NG-09-0837, Errata to the First Annual Amendment to License Renewal Application
| ML093170209 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 11/05/2009 |
| From: | Costanzo C NextEra Energy Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NG-09-0837 | |
| Download: ML093170209 (10) | |
Text
NEXTera ENERGYý./
DUN
ý~A R NOL D November 5, 2009 NG-09-0837 10 CFR 54.21(b)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Errata to the First Annual Amendment to the Duane Arnold Energy Center License Renewal Application
Reference:
Letter, Christopher R. Costanzo (NextEra Energy Duane Arnold LLC) to Document Control Desk (USNRC), "First Annual Amendment to the Duane Arnold Energy Center License Renewal Application," dated September 30, 2009, NG-09-0709 (ML092750089)
The referenced letter transmitted the annual update to the Duane Arnold Energy Center License Renewal Application (LRA), and submitted revised pages of the Environmental Report. Several amended pages of the Environmental Report were inadvertently left out. Of these, only page F-73 contains a material difference (removal of Severe Accident Mitigation Alternative Item 118). The remaining pages were impacted by pagination changes due to the deletion. These pages are provided in the Enclosure to this document. of the referenced letter stated "In LRA Section 2.5, Mr. Richard Anderson Vice President Duane Arnold Energy Center is changed to Mr. Christopher R. Costanzo Vice President Duane Arnold Energy Center." The reference to Section 2.5 is incorrect; the correct Section is LRA Section 1.5.
If you have any questions, please contact Mr. Kenneth Putnam at (319) 851-7238.
NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324
Document Control Desk NG-09-0837 Page 2 I declare, under penalty of perjury, that the foregoing is true and correct.
Executed on November 5, 2009.
Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC
Enclosure:
Replacement Pages to the Duane Arnold License Renewal Application Environmental Report Appendix F cc:
Administrator, Region III, USNRC Project Manager, DAEC, USNRC Senior Resident Inspector, DAEC, USNRC License Renewal Project Manager, USNRC License Renewal Inspection Team lead, Region III, USNRC M. Rasmusson (State of Iowa)
Enclosure to NG-09-0837 Replacement Pages to the Duane Arnold License Renewal Application Environmental Report Appendix F Pages, F-73 through F-79, have been updated and are to replace the corresponding pages in the Environmental Report as originally submitted.
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 108 Improve MSIV design.
Decreased likelihood of containment bypass Yes B - Implemented Improved in 1990.
scenarios.
OR Intent Met 110 Locate residual heat removal (RHR) Reduced frequency of ISLOCA outside Yes B - Implemented Pumps are within secondary inside containment, containment.
OR Intent Met containment.
112 Revise EOPs to improve ISLOCA Increased likelihood that LOCAs outside Yes B - Implemented EOPs and SAGs address this.
identification.
containment are identified as such. A plant OR Intent Met had a scenario in which an RHR ISLOCA could direct initial leakage back to the pressurizer relief tank, giving indication that the LOCA was inside containment.
113 Improve operator training on Decreased ISLOCA consequences.
Yes B - Implemented Done, EOP training covers ISLOCA coping.
OR Intent Met this topic.
115 Revise procedures to control vessel Improved availability of boron injection during Yes B - Implemented ATWS EOPs in place.
injection to prevent boron loss or ATWS.
OR Intent Met dilution following SLC injection.
116 Provide an alternate means of Improved probability of reactor shutdown.
Yes B - Implemented Procedures in place.
opening a pathway to the RPV for OR Intent Met SLC injection.
119 Provide ability to use control rod Improved availability of boron injection during Yes B - Implemented Procedures in place.
drive (CRD) or RWCU for alternate ATWS.
OR Intent Met boron injection.
121 Increase safety relief valve (SRV)
Reduced risk of dilution of boron due to SRV Yes B - Implemented Process monitoring program reseat reliability, failure to reseat after standby liquid control OR Intent Met in place to monitor SRV (SLC) injection.
health. PM program in place for the SRVs.
