ML061870011
| ML061870011 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 07/21/2006 |
| From: | Raghavan L NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Vanmiddlesworth G Nuclear Management Co |
| D. Spaulding LPL3-1 X2928 | |
| References | |
| TAC MC8713, TAC MC8784, TAC MC8785 | |
| Download: ML061870011 (13) | |
Text
July 21, 2006 Mr. Gary Van Middlesworth Vice President Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785
SUBJECT:
DUANE ARNOLD ENERGY CENTER - RELIEF REQUESTS RELATED TO THE FOURTH 10-YEAR INTERVAL INSERVICE TESTING (IST) PROGRAM (TAC NOS. MC8713, MC8784 AND MC8785)
Dear Mr. Van Middlesworth:
By letter to the Nuclear Regulatory Commission (NRC) dated August 1, 2005, as supplemented by letters dated January 4, May 8, and May 19, 2006, Nuclear Management Company, LLC (NMC) (the former licensee), for Duane Arnold Energy Center (DAEC), submitted three requests for relief which are related to the DAEC Inservice testing program (IST) program for the fourth 10-year interval. The supplemental letter dated May 8, 2006, provided additional information for two of the relief requests, VR-01 and PR-02 (TAC Nos. MC8713 and MC8785), withdrew one of the relief requests, PR-01 (TAC No. MC8784), and submitted a new relief request PR-03, for which the staff review is being completed under TAC No. MD1844).
Amendment No. 260, issued on January 27, 2006, transferred the DAEC license from NMC to FPL Energy Duane Arnold, LLC, (FPL Energy), thus, any reference to the licensee refers to FPL Energy.
The NRC staff has completed its review of the licensees submittal.
In regards to relief request VR-01, our safety evaluation (SE) concludes that the licensees proposed alternative provides reasonable assurance of the operational readiness of the identified pumps, and that the proposed alternatives provide an acceptable level of quality and safety. The NRC staff has determined that relief is authorized for VR-01 pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year IST program.
In regards to relief request PR-02, our SE concludes that compliance with the Code requirements is impractical and that the alternative provides reasonable assurance of the operational readiness of the Standby Liquid Control Pumps. The NRC staff has determined that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Relief is therefore authorized for PR-02 pursuant to 10 CFR 50.55a(f)(6)(i) for the fourth 10-year IST program.
G. Van Middlesworth If you have any questions concerning this matter, please contact your project manager, Ms. D. Spaulding of my staff at (301)415-2928.
A copy of the SE is also enclosed.
Sincerely,
/RA/
L. Raghavan, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
As stated cc w/encl: See next page
- CPTB SE ML06 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/DCI/CVIB OGC NRR/LPL3-1/BC NAME DSpaulding THarris TLiu*
MLemoncelli LRaghavan DATE 7/21/06 7/21/06 06/26/06 07/10/06 7/21/06
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NUCLEAR REACTOR REGULATION DUANE ARNOLD ENERGY CENTER FPL ENERGY DUANE ARNOLD, LLC DOCKET NO. 50-331
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC) dated August 1, 2005, as supplemented by letters dated January 4, May 8, and May 19, 2006, Nuclear Management Company, LLC (NMC) (the former licensee), for Duane Arnold Energy Center (DAEC), submitted three requests for relief which are related to the DAEC Inservice testing program (IST) program for the fourth 10-year interval. The supplemental letter dated May 8, 2006, provided additional information for two of the relief requests, VR-01 and PR-02 (TAC Nos. MC8713 and MC8785), withdrew one of the relief requests, PR-01 (TAC No. MC8784), and submitted a new relief request PR-03, for which the staff review is being completed under TAC No. MD1844.
Amendment No. 260, issued on January 27, 2006, transferred the DAEC license from NMC to FPL Energy Duane Arnold, LLC, (FPL Energy), thus, any reference to the licensee refers to FPL Energy.
2.0 REGULATORY EVALUATION
The Code of Federal Regulations, 10 CFR 50.55a, requires that IST of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) IST program intervals in accordance with the specified ASME Code incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. In accordance with 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met.
