NG-10-0009, Supplemental Information Regarding License Renewal Application

Supplemental Information Regarding License Renewal Application

ML100210191
Person / Time
Site:	Duane Arnold
Issue date:	01/14/2010
From:	Costanzo C NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2010-0209, NG-10-0009
Download: ML100210191 (31)

Text

NEXTera m EN ERG: *'DUANE

~ARNOLD January 14, 2010 NG10-0009 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Supplemental Information Regarding the Duane Arnold Energy Center License Renewal Application

References:

1. Letter, Richard L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "Duane Arnold Energy Center Application for Renewed Operating License (TSCR-109)," dated September 30, 2008, NG-08-0713 (ML082980623)

2. Letter, Richard L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "License Renewal Application, Supplement 1:. Changes Resulting from Issues Raised in the Review Status of the License Renewal Application for the Duane Arnold Energy Center," dated January 23, 2009, NG-09-0059 (ML090280418)

By Reference 1, FPL Energy Duane Arnold, LLC submitted an application for a renewed Operating License (LRA) for the Duane Arnold Energy Center (DAEC). Reference 2 provided Supplement 1 to the application.

During the course of the NRC review, several questions have been raised in conference calls and other interactions with the NRC staff that warrant clarifications or changes to the LRA. In addition, NextEra Energy has identified several LRA changes that have been determined to be appropriate. This letter provides those clarifications and changes.

Enclosure 1 contains LRA changes and clarifications which resulted from the NRC Region III License Renewal Inspection. Enclosure 2 contains LRA changes and clarifications which resulted from telephone conference calls with the NRC staff.

Enclosure 3 contains several self-identified LRA changes that NextEra Energy has determined to be appropriate.

This letter revises license renewal commitment 42 and adds new license renewal commitment 48, as discussed in Enclosure 2. Enclosure 4 provides a revised LRA Appendix A, Section 18.4, Table A-i, Duane Arnold License Renewal Commitments, ,413q?

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA52324

Document Control Desk NG-1 0-0009 Page 2 updated to reflect the license renewal commitment changes made in DAEC correspondence to date.

If you have any questions or require additional information, please contact Mr. Kenneth Putnam at (319) 851-7238.

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

Executed on January 14, 2010.

opher R Costanzon Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosures:

1. LRA Changes Resulting from NRC Region III License Renewal Inspection

2. LRA Changes Resulting from NRC Telephone Conference Calls

3. LRA Changes Self-Identified by NextEra Energy

4. License Renewal Commitment List Updated to Reflect DAEC Correspondence to date.

cc: Administrator, Region Ill, 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 1 to NG-10-0009 LRA Changes and Clarifications Resulting from NRC Region III License Renewal Inspection Flow-Accelerated Corrosion Program The inspection team noted that, since submittal of the LRA, the DAEC Flow-Accelerated Corrosion Program has been updated to the latest EPRI program standard, NSAC-202L Revision 3. The team requested that the LRA be updated to reflect this change. The LRA changes necessary to reflect this program update are as follows:

In LRA Table B.2.2-1, Aging Management Program Correlation, on page B-9, in the line item for XI.M17 - Flow-Accelerated Corrosion Program, the NUREG-1 801 Comparison entry is changed to read, "Consistent with NUREG-1801 with one exception."

In LRA Section B.3.24, Flow Accelerated Corrosion Program, Subsection B.3.24.1, Program Description, on page B-50, the first sentence of the third paragraph is revised to read; The program is based on the guidelines of NSAC-202L-R3.

In LRA Section B.3.24.2, NUREG-1801 Consistency, the existing text is replaced with the following:

This program is consistent with the ten elements of NUREG-1801 XI.M17 with one exception.

In LRA Section B.3.24.3, Exceptions to NUREG-1801, the existing text is replaced with the following:

DAEC implements the guidance provided in EPRI-NSAC-202L-R3, "Recommendations for an Effective Flow-Accelerated Corrosion Program," May 2006, in lieu of the NUREG-1801 recommendation of EPRI NSAC-202L-R2, "Recommendations for an Effective Flow-Accelerated Corrosion Program," April 1999. EPRI NSAC-202L-R3 is the most recent revision of this document.

Revision 3 refines and enhances the recommendations of the earlier versions, without contradiction, to ensure continuity of existing plant FAC programs. Use of the current guideline is an acceptable method to maintain the FAC-susceptible systems at DAEC.

In LRA Appendix A, Section 18.1.24, Flow Accelerated Corrosion Program, on pages A-10 and A-1 1, the existing text is replaced with the following:

The Flow Accelerated Corrosion Program manages the aging effect of loss of material due to flow-accelerated corrosion (FAC) on the internal surfaces of carbon or low alloy steel piping, elbows, reducers, tees, expanders,' and valve bodies which contain high energy fluids (both single phase and two phase flow).

The program is based on the guidelines of NSAC-202L-R3. This program uses CHECWORKS as a predictive tool. Included in the program are: (a) an analysis to determine flow-accelerated corrosion susceptible lines; (b) performance of Page 1 of 4

Enclosure 1 to NG-10-0009 LRA Changes and Clarifications Resulting from NRC Region III License Renewal Inspection baseline inspections; (c) follow-up inspections to confirm the predictions; and (d) repairing or replacing components, as necessary.

The program is consistent with the ten elements of NUREG-1801 XIlM17 with one exception. The DAEC program implements the guidance provided in EPRI-NSAC-202L-R3, "Recommendations for an Effective Flow-Accelerated Corrosion Program," May 2006, in lieu of the NUREG-1801 recommendation of EPRI NSAC-202L-R2, "Recommendations for an Effective Flow-Accelerated Corrosion Program," April 1999.