122 Provide an additional control system Improved redundancy and reduced ATWS Yes B - Implemented ARI system installed.
for rod insertion (e.g., AMSAC).
frequency.
OR Intent Met 124 Revise procedure to bypass MSIV Affords operators more time to perform Yes B - Implemented Procedures in place.
isolation in turbine trip ATWS actions. Discharge of a substantial fraction of OR Intent Met scenarios, steam to the main condenser (i.e., as opposed to into the primary containment) affords the operator more time to perform actions (e.g., SLC injection, lower water level, depressurize RPV) than if the main condenser was unavailable, resulting in lower human error probabilities.
APPENDIX F Update September 2009 Page F-73
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 125 Revise procedure to allow override Allows immediate control of low pressure Yes B - Implemented Procedures in place.
of low pressure core injection during core injection. On failure of high pressure OR Intent Met an ATWS event.
core injection and condensate, some plants direct reactor depressurization followed by five minutes of automatic low pressure core injection.
127 Improve inspection of rubber Reduced frequency of internal flooding due Yes B - Implemented Inspected every refueling expansion joints, to failure of circulating water system OR Intent Met outage. Program in place to expansion on main condenser. joints, replace before prior to end of life expectancy.
129 Increase seismic ruggedness of Increased availability of necessary plant Yes B - Implemented Done after Seismic plant components.
equipment during and after seismic events.
OR Intent Met Qualification Utilities Group Inspection. Also see SAMAs 152, 153, 154, 155, and 157 for plant specific seismic issues.
131 Modify safety related condensate Improved availability of CST following a Yes B - Implemented Although not safety related, storage tank.
seismic event.
OR Intent Met the CST is bolted in order to sustain seismic event.
133 Replace mercury switches in fire Decreased probability of spurious fire Yes B - Implemented Per IPEEE, the only mercury protection system.
suppression system actuation.
OR Intent Met switches in the control circuitry of the DAEC fire protection systems are associated with the diesel-driven fire pump and jockey pump low pressure initiation logic. This control circuitry in no way influences potential suppression system actuations.
136 Enhance procedures to use Increased probability of shutdown if the Yes B - Implemented Implemented using an alternate shutdown methods if the control room becomes uninhabitable.
OR Intent Met alternate mitigation strategy.
control room becomes uninhabitable.
137 Enhance fire brigade awareness.
Decreased consequences of a fire.
Yes B - Implemented The fire brigade training and OR Intent Met procedures meet current industry standards.
APPENDIX F Update September 2009 Page F-74
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 138 Enhance control of combustibles Decreased fire frequency and consequences. Yes B - Implemented Procedures in place.
and ignition sources.
OR Intent Met 140 Enhance procedures to mitigate Reduced consequences of a large break Yes B - Implemented EOPs and SAGs in place.
large break LOCA.
LOCA.
OR Intent Met 141 Install computer aided Improved prevention of core melt sequences Yes B - Implemented Done SPDS.
instrumentation system to assist the by making operator actions more reliable.
OR Intent Met operator in assessing post-accident plant status.
142 Improve maintenance procedures.
Improved prevention of core melt sequences Yes B - Implemented Continuous improvement by increasing reliability of important OR Intent Met program in progress.
equipment.
143 Increase training and operating Improved likelihood of success of operator Yes B - Implemented Current program meets experience feedback to improve actions taken in response to abnormal OR Intent Met current industry guidance.
operator response.
conditions.
145 Develop AOP or EOP for response Improved mitigation of total loss of DC power Yes B - Implemented Procedures exist for total loss to total loss of DC power. Many of events.
OR Intent Met of DC power, the control breakers in the plant that depressurization using require DC power are stored energy alternate power to the TBVs, breakers that can be locally and operation of RCIC without operated. Other strategies would DC power.
include using EHC panel power to manually jack open the TBVs in order to depressurize, taking local manual control of the RCIC system, and using portable generators to power essential DC loads.