In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Section 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Revision 1, Guidance for Inservice Testing at Nuclear Power Plants.
The DAEC, fourth 10-year IST interval commenced February 1, 2006. The program was developed in accordance with the 2001 Edition through 2003 Addenda of the ASME OM Code.
By letter dated August 1, 2005, NMC requested relief from certain requirements of the OM Code for its DAEC fourth 10-year IST interval.
The NRCs findings with respect to granting or denying the IST program relief requests are given below:
3.0 TECHNICAL EVALUATION
3.1 Relief Request No. VR-01 3.1.1 Code Requirements 2001 Edition and 2003 Addenda of the ASME OM Code Paragraph ISTC-3510 Exercising Test Frequency, Active Category A, Category B, and Category C check valves shall be exercised nominally every 3 months except as provided by ISTC-3520, ISTC-3540, ISTC-3550, ISTC-3560, ISTC-5221 and ISTC-5222. Power-operated relief valves shall be exercise tested once per fuel cycle. Relief is requested for the following excess flow check valves (EFCVs):
XFV2119 XFV4457B XFV4513 XFV4590 XFV4668 XFV2139 XFV4458A XFV4514 XFV4591 XFV4669 XFV2246A XFV4458B XFV4515 XFV4607 XFV4670 XFV2246B XFV4459A XFV4516 XFV4608 XFV4671 XFV2246C XFV4459B XFV4518 XFV4611 XFV4672 XFV2246D XFV4460A XFV4519 XFV4612 XFV4673 XFV2443A XFV4460B XFV4528 XFV4637 XFV4674 XFV2443B XFV4501A XFV4562 XFV4638 XFV4675 XFV2443C XFV4501B XFV4578 XFV4641A XFV4676 XFV2443D XFV4503 XFV4579 XFV4641B XFV4677 XFV4453A XFV4504 XFV4580 XFV4642A XFV4678 XFV4453B XFV4505 XFV4581 XFV4642B XFV4679 XFV4454A XFV4506 XFV4582 XFV4643A XFV4780 XFV4454B XFV4507 XFV4583 XFV4643B XFV4681 XFV4455A XFV4508 XFV4584 XFV4644A XFV4682 XFV4455B XFV4510A XFV4585 XFV4644B XFV4666 XFV4456A XFV4510B XFV4586 XFV4663 XFV4667 XFV4456B XFV4511 XFV4587 XFV4664 XFV4589 XFV4457A XFV4512 XFV4588 XFV4665 3.1.2 Licensees Basis for Requesting Relief (As Stated)
The licensee states:
The excess flow check valve is a simple device: the major components are poppet and spring. The spring holds the poppet open under static conditions. The valve will close upon sufficient differential pressure across the poppet. Functional testing of the valve is accomplished by venting the instrument side off the tube. The resultant increase in flow imposes a differential pressure across the poppet, which compresses the spring and decreases flow through the valve.
Excess flow check valves have been extremely reliable throughout the industry. In the first 30 years of operation at the DAEC, no excess flow check valve has failed to close due to actual valve failure (i.e., not related to test methodology). The DAEC Technical Specifications (TS) detail what frequency is required to maintain a high degree of reliability and availability, and provide an acceptable level of quality and safety. In the NRCs safety evaluation, associated with Amendmemt No. 29, the staff concluded, Based on the acceptability of the methods applied to estimate the release frequency, a relatively low release frequency estimate in conjunction with unlikely limit on core damage and negligible consequence of a release in the reactor building, we conclude that the increase in risk associated with the licensees request for relaxation of EFCV surveillance testing to be sufficiently low and acceptable. DAEC requested this relief pursuant to 10CFR50.55a(a)(3)(i) to exercise excess flow check valves at the frequency specified in amended DAEC TS Surveillance Requirement (SR) 3.6.1.3.7.
The NRCs Safety Evaluation also states that the radiological consequences of an unisolable rupture of an instrument line were evaluated in response to Regulatory Guide 1.11, as documented in DAEC UFSAR Section 1.8.11. This evaluation assumed a continuous discharge of reactor water through an instrument line with a 1/4 inch orifice for the duration of the detection and cooldown sequence. The assumptions for the accident evaluation do not change as a result of the change in test frequency, and the evaluation in the DAEC UFSAR Section 1.8.11 remains acceptable.
