NG-09-0327, Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01

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Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01
ML091250298
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 04/27/2009
From: Richard Anderson
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, NG-09-0327
Download: ML091250298 (6)
v • d • e


Text

NExTeraM ENER GY ARNOLD April 27, 2009 NG-09-0327 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC, 20555-001 Duane Arnold Energy Center Docket No. 50-331 License No. DPR-49

Subject:

Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01

References:

1. NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008.
2. Letteiri,:i.An derson (F'PL Energy Duane Arnold) to USNRC, "Three-MonthResponse to NRC Geneic Letter 2008'-01, 'Managihg Gas Accumulation jn.Emergency Core Cooling, Decay Heat Removal, and Containment'Spray Systems'," NG-08-0239, dated May 8, 2008.

(ADAMS Accession No. ML081420015)

3. Letterý, R. Anderson (FPL Energy Duane Arnold) to USNRC, "Nine-Mo*1*h Response to NRC Generic Letter 2008-01, 'Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems'," NG-08-0777, dated October 13, 2008.

(ADAMS Accession No. ML082970263)

4. Letter, K. Feintuch (USNRC) to R. Anderson (FPL Energy Duane Arnold), "Duane Arnold Energy Center - re: Generic Letter 2008-01,

'Managing Gas Accumulation In Emergency Core Cooling, Decay

-eat ?emoval, And Containment Spray Systems,' Proposed AlternauveCourse Of Action (TAC NO. MD7824)," dated August 6, 2008. (ADAMS -Accession No. ML081930209)

.5. NRC'Letter'to Nuc ear.Energy Institute, Dated July 8, 2008(ADAMS Acce'ssn No. ML0818305557)'

Acce S 0nNo. .... ' "-- ,,,'i-J-K,44s NextEra Energy Duane Arnold, LLC, 3277 DlAEC Read, Palo, IA52324

NG-09-0327 April 27, 2009 Page 2 of 3 The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1) to request that each licensee evaluate the licensing basis, design, testing, and corrective actions for the emergency core cooling (ECCS), decay heat removal (DHR), and containment spray systems to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.

As requested in Reference 4, please find enclosed NextEraTM Energy Duane Arnold, LLC's, f/k/a FPL Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) supplemental response to the nine month response letter (Reference 3). This supplemental response is being submitted within 90 days of startup from the outage in which the deferred actions were completed. GL response activities that remain to be accomplished, such as the long-term items identified in Reference 4, are considered to be confirmatory.

In summary, NextEra Energy Duane Arnold has concluded that the subject systems at Duane Arnold are operable and that Duane Arnold is currently in compliance with the licensing basis documentation and applicable regulations, including 10 CFR 50 Appendix B, Criteria Ill, V, XI, XVI, and XVII, with respect to the concerns outlined in GL 2008-01 regarding managing gas accumulation in these systems/functions.

This letter contains no new or revised NRC commitments.

This letter closes the following NRC commitments made in Reference 2:

1. Complete the detailed walkdowns and evaluations of those inaccessible sections of piping of GL subject systems, not otherwise exempted, prior to startup from the next Refuel Outage (currently scheduled for early 2009).
2. Submit a supplemental report to the original nine (9) month response, for those walkdowns and evaluations completed during the 2009 Refuel Outage, within 90 days after startup from that outage.

Please contact Steve Catron at (319) 851-7234 if you have further questions regarding this matter.

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

Executed on April 27, 2009.

Richard L. Anderso Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure

NG-09-0327 April 27, 2009 Page 3 of 3 cc: Administrator, Region I11,USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC

Enclosure to NG-09-0327 Page 1 of 3 NextEra Energy Duane Arnold Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems This Enclosure provides the Nine-Month Supplemental (Post Outage) Response to Generic Letter 2008-01 for actions that were deferred until the next refueling outage as requested by the NRC in Reference 4 of the cover letter.