146 Consider revision to the EOP Enhance ability to mitigate long term Yes B - Implemented Guidance in EOPs.
direction to terminate injection to the containment heatup scenarios.
OR Intent Met RPV from sources external to the drywell, irrespective of core cooling, in loss of containment heat removal scenarios where the Maximum Primary Containment Water Level Limit (MPCWLL) is reached.
APPENDIX F Update September 2009 Page F-75
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 147 Maintain heightened awareness of Eliminate scenarios in which SLC initiation is Yes B - Implemented Included in operator training the operations staff of the delayed in ATWS conditions to prevent-OR Intent Met program.
importance of timely injection of containment damage and subsequent core Standby Liquid Control in ATWS failure.
scenarios.
148 Provide a procedure with a tested Better mitigation of extended loss of AC Yes B - Implemented Procedures in place.
lineup that will allow the use of the power events.
OR Intent Met diesel fire pump to inject to the RPV in extended loss of AC power scenarios. Also provide direction to maintain sufficient DC power reserve to keep the containment and RPV a low enough pressure for the firewater to RPV lineup to be successful.
149 Change EOPs to allow the use of Initiation of drywell spray prior to RPV breach Yes B - Implemented Procedures in place.
Drywell Spray as well as removing would preclude the debris attack and failure OR Intent Met ambiguity regarding the diversion of of the drywell shell.
injection sources away from the RPV when adequate core cooling is not assured.
150 Relaxation of the restrictions on the Drywell sprays offer an additional alternative Yes B - Implemented Procedures in place.
use of the drywell sprays in the to the control of the drywell temperature to OR Intent Met DWSI curve of the EOPs may be a avoid premature containment failure.
possible future accident management item.
151 Provide accident management Reduction in the amount of release through Yes B - Implemented Procedure in place.
strategies that provide guidance to the containment vents early in the accident.
OR Intent Met the operators on protecting containment and cooling debris using methods that do not require the venting of the RPV and avoid using the drywell vent unless no other alternative exists.
APPENDIX F Update September 2009 Page F-76
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 152 One masonry block wall was Prevent damage to safety related equipment Yes B - Implemented Already Implemented. The identified that was not included in during a seismic event.
OR Intent Met wall was added to the list and the NRC IE Bulletin 80-11 program qualified.
as a masonry wall that could potentially damage Safe Shutdown Equipment List equipment.
153 Portions of the control room ceiling Prevent damage to safety related equipment Yes B - Implemented Already Implemented.
may not have adequate restraint of during a seismic event.
OR Intent Met Selected elements of the the membranes nor adequate control room ceiling were strength in the connections to modified.
preclude potential falling of ceiling elements onto critical equipment during a seismic loading.
154 Problems identified with the Prevent damage to safety related equipment Yes B - Implemented Already Implemented. Some adequacy of seismic equipment during a seismic event.
OR Intent Met identified anchorages were anchorages during field walkdowns qualified by analysis to use and UT examinations.
as-is, the remaining issues were resolved by maintenance actions or modifications.
155 Two air handlers in the HPCI room Prevent damage to equipment from post-Yes B - Implemented Already Implemented.
were identified as seismically seismic event flooding/spray.
OR Intent Met Further analysis shows that induced flood/spray outliers clearances between because nearby piping could equipment are sufficient to potentially impact fire protection preclude impact.
sprinkler piping and break off the sprinkler heads, which could damage the air handler motors.
157 Three areas were identified that Prevent damage to equipment from nearby Yes B - Implemented Already Implemented. Gas have gas storage bottles that were gas bottles post seismic event.
OR Intent Met bottles were either removed not adequately restrained against or additional restraint seismic events.
provided.
APPENDIX F Update September 2009 Page F-77
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 158 Prohibit any work in the switchgear Reduce the fire ignition frequency in the Yes B - Implemented Maintenance risk room supporting the operating river switchgear room supporting the operable OR Intent Met management program water train during any maintenance river water train, provides for protection of on the river water system.
certain systems when maintenance is being performed.