General Electric NEDO-32977-A (Boiling Water Reactor Owners Group (BWROG)
Topical Report B21-00658-01), Excess Flow Check Valve Testing Relaxation, dated November, 1998, (revised through June, 2000) was approved by the staff on March 14, 2000. NEDO-32977-A provides additional bases for this relief request.
The report concludes that the change in the test frequency had insignificant impact on valve reliability, and that the demonstrated reliability of EFCVs coupled with low consequences of EFCV failure provided adequate justification for extending the test interval up to once every 120 months.
3.1.3 Licensees Proposed Alternative Testing The licensee proposes:
Excess flow check valves will be exercised at the frequency specified in amended DAEC TS Surveillance Requirement (SR) 3.6.1.3.7. The surveillance requirement is to test a representative sample of Excess Flow Check Valves so that each Excess Flow Check Valve is tested at least once every 10 years.
The Excess Flow Check Valves have position indication in the control room. Check valve remote position indication is excluded from Regulatory Guide 1.97 as a required parameter for evaluating containment isolation. The remote position indication will be verified in the closed direction at the same frequency as the exercise test, which will be performed at the frequency prescribed in the amended DAEC TS Surveillance Requirement (SR) 3.6.1.3.7. After the close position test, the valves will be reset, and the remote open position indication will be verified. Although inadvertent actuation of an EFCV during operation is highly unlikely due to the spring-poppet design, the DAEC will verify the EFCV indicate open in the control room at a frequency greater than once every 2 years.
The failure of an EFCV to isolate would be evaluated per the DAEC corrective action program. The DAEC 10 CFR 50.65 Maintenance Rule Program specifies a performance criteria of less than or equal to 1 maintenance preventable failure to isolate per year on a 3 year rolling average.
3.1.4 Evaluation - Relief Request No. VR-01 An EFCV is provided in each instrument process line that penetrates the drywell and is connected to the reactor coolant pressure boundary. The EFCV is designed so that it will not close accidently during normal operation, will close if a rupture of the instrument line is indicated downstream of the valve, can be reopened when appropriate, and has its status indicated in the control room. Because of the unique design, testing of these ECVs and verifying their closure indication require a simulated instrument line break. With a larger number of EFCVs at DAEC, the Code-required test could result in a burden as well as significant costs for the licensee.
Therefore, the licensee proposes to perform the exercise tests on a sampling basis, i.e.,
approximately equal number of EFCVs are tested every 24 months and each EFCV is tested at least once every 10 years.
The proposed alternative described in the relief request is identical to the technical specification (TS) amendment request for Surveillance Requirement (SR) 3.6.1.3.7 that was submitted by letter dated April 12, 1999. The NRC staff safety evaluation (SE) regarding the proposed amendment was issued on December 29, 1999, and concluded that the increase in risk associated with the licensees request for relaxation of EFCV testing is sufficiently low and acceptable. Additionally, an orifice is installed just inside the drywell in each of these instrument lines. The orifice limits leakage to a level where the integrity and functional performance of secondary containment and associated safety systems are maintained, and the coolant loss is within the capability of the reactor coolant makeup system.
The initial relief request VR-01 submitted by the licensees letter dated August 1, 2005, referenced the DAEC TS Amendment No. 230 and referenced the Boiling-Water Reactor (BWR) Owners Group Topical report B21-00658-01, Excess Flow Check Valve Testing Relaxation as a basis for the relaxation. By letter dated March 14, 2000, the NRC submitted comments concerning generic application of EFCV testing relaxation to the BWR Owners Group on this Topical Report and requested that the report be revised accordingly. The General Electric NEDO-32977-A Report, dated June 2000, which was submitted in response to the NRC comments, concluded that individual licensees will develop their own EFCV performance criteria. This conclusion considered that DAEC has included the EFCVs as a subset within the Maintenance Rule. As identified in the March 14, 2000, letter to the BWR Owners Group, the EFCV performance criteria should be based on sound reliability modeling that is consistent with generally expected performance of the EFCVs. Further, the corrective action program must evaluate equipment failures and establish appropriate corrective actions to comply with the performance criteria. NEDO-32977-A also identifies that such performance criteria and the basis, once developed, will be subject to staff review.
