NG-10-0258, Supplemental Information Regarding License Renewal Application

Supplemental Information Regarding License Renewal Application

ML101190355
Person / Time
Site:	Duane Arnold
Issue date:	04/28/2010
From:	Costanzo C NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-10-0258
Download: ML101190355 (22)

Text

NEXTera M ENERGV~

/ DUANE ARNOLD

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April 28, 2010 NG-10-0258 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-1 09)," dated September 30, 2008, NG-08-0713 (ML082980623)

2. Letter, Richard L. Anderson (FPL Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "Ucense 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-Q,9-0059 (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. The need for certain LRA clarifications or changes has been identified through interactions with the Staff. These clarifications and changes are provided in Enclosure 1.

Enclosure 2 provides a revised LRA Appendix A, Section 18.4, Table A-1, Duane Arnold License Renewal Commitments, updated to reflect the I,icense renewal commitment changes made in DAEC correspondence to date.

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

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

Document Control Desk NG-10-0258 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 28, 2010.

Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosures:

1. Clarifications and LRA Revisions

2. Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments 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 1 to NG-10-0258 Clarifications and LRA Revisions RAI 4.3.4-3, Part 2 By letter NG-10-0091 dated March 9, 2010 (ML100700248), NextEra Energy, Duane Arnold provided the DAEC response to a Staff request for additional information (RAI) regarding the calculation of Fatigue Life Correction Factor (Fen) for Nickel Alloys. This response was the subject of a discussion with the NRC Staff on April 6, 2010. Based on this discussion, the following is provided with respect to the DAEC response to RAI 4.3.4-3, Part 2.

The numbers of vessel thermal and pressure transient cycles are tracked via a surveillance test procedure (STP) that is performed on a cyclic basis. Cycles that are inputs to the vessel fatigue evaluations are manually counted to ensure that the actual numbers of these cycles are less than the numbers used to determine the usage factors. This ensures that the usage factors remain below the calculated values and that design limits on fatigue usage are not exceeded. If the number of transient cycles approaches the number of cycles used in the fatigue calculation, the fatigue calculation would be evaluated and revised as needed.

As shown in LRA Table 4.3.4-1, Summary of EAF Evaluation Results for DAEC, the Recirculation Inlet Nozzle Safe End, Feedwater Nozzle Safe End, and Core Spray Nozzle Safe End are Nickel Alloy components. In the future, if the environmental fatigue calculations for these three Safe Ends are revised or updated, Fen data for Nickel Alloy from the methodology that is described in NUREG/CR-6909 will be used in the determination of usage factors.

In LRA Appendix A, Section 18.4, Duane Arnold License Renewal Commitments, a new license renewal commitment number 51 is provided, as follows:

Item System, Commitment Section Schedule No. Component or Program

51. Metal Fatigue of Future revisions/updates to the 18.2.2 Upon Reactor Vessel environmental fatigue calculations for the calculation Coolant Pressure Recirculation Inlet Nozzle Safe End, revision.

Boundary Program Feedwater Nozzle Safe End, and Core Spray Nozzle Safe End will use Fen data for Nickel Alloy from the methodology that is described in NUREG/CR-6909 in the determination of usage factors.

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Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions ASME Code Class 1 Small-bore Piping Inspection Program The DAEC ASME Code Class 1 Small-bore Piping Inspection Program was provided by letter dated October 13, 2009 (NG-09-0764) in response to RAI B.3.3-2. During a conference call on April 21, 2010, the Staff requested additional information regarding operating experience discussed in the Program. The Staff also discussed current expectations related to socket welds.

The information requested during the call, as well as revisions to the DAEC LRA, is provided below.

Information concerning Operating Experience In B.3.40.14 Operating Experience, the Program includes a discussion concerning leakage identified in December 1988 in the 2-inch diameter B Recirculation Pump Suction Drain Line. During a conference call on April 21, 2010, the Staff requested additional information regarding this operating experience.

As documented in NRC Inspection Report 50-331/89009 dated June 16 1989, metallurgical testing of the cracked fitting weld was performed to find the cause of the failure and to evaluate generic implications of the failure. The weld joint was a 2 sockolet type fitting. The NRC inspector observed the preparation of the samples and the following metallurgical analysis performed by Packer Engineering. Three test specimens were prepared for examination.