To reflect this exception, the notes associated with this program in various 3.X.2 tables are also being revised. In all places where a 3.X.2 table cites a note A in conjunction with the Flow-Accelerated Corrosion Program, the note is changed to B, and all citations of note C with this program are changed to D. The LRA tables affected by these changes are as follows:

Table 312.2-1 on page 3.2-26 Table 3.3.2-1 on page 3.3-68 Table 3.4.2-1 on page 3.4-26, Table 3.4.2-2 on pages 3.4-35, 3.4-36, 3.4-37 Table 3.4.2-3 on pages 3.4-45, 3.4-46, 3.4-47 Table 3.4.2-4 on pages 3.4-52, 3.4-53 Table 3.4.2-5 on page 3.4-65 Selective Leaching Program The inspection team noted that, for the detection of selective leaching, the LRA credited the use of mechanical tests that were not addressed in the NUREG-1 801 description of the Selective Leaching Program. NUREG-1801 specifically identifies the use of Brinnell hardness testing, which has limited applicability to many of the configurations found in DAEC plant equipment. The team requested that the LRA be revised to show the use of other mechanical tests as an exception to NUREG-1801. The LRA changes necessary to incorporate this exception are as follows:

In LRA Section B.3.36, Selective Leaching of Materials, Subsection B.3.36.2, NUREG-.

1801 Consistency, the existing text is revised to read as follows:

This program is consistent with the ten elements of NUREG-1 801 XI.M33 with one exception.

In LRASection B.3.36, Selective Leaching of Materials, Subsection B.3.36.3, Exceptions to NUREG-1801, the existing text is revised in its entirety to read as follows:

The DAEC program takes one exception to the guidance as stated in NUREG-1801 XI.M33. Visual inspection and mechanical test techniques (Brinnell Page 2 of 4

Enclosure I to NG-10-0009 LRA Changes and Clarifications Resulting from NRC Region, Ill License Renewal Inspection hardness testing or other mechanical tests. such as mechanical scraping, chipping or other types of hardness testing), or additional examination methods that become available to the nuclear industry, are used to determine if selective leaching is occurring on the surfaces of a selected set of components. NUREG-1801 recommends that visual inspections be performed with Brinnell hardness testing.

The visual inspection is capable of detecting corrosion while mechanical test techniques such as chipping, scraping or hardness testing are capable of-detecting a corroded or weakened component structure.

LRA Appendix A, Section 18.1.36, Selective Leaching of Materials, on page A-14, is replaced in its entirety with the following:

The Selective Leaching of Materials Program will ensure that cast iron, brass, bronze, and copper alloy components exposed to raw water, treated water, or ground water will maintain their integrity for the period of extended operation.

The program will include a one-time visual inspection and mechanical test of selected components that may be susceptible to selective leaching.

The program is consistent with the ten elements of NUREG-1801 XI.M33 with one exception. Visual inspection and mechanical test techniques (Brinnell hardness testing or other mechanical tests such as mechanical scraping, chipping or other types of hardness testing), or additional examination methods that become available to the nuclear industry, are used to determine if selective leaching is occurring on the surfaces of a selected set of components. The GALL recommends that visual inspections be performed with Brinnell hardness testing.

In LRA Table B.2.2-1, Aging Management Program Correlation, on page B-1 0, in the line item for XI.M33 - Selective Leaching of Materials, the NUREG-1801 Comparison entry is changed to read, "Consistent with NUREG-1801 with one exception."

To reflect this exception, the notes associated with this program in various 3.X.2 tables

,are also being revised. In all places where a 3.X.2 table cites a note A in conjunction with the Selective Leaching of Materials Program, the note is changed to B, and all citations of note C with this program are changed to D. The LRA tables affected by these changes are as follows:

Table 3.2.2-4 on page 3.2-48 Table 3.2.2-5 on page 3.2-57 Table 3.3.2-1 on page 3,3-70 Table 3.3.2-2 on pages 3.3-72, 3.3-73 Table 3.3.2-3 on page 3.3-78 Table 3.3.2-4 on page 3.3-82 Table 3.3.2-6 on pages 3.3-96, 3.3-102, 3.3-103, 3.3-104, 3.3-108 Page 3 of 4

Enclosure 1 to NG-10-0009 LRA Changes and Clarifications Resulting from NRC Region III License Renewal Inspection Table 3.3.2-10 on page 3.3-126 Table 3.3.2-11 on pages 3.3-128, 3.3-131, 3.3-132, 3.3-133, 3.3-134, 3.3-135, 3.3-137, 3.3-138, 3.3-140, 3.3-141, 3.3-143 Table 3.3.2-12 on page 3.3-147 Table 3.3.2-13 on page 3.3-153 Table 3.3.2-16 on pages 3.3-162, 3.3-164 Table 3.3.2-18 on pages 3.3-173, 3.3-174 Table 3.3.2-22 on page 3.3-192 Table 3.3.2-23 on pages 3.3-197, 3.3-199 Table 3.3.2-26 on page 3.3-217 Table 3.3.2-29 on pages 3.3-231, 3.3-233, 3.3-234, 3.3-235, 3.3-242, 3.3-247 Table 3.3.2-31 on page 3.3-256 Table 3.3.2-32 on page 3.3-261 Table 3.4.2-1 on page 3.4-23 Table 3.4.2-2 on page 3.4-40 Intake Structure Ventilation Dampers During a walkdown of the Intake Structure ventilation components (part of Plant Ventilation system), a question was raised regarding return dampers 1VAD0580 and 1VAD058P. Damper 1VAD0580 is the return air damper for supply fan 1VSF050, and 1VAD058P is the return air damper for supply fan 1VSF051. After review, it has been determined that these dampers should have been designated as safety-related and included in scope for license renewal. Accordingly, dampers 1VAD0580 and 1VAD058P have been brought into the scope of license renewal under 10 CFR 54.4(a)(1). This action does not result in any changes to the LRA since the component type, material and environment are already addressed.