In response to staff questions, the licensee submitted a revised VR-01 relief request by letter dated January 4, 2006. This revised relief request correctly references NEDO-32977-A dated June, 2000, as additional bases for the relief request. This report concludes that the change in the test frequency had insignificant impact on valve reliability, and that the demonstrated reliability of EFCVs coupled with low consequences of EFCV failure provided adequate justification for extending the interval up to once every 120 months.
Section 4.1 of NEDO-32977-A speculates that most EFCVs fail to close due to sticking, and Attachment A testing data identifies 21 failures on Browns Ferry Nuclear (BFN) Plant, Unit 2, and 5 failures on BFN, Unit 3, due to crud buildup and sticking after extended outages. Table 4-1 of NEDO-32977-A shows that both BFN and DAEC use the same make of EFCV.
Considering that NEDO-32977-A indicates DAEC has included EFCVs as a subset of the Maintenance Rule, the staff questioned if adequate maintenance would be performed on the EFCVs. The licensee was requested to indicate if there is any preventive maintenance performed on the EFCVs to prevent sticking and if no preventive maintenance is performed, to explain why such failures reported with similar valves are not expected when the valves are not exercised as frequently. The licensees response by letter dated May 8, 2006, stated that the EFCV vendor manual states that, under normal operating conditions, the valve does not require maintenance of any kind and DAEC concurs with the vendor that preventive maintenance is not needed. Although the licensee did not address valve failures at BFN, it appears that these failures may have resulted from the plant-specific layup conditions during the extended outage, rather than defective valves.
Attachment B to NEDO-32977-A includes a radiological analysis of the consequences of an unisolable instrument line break. The NRC staff was concerned that the consequences of a common-mode failure caused by sticking in the event of a postulated high-energy line break outside containment, should be considered in evaluating the reliability of the valves to close.
By letter dated May 19, 2006, the licensee responded that instrument lines containing EFCVs would not be impacted by postulated high-energy line breaks outside containment.
On the basis of information submitted by the licensee and the topical report submitted by the BWR Owners Group, there is reasonable assurance that the proposed alternative testing approach provides an acceptable level of quality and safety. The sampling approach that is consistent with the TSs will reduce radiation exposure during testing and provides a 95 percent confidence level for reliability based on current testing experience. Preventive maintenance is not required for these valves and the specified DAEC Maintenance Rule performance criteria should ensure continued reliability through effective corrective actions. The consequences of a rupture in an instrument line combined with a single-failure of an EFCV, have been analyzed and are shown to be acceptable. Therefore, the NRC staff finds that, due to the high reliability of the EFCVs and the acceptable consequences of a failure of an EFCV to isolate and trending of any EFCV test failures, the proposed alternative provides an acceptable level of quality and safety.
3.1.5 Conclusion - Relief Request No. VR-01 Based on the above evaluation, the staff concludes that the licensees alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the proposed alternative provides an acceptable level of quality and safety. The licensees proposed alternative provides reasonable assurance of the operational readiness of the identified pumps. Accordingly, the proposed alternative is authorized for the fourth10-year IST interval at DAEC.
3.2 Pump Relief Request No. PR-02 3.2.1 Code Requirements Paragraph ISTB 3510(e), General Frequency Response Range, of the ASME OM Code requires that the frequency response range of the vibration measuring transducers and their readout system shall be from one-third minimum pump shaft rotational speed to at least 1000 Hz. Relief is requested for the following standby liquid control (SBLC) pumps.
1P230A 1P230B 3.2.2 Licensees Basis for Requesting Relief The licensee states:
The nominal shaft rotational speed of these pumps is 242 rpm which is equivalent to approximately 4 Hz. Based on this frequency and ISTB-3510(e), the required frequency response range of instruments used for measuring pump vibration is 1.33 to 1000 Hz.