One of the specimens was broken to expose the fractured surface, using liquid nitrogen.

Examination of the fractured surface showed an elliptically shaped crack starting from the inside diameter and propagating to the surface. Macro samples were prepared from the remaining two specimens. Examination of the samples confirmed that crack growth started on the inside diameter at the interface between the fitting and the pipe, and propagated outward to the face of the weld. The crack exhibited many characteristics common to fatigue cracking.

The macro samples were etched and examined for sensitization. The grain boundaries were in excellent condition and showed no sensitization, either in the weld or the base material. This would eliminate IGSCC as the cause of failure. The fractured surface was examined in the scanning electron microscope. Some evidence of cyclic fatigue was evident due to the presence of striations.

The 2 drain line attachment to the 22 recirculation piping is located near the recirculation pump which could have contributed to the vibration fatigue cracking experienced in the 2 fittings weld. The Recirculation System is normally in operation.

Since the replacement of the leaking portion of pipe in 1989, no further cracking of the pipe has been observed.

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Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions Revisions to the DAEC LRA Based on the April 21, 2010 discussion with the Staff concerning current expectations related to socket welds, the following changes to the DAEC LRA are made:

The second paragraph of B.3.40.1 Program Description is revised to read as follows:

ASME Code Class 1 Small Bore socket welds presently receive a VT-2 visual inspection during system leakage tests each refueling outage per the requirements of IWB-2500-1, Examination Category B-P. DAEC will continue to perform these inspections per the ASME Section XI requirements during the period of extended operation. In addition, if an acceptable nuclear industry methodology for performing volumetric examinations of socket weld fittings is developed, DAEC will perform volumetric examination of a minimum of ten percent of the ASME Code Class 1 small bore socket welds each inspection interval. A destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations. If the acceptable methodology is developed in the middle of an inspection interval, the number of socket welds to be inspected will be prorated. If volumetric examination of small bore class 1 socket welds becomes a requirement of ASME Section XI, DAEC will perform examinations per the applicable code requirement.

The second paragraph of B.3.40.8 Detection of Aging Effects is revised to read as follows:

All ASME Code Class 1 Small Bore socket welds presently receive a VT-2 visual inspection during system leakage tests each refueling outage per the requirements of IWB-2500-1, Examination Category B-P. DAEC will continue to perform these inspections per the ASME Section XI requirements during the period of extended operation. In addition, if a nuclear industry acceptable methodology for performing volumetric examinations of socket weld fittings is developed, DAEC will perform volumetric examination of a minimum of ten percent of the ASME Code Class 1 small bore socket welds each inspection interval. A destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations.

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Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions In LRA Appendix A, Section 18.4, Table A-1 Duane Arnold License Renewal Commitments, Commitment 45 is revised to read as follows:

Item System, Commitment Section Schedule No. Component or Program

45. ASME Class Implement an ASME Code Class 1 Small-bore 18.1.40 Prior to the 1 Small-bore Piping Inspection Program period of Piping extended The ASME Code Class 1 Small-bore Piping Inspection operation inspection program will include provisions that a Program destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations.

Chlorination and Acid Feed System By email dated April 21, 2010, the Staff provided the following request for additional information.

RAI 3.3.2.3-X

Background

In LRA Table 3.3.2-3, Chlorination and Acid Feed System, the applicant stated that for stainless steel pipe, pipe fittings, hoses, tubes, rupture disk, valve and damper exposed to treated water (internal) where LRA footnote 218 is applicable (i.e., material science evaluation for this material in this environment results in no aging effects requiring management), there is no aging effect or proposed aging management program. The AMR line item cites generic note I, indicating that the aging effect in the GALL Report for this line items component, material and environment combination is not applicable.

Issue In its review of LRA section 3.4.2, the staff noted that LRA section 3.4.2.2.7 Item 1 referred to stainless steel piping components exposed to treated water. The staff further noted that the LRA states that stainless steel components exposed to treated water were managed for loss of material due to pitting and crevice corrosion by the Water Chemistry Program (B.3.39). The LRA further states that the effectiveness of the Water Chemistry Program would be confirmed by the One-Time Inspection Program (B.3.32) through an inspection of a representative sample of components crediting this program, including susceptible locations, such as areas of low or stagnant flow and areas of high concentrations of impurities.

