ML092940435
| ML092940435 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 11/02/2009 |
| From: | Harris B License Renewal Projects Branch 1 |
| To: | Costanzo C NextEra Energy Duane Arnold |
| Harris B, NRR/DLR, 415-2277 | |
| References | |
| TAC MD9769 | |
| Download: ML092940435 (11) | |
Text
November 2, 2009 Mr. Christopher Costanzo Vice President, Nuclear Plant Support NextEra Energy Duane Arnold, LLC P.O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
SCOPING AND SCREENING AUDIT REPORT REGARDING THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION (TAC NO. MD9769)
Dear Mr. Costanzo:
By letter dated September 30, 2008, as supplemented by letter dated January 23, 2009, FPL Energy Duane Arnold, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center. On August 10, 2009, the staff of the U.S. Nuclear Regulatory Commission conducted an on-site audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact me by telephone at 301-415-2277 or by e-mail at Brian.Harris2@nrc.gov.
Sincerely,
/RA by Bo Pham For/
Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
As stated cc w/encl: See next page
November 2, 2009 Mr. Christopher Costanzo Vice President, Nuclear Plant Support NextEra Energy Duane Arnold, LLC P.O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
SCOPING AND SCREENING AUDIT REPORT REGARDING THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION (TAC NO. MD9769)
Dear Mr. Costanzo:
By letter dated September 30, 2008, as supplemented by letter dated January 23, 2009, FPL Energy Duane Arnold, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center. On August 10, 2009, the staff of the U.S. Nuclear Regulatory Commission conducted an on-site audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact me by telephone at 301-415-2277 or by e-mail at Brian.Harris2@nrc.gov.
Sincerely,
/RA by Bo Pham For/
Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
See next page ADAMS Accession No.: ML092940435 OFFICE: PM:RPB1:DLR LA:DLR BC:RPB1:DLR PM:RPB1:DLR NAME: BHarris SFigueroa BPham BHarris (Signature)
DATE: 10/28/09 10/28/09 10/30/09 11/2/09 OFFICIAL AGENCY RECORD
Letter to Christopher Costanzo from Brian K. Harris dated November 2, 2009
SUBJECT:
SCOPING AND SCREENING AUDIT REPORT REGARDING THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION (TAC NO. MD9769)
DISTRIBUTION:
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B. Harris C. Eccelston M. Spencer K. Feintuch
Duane Arnold Energy Center cc:
Mr. M. S. Ross Ms. Melanie Rasmussen Vice President and Associate Radiation Control Program Director General Counsel Bureau of Radiological Health Florida Power & Light Company Iowa Department of Public Health P.O. Box 14000 Lucas State Office Building, 5th Floor Juno Beach, FL 33408-0420 321 East 12th Street Des Moines, IA 50319-0075 Ms. Marjan Mashhadi Senior Attorney Chairman, Linn County Florida Power & Light Company Board of Supervisors 801 Pennsylvania Avenue, NW 930 1st Street SW Suite 220 Cedar Rapids, IA 52404 Washington, DC 20004 Mr. Raj Kundalkar, Vice President Mr. Steven R. Catron Fleet Organizational Support Manager, Regulatory Affairs Florida Power & Light Company Duane Arnold Energy Center P.O. Box 14000 3277 DAEC Road Juno Beach, FL 33408-0420 Palo, IA 52324 Mr. McHenry Cornell U.S. Nuclear Regulatory Commission Director, Licensing and Performance Resident Inspector=s Office Improvement Rural Route #1 Florida Power & Light Company Palo, IA 52324 P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. Mano Nazir Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Mr. D. A. Curtland Plant Manager Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785 Abdy Khanpour Vice President, Engineering Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF LICENSE RENEWAL Docket No: 50-331 License No: DPR-049 Licensee: FPL Energy Duane Arnold, LLC Facility: Duane Arnold Energy Center Location: 3277 DAEC Road Palo, IA 52324-9785 Dates: August 24, 2009-August 28, 2009 Reviewers: B. Rogers, Reactor Engineer, Division of License Renewal (DLR)
B. Harris, Project Manager, DLR D. Brittner, Mechanical Engineer, DLR J. Shea, Mechanical Engineer, DLR A. Paulson, Mechanical Engineer, DLR ENCLOSURE
SCOPING AND SCREENING METHODOLOGY TRIP REPORT DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION I. Introduction During the week of August 24-28, 2009, the Division of License Renewal (DLR) performed an audit of the FPL Energy Duane Arnold, LLC (the applicant) license renewal scoping and screening methodology developed to support the license renewal application (LRA) for Duane Arnold Energy Center (DAEC). The audit was performed at the applicants facility located in Palo, Iowa. The focus of the staffs audit was the applicants administrative controls governing implementation of the LRA scoping and screening methodology and review of the technical basis for selected scoping and screening results for various plant systems, structures, and components (SSCs). The audit team also reviewed quality attributes for aging management programs (AMPs), quality practices used by the applicant to develop the LRA, and training of personnel that developed the LRA.