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Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls Plant-Specific Program for Surveillance of Boral in Spent Fuel Racks In conference calls on November 12, 2009, and December 3, 2009, monitoring of the Boral neutron absorber in spent fuel racks was discussed. It was determined that DAEC would incorporate into the LRA a plant-specific program for the aging management of Boral. The LRA changes to incorporate this program are as follows:

In LRA Appendix B, a new Section B.3.41, Boral Surveillance Program, is added to read as follows:

B.3.41 BORAL SURVEILLANCE PROGRAM B.3.41.1 PROGRAM DESCRIPTION The Boral material managed by this program is incorporated in the spent fuel storage rack design to assist in controlling spent fuel pool reactivity. It is described as a uniformly dispersed mixture of boron carbide (B4C) and aluminum powders, clad in aluminum sheets, and hot rolled to produce an integral three layer panel.

The Boral surveillance program consists of representative coupon. testing for the Holtec racks and in-situ neutron attenuation testing for the Programmed and Remote (PaR) racks. This program will ensure the assumptions of the fuel pool criticality analysis will continue to be met during the period of extended operation.

B.3.41.2 NUREG-1801 CONSISTENCY This is a plant specific program.

B.3.41.3 EXCEPTIONS TO NUREG-1801 This is a plant specific program.

B.3.41.4 ENHANCEMENTS TO DUANE ARNOLD PROGRAM This is a plant specific program.

B.3.41.5 SCOPE OF PROGRAM The Boral surveillance program consists of representative coupon testing for Holtec racks and in-situ neutron attenuation testing for PaR racks. This program ensures that there are no dimensional changes or loss of neutron absorbing material which would affect the assumptions used in the fuel pool criticality analysis.

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Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls 1B.3.41.6 PREVENTIVE ACTIONS The DAEC Boral Surveillance Program consists of inspections and evaluations of those inspections. The DAEC program does not provide guidance on methods to mitigate aging of the Boral material.

B.3.41.7 PARAMETERS MONITORED OR INSPECTED The DAEC Boral Surveillance Program monitors for changes in physical properties of the Boral absorber material in the Holtec racks by performing the following measurements of representative boral coupon samples on a pre-planned schedule: a) Visual Observation and Photography, b)

Neutron Attenuation and (optional) Radiography, c) Dimensional Measurements (length, width, and thickness), d) Weight and Specific Gravity. The most significant measurements are the thickness (to monitor for'swelling) and neutron attenuation (to confirm the concentration of Boron-10 in the absorber material).

Neutron Attenuation Tests are performed as laboratory tests on Boral coupons for the Holtec racks or as in-situ tests for the PaR racks.

B.3.41.8 DETECTION OF AGING EFFECTS The following measurements are made on each coupon removed from the Holtec racks: a) Visual examination and photographic documentation of appearance; b) Dimensional Measurements (length, width, and thickness);

c) Neutron Attenuation and (optional) radiography, and d) Weight and Specific Gravity.

For the PaR racks, in-situ neutron attenuation testing is performed to confirm that the Boral neutron absorber panels'continue to meet the assumptions of the fuel pool criticality analysis.

B.3.41.9 MONITORING AND TRENDING The DAEC Boral Surveillance Program monitors and trends any degradation of the Boral Coupons for the Holtec racks by comparing the as-found parameters of the coupon with the as-installed parameters. By comparing as-found parameters to the very accurate as-installed parameters, very small changes or degradation can be recognized and evaluated. The program requires removal and testing of a coupon prior to every third refueling outage.

For the PaR racks a baseline neutron attenuation test will be performed to determine the Boral areal density, and the results are used to confirm the Boral panels continue to meet the assumptions of the fuel pool criticality analysis. The first test will be performed prior to entering the period of Page 2 of 9

Enclosure 2 to NG-10-0009 LRAChanges Resulting from NRC Telephone Conference Calls extended operation. A follow-up test will be performed at a date to be determined based on the results of the baseline test and relevant industry experience, but not to exceed ten years after the baseline test.

B.3.41.10 ACCEPTANCE CRITERIA The Boral Surveillance Program acceptance criteria are based on a comparison between the as-found parameters and the original coupon parameters for the Boral in the Holtec racks. A decrease of no more than 5% in Boron-10 content as determined by neutron attenuation is acceptable. An increase in thickness at any point shall not exceed 10% of the initial thickness at that point.

For the Boral in the PaR racks, neutron attenuation testing will be performed to confirm that the Boral neutron absorber panels continue to meet the assumptions of the fuel pool criticality analysis.

B.3.41.11 CORRECTIVE ACTIONS The FPL Quality Assurance Program as described in FPL-1 Quality Assurance Topical Report will be utilized to meet Element 7 Corrective Actions. As discussed in NUREG-1800, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions, confirmation process, and administrative controls.

B.3.41.12 CONFIRMATION PROCESS The FPL Quality Assurance Program as described in FPL-1 Quality Assurance Topical Report will be utilized to meet Element 8 Confirmation Process. As discussed in NUREG-1800, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions, confirmation process, and administrative controls.

B.3.41.13 ADMINISTRATIVE CONTROLS The FPL Quality Assurance Program as described in FPL-1 Quality Assurance Topical Report will be utilized to meet Element 9 Administrative Controls. As discussed in NUREG-1800, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions, confirmation process, and administrative controls.

B.3.41.14 OPERATING EXPERIENCE The industry operating experience has identified several instances of" blistering in Boral coupons. DAEC has not identified blistering to be an issue with its coupons. Neither industry nor DAEC operating experience have identified any reduction of neutron absorption capability in Boral.

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Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls DAEC examinations of Boral Surveillance coupons show that the Holtec rack coupons are in good condition, with no apparent defects. None of the coupon measurements indicated degradation, and within the accuracy of the measurements, no loss in Boron-1 0.areal density was observed.

Therefore, it is concluded that the Boral absorbers in the Holtec storage racks have retained their dimensional and neutron-absorption properties and are capable of continuing to perform their intended function of controlling reactivity.

There is no industry operating experience indicating loss of areal density in Boral that would apply to the PaR racks. DAEC will be performing in-situ Boron-1 0 areal density testing of the PaR racks to confirm that no degradation is occurring which would cause the racks to not'meet the assumptions of the fuel pool criticality analysis.