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Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions Request

1. Please provide justification for why stainless steel piping components exposed to treated water in the Chlorination and Acid Feed System is listed as having no aging effect or proposed aging management program, when the same material, component and environment combination is listed in the LRA Further Evaluation Section 3.4.2.2.7 Item 1 as being managed for the loss of material by the Water Chemistry Program.

2. Additionally, the staff requests that the applicant provide sufficient detail from the material science evaluation discussed in LRA footnote 218 to allow the staff to independently review the evaluation.

DAEC Response The stainless steel piping and valves exposed to treated water in the Chlorination and Acid Feed System in this particular case are unique in that they contain water treatment chemicals. GALL AMP XI.M2, Water Chemistry and the DAEC Water Chemistry Program apply to water chemistry control of reactor water and systems which communicate with the reactor. The Chlorination and Acid Feed System does not contain reactor water and does not communicate with the reactor so it is not equivalent to water chemistry controls of reactor grade water. Therefore, the M2, Water Chemistry Program is not applicable. However, upon further review, it is determined that loss of material due to pitting and crevice corrosion should have been considered as aging effects.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, M38 should have been chosen for aging management of the subject Chlorination and Acid Feed System components because it adequately manages the subject stainless steel piping and valves for this system.

On page 3.3-76, in LRA Table 3.3.2-3, Summary of Aging Management Review Results Chlorination and Acid Feed System, the line for Pipe, pipe fittings, hoses, tubes, rupture disk with an environment of Treated water (internal) is revised to read 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 Pipe, pipe Leakage Stainless Treated Loss of Inspection of VII.E3-15 3.3.1- E fittings, boundary steel water material Internal 24 hoses, (spatial) (internal) Surfaces in tubes, Miscellaneous rupture disk Piping and Ducting Components Program 5 of 7

Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions On page 3.3-79, in LRA Table 3.3.2-3, Summary of Aging Management Review Results Chlorination and Acid Feed System, the line for Valve, damper with an environment of Treated water (internal) is revised to read 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 Valve, Leakage Stainless Treated Loss of Inspection of VII.E3-15 3.3.1- E damper boundary steel water material Internal 24 (spatial) (internal) Surfaces in Miscellaneous Piping and Ducting Components Program This revision removes the reference to the plant-specific note 218 in LRA Table 3.3.2-3.

RAI 3.3.2.3.6-1 By email dated April 22, 2010, the Staff provided the following request for additional information.

RAI 3.3.2.3.6-1

Background

The GALL Report item VII.F1-19 recommends use of the Lubricating Oil Analysis and One-Time Inspection Programs for managing loss of material/general, pitting, and crevice corrosion for steel (carbon steel) piping, piping components, and piping elements in lubricating oil environment.

Issue LRA Table 3.3.2-6 Summary of Aging Management Review Results, Control Building Heating, Ventilation, and Air Conditioning (page 3.3-107) the applicant addresses the AMR line item valve, damper made of carbon steel in a lubricating oil (internal) environment as having no aging effect. The staff also noted that the applicant assigned for this AMR line item the Generic Note I, which means that aging effect in the GALL Report for this component, material and environment is not applicable. The applicant supplemented the Note I with a plant specific Note 232, which states that these components do not have the potential for water contamination. Moreover, the staff noted in the same table (page 3.3-101) for items VII.F1-19, pipes, pipe fittings, hoses, tubes, rupture disks, made of carbon steel in lube oil (internal) environment the applicant proposes to manage loss of material with the Lubricating Oil Analysis and One-Time Inspection Programs.

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Enclosure 1 to NG-10-0258 Clarifications and LRA Revisions Request

1. Please provide, in sufficient detail, the technical basis for the staff to evaluate plant specific Note 232.

2. Explain the variance between the line item on page 3.3-107 to that on page 3.3-101.

DAEC Response After additional review, DAEC has concluded that the carbon steel valves with an environment of lube oil, discussed in the above NRC request, should be managed for loss of material. Therefore, on page 3.3-107, in LRA Table 3.3.2-6, Summary of Aging Management Review Results Control Building Heating, Ventilation, and Air Conditioning, the line for Valve, damper with an environment of Lube oil (internal) is revised to read 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 Valve, Pressure Carbon Lube oil Loss of Lubricating VII.F1-19 3.3.1- 202, damper boundary steel (internal) material Oil Analysis (AP-30) 14 A Program One-Time Inspection Program This revision removes the reference to the plant-specific note 232 in LRA Table 3.3.2-6.

