NG-99-0308, Application for Amend to License DPR-49,relaxing SR Frequency by Allowing Representative Sample of Excess Flow Check Valves to Be Tested Every 24 Months,Such That Each Will Be Tested at Least Once Every 10 Yrs

Application for Amend to License DPR-49,relaxing SR Frequency by Allowing Representative Sample of Excess Flow Check Valves to Be Tested Every 24 Months,Such That Each Will Be Tested at Least Once Every 10 Yrs

ML20205P796
Person / Time
Site:	Duane Arnold
Issue date:	04/12/1999
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205P800	List: ML20205P803 ML20205P809 NG-99-0308, Application for Amend to License DPR-49,relaxing SR Frequency by Allowing Representative Sample of Excess Flow Check Valves to Be Tested Every 24 Months,Such That Each Will Be Tested at Least Once Every 10 Yrs
References
NG-99-0308, NG-99-308, NUDOCS 9904200372
Download: ML20205P796 (7)

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]y ALLi UTillTIES ANT in nan,e, in, t hune Arn..ld Lnerp Center IES Utilities w Itue uma l%Iu,lA U Ul' chi Otk e. I19 M I7f.!I April 12,1999 [t'1,Ye[.L,,n NG-99-0308 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk i Mail Station 0-PI-17 Washington, DC 20555-000l l

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Technical Specification Change Request (TSCR-010):

" Relaxation of Excess Flow Check Valve Surveillance Testing" 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 (TS) for the Duane Arnold Energy Center (DAEC).

Surveillance Requirement (SR) 3.6.1.3.7 currently requires verification of the actuation ,

capability of each reactor instrumentation line Excess Flow Check Valve (EFCV) every 24 ,/,

months. This proposed change is to relax the SR frequency by allowing a " representative sample" of EFCVs to be tested every 24 months, such that each EFCV will be tested at least once every 10 years (nominal). The proposed change is similar to existing performance-based testing programs, such as inservice Testing (snubbers) and Option B to 10 CFR 50 Appendix J.

467)j 9904200372 990412 PDR ADOCK 05000331 P PDR .

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scve>-own  ;

April 12,1999 I Page 2 l

I The basis ti>r this amendment is consistent with that described in a iloiline Water Reactor j Owners' Group (llWROG) report, B21-00658-01, oated November 1998. Ilowever, this request has been tailored to the preferences stated t r NRC Staff after reviewing that report at an August 6,1998 meeting with the BWOG. In keeping with those preferences, the 1)AliC is submitting this request as a lead plant and a generic TS change has been initiated li>r NURliG 1433.

In addition, a revision to the TS BAS!!S has been initiated pursuant to the BASliS l Control Program of TS 5.5.10 and to CFR 50.36(a) and is included to assist the Staffin l its review of the proposed TS change. These changes are included for intbrmation only and are not considered part of this application for license amendment.

The I)AliC Operations Committee and the Safety Committee have reviewed this application. A copy of this submittal, along with the evalurlion of No Significant llazards Consideration, is being lbrwarded to our appointed state official pursuant to 10 CFR 50.91. We respectfully request a 60-day implementation period for this revision.

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

II!S UTILITil!S INC.

By h-John F. Franz Vice President, Nuclear State of Iowa (County) of Linn Signed and sworn to belbre me on this I day of I Y'\

t 1999 By lbid L W\$m d RCy. .

Locb

. ;. c Notah Public in and for the State ofIowa i/A' V'NCY S FMNCK e

ww y O [ '[)l

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Commission lixpires

NG-99-0308 April 12,1999 Page 3 Attachments: 1) EVALUATION OF CilANGE PURSUANT TO 10 CFR SECTION 50.92

2) PROPOSED CllANGE TSCR-010 TO Tile DUANE ARNOLD ENERGY CENTER TECilNICAL SPECIFICATIONS

3) SAFETY ASSESSMENT

4) ENVIRONMENTAL CONSIDERATION

5) IlWROG REPORT B21-00658-01," EXCESS FLOW CIIECK VALVE TESTING RELAXATION," dated November 1998.

cc: J. W. Karrick E. Protsch (w/o)

D. Wilson (w/o)

B. Mozafari (NRC-NRR)

J. Dyer (Region III)

P. Baig (State ofIowa)

NRC Resident Office Docu

4 TSCR-0J O Anachment I to NG-99-0308 l' age I of 4 EVAL,UATION OF CHANGE PilRSIJANT TO 10 CFR SECTION 50.92 Backuround:

DAEC Technical Specification Surveillance Requirement (SR) 3.6.l.3.7 currently requires verification of the actuation capability of each reactor instrumentation line Excess Flow Check Valve (EFCV) every 24 months. This proposed change is to relax the SR frequency by allowing a " representative sample" of EFCVs to be tested every 24 months, such that each EFCV will be tested at least once every 10 years (nominal). The proposed change is similar to existing performance-based testing programs, such as inservice Testing (snubbers) and Option B to 10 CFR 50 Appendix J.

