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Category:Letter type:NG
MONTHYEARNG-23-0010, Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-12-0606 December 2023 Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule NG-23-0009, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule NG-23-0006, Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-05-23023 May 2023 Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update NG-23-0004, 2022 Annual Radioactive Material Release Report2023-04-25025 April 2023 2022 Annual Radioactive Material Release Report NG-23-0003, 2022 Annual Exposure Report - Form 5s2023-04-21021 April 2023 2022 Annual Exposure Report - Form 5s NG-23-0002, 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report2023-03-27027 March 2023 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report NG-23-0001, 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report2023-03-27027 March 2023 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-22-0055, Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan2022-05-20020 May 2022 Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan NG-22-0053, 2021 Annual Radiological Environmental Operating Report2022-05-0606 May 2022 2021 Annual Radiological Environmental Operating Report NG-22-0052, Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative2022-05-0404 May 2022 Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative NG-22-0050, Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 02022-04-26026 April 2022 Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 0 NG-22-0049, 2021 Annual Radioactive Material Release Report2022-04-26026 April 2022 2021 Annual Radioactive Material Release Report NG-22-0035, Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 02022-04-13013 April 2022 Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 0 NG-22-0047, Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2022-04-11011 April 2022 Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool NG-22-0042, Registration of Independent Spent Fuel Installation Storage Casks2022-04-0808 April 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0041, and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report2022-03-31031 March 2022 and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-22-0031, 2021 Annual Exposure Report - Form 5s2022-03-23023 March 2022 2021 Annual Exposure Report - Form 5s NG-22-0030, Registration of Independent Spent Fuel Installation Storage Casks2022-03-23023 March 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0025, Registration of Independent Spent Fuel Installation Storage Casks2022-03-0808 March 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0021, Registration of Independent Spent Fuel Installation Storage Casks2022-02-24024 February 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0014, Registration of Independent Spent Fuel Installation Storage Casks2022-02-10010 February 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0009, Registration of Independent Spent Fuel Installation Storage Casks2022-01-20020 January 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0001, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister2022-01-0606 January 2022 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister NG-21-0038, Registration of Independent Spent Fuel Installation Storage Casks2021-12-22022 December 2021 Registration of Independent Spent Fuel Installation Storage Casks NG-21-0035, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-12-10010 December 2021 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister NG-21-0030, Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-10-21021 October 2021 Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister NG-21-0028, Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 02021-07-30030 July 2021 Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 0 NG-21-0010, License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2021-06-28028 June 2021 License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme NG-21-0026, CFR 72.48 Report of Changes. Tests. and Experiments2021-06-16016 June 2021 CFR 72.48 Report of Changes. Tests. and Experiments NG-21-0011, Submittal of 2020 Annual Radiological Environmental Operating Report2021-05-0404 May 2021 Submittal of 2020 Annual Radiological Environmental Operating Report NG-21-0009, Report of Facility Changes. Tests and Experiments. and Commitment Changes2021-04-27027 April 2021 Report of Facility Changes. Tests and Experiments. and Commitment Changes NG-21-0021, Supplement to License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements2021-04-22022 April 2021 Supplement to License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements NG-21-0006, 2021 Annual Decommissioning and Spent Fuel Management Funding Status Report2021-03-31031 March 2021 2021 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-21-0005, NextEra Energy Duane Arnold, LLC - Transmittal of the DAEC Defueled Safety Analysis Report Revision 02021-03-29029 March 2021 NextEra Energy Duane Arnold, LLC - Transmittal of the DAEC Defueled Safety Analysis Report Revision 0 NG-20-0094, License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool2021-02-19019 February 2021 License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool NG-21-0004, Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report2021-02-0505 February 2021 Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report NG-20-0078, Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)2021-01-13013 January 2021 Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) NG-20-0101, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID-19 Pandemic2020-12-29029 December 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID-19 Pandemic NG-20-0099, Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2020-12-0101 December 2020 Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme NG-20-0093, Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2020-10-29029 October 2020 Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme NG-20-0090, Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center2020-10-12012 October 2020 Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center NG-20-0083, Registration of Independent Spent Fuel Installation Storage Casks2020-10-12012 October 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0069, Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E2020-10-0707 October 2020 Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E NG-20-0082, Registration of Independent Spent Fuel Installation Storage Casks2020-09-28028 September 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0071, Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Evaluated Exercise Requirements Due to COVID-19 Pandemic2020-09-22022 September 2020 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Evaluated Exercise Requirements Due to COVID-19 Pandemic NG-20-0077, Registration of Independent Spent Fuel Installation Storage Casks2020-09-10010 September 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0073, Notice Regarding Proposed Amendment to Decommissioning Trust Agreements2020-09-0101 September 2020 Notice Regarding Proposed Amendment to Decommissioning Trust Agreements NG-20-0074, Certification of Permanent Cessation of Power Operations2020-08-27027 August 2020 Certification of Permanent Cessation of Power Operations NG-20-0067, Registration of Independent Spent Fuel Installation Storage Casks2020-08-12012 August 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0035, Request for Exemption from 10 CFR 50.54(w)(1)2020-07-16016 July 2020 Request for Exemption from 10 CFR 50.54(w)(1) 2023-05-23
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FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324 FPLEnergy.