The regulatory bases for the audit were Title 10 of the Code of Federal Regulations, Part 54 (10 CFR 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, and NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 1 (SRP-LR). In addition, the applicant developed the LRA in accordance with Nuclear Energy Institute (NEI) 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR 54 - The License Renewal Rule, Revision 6 (NEI 95-10) which the U.S. Nuclear Regulatory Commission (NRC) has endorsed via Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, (RG 1.188).
II. Background 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for license renewal contain an integrated plant assessment (IPA). Furthermore, the IPA must list and identify those structures and components (SCs) subject to an aging management review (AMR) from the SSCs that are included within the scope of license renewal. 10 CFR 54.4(a) identifies the plant SSCs within the scope of license renewal. SCs within the scope of license renewal are evaluated to determine if they are long-lived and passive equipment and, therefore, subject to an AMR in accordance with 10 CFR 54.21(a)(1).
III. Scoping Methodology The scoping evaluations for the DAEC LRA were performed by the applicants license renewal project personnel. The audit team conducted detailed discussions with the applicants license renewal project personnel and reviewed documentation pertinent to the scoping process. The audit team assessed whether the scoping methodology outlined in the LRA and implementation procedures were appropriately implemented and whether the scoping results were consistent with current licensing basis requirements.
The audit team also reviewed a sample of system scoping results for the following systems and structures: safety related air, residual heat removal, emergency service water, and the turbine building. The audit team determined that the applicants scoping methodology was generally
consistent with the requirements of the Rule for the identification of SSCs that meet the scoping criteria of 10 CFR 54.4(a). However, the audit team determined that additional information was required in order for the staff to complete its review:
! The staff requested the basis for not including certain components, classified as safety-related in the equipment database, within the scope of license renewal in accordance with 10 CFR 54.4(a)(1).
! The staff requested the basis for not including certain nonsafety-related tubing (that is a portion of a nonsafety-related piping system attached to safety-related SSCs) within the scope of license renewal. The applicant indicated that the interface between the pipe and the tubing identified the boundary of the nonsafety-related component to be included within the scope of license renewal (the pipe was included while the tubing was not).
! The staff requested the basis for not including the nonsafety-related trash bars and trash rake IS-83, located adjacent or within the safety-related intake structure, within the scope of license renewal.
IV. Screening Methodology The audit team reviewed the methodology used by the applicant to determine if mechanical, structural, and electrical components within the scope of license renewal would be subject to an AMR (screening). The applicant provided the audit team with a detailed discussion of the processes used for each discipline and provided administrative documentation that described the screening methodology. The audit team also reviewed the screening results reports for the safety-related air, residual heat removal, emergency service water, and the turbine building.
The audit team noted that the applicants screening process was performed in accordance with its implementing requirements and was consistent with the guidance provided in the SRP-LR and NEI 95-10. The audit team determined that the screening methodology was consistent with the requirements of the Rule for the identification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).
V. Aging Management Program Quality Assurance Attributes The audit team reviewed the applicants AMPs described in Appendix A, Duane Arnold Updated Final Safety Analysis Report Supplement, and Appendix B, Aging Management Programs and Activities, of the DAEC LRA for inclusion of the appropriate quality assurance (QA) requirements for elements No. 7 (corrective action), No. 8 (confirmation process), and No. 9 (administrative controls). In addition, the audit team reviewed each individual AMP basis document to ensure consistency in the use of the QA attributes for each program. The purpose of this review was to ensure that the aging management activities were consistent with the staffs guidance described in SRP-LR, Section A.2, Quality Assurance for Aging Management Program (Branch Technical Position IQMB-1).
Based on the audit teams evaluation, the descriptions and applicability of the AMPs and their associated quality attributes, provided in Appendix A, Section 18.1, Aging Management Programs, and Appendix B, Section B.1.3, Quality Assurance Program and Administrative Controls, of the LRA, were determined to be generally consistent with the staffs position regarding QA for aging management.
VI. Quality Assurance Controls Applied to LRA Development The staff reviewed the quality controls used by the applicant to ensure that scoping and screening methodologies used to develop the LRA were adequately implemented. The applicant utilized the following quality control processes during the LRA development:
! Written procedures were developed to govern the implementation of the scoping and screening methodology.
! Basis documents were prepared for each system that provided descriptions of system functions, system function references, equipment within the boundary, and components subject to an aging management review.
! Scoping and screening summary reports and revisions were prepared, independently verified and approved.
! All project deliverables included a preparer, verifier, technical lead, project lead and the program owner when appropriate.
! Lessons learned from prior license renewal applications were incorporated into the application.
! Documents received an industry peer review.
! A sample of systems in the license renewal database was reviewed by an independent evaluator to verify that systems scoping had been documented appropriately.
! Two oversight evaluations were performed to review the license renewal activities and concluded that license renewal activities were satisfactory.
! Staff involved in the license renewal process participated in NEI sponsored industry groups.