The following information is provided in this

Enclosure:

A description of the results of evaluations that were performed pursuant to Generic Letter 2008-01 on the previously incomplete activities, such as system piping walkdowns, at the Duane Arnold Energy Center (DAEC) (see Section A of this Enclosure),

A description of any additional corrective actions determined necessary to assure system Operability and compliance with the quality assurance criteria in Sections III, V, Xl, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license with respect to the subject systems, including a schedule and a basis for that schedule (see Section B1 of this Enclosure), and summary of any changes or updates to previous corrective actions, including any schedule change and the basis for the change. (See Section B2 of this Enclosure).

The original conclusions documented in the 9 month response with respect to the licensing basis evaluation, testing evaluations, and corrective action evaluations have not changed. This supplement will only discuss the results of design evaluation reviews conducted during the recent refueling outage associated with walkdowns of previously uncompleted activities.

Enclosure to NG-09-0327 Page 2 of 3 A. EVALUATION RESULTS

1. Design Basis Documents There have been no changes in the DAEC design basis documentation related to gas accumulation since the 9-month response (Reference 3 of the cover letter). Plant drawings have been updated to reflect the addition of the new vent line and valves discussed below.
2. Confirmatory Walkdowns As noted in Reference 2 of the cover letter, walkdowns of piping systems in a number of inaccessible areas of the plant were deferred until this recent refuel outage (RFO21). In addition, one section of Core Spray discharge piping was determined to be inaccessible during the on-line walkdowns performed for the 9-month response letter (Reference 3 of the cover letter).

All of the inaccessible piping walkdowns were completed during RFO21. All inaccessible piping system segments conformed to the design information; in particular, the location of high point vents. Piping slopes were measured by combinations of laser scanning of insulated piping and inclinometer (bubble level) on un-insulated pipe.

As described in the 9-month response (Reference 3 of the cover letter), none of these inaccessible piping segments were believed to contain locations that would accumulate voids that could challenge the system's safety/design functions, provided the piping was found in accordance with the plant's design documents. The walkdowns did confirm that all piping slopes and vent locations were in accordance with the piping design documents.

Notwithstanding, one confirmatory ultrasonic (UT) examination of a single piping elbow was performed, as the piping was found to have a slight (<1 degree) upslope at this location. No void was found at this piping location.

3. Vent Valves As discussed in the 9-month response (Reference 3 of the cover letter), NextEra Energy Duane Arnold was evaluating the prudence of installing a new vent line and valves in the abandoned Residual Heat Removal (RHR) steam-condensing mode pipe leg. It was subsequently decided to install this new vent, in lieu of removing this piping. The vent installation has been completed. Post-modification UT examination confirmed no voiding in this pipe segment.
4. Procedures As discussed in the 9-month response (Reference 3 of the cover letter), NextEra Energy Duane Arnold was evaluating enhancements to the existing procedure steps utilized for filling and venting as part of restoring the subject systems/functions after maintenance or testing, such as dynamic venting and confirmatory UT exams at designated high points.

Those changes have been implemented.

B. DESCRIPTION OF NECESSARY ADDITIONAL CORRECTIVE ACTIONS

1. Additional Corrective Actions No new corrective actions were identified as a result of the walkdowns performed during RFO21.

Enclosure to NG-09-0327 Page 3 of 3

2. Corrective Action Updates All previously-identified corrective action documents associated with this GL having due dates prior to startup from RFO21 have been completed. Only one outstanding corrective action remains - the commitment to submit the final Technical Specification changes within 180 days following issuance of the Federal Register Notice for adoption of the Technical Specification Task Force traveler. No changes in the schedule for closing this commitment have been made.

Conclusion NextEra Energy Duane Arnold has completed the evaluation of the previously inaccessible portions of the applicable systems/functions at DAEC that perform the functions described in the GL and has concluded that these systems are Operable, as defined in the DAEC TS, and are in conformance with the DAEC licensing basis and compliance with all applicable regulations, including 10 CFR 50 Appendix B, Criteria IlI, V, XI, XVI, and XVII.