The BWROG has issued a report that provides a basis for this request. This report (B21-00658-01 dated November 1998), enclosed as Attachment 5 to this submittal, provides justification for both relocation of this SR from TS to the Technical Requirements Manual (TRM) and a relaxation in the SR frequency as described above. The report demonstrates, through operating experience, a high degree of reliability with the EFCVs and the low consequences of an EFCV fitilure. Reliability data in the report (Table 4-1) documents zero EFCV litilures (to isolate) at the DAEC.

Members of the NRC Staff and the BWROG EFCV Committee met on August 6,1998, to discuss the report contents. Based upon the outcome of this meeting,(documented in GE meeting summary OG98-0327-213, dated August 17,1998) the DAEC is submitting this request as a lead plant. A generic TS change request has been initiated for BWR-4 (NtJREG 1433) plants. Also in keeping with the August 6th meeting, this proposed change does not relocate the SR from the TS as justified in the report. This specific request is solely for the relaxation in the SR frequency as described above, with the SR remaining in the plant TS.

In addition, a revision to the TS BASES has been initiated pursuant to the BASES Control Program of TS 5.5.10 and 10 CFR 50.36(a) and is included to assist the Staffin its review of the proposed TS change. This TS BASES change is included Ibr information only and is not considered part of this application ihr license amendment.

This change includes the incremental testing (approximately 20% per cycle) and actions to be taken when test failures occur as discussed at the August 6th meeting with the Staff.

While the generic change includes discussions regarding grouping of the EFCVs based on valve design and environmental conditions, since all the EFCVs at DAEC are of the same design with similar environmental conditions, sub-grouping of the valves is not considered necessary at the DAEC.

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4 TSCR-010 Attachment I to NG-99-0308 Page 2 of 4 l

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

Duane Arnold Eneruv Center. I, inn County. Iowa Date of Amendment Request: April 12.1999 Description of Amendment Request:

The proposed amendment:

1. Relaxes the number of EFCVs tested every 24 months from "each" to a

" representative sample" every 24 months. The representative sample is based on approximately 20% of the val >es each cycle such that each valve is tested every 10  !

years (nominal).

Basis for proposed No Sieniticant Ilazards 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 liteility in accordance with the proposed amendment would not (1) involve a significant increase in the pcobability or consequences of an accident previously evaluated;(2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Aller reviewing this proposed amendment, we have concluded:

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

The current SR frequency requires each reactor instrumentation line EFCV to be j tested every 24 months. The EFCVs at DAEC are designed so that they will not close accidentally during normal operation, will close if a rupture of the instrument line is indicated downstream of the valve, can be reopened when appropriate, and have their status indicated in the control room (reference DAEC UFSAR 1.8.11). This proposed change allows a reduced number of EFCVs to be tested every 24 months. There are no physical plant modifications associated with this change. Industry operating experience demonstrates a high reliability of these valves. Neither EFCVs nor their failures are capable ofinitiating previously evaluated accidents: therefere there can be no increase in the probability of occurrence of an accident regarding this proposed change.

Instrument lines connecting to the Reactor Coolant Pressure Boundary (RCPB) with EFCVs installed also have a flow-restricting orifice upstream of the EFCV. The 1

TSCR-010 Attachment I to NG-99-0308 Page 3 of 4 consequences of an unisolable rupture of such an instrument line has been previously evaluated in response to Regulatory Guide (RG) 1.11 (DAEC UFSAR 1.8.1.1). That evaluation assumed a continuous discharge of reactor water for the duration of the detection and cooldown sequence (3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />). Therefore, although not expected to occur as a result of this change, the postulated failure of an EFCV to isolate as a result of reduced testing is bounded by this previous evaluation. Therefore, there is no increase in the previously evaluated consequences of the rupture of an instrument line and there is no potential increase ;n the consequences of an accident previously evaluated as a result of this change.

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

This proposed change allows a reduced number of EFCVs to be tested each operating cycle. No other changes in requirements are being proposed. Industry operating experience demonstrates the high reliability of these valves. The potential titilure of an EFCV to isolate by the proposed reduction in test frequency is bounded by the previous evaluation of an instrument line rupture. This change will not physically alter the plant (no new or different type of equipment will be installed). This change will not alter the operation of process variables, structures, systems, or components as described in the safety analysis. Thus, a new or different kind of accident will not be created.

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

The consequences of an unisolable rupture of an instrument line has been previously evaluated in response to RG 1.11 (reference DAEC 1;FSAR 1.8.1.1). That evaluation assumed a continuous discharge of reactor water for the duration of the detection and cooldown sequence (3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />). The only margin of safety applicable to this proposed change is considered to be that implied by this evaluation. Since a continuous discharge was assumed in this evaluation, any potential failure of an EFCV to isolate postulated by this reduced testing frequency is bounded and does not

, involve a significant reduction in the margin of safety.

Ilased upon the above, the proposed amendment is judged to involve no significant hazards considerations.

I

ISCR-010 Attachment I to NG-09-0308 Page 4 of 4 Imcal Public Document Room I.ocation: Cedar Rapids Public Library,500 First Street  ;

SE, Cedar Rapids, Iowa 52401 Attornev for 1.icensee: Jack Newman, Al Gutterman; Morgan, i.ewis & Ilockius,1800 M Street NW, Washington, D.C. 20036-5869 l

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