! Management oversight was provided in monthly meetings to review the status of projects and issues.
The audit team performed a sample review of reports and LRA development guidance, the applicants documentation of the activities performed to assess the quality of the LRA, and held discussions with the applicants license renewal personnel. The audit team determined that the applicants activities provide assurance that LRA development activities were performed consistently with the applicants license renewal program requirements.
VII. Training for License Renewal Project Personnel The audit team reviewed the applicants training process to ensure the guidelines and methodology for the scoping and screening activities were applied in a consistent and appropriate manner. The applicant required training for all personnel participating in the development of the LRA and used only trained and qualified personnel to prepare the scoping and screening implementing procedures.
! A license renewal training program was developed following an industry training process to develop a Job Familiarization Guide (JFG) for license renewal.
! All license renewal team members were required to complete the appropriate JFG in accordance with station procedures and be assessed during an interview to verify an understanding of the material.
! The training material for JFG was detailed and covered the entire license renewal process as defined in the license renewal administrative control procedures.
! All license renewal team members were required to complete the JFG prior to signing a report.
! Certain work on the license renewal projects required staff to be qualified in additional qualification programs.
! The training process incorporated lessons-learned from other license renewal projects.
! The Electric Power Research Institute (EPRI) provided two training sessions on recognizing aging effects.
On the basis of discussions with the applicants license renewal personnel responsible for the scoping and screening process, and a review of selected documentation in support of the process, the NRC audit team determined that the applicants personnel understood the requirements and adequately implemented the scoping and screening methodology established in the applicants renewal application.
VIII. Final Briefing A final briefing was held with the applicant on August 28, 2009, to discuss the results of the scoping and screening methodology audit. The audit team identified preliminary areas where additional information would be required to support completion of the staffs LRA review.
IX. Documents Reviewed
- 1. NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 1
- 2. NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54, The License Renewal Rule, Revision 6
- 3. Advanced License Extension (ALEX) Process Management System, license renewal database
- 5. ACP 1210.4, License Renewal Scoping and Screening
- 6. ACP 1210.5, License Renewal Documents and Output Results
- 7. LRSP-01, Scoping and Screening Report
- 8. LRSP-TBS, Turbine Building
- 9. LRSP-16.00, RHR Service Water System
- 10. LRSP-30.03, A & B Safety-Related Air System
- 11. LRSP-35.00, Fuel Pool Cooling and Cleanup System
- 12. LRSP-49.00, Residual Heat Removal System
- 13. LRSP-54.00, Emergency Service Water
- 14. LRTR-NSAS, Non-Safety Affecting Safety
- 15. LRTR-MFP, Fire Protection
- 17. LRTR-EEQ, Environmental Qualification
- 18. LRTR-ESBO, Station Blackout
- 19. LRTR-002, Treatment of Consumables
- 20. LRTR-003, Insulation
- 21. LRTR-006, Treatment of Staged Equipment
- 22. LRTR-COE, Civil Operating Experience
- 23. LRTR-CRA, Cranes
- 24. LRTR-EMIS, Missile Scoping
- 25. LRTR-QUAL, Corrective Action, Confirmation Process and Administrative Controls
- 26. License renewal lesson plans and presentations
- 27. License renewal project quality assurance information
- 28. BECH-M111-LR (drawing)
- 29. BECH-M113-LR (drawing)
- 30. BECH-M130(3)-LR (drawing)
- 31. BECH-M130(9)-LR (drawing)
- 32. BECH-M157(1)-LR (drawing)
- 33. BECH-M158-LR (drawing)
- 34. BECH-M161-LR (drawing)
- 35. BECH-M173-LR (drawing)
- 36. BECH-176(2)-LR (drawing)
X. NRC Audit Team Members Bill Rogers Office Nuclear Reactor Regulation (NRR)/DLR Alice Paulsen NRR/DLR Bennett Brady NRR/DLR Donald Britner NRR/DLR James Shea NRR/DLR Stanley Gardocki NRR/Division of Safety Systems (DSS)
Gary Armstron g NRR/DSS XI. Applicant Personnel Contacted During Audit Chris Costanzo Site Vice President Dean Curtland Plant General Manager Ken Putnam LR Project Manager Mike Fairchild LR Electrical Lead Curt Bock LR Mechanical Lead Ken Chew LR Structural Lead Ginna Holt Audit Support Lead Lori Ohrt DAEC Clara Rushworth DAEC
Bill Bryant DAEC Thomas Byrne DAEC Bob Vincent DAEC John Van Sickel DAEC Tracy Weaver DAEC Michael Fetzer DAEC Bob Orlikowski DAEC Roger Jennings DAEC Don Arp DAEC Russ Elmers DAEC Jerold Whittle DAEC Herb Giorgio DAEC Gary Hawkins DAEC Jack Cadogan DAEC Bill Roberts DAEC Miles Railey DAEC Narindra N. Sikka DAEC Tim Holt DAEC Steve Catron DAEC Steve Inghram DAEC