NG-98-0167, Application for Amend to License DPR-49,consisting of Request for TS Change RTS-299,revising Definitions of Cold Condition & Cold Shutdown & Adding Section 3.17,vessel Hydrostatic Pressure & Leak Testing,Per NUREG 1433,Rev 1

Application for Amend to License DPR-49,consisting of Request for TS Change RTS-299,revising Definitions of Cold Condition & Cold Shutdown & Adding Section 3.17,vessel Hydrostatic Pressure & Leak Testing,Per NUREG 1433,Rev 1

ML20199K975
Person / Time
Site:	Duane Arnold
Issue date:	02/03/1998
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199K978	List: ML20199K987 NG-98-0167, Application for Amend to License DPR-49,consisting of Request for TS Change RTS-299,revising Definitions of Cold Condition & Cold Shutdown & Adding Section 3.17,vessel Hydrostatic Pressure & Leak Testing,Per NUREG 1433,Rev 1
References
RTR-NUREG-1433 NG-98-0167, NG-98-167, NUDOCS 9802090067
Download: ML20199K975 (6)

Text

IES Uteties Inc.

200 Fnt Street S E.

PO. Box 351 s- Cedar Reds, M 5240&O351 Telephone 319 398 81F2 Fat 3I9 398 8I92 Johts F. Freru, Jr.

February 3,1998 NG-98-0167 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37 Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Request for Technical Specification change (RTS-299): " Revision of Vessel llydrostatic Pressure and Leak Testing Operability Requirements"

References:

1) NUREG 1433 Revision 1," Standard Technical Specifications, General Electric Plants,13WR/4"

2) Letter, J. Franz (IES) to F. Miraglia (NRC), " Submittal of License Amendment Request to Convert DAEC Technical Specifications to Improved Technical Specifications NUREG 1433," NG-96-2322, dated October 30,1996 (RTS 291)

File: A-ll7

Dear Sir (s):

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

The proposed amendment will revise the d:linitions of COLD CONDITION and COLD SHUTDOWN a,d a H a new section,3.17, VESSEL HYDROSTATIC PRESSURE AND LEAK Th 7 N'i, to the Technical Specifications to specifically allow reactor vessel hydrostatic pressure testing to be performed during plant shutdow'. The proposed changes are consistent with NUREG 1433, Rev.1 (Reference 1) and the DAEC's proposed conversion to the Improved Standard Technical Specifications (Reference 2).

This application has been reviewed by the DAEC Operations Ccmmittee and the Safety G,u319 Committee. A copy of this submittal, along with the evaluation of No Significant Hazards Consideration, is being forwarded to our appointed state official pursuant to 10 CFR Section 50.91. We ask that this application be given immediate attention to support ,I the 1993 refueling outage which is scheduled to begin April 2,1998.

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9902090067 790203 8 DR ADOCK OS 3 1 l- l- l-l in its innustnes coinvany

ND-98-0167 y February 3,1998

. age 2 Approval of this application by April 15,1998 is requested to support implementation during RFO 15. Should you have any questions regarding this matter, please contact this ofrice.

This lettei is true and cccu. ate to the best of my knowledge and belief.

IES UTILITIES INC.

By / \ M _

hn FI Franz ' I ice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this J^ day of J M 9 ,,1998, by 0 wb A.%r 9

ig.N.,1 D0hNA M. BIRidC)I ,

['M Notary Public in and for the State ofIowa

)E % J E /777 Conimissiori Expires Atteff.unents: 1) Evaluation of Change Pursuant to 10 CFR Section 50.92

2) Proposed Change RTS-299 to the Duane Arnold Energy Certer Technical Specifications

3) Safety Assessment

4) Environmental Consideration LLS/lls cc: L. Sueper L. Root D. Wilson (w/o)

R. Laufer (NRC-NRR)

B. Beach (Region III)

P. Baig (State ofIowa)

NRC Resident Office Docu I

. RTS-299 At6achment I to NG 98-0167 Page I of 4

'. EVALUATION OF CHANGE PURSUANT TO 10 CFR SECTION 50.92 Backcround:

The current DAEC Technical Specifications (T.S.) contain no explicit exceptions to the definition of COLD CONDITION to allow performing inservice hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. This testing is required to be performed psior to the reactor going critical after a refueling outage. Recirculation pump operation and a water solid reactor pressure vessel (RP V), as well as hydrostatic pump and control rod drive pump operation, are used to achieve the necessary temperatures and pressures required for these tests. The minimum allowed temperatures for these tests are determined from the Operating Limits Curve, T.S. Figure 3.6-1. These temperatures are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vcssel neutron fluence.

With increased reactor vessel fluence over time, the minimum allov able vessel temperature increases at a given pressure. Periodic updates to Figure 3.6-1 are performed as necessary, based upon the results of analyses ofirradiated surveillance specimens removed from the vessel. Hydrostatic pressure and leak testing will eventually be required with minimum reactor coolant temperamres greater than 212 F.

Since the hydrostatic or leak tests are performed at low decay heat values the stored energy in the reactor core will be very low. Under these conditions, the potential for failed fuel is inimized.