B.3.41.14 CONCLUSION -,

The DAEC Boral Surveillance Program provides reasonable assurance that the components managed by this program will continue to meet their current licensing basis requirements during the period of extended operation.

In LRA Section 2.1.2.3, Interim Staff Guidance, on page 2.1-17, at the end of the existing entry, the following new bullet is added, to read as follows:

Draft LR-ISG-2009-01, Staff Guidance Regarding Plant-Specific Aging Management Review and Aging Management Program for Neutron-Absorbing Material in Spent Fuel Pools In LRA Table 2.4-10, Supports, on page 2.4-32, new line items are added, to appear as follows:

Component Types Intended Function Boral in Holtec Spent Fuel Racks Absorb neutrons Boral in PaR Spent Fuel Racks Absorb neutrons LRA Section 3.3.2.2.6, Reduction of Neutron-Absorbing Capacity and Loss of Material, Due to General Corrosion, on pages 3.3-38 and 3.3-39, is revised in its entirety to read as follows:

Reduction of neutron-absorbing capacity and loss of material due to general corrosion could occur in the neutron-absorbing sheets of BWR and PWR spent fuel storage 'racks exposed to treated water or to treated borated water. The Spent Fuel Storage Racks are evaluated as structural components in Section 3.5.

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Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls Duane Arnold has Boral in Holtec stainless steel fuel racks and in PaR anodized aluminum fuel racks. The Boral in the Holtec racks is contained in a vented space and thus is exposed to fuel pool water. Loss of material is an aging effect requiring management for Boral spent fuel storage racks exposed to a treated water environment. The Boral in the PaR racks is contained within two concentric square aluminum tubes which are seal welded together to isolate the Boral from the spent fuel pool water.

The AMR evaluation reviewed the current industry and plant-specific operating experience for Boral and determined that negligible adverse operating experience has been recorded. The NRC has concluded that degradation of neutron absorption performance has not been observed in materials other than Boraflex for any operating reactors in the United States.

However, the Boral Surveillance Program will continue to test coupons which represent the Boral in the Holtec racks throughout the period of extended operation to confirm the absence of aging effects on Boral coupon samples stored in the Spent Fuel Pool. Aging effects that could affect rack integrity or neutron absorption characteristics are not expected since none have been observed during coupon sample evaluations. in addition, in-situ neutron attenuation testing will be implemented for the Boral in the PaR racks to confirm that the Boral continues to meet the assumptions of the fuel pool criticality analysis.

In LRA Section 3.5.1.10, Supports, on page 3.5-11, new bullets are provided under each of the sub-headings, as follows:

Under Materials, the new bullet, Boral, is added.

Under Environments, the new bullet, Gas, is added.

Under Aging Effects Requiring Management, the new bullet, Reduction of Neutron Absorbing Capacity, is added.

Under Aging Management Programs, the new bullet, Boral Surveillance Program, is added.

In LRA Table 3.5.2-10, Summary of Aging Management Review Results 1 Supports, on page 3.5-111, new line items are added to appear as follows:

Component Intended Material Environment Aging Effects. Aging NUREG-I801 Table Notes Type Function Requiring Management Volume 2 3.x-1 Management Program Line Item Item Boral in Absorb Boral Treated Water Reduction of Boral - VII.A2-3 3.3.1- E Holtec Spent neutrons (external) neutron Surveillance (A-89) 13 Fuel Racks absorbing Program capacity Loss of material Boral in PaR Absorb Boral Gas (external) Reduction of Boral - VII.A2-3 3.3.1- G, 207 Spent Fuel neutrons neutron Surveillance (A-89) 13 Racks absorbing Program capacity Page 5 of 9

Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls In LRA Appendix A, a new Section 18.1.41, Boral Surveillance Program, is added to read as follows:

18.1.41 BORAL SURVEILLANCE PROGRAM The Boral Surveillance Program provides representative coupon testing for Holtec spent fuel racks and in-situ neutron attenuation testing for PaR spent fuel racks in order to ensure the Boral in the spent fuel racks continues to meet the assumptions of the spent fuel pool criticality analysis.

In LRA Section B.2, Aging Management Programs, on page B-6, a new bullet is added to read as follows:

. Boral Surveillance Program - Subsection B.3.41 In LRA Table B.2.2.1, Aging Management Correlation, on page B-11, a new line item is added as follows:

NUREG-1801 AGING DUANE ARNOLD AGING NUREG-1801 NEW/EXISTING MANAGEMENT MANAGEMENT PROGRAM COMPARISON PROGRAM PROGRAM Plant-Specific Boral Surveillance Not applicable New Program Program In LRA Appendix A, Section 18.4, Duane Arnold License Renewal Commitments, a new license renewal commitment number 48 is also provided, as follows:

Item System, Commitment Section Schedule No. Component or Program

48. Boral Implement a Boral Surveillance Program and 18.1.41 Prior to Surveillance complete the first in-situ neutron attenuation test entering the Program of the PaR spent fuel racks. period of extended operation Page 6 of 9

Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls Updated RAI Responses Regarding BWR Penetrations Program In letter NG-09-0764 dated October 13, 2009, NextEra Energy responded to NRC RAIs B.3.10-5 and B.3.10-7 related. to the BWR Penetrations Program. Additional clarifications were provided for penetrations in response to RAI 3.1.2.1-a in letter NG-09-0825 dated December 14, 2009. In conference calls on December 14, 2009, and January 8, 2010, NextEra Energy agreed to make additional changes to certain information in these responses. The changes are .provided below:

In the NextEra Energy response to RAI B.3.10-5 in letter NG-09-0764 dated October 13, 2009 (page 92 of Enclosure 1), the revised license renewal Commitment 42 is superseded and replaced with the following:

Item System, Commitment Section Schedule No. Component or Program

42. BWR The implementing document for the BWR 18.1.10 Priorto Penetrations Penetrations Program will be revised to specify that the period Program guidance in BWRVIP-14, -59 and -60 will be used, of as appropriate, depending on material, in the extended evaluation of crack growth in stainless steel, nickel operation alloys and low-alloy steels, respectively, when flaws are identified and evaluation required.