Duane Arnold Energy Center December 21, 2006 NG-06-0856 10 CFR 50.55a U.S. Nudear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Response to Request for Additiondl Iformation Related to Relief Request NDE-R001
References:
- 1. NG-06-0439, dated June 30, 2006, Fourth Ten-Year Inservice Inspection Plan
- , 2. Letter dated November 22, 2006, Request for Additional Information Related to Relief Request NDE-ROO1 The Duane Arnold Energy Center (DAEC) fourth ten-year inservice inspection (ISI) plan was submitted by letter dated June 30, 2006 (Reference 1). This plan included relief request NDE-ROO1.
By letter dated November 22, 2006, the Staff issued a request for additional information regarding relief request NDE-ROO1 (Reference 2). Additional information concerning NDE-R001 is provided in the enclosure to this letter.
This letter makes no new commitments nor changes to any existing commitments. If you have any questions, please contact Steve Catron at (319) 851-7234.
Gary Van Middlesworth Site Vice President, Duane Arnold Energy Center...
FPL Energy Duane Arnold, LLC "
Enclosure . _:. ' ... . ,, .
cc: ,,-.Administrator,-Region Il!U N ,, ..
Projent Managtr DEIner, DAEC, USNRC ) -/"'
Senior Res ident Inspector, DAEC, USNRCf-
Enclosure to NG-06-0856 Page 1 of 4 Response to Request for Additional Information (RAI) Related to Relief Request No. NDE-R001 Examination and Testing of Class 1, 2, and 3 Snubbers As discussed in the RAI, FPL Energy Duane Arnold's relief request contained a table with comparisons between the Duane Arnold Energy Center (DAEC) Technical Requirements Manual (TRM) and Subsection ISTD of the ASME OM Code. As discussed in a conference call between the NRC staff and FPL Energy on October 12, 2006. the comparison table was not intended to denote any planned DAEC commitment to Subsection ISTD. Therefore, the NRC staff will compare the TRM requirements against the requirements specified in ASME/ANSI OM-1 987, Part 4 (OM-4) with OMa-1988.
NRC Question 1 Regarding Relief Request NDE-R001
- 1. In Relief Request NDE-ROO1, under "Alternate Examination," the licensee states:
"Visual examiners, who are qualified to the applicable rules of ASME Section Xl, Article IWA-2300, =Qualification of Nondestructive Examination Personnel" will perform the examinations and tests of Class 1, 2, and 3 component snubbers."
Please explain whether and how the VT-3 requirements, as described in IWA-2213, will be met by using IWA-2300 requirements.
FPL Energy Duane Arnold Response to Question I Regarding Relief Request NDE-R001 IWA-2213 will be used to identify the examination technique utilized and IWA-2300 will be used to qualify/certify the VT-3 examiners. FPL Energy Duane Arnold's NDE Written Practice for VT-3 examiner qualification meets the requirements of IWA-2300. IWA-2317"Altemative Qualification-of-V-T-3 Examination-Personnel"'will not be used.
NRC Question 2 Regarding Relief Request NDE-RO01
- 2. ASME/ANSI OM-1 987, Part 4 (OM-4) with OMa-1 988, Paragraph 3.2.4.2 states:
"Unacceptable snubber(s) shall be categorized into failure mode group(s). A test failure mode group(s) shall include all unacceptable snubbers that have a given failure mode, and all other snubbers subject to the same failure mode." Please explain whether and how the requirements of OM-4, Paragraph 3.2.4.2 will be met by using Technical Requirement Manual Section 3.7.2 and its bases.
FPL Energy Duane Arnold Response to Question 2 Regarding Relief Request NDE-R001 OM-1 987, Part 4 with OMa-1 988 describes five potential failure mode groups:
Enclosure to NG-06-0856 Page 2 of 4
- Maintenance / Repair I Installation
- Unexplained Although not defined as failure mode groups, the TRM does require sample expansions based on type of failure:
- TRM 3.7.2, Required Action A.1.1, requires to "Clearly establish and remedy the cause of the rejection for that snubber and for other snubbers that may be
- generically susceptible." This requirement would establish the failure mode group.
" TRM 3.7.2, Required Actions B.3, requires sample expansions based on snubber type of failure.
" TRM 3.7.2, Required Actions B.4.1 and B.4.2, addresses the testing of all snubbers found subject to the same manufacturing or design deficiency.
- TRM TSR 3.7.2.1 addresses actions required following a System Transient.
- TRM Bases, 3.7.2, further describes "Generically Susceptible Snubbers" as snubbers subject to the same environmental conditions.
