NG-99-0112, Application for Amend to License DPR-49,proposing Rev to TS SR 3.8.1.7,consisting with NRC-approved Generic Traveler to ISTSs for General Electric BWR/4 Plants NUREG-1433,TSTF- 163,Rev 2

Application for Amend to License DPR-49,proposing Rev to TS SR 3.8.1.7,consisting with NRC-approved Generic Traveler to ISTSs for General Electric BWR/4 Plants NUREG-1433,TSTF- 163,Rev 2

ML20202E581
Person / Time
Site:	Duane Arnold
Issue date:	01/22/1999
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202E584	List: ML20202E593 NG-99-0112, Application for Amend to License DPR-49,proposing Rev to TS SR 3.8.1.7,consisting with NRC-approved Generic Traveler to ISTSs for General Electric BWR/4 Plants NUREG-1433,TSTF- 163,Rev 2
References
RTR-NUREG-1433 NG-99-0112, NG-99-112, NUDOCS 9902030081
Download: ML20202E581 (7)

Text

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g UTILITIESA L L'l A N T its uunue,Inc.

Duane Arnold Energy Center IES Utilities - 32n DAEC Road Palo,IA 52324@785 January 22,1999 ff;bff%%"-

3 NG-99-Oll2 ***.m.nannsymn Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission .

Attn: Document Control Desk Mail Station 0-PI-17 Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center Docket No: 50-331 s ' Op. License No: DPR-49 Technical Specification Change Request (TSCR-022):

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" Revision to Diesel Generator Surveillance Requirement"

Reference:

Letter, D. Wilson (IES) to U.S.NRC, " Request for Enforcement Discretion to Duane Arnold Energy Center Technical Specification Surveillance Requirement 3.8.1.7," NG-99-0115, January, 21,1999.

' File: A-117

Dear Sir (s):

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

As discussed with the Staffin a conference call on January 20,1999, IES Utilities proposes to revise the DAEC Technical Specifications (TS) Surveillance Requirement (SR) 3.8.1.7.

The proposed change is consistent with an NRC-approved Generic Traveler to the Improved Standard Technical Specifications for General Electric BWR/4 plants (NUREG-1433),

TSTF-163, Revision 2.. In addition, revisions to the TS BASES have been made pursuant to

. the BASES Control Program of TS 5.5.10 and 10 CFR 50.36(a) and are included to assist the

Staffin its review of the proposed TS changes. The BASES changes are included for information only and are not considered part of this application for license amendment.

~As discussed in the referenced letter, IES requests that this amendment be processed as an I

-. exigent request, pursuant to 10 CFR 50.91 (a) (6). The exigency is created due to the existing TS surveillance; SR 3.8.1.7, containing inappropriate acceptance criteria which the diesel l generator is not designed to meet and which is overly conservative with respect to the DAEC

Updated Final Safety Analysis Report (UFSAR) requirements for the diesel generators. This y\

i acceptance criteria was incorporated into the TS just prior to the approval of DAEC's conversion to Improved Standard TS (NUREG 1433). We did not intend that the basic hD

~ requirements of this testing be different from those contained in the former custom TS (CTS 4.8.A.2.a.2).1 However, a significant change was, in fact, introduced due to the adoption of

' the wording of NUREG-1433. Because this change was not recognized at that time, the plant 9902030001 990122 ' % .

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, NG-99-Ol l2 January 22,1999 l

Pr.ge 2 procedure for the new SR did not correctly implement the TS, as discussed in the referenced letter. It was only recently, during the review of the BASES for this SR for another issue, that i this error was recognized. Thus, the exigency could not have been avoided.

This application has been reviewed by the DAEC Operations Committee and the Safety l Committee. A copy of this submittal, along with the 10CFR50.92 evaluation of No Significant Hazards Consideration, is being forwarded to our appointed state official pursuant I to 10 CFR Section 50.91.-

l The following new commitment is being made in this letter:

Incorporate into the DAEC TS BASES for SR 3.8.1.7, a commitment to periodically i

monitor and trend the time for the DG to reach steady state operation to detect possible degradation in DG governor and voltage regulator performance. This '

BASES change will be made as a part of the implementation of this license amendment request.

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

IES UTILITI - INC. {

By John F. Franz Vice President, Nuclear State ofIowa (County) of Linn Signed and sworn to before me on this 2 3 -

day of h_ .uctm ,1999, by k g A L hdh .

kcut m Chdc.n f*g KATHkYN DUNLAP Notab P'u'b'lj$n and for thd State ofIowa

• WCOMRSSMDNES 7-24 99 Commission Expires Attachments: 1) EVALUATION OF CHANGE PURSUANT TO 10 CFR SECTION 50.92

2) PROPOSED CHANGE TSCR-022 TO THE DUANE ARNOLD ENERGY CENTER TECIINICAL SPECIFICATIONS

3) SAFETY ASSESSMENT

4) ENVIRONMENTAL CONSIDERATION

NG-99-Ol l2 January 22,1999 Page 3

. cc: C. Rushworth E. Protsch (w/o)

D. Wilson (w/o)

R. Laufer (NRC-NRR) -

J. Dyer (Region III)

P. Baig (State ofIowa)

NRC Resident Oflice Docu

. h4

TSCR-022 Attachment I to NG-99-O l l2 PageIof3

, EVALUATION OF CHANGE PURSUANT TO 10 CFR SECTION 50.92

Background:

On January 19,1999, it was determined that the surveillance test procedure (STP) used to demonstrate compliance with Technical Specification (TS) SR 3.8.1.7 did not adequately do so. Specifically, the STP did not account for any potential " overshoot" in voltage or frequency outside the allowed limits due to the diesel generator (DG) being tested in an unloaded condition. Itjust confirmed that the DG initially reached the required min: mum voltage and frequency values in the stated time of s 10 seconds. When the STP was revised to comply with the existing SR and re-performed on January 20, the DGs did not meet the revised test criteria. Both DGs were declared inoperable and appropriate TS Required Actions entered. After discussions with the NRC Staff, a Notice of Enforcement Discretion was verbally granted on January 20,1999, to allow continued plant operation and avoid the plant challenge associated with a TS-required shutdown.