159 Post a fire watch in the switchgear Maximize the ability to respond to and Yes B - Implemented. Maintenance risk room supporting the operating river mitigate a fire in the switchgear room OR Intent Met management program water train, or stage temporary supporting the operable river water train, provides for protection of hoses for implementation of AOP-certain systems when 410, Total Loss of River Water.
maintenance is being performed.
160 Modify piping design to eliminate Eliminate or reduce the damage caused by Yes B - Implemented Already Implemented. These the flooding sequences from the fire flooding from rupture of this fire protection OR Intent Met fire protection systems were protection piping in the control piping.
changed to "dry pipe" building HVAC room above the systems.
control room.
161 Increase the distance of installation Minimize damages to safety related Yes B - Implemented Already Implemented. The of a new hydrogen storage tank equipment from fires/explosions in the new OR Intent Met new tank was sited properly in from safety related structures.
hydrogen storage facility, relation to safety related structures. The new location was determined to be in accordance with EPRI guidelines and to be consistent with recommendations in GL 93-06.
162 Install concrete barriers around the Eliminate the risk of propane tank damage Yes B - Implemented Already Implemented.
auxiliary boiler propane tank.
and subsequent fire/explosion caused by OR Intent Met Concrete barriers installed.
vehicle impacts on the propane tank.
2 Replace lead-acid batteries with fuel Extended DC power availability during an Yes C - Combined Combine with SAMA 3.
cells.
SBO.
5 Provide DC bus cross-ties.
Improved availability of DC power system.
Yes C - Combined Combine with SAMA 3.
14 Install an additional, buried off-site Reduced probability of loss of off-site power.
Yes D - Excess Cost Standby Transformer already power source.
underground. A line to the nearest offsite black start unit would exceed 50 miles.
APPENDIX F Update September 2009 Page F-78
Duane Arnold Energy Center License Renewal Application Environmental Report Table 6-1 DAEC Phase I SAMA Analysis (Cont.)
DAEC Potential Improvement Discussion Screened Screening Phase I Disposition SAMA Out Ph 1?
Criterion Number 26 Bury off-site power lines.
Improved off-site power reliability during Yes D - Excess Cost Standby Transformer already severe weather.
underground. A line to the nearest offsite black start unit would exceed 50 miles.
51 Add redundant DC control power for Increased availability of SW.
Yes D - Excess Cost Cost would exceed maximum SW pumps.
benefit. Mods would be required for RHRSW, ESW, and RWS.
80 Install a passive drywell spray Improved drywell spray capability.
Yes D - Excess Cost Excess Cost.
system.
86 Install a filtered containment vent to Increased decay heat removal capability for Yes D - Excess Cost Cost will exceed maximum remove decay heat.
non-ATWS events, with scrubbing of benefit.
Option 1: Gravel Bed Filter.
released fission products.
Option 2: Multiple Venturi Scrubber.
94 Create a large concrete crucible Increased cooling and containment of molten Yes D - Excess Cost Excess Cost.
with heat removal potential to core debris. Molten core debris escaping contain molten core debris, from the vessel is contained within the crucible and a water cooling mechanism cools the molten core in the crucible, preventing melt-through of the base mat.
95 Create a core melt source reduction Increased cooling and containment of molten Yes D - Excess Cost Excess Cost.
system.
core debris. Refractory material would be placed underneath the reactor vessel such that a molten core falling on the material would melt and combine with the material.
Subsequent spreading and heat removal from the vitrified compound would be facilitated, and concrete attack would not occur.
96 Strengthen primary/secondary Reduced probability of containment over-Yes D - Excess Cost Excess Cost.
containment (e.g., add ribbing to pressurization.
containment shell).
97 Increase depth of the concrete base Reduced probability of base mat melt-Yes D - Excess Cost Excess Cost.
mat or use an alternate concrete through.
material to ensure melt-through does not occur.
APPENDIX F Update September 2009 Page F-79