Procurement and calibration of instruments to cover this range is impractical due to the limited number of vendors supplying such equipment and the level and sophistication and cost of the equipment.
These are of a simplified reciprocating (piston) positive displacement design with rolling element bearings, Model Number TD-60, manufactured by Union Pump Corporation.
Union Pump Corporation has performed an evaluation of the pump design and has determined that there are no probable sub-synchronous failure modes associated with these pumps under normal operating conditions. Furthermore, there are no known failure mechanisms that would be revealed by vibration at frequencies below that related to shaft speed (4 Hz); thus no useful information is obtained below this frequency nor will indication of pump degradation be masked by instrumentation unable to collect data below this frequency to within tolerance prescribed by IST.
Sub-synchronous peaks are usually associated with sleeved bearing components.
These frequencies detect shaft to sleeve rub and oil whirl. The IST requirement for detection to 1/3 running speed is to detect these failure mode types. However, this Union pump design utilizes roller bearings which do not have the same failure modes.
For a roller bearing design, typical failure is ball or race related and occurs at frequencies greater than turning speed, classified as non-synchronous. As roller bearing fails, a corresponding change in 1 times turning speed and harmonics indicating excessive looseness and random impacting, not sub-synchronous frequencies, will be seen.
Per the manufacturer, there is no internal gearing in this pump model, therefore the input shaft RPM is also the crank RPM. The instrumentation for measuring vibration must be adequate for accurately assimilating information at this RPM. The significant modes of vibration with respect to equipment monitoring are as follows:
1-Times Crankshaft Speed - An increase in vibration at this frequency may be an indication of rubbing between a single crankshaft cheek and rod end, cavitation at a single valve, or coupling misalignment.
2-Times Crankshaft Speed - An increase in vibration at this frequency may be an indication of looseness at a single rod bearing or crosshead pin, a loose valve seat in the fluid cylinder, a loose plunger/crosshead stub connection, or coupling misalignment.
Other Multiple of Shaft Speed or Non-synchronous peaks - An increase in vibration at other frequencies may be an indications of cavitation at several valves, looseness at multiple locations or bearing degradation.
Per the manufacturer, all failure modes that cause vibration in the pump will be at multiples greater than the crank RPM.
Based on the forgoing discussion, it is clear that monitoring pump vibration within the frequency range of 4 to 1000 Hz will provide adequate information for evaluating pump condition and ensuring continued reliability with respect to the pumps function.
Relief is requested pursuant to 10CFR 50.55a(a)(3)(i); the alternative testing will provide an acceptable level of quality and safety 3.2.3 Licensees Proposed Alternative Testing The licensee proposes:
Vibration levels of Standby Liquid Control Pumps will be measured in accordance with the applicable portions of ISTB 3500 with the exception of the lower frequency response limit for the instrumentation (ISTB 3510(e). In this case the lower response limit of the vibration measuring equipment will be 4.00 Hz.
In addition to the normal SBLC pump IST vibration peak overall result, DAEC engineering department personnel will routinely perform post spectral/waveform analysis of the vibration data to ensure no adverse trends toward mechanical degradation go undetected. This lower limit restriction will not affect the operational readiness of the Standby Liquid Control Pumps, and the OM Code maximum allowable vibration limits for the required action range are being maintained.
The proposed alternative will result in corrective action on a pump prior to the occurrence of significant degradation.
3.2.4 Evaluation - Relief Request No. PR-02 The licensee requests relief from the frequency response range requirements for the SBLC P230A and P230B. This relief is requested for the 4th 10-year inservice testing program interval.
The ASME OM Code in paragraph ISTB 4.7.1(f) requires that the frequency response range for vibration measuring transducers and their readout system shall be from one-third of the minimum pump shaft rotational speed (2.3 Hz) to at least 1,000 Hz. The licensee proposes to use its existing instrumentation with a range of 4.03 Hz to 1,000 Hz.
These pumps are simplified, reciprocating (piston), positive-displacement pumps with rolling-element bearings. The pump manufacturer informed the licensee that this type of pump has no sub-synchronous failure modes. Furthermore, there are no known failure mechanisms that would be revealed by vibration at frequencies below those related to shaft speed (4 Hz).