In the NextEra Energy response to RAI B.3.10-7 in letter NG-09-0764 dated October 13, 2009 (page 95 of Enclosure 1), the line item for Nozzle - jet pump instrumentation in LRA Table 3.1.2-1 on page 3.1-46 is revised to appear as follows:

Component Intended Material Environment Aging Effect Aging NUREG- Table Notes Type Function Requiring Management 1801 3.X.1 Management Program Volume item 2 line Item Nozzle-jet Pressure Carbon Reactor cracking ASME IV.A1-5 3.1.1- E pump boundary steel Coolant Section XI (R-69) 40 instrumentation with (Internal) Inservice stainless Inspection, steel Subsections cladding IWB, IWC and IWD Program Water Chemistry Program Page 7 of 9

Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls In the NextEra Energy response to RAI B.3.10-7 in letter NG-09-0764 dated October 13, 2009 (page 95 of Enclosure 1), the line item for Safe end - control rod drive in LRA Table 3.1.2-1 on page 3.1-55) is revised to appear as follows:

Component Intended Material Environment Aging Effect Aging NUREG- Table Notes Type Function Requiring Management 1801 3.X.1 Management Program Volume 2 item line Item Safe end - Pressure Stainless Reactor Cracking BWR Control IV.A1-1 3.1.1- E control rod boundary steel Coolant Rod Drive (R-68) 41 drive (Internal) Return Line Nozzle Program In the NextEra Energy response to RAI B.3.10-7 in letter NG-09-0764 dated October 13, 2009 (page 96 of Enclosure 1), the line item for Safe end - jet pump instrumentation in LRA Table 3.1.2-1 on page 3.1-58 is revised to appear as follows:

Component Intended Material Environment Aging Effect Aging NUREG- Table Notes Type Function Requiring Management 1801 3.X.1 Management Program Volume item 2 line Item Safe end -jet Pressure Stainless Reactor Cracking ASME IV.A1-5 3.1.1- E pump boundary steel Coolant Section XI (R-69) 40 instrumentation (Internal) Inservice Inspection, Subsections IWB, IWC and IWD Program Water Chemistry Program In LRA Table 3.1-1, Summary of Aging Management Evaluations in Chapter IV of NUREG-1801 - Reactor Coolant System, in line item 3.1.1-41, the Discussion entry is revised in its entirety to read as follows:

At Duane Arnold, cracking in stainless steel, nickel alloy and steel clad with stainless steel components in reactor coolant is managed by the BWR Stress Corrosion Cracking Program, the Water Chemistry Program, and the BWR Control Rod Drive Return Line Nozzle Program (for the control rod drive safe end).

It should be noted that the summary information for these penetrations provided in the response to RAI 3.1.2.1-a in letter NG-09-0825 dated December 14, 2009, is superseded by the above line item changes.

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Enclosure 2 to NG-10-0009 LRA Changes Resulting from NRC Telephone Conference Calls Reactor Water Cleanup System Program UFSAR Supplement In a telephone call on, January 8, 2009, a question was raised regarding the UFSAR entry for the BWR Reactor Water Cleanup System Program provided in Enclosure 2 (page 4 of 5) of letter NG-09-0825 dated December 14, 2009. For completeness, the UFSAR entry is being expanded, as follows, to more closely conform to the information in NUREG-1 800 Table 3.3-2.

LRA Appendix A, Section 18.1.11, BWR Reactor Water Cleanup System Program, on page A-7, is revised to read as follows:

The BWR Reactor Water Cleanup System Program ensures that cracks due to stress corrosion cracking and intergranular stress corrosion cracking in the Reactor Water Cleanup System pipe welds will be detected prior to loss of its intended function. The program includes periodic inspections, water chemistry control, and plant modifications.

The program includes measures delineated in NUREG-0303, Rev. 2 and NRC Generic Letter 88-01, and Inservice Inspection in conformance with the American Society of Mechanical Engineers (ASME) Code,Section XI.

The program is consistent with the ten elements of NUREG-1801 XI.M25 and takes no exception to NUREG-1801 XI.M25.

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Enclosure 3 to NG-10-0009 LRA Changes'Identified by NextEra Energy As a result of ongoing activities, NextEra Energy has identified several minor LRA changes and corrections to previous RAI responses that should be made for completeness and accuracy. The changes are as follows.

Drywell Head Access Hatch and Bellows To improve the completeness of the Primary Containment Structure description provided in the LRA, it has been determined that several in-scope components should be more explicitly described in the LRA tables. In addition, certain additions, clarifications or corrections are warranted for selected line items in Tables 2.4-7 and 3.5.2-7. The LRA changes to incorporate these items are as follows:

In LRA Table 2.4-7; Primary Containment Structure, on pages 2.4-24 through -26, the following line items are added:

Component Types Intended Function Drywell head access hatch carbon steel air- Structural pressure barrier indoor uncontrolled Penetration bellows stainless steel air-indoor Flood barrier uncontrolled HELB shielding Structural pressure barrier Torus carbon steel structural steel in air-indoor Structural support uncontrolled Torus penetration carbon steel in air-indoor Structural pressure barrier uncontrolled Structural support In addition, in LRA Table 2.4-7 on page 2.4-26, in the line item for Torus shell and ring girders carbon steel in treated water, the additional Intended Function, Heat sink, is added.-

In LRA Table 3.5.2-7, Summary of Aging Management Review Results - Primary Containment Structure, on page 3.5-83, in the line item for Penetration bellows of Material Carbon Steel with an Aging Effect Requiring Management of Cracking, the additional Aging Management Program, 10 CFR 50 Appendix J Program, is added.