- "Isolated" & "Unexplained Failures" are not specifically addressed in the TRM; however, if an isolated or unexplained failure were to occur, a random 5%
sample plan expansion would be required for that type of snubber per Required Action B.3.
The differences between OM-4 and DAEC's TRM requirements concerning the establishment of "Failure Mode Groups" are concluded to be differences in terminology. Both the OM-4 Code and DAEC's TRM recognize the importance of determining why a snubber failed and the need to test other snubbers subject to a similar failure. The DAEC TRM is slightly more conservative in the fact that small failure mode groups still require, a minimum 5% sample expansion. Therefore, the intent of establishing failure mode groups in OM-4, paragraph 3.2_4.2 is met-b- b .....
evaluating the snubber's failure and expanding the sample plan based on the type of failure.
NRC Question 3 Regarding Relief Request NDE-RO01
- 3. OM-4, Paragraphs 1.5.6, "Snubber Maintenance or Repair," and 1.5.7, "Snubber Modification and Replacement," specify requirements for snubber repair and replacement. The submitted relief request and the TRM do not address the requirements of OM-4, Paragraphs 1.5.6, and 1.5.7. Please explain, whether and how these requirements will be met.
Enclosure to NG-06-0856 Page 3 of 4 FPL Energy Duane Arnold Response to Question 3 Regarding Relief Request NDE-R001 Any repair/replacement activity on snubbers that are classified as Safety Related will be performed in accordance with IWA-4000. Maintenance activities on snubbers will be performed in accordance with the FPL Energy Duane Arnold Quality Assurance Topical Report (QATR). Any snubber that is corrected by maintenance or repaired/replaced will be functionally tested in accordance with the TRM and receive a Preservice VT-3 Examination after installation. Any modifications to a snubber will be subject to DAEC's Design Control process. Both DAEC'sSection XI Repair /
Replacement process and DAEC's Design Control Process evaluate changes that may affect a snubber's function. Therefore, the requirements of OM-4, paragraphs 1.5.6 and 1.5.7, are met.
NRC Question 4 Regarding Relief Request NDE-ROO1
- 4. ASME Section XI, IWF-5000 contains Section IWF-5400 "Repair/Replacement Activities." In the relief request, the licensee is silent regarding IWF-5400. IWF-5400 states: "Repair/replacement activities performed on snubbers shall be in accordance with IWA-4000. Snubbers installed, corrected or modified by repair/replacement activities shall be examined and tested in accordance with the applicable requirements of IWF-5200 prior to return to service.' Please explain, whether and how these requirements will be met.
FPL Energy Duane Arnold Response to Question 4 Regarding Relief Request NDE-R001 FPL Energy Duane Arnold will apply the requirements of IWF-5400 "Repair/
Replacement/Modification Activities" to all safety related snubbers. As stated above, any repair/replacement/modification activity will be performed on those safety related snubbers in accordance with IWA-4000 of the ASME Section XI code. All snubbers that have been repaired/replaced/modified wiltreceive a Preservice VT-3 examination by personnel qualified and certified in accordance with IWA-2300.
Part 4 under OM-4 Paragraph 2.1.2 states that if snubbers are installed incorrectly or otherwise fail to meet the requirements of paragraph 2.1.1, those snubbers shall be corrected, repaired or replaced. The corrected, repaired, or replaced snubber shall be examined in accordance with paragraph 2.1.1 and shall meet the requirements therein.
OM-4 Paragraph 2.1.1 provides 5 criteria that need to be met:
- 1) no visible signs of damage or impaired operability as a result of storage handling or installation,
- 2) load rating, location, orientation, position setting, and configuration (attachments, extensions, etc.) are in accordance with design drawings and specifications,
Enclosure to NG-06-0856 Page 4 of 4
- 3) adequate swing clearance is provided to allow snubber movement,
- 4) fluid is at the recommended level and is not leaking, and
- 5) structural connections such as pins, bearings, studs, fasteners, and other connecting hardware such as lock nuts, tabs, wire, and cotter pins are installed correctly.
FPL Energy Duane Arnold meets these requirements in the Surveillance Test Procedures NS992802, "Bergen Paterson Hydraulic Snubbers Visual Inspection Guidelines and Acceptance Criteria," and NS992806, "Lisega Hydraulic Snubbers Visual Inspection Guidelines and Acceptance Criteria." Both of these Surveillance Test Procedures include the following criteria:
- 1) No visible indications of damage or impaired OPERABILITY,
- 2) Attachments to the foundation or supporting structure are secure, and
- 3) Fasteners for the attachment of the snubber anchorage are secure.
Both Surveillance Procedures provide detailed inspection points for the following locations of each snubber:
- 1) Shaft
- 2) Bolting and fasteners
- 3) Front-end support (at pipe)
- 4) Rear-end support (at structural attachment)
- 5) Spherical Bearing
- 6) Overall (includes no indications of excessive fluid leakage)
These examinations are conducted by a Qualified and Certified VT-3 Examiner.