The licensee states that, based upon the absence of a credible failure mode, no useful information will be obtained by testing below the 4 Hz frequency nor will any indication of pump degradation be masked by instrumentation unable to collect data below frequency.
The licensee identified the frequencies where high vibration would provide an indication of pump degradation as a one time (1X) pump running speed, (2X) pump running speed, and multiples of pump running speed. The types of problems that could be encountered at these frequencies were also identified. The frequency spectrum of the signals generated is characteristic of each pump and constitutes a unique pattern. Analysis of the pattern allows identification of vibration sources, and monitoring of change over time permits evaluation of the mechanical condition of the pump.
By letter dated May 8, 2006, the licensee provided additional information to support the determination that the low frequency Code requirement was impractical for this application.
The licensee stated that, in regard to a similar relief request for Pilgrim addressed in NUREG/CP-0152, Vol. 5, that the instrumentation utilized for Pilgrim would not meet the Code required accuracy for the DAECs lower value of 1.33 Hz. Further, based on discussion with the DAEC instrument vendor, the licensee stated that technology is not readily available that can achieve the Code-required accuracy for the DAECs 1/3 turning speed frequency of 1.33 Hz.
On the low end of the range, the signal is integrated from acceleration to obtain velocity.
The instrument manufacturer indicated that even with additional signal filtering the integration from acceleration to velocity will create a slope that would prevent from obtaining reliable data at frequencies this low. The integration creates a ski-slope on the low end so that at the Code-required frequencies low end frequencies for the DAEC, the data is corrupted by the ski-slope and the data would be unreliable.
Relief is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on (1) the impracticality of performing the Code required testing; (2) consideration of the burden on the licensee if the Code requirements were imposed on the facility, and; (3) the proposed alternative testing providing an acceptable level of assurance of the operational readiness of the pumps.
3.2.5 Conclusion - Relief Request PR-02 Based on the above evaluation, the staff concludes that the licensees alternative is authorized pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the Code requirements is impractical and that the alternative provides reasonable assurance of the operational readiness of the SBLC Pumps. The staff further concludes that granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. The licensees proposed alternative provides reasonable assurance of the operational readiness of the identified pump. Accordingly, relief is authorized for the fourth 10-year IST interval.
4.0 CONCLUSION
In regards to relief request VR-01, our SE concludes that the licensees proposed alternative provides reasonable assurance of the operational readiness of the identified pumps, and that the proposed alternatives provide an acceptable level of quality and safety. The NRC staff has determined that relief is authorized for VR-01 pursuant to 10 CFR 50.55a(a)(3)(i) for the fourth 10-year IST program.
In regards to relief request PR-02, our SE concludes that compliance with the Code requirements is impractical and that the alternative provides reasonable assurance of the operational readiness of the SBLC Pumps. The NRC staff has determined that granting relief pursuant to 10 CFR 50.55a(f)(6)(i) is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility. Relief is therefore authorized for PR-02 pursuant to 10 CFR 50.55a(f)(6)(i) for the fourth 10-year IST program.
Principal Contributor: R. McNally Date: July 21, 2006
Duane Arnold Energy Center cc:
Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. M. S. Ross Managing Attorney Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. R. E. Helfrich Senior Attorney Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. W. E. Webster Vice President, Nuclear Operations Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 John Bjorseth Site Director Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Steven R. Catron Manager, Regulatory Affairs Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 Palo, IA 52324 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Mr. M. Warner Vice President, Nuclear Operations Support Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Mr. D. A. Curtland Plant Manager Duane Arnold Energy Center 3277 DAEC Rd.
Palo, IA 52324-9785 Mr. R. S. Kundalkar Vice President, Nuclear Engineering Florida Power & Light Company P. O. Box 14000 Juno Beach, FL 33408-0420 Daniel McGhee Utilities Division Iowa Department of Commerce Lucas Office Buildings, 5th Floor Des Moines, IA 50319 Chairman, Linn County Board of Supervisors 930 1st Street SW Cedar Rapids, IA 52404