Text

NExTeraM ENER GY ARNOLD April 27, 2009 NG-09-0327 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC, 20555-001 Duane Arnold Energy Center Docket No. 50-331 License No. DPR-49

Subject:

Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01

References:

1. NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008.
2. Letteiri,:i.An derson (F'PL Energy Duane Arnold) to USNRC, "Three-MonthResponse to NRC Geneic Letter 2008'-01, 'Managihg Gas Accumulation jn.Emergency Core Cooling, Decay Heat Removal, and Containment'Spray Systems'," NG-08-0239, dated May 8, 2008.

(ADAMS Accession No. ML081420015)

3. Letterý, R. Anderson (FPL Energy Duane Arnold) to USNRC, "Nine-Mo*1*h Response to NRC Generic Letter 2008-01, 'Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems'," NG-08-0777, dated October 13, 2008.

(ADAMS Accession No. ML082970263)

4. Letter, K. Feintuch (USNRC) to R. Anderson (FPL Energy Duane Arnold), "Duane Arnold Energy Center - re: Generic Letter 2008-01,

'Managing Gas Accumulation In Emergency Core Cooling, Decay

-eat ?emoval, And Containment Spray Systems,' Proposed AlternauveCourse Of Action (TAC NO. MD7824)," dated August 6, 2008. (ADAMS -Accession No. ML081930209)

.5. NRC'Letter'to Nuc ear.Energy Institute, Dated July 8, 2008(ADAMS Acce'ssn No. ML0818305557)'

Acce S 0nNo. .... ' "-- ,,,'i-J-K,44s NextEra Energy Duane Arnold, LLC, 3277 DlAEC Read, Palo, IA52324

NG-09-0327 April 27, 2009 Page 2 of 3 The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1) to request that each licensee evaluate the licensing basis, design, testing, and corrective actions for the emergency core cooling (ECCS), decay heat removal (DHR), and containment spray systems to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.

As requested in Reference 4, please find enclosed NextEraTM Energy Duane Arnold, LLC's, f/k/a FPL Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) supplemental response to the nine month response letter (Reference 3). This supplemental response is being submitted within 90 days of startup from the outage in which the deferred actions were completed. GL response activities that remain to be accomplished, such as the long-term items identified in Reference 4, are considered to be confirmatory.

In summary, NextEra Energy Duane Arnold has concluded that the subject systems at Duane Arnold are operable and that Duane Arnold is currently in compliance with the licensing basis documentation and applicable regulations, including 10 CFR 50 Appendix B, Criteria Ill, V, XI, XVI, and XVII, with respect to the concerns outlined in GL 2008-01 regarding managing gas accumulation in these systems/functions.

This letter contains no new or revised NRC commitments.

This letter closes the following NRC commitments made in Reference 2:

1. Complete the detailed walkdowns and evaluations of those inaccessible sections of piping of GL subject systems, not otherwise exempted, prior to startup from the next Refuel Outage (currently scheduled for early 2009).
2. Submit a supplemental report to the original nine (9) month response, for those walkdowns and evaluations completed during the 2009 Refuel Outage, within 90 days after startup from that outage.

Please contact Steve Catron at (319) 851-7234 if you have further questions regarding this matter.

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

Executed on April 27, 2009.

Richard L. Anderso Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure

NG-09-0327 April 27, 2009 Page 3 of 3 cc: Administrator, Region I11,USNRC Project Manager, DAEC, USNRC Resident Inspector, DAEC, USNRC

Enclosure to NG-09-0327 Page 1 of 3 NextEra Energy Duane Arnold Nine-Month Supplemental (Post-Outage) Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems This Enclosure provides the Nine-Month Supplemental (Post Outage) Response to Generic Letter 2008-01 for actions that were deferred until the next refueling outage as requested by the NRC in Reference 4 of the cover letter.