Further review of the use of note 232 in the 3.X.2 Tables identified the following additional LRA changes.

On page 3.4-41, in LRA Table 3.4.2-2, Summary of Aging Management Review Results Condensate and Feedwater System, the Notes entry for Valve, damper with an environment of Lube oil (internal) is changed from 232, I to 225, I.

In Table 3.2.2-3, Summary of Aging Management Review Results Primary Containment, on page 3.2-43, the line for Pipe, pipe fittings, hoses, tubes, rupture disk with an environment of Hydraulic oil (internal) is deleted. On page 3.2-44, the line for Valve, damper with an environment of Hydraulic oil (internal) is deleted. These components were removed from service by modification, and no longer have a license renewal intended function.

In Table 3.0-1, Service Environments, on page 3.0-13, the line entry for Hydraulic oil is deleted. In Section 3.2.1.3 Primary Containment, on page 3.2-4, Hydraulic oil is deleted from the list of Environments. These changes are made to reflect the revisions to Table 3.2.2-3 made in the preceding paragraph.

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Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

1. 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 operation

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

Page 1 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

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 operation

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

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 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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 operation

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

12. Fire Water System Enhance procedures to include NFPA 25 criteria for sprinklers 18.1.23 Prior to the Program regarding replacing or testing period of extended operation Page 3 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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]

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Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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 operation

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

[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 operation

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

Page 5 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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 operation

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

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

Page 6 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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

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

27. Reactor Vessel Revise the Reactor Vessel Surveillance Program to implement 18.1.35 Prior to the Surveillance Program the recommendations of BWRVIP-116 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]

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Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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 5 period of year periodicity. extended operation

[Revised in letter NG-10-0043 in response to Follow-up RAI B.3.37-2]

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 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 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 operation (CASS) Program [Revised in DAEC letter NG-09-0764 in response to New Program Commitment RAI]

37. Reactor Internals DAEC will ensure that aging of core plate hold down bolts is 18.1.14 Prior to appropriately addressed by completing one of the following entering the actions: 18.3.1.7 period of extended Install core plate wedges to eliminate the function of core operation plate hold down bolts.

Perform analysis of the core plate rim hold down bolts that demonstrates adequacy to perform their intended function including loss of pre-load in the period of extended operation including the effects of projected neutron fluence. Inspection of core plate hold down bolts will be performed in accordance with BWRVIP-25, or a deviation disposition will be developed/submitted in accordance with BWRVIP-94.

[Revised in DAEC letter NG-10-0091]

Page 9 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

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)

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 XI 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]

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Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

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]

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 CO2 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]

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Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

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 extended The ASME Code Class 1 Small-bore Piping inspection program operation will include provisions that a destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations.

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

[Revised in letter NG-10-0258]

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/cm2 (E > 1 MeV), as needed.

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

47. Not Used

[Withdrawn in letter NG-10-0091]

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 extended

[Added in letter NG-10-0009]

operation Page 12 of 13

Enclosure 2 to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

49. Fire Protection Program Enhance procedures to inspect the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated gypsum 18.1.22 Prior to the board wall that separates the control room computer room area period of from the front panel area for aging due to cracking. extended operation

[Added in letter NG-10-0043]

50. ASME Section XI, Perform recoating of suppression pool interior surfaces below 18.1.4 Complete Inservice Inspection, the water line. recoating Subsection IWE Program prior to

[Added in letter NG-10-0091]

startup from the first refuel outage during the period of extended operation

51. Metal Fatigue of Reactor Future revisions/updates to the environmental fatigue 18.2.2 Upon Vessel Coolant Pressure calculations for the Recirculation Inlet Nozzle Safe End, calculation Boundary Program Feedwater Nozzle Safe End, and Core Spray Nozzle Safe End revision.

will use Fen data for Nickel Alloy from the methodology that is described in NUREG/CR-6909 in the determination of usage factors.

[Added in letter NG-10-0258]

1 Table is updated to reflect DAEC correspondence through 4/28/2010.

2 In 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 13 of 13