ML090210036

MD7098 - Duane Arnold Energy Center (DAEC) - Record of Discussion of Approved Use of Code Case N-686 by DAEC

ML090210036
Person / Time
Site:	Duane Arnold
Issue date:	01/16/2009
From:	Feintuch K Plant Licensing Branch III
To:	Feintuch K Plant Licensing Branch III
Feintuch K, NRR/DORL/LPL3-1, 415-3079
References
TAC MD7098
Download: ML090210036 (2)

Text

From: Karl Feintuch Sent: Friday, January 16, 2009 12:16 PM To: Karl Feintuch Cc: Karen Zeleznock

Subject:

MD7098 - Duane Arnold Energy Center (DAEC) - Record of discussion of approved use of Code Case N-686 by DAEC Categories: Today On January 8, 2009, Tony Browning, licensing engineer for Duane Arnold Energy Center (DAEC) contacted Karl Feintuch (USNRC) to schedule a conference call with Terence Chan.

The agenda for the call was:

(1) to clarify the scope of approved use of N-686 by Duane Arnold in the context of the revision of Code Case N-686 Revision 0 (published February 4, 2003) to N-686 Revision 1 (published January 10, 2007) that occurred at approximately the same time as the approval from the USNRC (issued January 31, 2007, based on Duane Arnold's application dated June 30, 2006) for Duane Arnold to use N-686; and (2) to discuss appropriate approaches to apply for a relief, consistent with the status of the current approval by the USNRC in effect, if additional licensing action is needed.

The conference call took place on January 8, 2009 at 11:00 AM ET with the following attendance:

For Duane Arnold: Tony Browning, Gary Park, Jason Dubois For USNRC: Karl Feintuch, Terence Chan.

Gary Park described the circumstances that lead to the enquiry. Terence Chan stated that he would review the approval issued by the USNRC and respond to the enquiry by Duane Arnold.

On January 8, 2009 at 6:44 PM ET, Terence Chan responded:

======== begin text of Chan January 8, 2009 response =======

From: Terence Chan Sent: Thursday, January 08, 2009 6:44 PM To: gary_park@fpl.com; Karl Feintuch Cc: Wallace Norris; David Hills; Mel Holmberg; George Hopper; Eric Michel; John White; Harold Gray; Wayne Sifre; Carol Nove; Louis Lake

Subject:

Use of N-686

Gary,

Background

N-686 approved by ASME 02/14/2003, applicable up to the 1998 edition with 2000 addenda.

N-686-1 approved by ASME 01/10/2007, applicable up to the 2004 edition.

RG 1.147, Rev.15 (October 2007) shows N-686 approved without conditions.

Based on discussion with our OGC, we've determined that continued use of N-686 as proposed by FPL Energy on June 30, 2006 and authorized by NRC letter dated Jan. 31, 2007, is permissible despite the applicability dates of N-686 do not include the 2001 edition through

2003 addenda - the version upon which DAEC's 4th ISI program is based. A request to use N-686-1, whose applicability dates include up to the 2004 edition, is not necessary. The basis for this determination is that our SE approved the use of N-686 for the 4th ISI interval which DAEC identified would be based on the 2001 Edition through the 2003 Addenda of the Code. This authorization also had the effect of subrogating the Code case applicability dates established by ASME as applied to DAEC for the 4th ISI interval. Since RG 1.147, Rev. 15, which was made effective on January 18, 2008 places no conditions on the use of N-686 beyond which DAEC was already approved to use, DAEC's use of the Code case is consistent with that of the RG.

Although the applicability dates of Code cases as imposed by ASME must be observed by users of the cases when they are invoked via RG 1.147, in this specific circumstance, the staff's specific authorization of Jan. 31,2007 supersedes the general authorization of RG 1.147, Rev.

15 as stated in 50.55a(b)(5).

However, because the reference to Section V, Article 9, T-941 and T-990 in paragraph (a) of the reply section in N-686 is not correct for the 2003 addenda, pointers to the correct Section V provisions when using N-686 should be identified in your internal procedures and documents, and the FSAR and/or ISI program plan should be revised to note that your implementation of N-686 will reflect the use of the correct provisions of Section V (i.e., 2001 edition consistent with N-686-1).

If you have any questions, feel free to call me.

Terence L. Chan, Chief Piping and NDE Branch Division of Component Integrity Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Terence.Chan@nrc.gov

=========== end text of Chan January 8, 2009 response ==========

Regarding the stated agenda, the January 8, 2009 response indicated that:

(1) a request by Duane Arnold for further action was not necessary; (2) no discussion of approaches to applying for a relief is necessary; and (3) affected DAEC documents should be revised to note the implementation of N-686 consistent with N-686-1).

=========== begin update on January 16, 2009 =================

In separate communication by me (Karl Feintuch) with Terence Chan and Tony Browning, Terence Chan affirmed that this record was complete from his perspective, and Tony Browning affirmed that the January 8, 2009 response (above), placed on the docket, was adequate for Duane Arnold Energy Center's needs.

=========== end update ==================================

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Subject:

MD7098 - Duane Arnold Energy Center (DAEC) - Record of discussion of approved use of Code Case N-686 by DAEC Sent Date: 1/16/2009 12:16:27 PM Received Date: 1/16/2009 12:16:27 PM From: Karl Feintuch Created By: Karl.Feintuch@nrc.gov Recipients:

Karl.Feintuch@nrc.gov (Karl Feintuch)

Tracking Status: None Karen.Zeleznock@nrc.gov (Karen Zeleznock)

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HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 18686 1/16/2009 Options Expiration Date:

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