The following information is provided in this

Enclosure:

A description of the results of evaluations that were performed pursuant to Generic Letter 2008-01 on the previously incomplete activities, such as system piping walkdowns, at the Duane Arnold Energy Center (DAEC) (see Section A of this Enclosure),

A description of any additional corrective actions determined necessary to assure system Operability and compliance with the quality assurance criteria in Sections III, V, Xl, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license with respect to the subject systems, including a schedule and a basis for that schedule (see Section B1 of this Enclosure), and summary of any changes or updates to previous corrective actions, including any schedule change and the basis for the change. (See Section B2 of this Enclosure).

The original conclusions documented in the 9 month response with respect to the licensing basis evaluation, testing evaluations, and corrective action evaluations have not changed. This supplement will only discuss the results of design evaluation reviews conducted during the recent refueling outage associated with walkdowns of previously uncompleted activities.

Enclosure to NG-09-0327 Page 2 of 3 A. EVALUATION RESULTS

1. Design Basis Documents There have been no changes in the DAEC design basis documentation related to gas accumulation since the 9-month response (Reference 3 of the cover letter). Plant drawings have been updated to reflect the addition of the new vent line and valves discussed below.
2. Confirmatory Walkdowns As noted in Reference 2 of the cover letter, walkdowns of piping systems in a number of inaccessible areas of the plant were deferred until this recent refuel outage (RFO21). In addition, one section of Core Spray discharge piping was determined to be inaccessible during the on-line walkdowns performed for the 9-month response letter (Reference 3 of the cover letter).

All of the inaccessible piping walkdowns were completed during RFO21. All inaccessible piping system segments conformed to the design information; in particular, the location of high point vents. Piping slopes were measured by combinations of laser scanning of insulated piping and inclinometer (bubble level) on un-insulated pipe.

As described in the 9-month response (Reference 3 of the cover letter), none of these inaccessible piping segments were believed to contain locations that would accumulate voids that could challenge the system's safety/design functions, provided the piping was found in accordance with the plant's design documents. The walkdowns did confirm that all piping slopes and vent locations were in accordance with the piping design documents.

Notwithstanding, one confirmatory ultrasonic (UT) examination of a single piping elbow was performed, as the piping was found to have a slight (<1 degree) upslope at this location. No void was found at this piping location.

3. Vent Valves As discussed in the 9-month response (Reference 3 of the cover letter), NextEra Energy Duane Arnold was evaluating the prudence of installing a new vent line and valves in the abandoned Residual Heat Removal (RHR) steam-condensing mode pipe leg. It was subsequently decided to install this new vent, in lieu of removing this piping. The vent installation has been completed. Post-modification UT examination confirmed no voiding in this pipe segment.
4. Procedures As discussed in the 9-month response (Reference 3 of the cover letter), NextEra Energy Duane Arnold was evaluating enhancements to the existing procedure steps utilized for filling and venting as part of restoring the subject systems/functions after maintenance or testing, such as dynamic venting and confirmatory UT exams at designated high points.

Those changes have been implemented.

B. DESCRIPTION OF NECESSARY ADDITIONAL CORRECTIVE ACTIONS

1. Additional Corrective Actions No new corrective actions were identified as a result of the walkdowns performed during RFO21.

Enclosure to NG-09-0327 Page 3 of 3

2. Corrective Action Updates All previously-identified corrective action documents associated with this GL having due dates prior to startup from RFO21 have been completed. Only one outstanding corrective action remains - the commitment to submit the final Technical Specification changes within 180 days following issuance of the Federal Register Notice for adoption of the Technical Specification Task Force traveler. No changes in the schedule for closing this commitment have been made.

Conclusion NextEra Energy Duane Arnold has completed the evaluation of the previously inaccessible portions of the applicable systems/functions at DAEC that perform the functions described in the GL and has concluded that these systems are Operable, as defined in the DAEC TS, and are in conformance with the DAEC licensing basis and compliance with all applicable regulations, including 10 CFR 50 Appendix B, Criteria IlI, V, XI, XVI, and XVII.

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