The existing TS Surveillance Requirement (SR) is inappropriate. This was recognized l subsequent to the DAEC's conversion to Improved Standard TS. A change to the  !

Standard TS ('NUREG-1433, improved Standard Technical Specifications for General Electric BWR/4 Plants) has been approved by the NRC as Generic Traveler # TSTF-163, Revision 2. The proposed revision to the DAEC TS is consistent with this traveler.

IES Utilities Inc.. Docket No. 50-331 Duane Arnold Enerev Center. Linn County. Iowa Date of Amendment Reauest: January 22.1999  !

Description of Amendment Reauest: I Technical Specification (TS) Surveillance Requirement (SR) 3.8.1.7 is revised to state:

Verify each DG starts from standby condition and achieves l

a. in 510 seconds, voltage 2 3744V and frequency 2 59.5Hz; and I

b. steady state voltage 2 3744V and s 4576V and frequency 2 59.5Hz and 560.5Hz. l l

Basis for proposed No Sienificant Hazards 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 l operating license for a facility involves no significant hazards consideration if operation I 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 from any j accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

After reviewing this proposed amendment, we have concluded:

TSCR-022 Attachment I to NG-99-0112 Page 2 of 3

i. The' proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The safety function of the DG is to provide AC power to required safety systems during any Loss of Offsite Power (LOOP) event. The limiting design basis accident is the Loss of Coolant Accident with concurrent LOOP (LOOP-LOCA). This proposed amendment modifies a DG surveillance requirement and does not impact the off-site AC distribution system; therefore the probability of any LOOP event, including the LOOP-LOCA is not significantly increased.

This proposed change revises the SR to better match the plant conditions during the test.

SR 3.8.1.7 is performed with the DG unloaded. As a result, the DG initially over-shoots its target nominal voltage and frequency during testing. In an actual event, the DG would be almost immediately loaded once minimum voltage and frequency requirements are met, thereby limiting the over-shoot.

To ensure the DGs are able to fulfill their safety function, the proposed SR requires DG voltage and frequency to achieve the specified minimum acceptable values within 10 seconds and settle to a steady state voltage and frequency within the specified minimum and maximum values. That is, the upper limits are only applicable for steady state operation and do not apply during the transient portion of the DG start. The revision changes the SR 3.8.1.7 criteria to clarify which voltage and frequency limits are applicable during the transient and steady state portions of the DG start.

This change does not affect the DG's ability to supply the minimum voltage and frequency required within 10 seconds or the steady state voltage and frequency required by the UFSAR. The DGs will continue to perform their intended safety function, in accordance with the DAEC accident analysis. Thus, the consequences of any previously-analyzed event are not significantly increased by this change.

Therefore, the proposed amendment will not involve a significant increase in the probability or consequences of an accident preGoMy evaluated.

2. The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The revision changes the SR 3.8.1.7 criteria to clarify which voltage and frequency limits are applicable during the transient and steady state portions of the DG start. No changes are being made in how the system actually operates or is physically tested.

Therefore, the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

l

TSCR-022 Attachment I to NG-99-0112 Page 3 of 3

3. The, proposed amendment will not involve a significant reduction in a margin of safety.

The margin of safety is not significantly reduced. The DGs will perform their intended safety function,in accordance with the DAEC accident analysis. The revised test criteria are a better match for the tested condition (unloaded). The performance of other TS Surveillances (in particular, SRs 3.8.1.9,3.8.1.12 and 3.8.1.13) demonstrate DG Operability in conditions which are more representative of postulated accident conditions (loaded in the actual time sequence assumed in the accident analysis). The DGs will continue to perform their intended safety function in accordance with the DAEC accident analysis and UFSAR requirements. Therefore, the proposed amendment will not involve a significant reduction in a margin of safety.

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: Al Gutterman; Morgan, Lewis & Bockius,1800 M Street NW, Washington, D.C. 20036-5869 h

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TSCR-022 Attachment 2 to NG-99-0112 Page1ofI

' PROPOSED CHANGE TSCR-022 TO THE DUANE ARNOI.7 ENERGY CENTER TECHNICAL SPECIFICATIONS 1

.The holders oflicense DPR-49 for the Duane' Arnold Energy Center propose to amend -

~t he Technical Specifications by deleting the referenced pages and replacing them with the enclosed new pages.

SUMMARY

OF CHANGES: i Page Description of Chances

'3.8-7 Technical Specification (TS) Surveillance Requirement (SR) 3.8.1.7 is F revised to state: )

1 Verify each DG starts from standby condition and achieves  :

a. in s 10 seconds, voltage 2 3744V and frequency 2 59.5Hz; and 3

b. steady state voltage 2 3744V and s 4576V and frequency 2 l 59.5Hz and $60.5Hz.

B3.8-16 The associated Bases are revised to reflect the revision to SR 3.8.1.7.

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