Page 1 of 4

Enclosure 3 to NG-10-0009 LRA Changes Identified by NextEra Energy In LRA Table 3.5.2-7, on page 3.5-83, a new line item is added to appear as follows:

Component Intended Material Environment Aging Effects Aging NUREG- Table Notes Type Function Requiring Management 1801 3.x-1 Management Program Volume 2 Item Line Item Penetration Flood Stainless Air- indoor Cracking ASME Section II.B4-3 3.5.1-12 A bellows barrier steel uncontrolled X1, Subsection (C-14)

HELB (external) ]WE Program shielding 10 CFR 50 Appendix J Structural Program pressure barrier In LRA Table 3.5.2-7, Summary of Aging Management Review Results - Primary Containment Structure, on page 3.5-86, the line item for Torus structural steel in an Environment of Treated water (internal) is revised to appear as follows:

Component Intended Material Environment Aging Effects Aging NUREG- Table Notes Type Function Requiring Management 1801 3.x-1 Management Program Volume 2 Item I Line Item Torus Structural Carbon Treated water Loss of ASME Section 11.B1.1-2 3.5.1-5 A structural support steel (external) material X1, Subsection (C-19) steel ]WE Program Stop Logs NextEra Energy letter dated October 1, 2009, provided a change to LRA Table 3.5.2-5, Summary of Aging Management Review Results - Miscellaneous Yard Structures, to incorporate stop logs constructed of treated wood. It has been noted that the summary listing of materials for miscellaneous yard structures in LRA Section 3.5.1.5 does not list treated wood as one of the materials.

Accordingly, in LRA Section 3.5.1.5, Miscellaneous Yard Structures, on page 3.5-5, a new bullet is added under Materials to read, Treated Wood.

Steel Duct Embedded in Concrete Duct Bank LRA Tables 2.4-5 and 3.5.2-5 contain line items for Rigid steel duct embedded in reinforced concrete duct bank. It has been determined that these line items were listed in error.

Page 2 of 4

Enclosure 3 to NG-10-0009 LRA Changes Identified by NextEra Energy Accordingly, 'the following changes are made to delete this component type from the LRA:

In LRA Table 2.4-5, Miscellaneous Yard Structures, on page 2.4-21, the line item for Rigid steel duct embedded in reinforced concrete duct bank is deleted.

In LRA Table 3.5.2-5, Summary of Aging Management Review Results - Miscellaneous Yard Structures, on page 3.5-71, the line item for Rigid steel duct embedded in concrete duct bank is deleted.

Aging Management Program for CARDOX System In the.NextEra Energy responses to RAIs B.3.22-1 and B.3.22-3 in letter NG-09-0764 dated October 13, 2009, it was indicated that the CARDOX system inspections would be performed under the Fire Protection Program. It has been determined that LRA Table 3.3.2-11 for the Fire Protection System does not include all the component type -

material - environment combinations associated with the CARDOX system.

For completeness, in LRA Table 3.3.2-11, Summary of Aging Management Review Results - Fire Protection System, on pages 3.3-128 through 3.3-145, the following new line items are added to appear as follows:

Component Intended Material Environment Aging Effects Aging NUREG- Table Notes Type Function Requiring Management 1801 3.x-1 Management Program Volume 2 Item Line Item Accumulator, Pressure Carbon Air- indoor Loss of Fire Protection VII.1-8 3.3.1-58 E pulsation boundary steel uncontrolled material Program (A-77) damper, low (external) pressure tank Pipe, pipe Pressure Carbon Air - indoor Loss of Fire Protection VII.1-8 3.3.1-58 E fittings, boundary steel uncontrolled material Program (A-77) hoses, tubes, (external) rupture disk Valve, Pressure Carbon Air- indoor Loss of Fire Protection VII.I-8 3.3.1-58 E damper boundary steel uncontrolled material Program (A-77)

(external)

To reflect this change, LRA Table 3.3-1, Summary of Aging Management Evaluations in Chapter VII of NUREG-1801 Auxiliary Systems, on page 3.3-55, the Discussion entry for line item 3.3.1-58 is revised to read as follows:

Loss of material of steel external surfaces exposed to air and condensation is managed by the External Surfaces Monitoring Program, the Fire Protection Program, and the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program at DAEC.

Page 3 of 4

Enclosure 3 to NG-10-0009 LRA Changes Identified by NextEra Energy Editorial Correction to NextEra Energy Response to RAI 3.3.2.2.3.2-1 In letter NG-09-0825 dated December 14, 2009, NextEra Energy responded to RAI 3.3.2.2.3.2-1. It has been determined that the response contained editorial errors.

Accordingly, in Enclosure 1 ofthe December 14, 2009 letter, on page 25 of 68, the sentence that begins "In LRA Section 3.3.2.3.2 on page 3.3-27, the ... " is revised to read, "In LRA Section 3.3.2.2.3.2 on page 3.3-37, the ...."

Editorial Correction to NextEra Response to RAI 3.3.2.1-5 In letter NG-09-0825 dated December 14, 2009, NextEra Energy responded to RAI 3.3.2.1-5. It has been determined that the response inadvertently omitted one change.

Accordingly, in Enclosure 1 of the December 14, 2009 letter, on page 13 of 68, the last paragraph of the response to RAI 3.3.2.1-5 is revised to read:

In LRA Table 3.5.2-2, Summary of Aging Management Review Results Control Building, in the line item for Concrete with an Aging Effect Requiring Management of Expansion and cracking and an Aging Management Program of Fire Protection Program, the Aging Effect Requiring Management is changed to Loss of Material, the NUREG-1801 Volume 2 Line Item entry is changed to VII.G-29 (A-92) and the Table 3.X-1 Item entry is changed to 3.3.1-67.

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Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program Buried Piping and Tanks Implement Buried Piping and Tank Program 18.1.7 Prior to the Inspection Program period of extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

2. BWR Vessel Internals Perform an EVT-1 inspection of 5% of the top guide locations 18.1.14 Within six Program years of entering the period of extended operation

3. BWR Vessel Internals Perform an EVT-1 inspection of an additional 5% of the top 18.1.14 Within 12 Program guide locations years of entering the period of extended operation

4. Electrical Cables and Implement an Electrical Cables and Connections Program and 18.1.17 Prior to the Connections Program complete the first inspection prior to the period of extended period of operation. extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

Page 1 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item No.