The proposed change will revise the definitions of COLD CONDITION and COLD SilUTDOWN to state that during the performance of vessel hydrostatic pressure and leak testing the reactor coolant temperature may be considered NA (may exceed 212*F), the reactor may be pressurized above atmospheric, and the reactor may be considered to remain in a COLD CONDITION / COLD SHUTDOWN as long as the requirenumts of a newly created section 3.17, VESSEL HYDROSTATIC PRESSURE AND LEAK TESTING, are compded with. Under this proposed change tl.e secondary containment, secondary containment isolation logic, secondary containment automatic isolation valves, and standby gas treatment system would be required to be OPERABLE during the performance of hydrostatic and leak testing and would be capable of handling any airbome radioactivity onteam leaks that could occur. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the po t ilated main steaan line break outside of primary containment. Therefore, these requirements would conservatively limit radiation releases to the environment.

^

, RTS-299 Attachment I to NG-98-0167 Page 2 of 4

$ 'The hoposed change will also add a surveillance requirement to perform channel checks every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> on the Reactor 'tessel Water Level -Low, Refuel Floor Exhaust Duct -

liigh Radiation, and Reacter Building Exhaust Shaft - liigh Radiation trip functions.

This surveillance requirement parallels the requirement in LCO 3.3.6.2," Secondary Containment isolation Instrumentation," Functions 1,3, and 4 of Table 3.3.6.2-1 of the DAEC's submittal for impmved Technical Specifications. LCO 3.3.6.2 is a condition of '

LCO 3.10.1 for performing system leakage or hydrostatic testing.

Ilydrostatic and leak tests, in and of themselves, are not considered to be Operations with the Patential for Draining the Reactor Vessel (OPDRVs). Small system leaks would be detected by leakage inspections before significant inventory losses occurred. Ilowever, in the event of a large primary system len, the reactor vessel would rapidly depressurize, allowing the low pressure core cooling systems to operate. Under this proposed change, two low pressure Emergency Core Cooling pumps (Core Spray and/or LPCI) capable )f injecting into the vessel would be required ta be OPERABLE which would be more than adequate to keep the core flooded under this low decay heat load condition. The proposed changes are consistent with NUREG 1433 Rev. I and the DAEC submittal for Improved Technical Specifications.

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

D"ane Ainold Enercy Center. Linn County. Iowa Date of Amendment Reauest: February 3.1998 Descrintion of Amendment Req 11t;.

The proposed amendment:

1. Revises the definitions of COLD CONDITION and COLD SHUTDOWN to state that, "During the performance of vessel hydrostatic pressure and leak testing the reactor coolant temperature may be considered NA, the reactor may be pressurized ahave atmospheric, and the reactor may be considered to remain in a COLD CONDITION /

COLD SilUTDOWN if the requirements of 3.17.A ar: met."

2. Adds note (g) to th,: AVERAGE REACTOR COOLANT TEMPERATURE column of Table 1.0-1 which states, "During the performance of vessel hydrostatic pressure and leak testing the reactor coolant temperature may be considered NA and the reactor may be considered to remain in COLD SHUTDOWN if the requirements of 3.17.A are met."

, RTS 2'99 Attachment I to NG-98-0167 Page 3 of 4

3. Ands a new section,3.17, VESSEL IIYDROSTATIC PRESSURE AND LEAK TESTING which will require that the following remain OPERABLE during the

(- performance of hydrostatic and leak testing: the Secondary Containment Isolation Functions Reactor Vessel Water Level - Low, Refuel Floor Exhaust Duct - liigh Radiation, and Reactor Building Exhaust Shaft - liigh Radiation; Secondary Containment Secondary Containment Automatic Isolation Dampers; Standby Gas Treatment; and two low pressure core cooling pumps (Core Spray and/or LPCI) capable ofinjecting into the vessel. In addition, Surveillance Requirement 4.17.A.1 will require that the Secondary Containment isolation Functions be channel checked every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during the performance of hydrostatic and leak testing.

Ilasis for nronosed No Sianificant 11azards Consideration:

The Commission has provided standards (10 CFR Section 50.92(c)) for determining whether a 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 possibility of a new or different kind of accident froni any accident previously e valuated; or (3) involve a significant reduction in a margin of safety.

After reviewing this proposed amendment, we have concluded:

1) The proposed amendment will t.ot mvohe a significant increase in the probability or consequences of an accident previously evaluated. Under this proposed change the secondary containment, secondary containment automatic isolation valves, and standby gas treatment systems would be required to be operable during the performance of hydrostatic and leak testing and would be capable of handling any airborne radioactivity or steam leaks that could occur. The required pressure testing conditions provide adequate assurance that the consequences of a steam leak will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment. The proposed change will not result in a significant change in the stored energy in the reactor vessel during the performance of the testing

2) The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed change will not alter the way hydrostatic pressure and leak testing is performed or significantly change the temperatures and pressures achieved to perfo m the test.

s

l -

, RTS-299 Attschment 1 to NG 98-0167 Page 4 of 4

3) Th'e proposed amendment will not involve a significant reduction in a margin of safety. The proposed changes and additions result in increased system operability requirements above those that currently crist during the performance of hydrostatic and leak testing and are consistent with the requirements of NUREG 1433 Rev.1. and the DAEC submittal for Improved Technical Specifications. The incremental increase in stored energy in the vessel during testing will be conservatively bounded by the consequences of the postulated main steam line break outside of primary containment.

Therefore, this change does not involve a significant reduction in a margin of safety, Based upon the above, we have determined that the proposed amendment will not involve 'i a significant hazards consideration.

Local Public Docu nent Room Location: Cedar Rapids Public Library,500 First Street SE, Cedar Rapids, Iowa 52401 Attorney for Licensee: Alvin Gutterman; Morgan, Lewis & Bockius,1800 M Street NW, i Washington, D.C. 20036-5869 l

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