NG-17-0177, Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-01

Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-01

ML17250A920
Person / Time
Site:	Duane Arnold
Issue date:	09/05/2017
From:	Dean Curtland NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-17-0177
Download: ML17250A920 (5)

Text

NEXTera EN ERGY~

September 5, 2017 DUANE ARNOLD NG-17-0177 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Response to Request for Additional Information, Fifth lnservice Inspection Interval Program Plan, Relief Request RR-01

References:

1) Letter, Curtland (NextEra) to U.S. NRC, "Fifth lnservice Inspection Interval Program Plan, dated March 7, 2017 (ML17069A172)

2) Electronic Communication, Request for Additional Information -

Duane Arnold Energy Center - Relief Request RR Extension of Permanent Relief from Ultrasonic Examination of RPV Circumferential Shell Welds for the Renewed Operating License Term, dated July 20, 2017 In the Reference 1 letter, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted our Fifth lnservice Inspection Interval Program Plan pursuant to 10 CFR 50.55a. The NRC Staff requested, via Reference 2, additional information regarding Relief Request RR-01 which is contained in Reference 1.

The Enclosure to this letter contains the requested information.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-17-0177 Page 2 of 2 This letter does not contain any new or revised commitments.

If you have any questions or require additional information, please contact J. Michael Davis at 319-851-7032.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 5, 2017.

Dean Curtland Site Director l"AikQ_ Smr.Q.....

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NextEra Energy Duane Arnold, LLC Enclosure cc:

NRC Regional Administrator NRC Resident Inspector NRC Project Manager

Enclosure to NG-17-0177 Response to Request for Additional Information, Fifth lnservice Inspection Interval Program Plan, Relief Request RR-01 2 pages follow

1.0 INTRODUCTION

In the Reference 1 letter, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted our Fifth lnseNice Inspection lnteNal Program Plan pursuant to 10 CFR 50.55a. The NRG Staff requested, via Reference 2, additional information regarding Relief Request RR-01 which is contained in Reference 1. The requested information is given below.

2.0 REQUEST FOR ADDITIONAL INFORMATION By letter dated March 7, 2017 (Agencywide Documents Access and Management System Accession No. ML17069A172), NextEra Energy Duane Arnold, LLC (the licensee) submitted Relief Request No. 1 with a proposed alternative to the U.S. Nuclear Regulatory Commission (NRG) for relief from certain American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI requirements for inspection of reactor pressure vessel (RPV) circumferential welds at Duane Arnold Energy Center (DAEC).

The NRG staff has reviewed the submittal and determined that the additional information below is needed to complete the review.

RAl-1 The listed component numbers under "ASME Code Component(s) Affected" contains a potential misprint. Component Number VCB-A002 stands out from the rest of the component numbers: VCB-B001, VCB-B003, and VCB-B004.

Please confirm that Component Number VCB-A002 is correct.

RESPONSE

Component Number VCB-A002 is correct.

RAl-2 The proposed alternative contains several elements. The first element states that, "The examination requirements of ASME Code Section XI, Table IWB-2500-1, Examination Category B-A, Item No B 1.12, for the RPV longitudinal shell welds, also known as vertical or axial welds, will be performed as required to the extent possible." Please note that "to the extent possible" (a qualitative description) could be interpreted as an effort very different from the ASME Code required "essentially 100% of the weld length" (a quantitative description).

Please clarify the statement "to the extent possible" and note that if DAEC's future inspection of RPV axial welds is less than the ASME code requirement of "essentially 100% of the weld length," a request of relief from the ASME Code is required.

Page 1 of 2 Enclosure to NG-17-0177

RESPONSE

Use of the term "to the extent possible" is meant to convey that NextEra Energy Duane Arnold examines the required accessible volume either remotely from the internal surface or in combination with manual examination from the external surface of the reactor vessel in order to achieve essentially 100% of the longitudinal shell welds, also known as vertical or axial welds.

3.0 REFERENCES

1)

Letter, Curtland (NextEra) to U.S. NRC, "Fifth lnservice Inspection Interval Program Plan, dated March 7, 2017(ML17069A172)

2)

Electronic Communication, Request for Additional Information - Duane Arnold Energy Center-Relief Request RR Extension of Permanent Relief from Ultrasonic Examination of RPV Circumferential Shell Welds for the Renewed Operating License Term, dated July 20, 2017 Page 2 of 2 Enclosure to NG-17-0177