System, Component or Program Commitment 2 Section I Schedule

5. Electrical Cables and Implement an Electrical Cables and Connections Used in 18.1.18 Prior to the Connections Used in Instrumentation Circuits Program and complete the first period of Instrumentation Circuits inspection prior to the period of extended operation. extended Program [Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

6. Electrical Connections Implement an Electrical Connections Program and complete the 18.1.19 Prior to the Program one time inspection prior to the period of extended operation. period of extended

[Revised in DAEC letter NG-09-0764 in response to New ertin Program Commitments RAI] operation

7. Electrical Penetration Implement an Electrical Penetration Assemblies Program. 18.1.20 Prior to the Assemblies Program period of

[Revised in DAEC letter NG-09-0764 in response to new extended Program Commitments RAI] operation

8. External Surfaces Revise the inspection program to address inspector 18.1.21 Prior to the Monitoring Program qualifications, types of components, degradation mechanisms, period of aging effects, acceptance criteria, inspection frequency, and extended periodic reviews to determine program effectiveness. The operation program will also specifically address inaccessible areas and include inspections of opportunity for possible corrosion under insulation.

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.21-2]

Page 2 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

9. Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance 18.1.22 Prior to the procedure will be enhanced to include criteria for visual period of inspections of fire barrier wall, ceiling and floors to examine for extended any sign of degradation such as cracking, spalling and loss of operation material caused by freeze-thaw, chemical attack and reaction with aggregates by fire protection qualified inspectors.

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.22-1]

10. Fire Protection Program Enhance procedures to inspect the entire diesel driven fire 18.1.22 Prior to the pump fuel supply line for age related degradation. period of extended operation

11. Fire Water System Implement maintenance activities to perform volumetric 18.1.23 Prior to the Program examinations for pipe wall thinning of fire protection piping period of periodically during the period of extended operation. extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

12. Fire Water System Enhance procedures toinclude NFPA 25 criteria for sprinklers 18.1.23 Prior to the Program regarding replacing or testing period of extended operation Page 3 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

13. Fire Water System Enhance procedures to perform visual inspection of fire 18.1.23 Prior to the, Program hydrants annually period of extended operation

14. Fuel Oil Chemistry Revise the program to require particulate testing of fuel oil 18.1.25 Prior to the Program samples from the diesel fire pump day tank period of extended operation

15. Fuel Oil Chemistry Enhance procedures to require sampling and testing of new fuel 18.1.25 Prior to the Program oil delivered to the diesel fire pump day tank; and to require that period of purchase orders and sampling procedures for diesel fuel extended delivered to and stored in the diesel fire pump day tank prohibit operation the delivery and use of biodiesel fuel.

[Revised in letter NG-09-0764 in response to RAI B.3.25-1]

16. Fuel Oil Chemistry Enhance procedures to perform periodic (10 year) draining, 18.1.25 Prior to the Program cleaning and visual inspection of the diesel fuel oil day tanks, period of diesel fire pump day tank, and diesel driven air start air extended compressor fuel oil tanks. operation

[Revised in letter NG-09-0764 in response to RAI B.3.25-4]

Page 4 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

17. Fuel Oil Chemistry Implement procedures to require bottom thickness testing of the 18.1.25 Prior to the Program Standby Diesel Generator Day Tanks and the Diesel Fire Pump period of Day Tank. extended'

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

18. Fuse Holders Program Implement a Fuse Holders Program and complete the first test 18.1.26 Prior to the prior to the period of extended operation. period of extended ertin

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.26-operation 1 and New Program Commitments RAI]

19. Inaccessible Medium Implement an Inaccessible Medium Voltage Cable Program and 18.1.27 Prior to the Voltage Cable Program complete the first inspection or test prior to the period of period of extended operation. extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

20. Inspection of Internal Implement an Inspection of Internal Surfaces in Miscellaneous 18.1.28 Prior to the Surfaces in Miscellaneous Piping and Ducting Components Program. period of Piping and Ducting Components Program [Revised in DAEC letter NG-09-0764 in response to New extended operation Program Commitments RAI]

Page 5 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

21. Inspection of Overhead Enhance procedures to monitor for corrosion and wear of the 18.1.29 Prior to the Heavy Load and Light supporting steel and rails period of Load (Related to extended Refueling) Handling operation Systems Program

22. Inspection of Overhead Enhance procedures to record usage of the reactor building and 18.1.29 Prior to the Heavy Load and Light turbine building cranes period of Load (Related to extended Refueling) Handling operation Systems Program

23. Lubricating Oil Analysis Enhance procedures to include diesel fire pump 18.1.30 Prior to the Program period of extended operation

24. Metal Enclosed Bus Implement a Metal Enclosed Bus Program and complete the 18.1.31 Prior to the Program first inspection prior to the period of extended operation. extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

25. One-Time Inspection Implement a One-Time Inspection Program and complete the 18.1.32 Prior to the Program one-time inspections prior to the period of extended operation. period of

• extended operation

[Revised in DAEC letter NG-09-0764 in response to New RAI]

Program Commitments Page 6 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

26. Reactor Vessel Implement a procedure to evaluate the BWRVIP ISP data as it 18.1.35 Prior to the Surveillance Program becomes available, period of extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAIl

27. Reactor Vessel Revise the Reactor Vessel Surveillance Program to implement 18.1.35 Prior to the Surveillance Program the recommendations of BWRVIP-1 16 BWR Vessel and period of Internals Project Integrated Surveillance Program extended BWRVIP-74-A BWR PRV Implementation for License Renewal. operation Inspection and Flaw Evaluation Guidelines for License Renewal

28. Reactor Vessel Implement BWRVIP-116 with the conditions documented in 18.1.35 Prior to the Surveillance Program Sections 3 and 4 of the NRC Staffs SE dated March 1, 2006 for period of BWRVIP- 116 extended operation

29. Selective Leaching of Implement and complete a program to include one-time visual 18.1.36 Prior to the Materials Program inspection and hardness measurement of selected components period of susceptible to selective leaching extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

