowa)

G. Kelly (NRC-NRR)

J. Martin (Region III)

NRC Resident OfIice Docu .

l. l i

i RTS-274 Attachment;l to -

NG-95-0759 l

~ Page l of 3 EVALUATION OF CHANGE WITH RESPECT TO 10 CFR 50.92

Background:

Sections 4.5 and 4.8 of the Duane Arnold Energy Center (DAEC) Technical l

Specifications (TS) currently require that various pumps and valves be tested once per three (3) months. The TS Bases for Sections 4.5 and 4.8 state that the test intervals for .

l this equipment " ..are based upon Section XI of the ASME code." Currently, altering the testing frequencies for any of the affected pumps and valves requires a' revision to the .

?

DAEC TS. This results in an unnecessary burden on the NRC staff and an undue delay to

the licensee because ASME/ ANSI OM-6 and OM-10 already contain' provisions for.

allowed deviations from the nominal three month testing frequencies. ,

The proposed change will revise the surveillance criteria _for the testing of certain pumps and valves in the Low Pressure Coolant Injection (LPCI) subsysten the Core Spray )

subsystems, and the Residual Heat Removal (RHR) Service Water, High Pressure Coolant '

' Injection (HPCI), Emergency Service Water'(ESW), and River Water Supply systems .i from every three months to the testing frequency specified by the DAEC IST program.

j The proposed change is consistent with NUREG-1433, " Standard Technical i Specifications, General Electric Plants, BWR/4," which generally defers to the IST

! program for the testing frequencies of pumps and valves.

The DAEC is committed to performing all required pump and valve testing in accordance with ASME Section XI (OM-6 and OM-10 respectively). Section 4.6.G.1 of the DAEC TS states, " inservice testing of ASME Section XI Code Class 1, Class 2 and Class 3 i

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

4

, IES Utilities Inc.. Docket No. 50-331.

j Duane Arnold Enerav Center. Linn County. Iowa Date of Amendment Request: March 1.- 1995 Description of Amendment Reauest:

L The proposed License Amendment would revise Sections 4.5 and 4.8 of the DAEC TS to reflect the changes to pump and valve testing frequency criteria.

i Specifically, the proposed amendment: l l-

! 1. Changes the criteria for testing frequency specified in Section 4.5.A.l.bf for Core Spray Pump Operability from "Once/3 months" to "As specified in the IST Program."

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RTS-274 . Attachment I to

, NG-95-0759 Page 2 of 3

2. Changes the criteria for testing frequency specified in Section 4.5. A.l.c. for Core Spray Motor-Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

- 3. Changes the criteria for testing frequency specified in Section 4.5.A.3.b. for LPCI Pump Operability frem "Once/3 months" to "As specified in the IST Program."-

4. Changes the' criteria for testing frequency specified in Section 4.5.A.3.c. for LPCI .

Motor-Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

5. Changes the criteria for testing frequency specified in Section 4.5.C.I.a. for RHR '

Service Water Pump and Motor Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

6. Changes the criteria for testing frequency specified in Section 4.5.D. l.b. for HPCI

' Pump Operability frorn "Once/3 months" to "As specified in the IST Program."

7. Changes the criteria for testing frequency specified in Section 4.5.D.I.c. for HPCI Motor Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

8. Changes the criteria for testing frequency specified in Section 4.5.J.l.b. for River Water Supply Pump and Motor Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

9. Deletes the sentence "The pumps and motor operated injection valves are also tested every three months to assure their operability." from Section 4.5 BASES.

10. Changes the criteria for testing frequency specified in Section 4.8.E.1.b for ESW Pump and Motor-Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

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RTS-274 Attachment I to NG-95-0759-Page 3 of 3 )

Basis for Proposed No Significant flazards Determination:

The Commission has provided standards (10 CFR 50.92(c)) for determining whether a L significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the -

L possibility of a new or ditTerent kind of accident from any accident previously evaluated;  ;

L or (3) involve a significant ' reduction in a margin of safety.

l Afler reviewing this proposed request for Technical Specification change, we have -

concluded: l

.1. The affected pumps and valves in Sections 4.5 and 4.8 will continue to be tested in

,. . accordance with ASME Section XI OM-6 and OM-10. The affected pumps and -

L valves will continue to function as before and this change will not result in a decrease  :

in their availability to mitigate the consequences of certain accidents and transients.

The proposed amendment will not affect the consequences of these accidents and '

transients.~ Therefore, the proposed amendment does not involve a change in the probability or consequences of an accident previously evaluatedJ

2. The proposed license amendment does not create the possibility of a new or different kind of accident from any previously evaluated. The safety functions of the affected pumps and valves will remain unchanged. This amendment will result in no physical changes to the affected pumps, valves or systems. Consequently, the proposed license j amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed amendment will not reduce the margin of safety. :The actual operation of the affected pumps and valves will remain unchanged. . Testing in a'ccordance with

[ ASME Section XI OM-6 and OM-10 will continue to provide assurance that degradation in tested components will be detected and addressed.

Based upon the above, we have determined that the proposed amendment will not involve -

-a significant hazards consideration.

Local Public Document Room Location: Cedar Rapids Public Library, 500 First Street -

SE, Cedar Rapids, Iowa 52401 Attorney for Licensee: Jack Newman, Kathleen H.'Shea; Morgan, Lewis & Bockius,-

1800 M Street NW Washington, D.C. 20036-5869

. RTS-274 Attachment 2 to NG-95-0759 Page 1 of 2 PROPOSED _CIIANGE (RTS-274) TO THE DUANE ARNOLD ENERGY CENTER TECHNICAL SPECIFICATIONS The holders of ficense DPR-49 for the Duane Arnold Energy Center propose to amend Appendix A (Technical Specifications) to said license by revising certain current pages and replacing tl.em with the attached, new pages. The List of Affected Pages is given below.

LIST OF AFFECTED PAGES 3.5-1 3.5-3 3.5-5 3.5-6 3.5-12 3.5-23 3.8-6

SUMMARY

OF CHANGES:

The following list of proposed changes is in the order that the changes appear in the Technical Specifications (TS).

P_a.gg Description of Changes 1

3.5-1 Changes the criteria for testing specified in Section 4.5. A. I.b. for Core Spray Pump Operability from "Once/3 months" to "As specified in the IST Program."

3.5-1 Changes the criteria for testing specified in Section 4.5.A.I.c. for Core Spray Motor-Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

3.5-3 Changes the criteria for testing specified in Section 4.5.A.3.b. for LPCI Pump Operability from "Once/3 months" to "As specified in the IST Program."

3.5-3 Changes the criteria for testing specified in Section 4.5. A.3.c. for LPCI Motor Operated Valve Operability from "Once/3 months" to "As specified in the IST Program"

. RTS-274 Attachment 2 to NG-95-0759

' Page 2 of 2 3.5-5 Changes the criteria for testing specified in Section 4.5.C.I.a. for RHR Service Water Pump and Motor Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

3.5-6 Changes the criteria for testing specified in Section 4.5.D.l.b. for HPCI Pump Operability from "Once/3 months" to "As specified in the IST Program."

3.5-6 Changes the criteria for testing specified in Section 4.5.D.I.c. for HPCI Motor Operated Valve Operability from "Once/3 months" to-

"As specified in the IST Program."

3.5-12 Changes the criteria for testing specified in Section 4.5.J.l.b. for River Water Supply Pump and Motor Operated Valve Operability from "Once/3 months". to "As specified in the IST Program."

3.5-23 Deletes the sentence "The pumps and motor operated injection valves are also tested every three months to assure their operability." from Section 4.5 BASES.

3.8-6 Changes the criteria for testing specified in Section 4.8.E.1.b for ESW Pump and Motor-Operated Valve Operability from "Once/3 months" to "As specified in the IST Program."

N&waM.icemingupjvWts-274Ax

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RTS-274 - Attachment 3 to -

' NG-95-0759 R I

Page1of1 l

, SAFETY ASSESSMENT Introduction By letter dated March 1,1995, IES Utilities Inc. submitted a request for revision of the Technical Specifications (TS) for the Duane Arnold Energy Center (DAEC), The .

- proposed changes revise the surveillance requirements for the testing of the pumps and.

motor-operated valves for the Low Pressure Coolant Injection and Core Spray-subsystems, Emergency Service Water and the Residual Heat Removal Service Water,

High Pressure Coolant Injection, a_nd River Water Supply systems from a frequency of o.nce per three (3) months to the frequency specified in the DAEC ASME Section XI -

i . Inservice Testing (IST) program.

Assessment -

The current three m_onth frequency for the testing of the subject pumps and motor -

operated valves is based on Section XI of the ASME Boiler and Pressure Vessel Code.

The DAEC IST program assures that inservice testing requirements of ASME Section XI

' (including OM-6 and OM-10) and approved relief requests are met. The affected pumps a and motor operated valves are in the DAEC IST program. Only those changes to the j testing frequencies of pumps and valves already allowed ~under OM-6 and OM-10 will be

made without requesting approval via relief request.

4 Based upon the above information, we have concluded that the proposed changes to the DAEC TS 'are acceptable.

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. RTS-274 - Attachment 4 to NG-95-0759

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! ENVIRONMENTAL CONSIDERATION i.

10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions which are eligible fer categorical exclusion from the requirement to perform an environmental assessment. ,

A proposed amendment to an operating license for a facility requires no environmental I assessment if operation of the facility in accordance with the proposed amendment would - ,

not: (1) involve a significant hazards consideration;(2) result in a significant change in the - 'I types or significant increase in the amounts of any effluents that may be released offsite; . )

and (3) result in a significant increase in individual'or cumulative occupational radiation .  !

exposure. IES Utilities Inc. has reviewed this request and determined that the proposed amendment meets the eligibility criteria'for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51'22(b), no environmental impact statement or -

environmental assessment needs to be prepared in connection with the issuance of the . .) '

amendment. The basis for this determination follows:

Basis )

The change meets the eligibility criteria for categorical exclusion set forth in 10 CFR S l.22(c)(9)' for the following reasons:

1. As demonstrated in Attachment I to this letter, the proposed Amendment does not involve a'significant hazards consideration.  ;

2. The proposed Amendment makes no changes to the surveillance testing frequencies of the affected pumps and valves that will residt in a significant change in the types or significant increase in the amounts of any emuents that may be  ;

. released offsite .

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3. The proposed Amendment makes no changes to_the existing surveillance testing j frequencies or the testing methodology of the affected pumps and valves that .I

! would result in a significant increase in either individual or cumulative occupational exposure.

l-N:%ma% Licensing 4pjvVrts-274 i

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