Page 7 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

30. Structures Monitoring Enhance procedures to include structures and structural 18.1.37 Prior to the Program components not currently in Maintenance Rule Program period of extended operation

31. Structures Monitoring Enhance procedures to include periodic sampling of 18.1.37 Prior to the Program groundwater for pH, chloride and sulfate concentration on a 10 period of year periodicity. extended operation

32. Structures Monitoring Enhance procedures to include a elastomer inspection to 18.1.37 Prior to the Program prevent leakage through containment penetration. period of extended operation

33. Structures Monitoring Enhance procedures to include a requirement to contact the 18.1.37 Prior to the Program proper personnel to allow opportunistic inspection of the buried period of concrete foundation. extended operation

34. Structures Monitoring Enhance procedures to include opportunistic inspections of the 18.1.37 Prior to the Program buried concrete foundation on a 10 year periodicity. period of extended operation Page 8 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

35. Metal Fatigue of Reactor Enhance procedures to incorporate the requirements of 18.2.2 Prior to the Vessel Coolant Pressure NUREG/CR-6260 locations into the implementing procedures. period of Boundary Program extended operation

36. Thermal Aging and Implement a Thermal Aging and Neutron Irradiation 18.1.38 Prior to the Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) period of-Embrittlement of Cast Program. extended Austenitic Stainless Steel [Revised in DAEC letter NG-09-0764 in response to New operation (CASS) Program Program Commitment RAI]

37. BWR Vessel Internals Inspect a sample of the rim hold-down bolts by VT-3 until an 18.1.14 Prior to the Program expanded technical basis for not inspecting is approved by the period of NRC. extended operation

38. Reactor Vessel Submit a relief request to address the frequency requirements 18.3.1.4 Prior to the Circumferential Weld TLAA of the inservice inspection of the RPV circumferential welds. period of (BWRVIP-05). extended operation

39. Quality Assurance Expand the.scope of its 10 CFR Part 50, Appendix B Quality UFSAR Prior to the Program (Corrective Assurance program to include non-safety-related structures and 17.1.2 period of Action, Confirmation components subject to an AMR for license renewal. extended Process, Administrative operation Controls)

Page 9 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

40. Operating Experience Perform an operating experience review of extended power Prior to the uprate and its impact on aging management programs for period of systems, structures, and components (SSCs) before entering extended the period of extended operation. operation

41. Bolting Integrity Program Revise the implementing procedures for the ASME Section XI 18.1.6 Prior to the Inservice Inspection Subsections IWB, IWC, and IWD Program; period of ASME Section Xl Inservice Inspection, Subsection IWF extended Program; External Surfaces Monitoring Program; Structural operation Monitoring Program; and Buried Piping and Tanks Program such that they specifically address the inspection of fasteners (bolting, washers, nuts, etc.) for signs of leakage, corrosion/loss of material, cracking, and loss of preload/loss of prestress, as applicable.

[Added in letter NG-09-0764 in response to RAI B.3.6-02]

42. BWR Penetrations >The implementing document for the BWR Penetrations Program 18.1.10 Prior to the Program will be revised to specify that guidance in BWRVIP-14, -59 and - period of 60 will be used, as appropriate, depending on material, in the extended evaluation of crack growth in stainless steel, nickel alloys and operation low-alloy steels, respectively, when flaws are identified and evaluation required.

[Added in letter NG-09-0764 in response to RAI B.3.10-5]

[Revised in letter NG-10-0009]

Page 10 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS 1 Item System, Component or Commitment 2 Section Schedule No. Program

43. Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance 18.1.22 Prior to the procedure will be enhanced to ensure a approximately 10% of period of each type of penetration seal is included in the 35 percent extended selection of fire penetration seals that are visually inspected at operation an 18 month interval.

.[Added in letter NG-09-0764 in response to RAI B.3.22-1]

44. Fire Protection Program The DAEC Surveillance Procedure for the C02 Cardox System 18.1.22 Prior to the Operability Annual Test will be enhanced to include a step to period of perform an inspection for corrosion and mechanical damage to extended system components. operation

[Added in letter NG-09-0764 in response to RAI B.3.22-1]

45. ASME Class 1 Small-bore Implement an ASME Code Class 1 Small-bore Piping Inspection 18.1.40 Prior to the Piping Inspection Program Program. period of

[Added in letter NG-09-0764 in response to RAI B.3.3-2] extended operation

46. BWR Vessel Internals The BWR Vessel Internals Program will incorporate the crack 18.1.14 Prior to the Program growth rate evaluations specified in the BWRVIP-100-A report. period of Plant-specific inspection intervals will be developed for DAEC extended core shroud welds that are exposed to a neutron fluence value operation equal to or greater than 1 X 1021 n/cm 2 (E > 1 MeV), as needed.

[Added in letter NG-09-0663 in response to RAI B.3.14-5]

Page 11 of 12

Enclosure 4 to NG-10-0009 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-I, Duane Arnold License Renewal Commitments TABLE A-1 1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS Item System, Component or Commitment 2 Section Schedule No. Program

47. Reactor Internals DAEC will submit an analysis for loss of preload in core plate 18.3.1.7 Two years hold-down bolts due to stress relaxation to the NRC for Staff prior to review. The analysis will use projected neutron fluence values entering the for the end of the period of extended operation. The analysis period of will be submitted 2 years prior to entering the period of extended extended operation. operation

[Added in letter NG-09-0663 in response to RAI 4.2.7-1]

48. Boral Surveillance Implement a Boral Surveillance Program and complete the first 18.1.41 Prior to the Program in-situ neutron attenuation test of the PaR spent fuel racks. period of

[Added in letter NG-1 0-0009] extended operation

'Table is updated to reflect DAEC correspondence through 1/14/2010.

2In the table, the term "implement" means that the program is described in an approved procedure or other approved formal document; the test, inspection or monitoring procedure has been developed and approved; and the first test, inspection or monitoring activity has been scheduled.

Page 12 of 12