NG-10-0258, 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~
April 28, 2010
/
DUANE ARNOLD 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. 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) to NG-10-0258 Clarifications and LRA Revisions 1 of 7 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 No.
- System, Component or Program Commitment Section Schedule
- 51.
Metal Fatigue of Reactor Vessel Coolant Pressure Boundary Program Future revisions/updates to the environmental fatigue calculations for the Recirculation Inlet Nozzle Safe End, 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.
18.2.2 Upon calculation revision.
to NG-10-0258 Clarifications and LRA Revisions 2 of 7 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.
to NG-10-0258 Clarifications and LRA Revisions 3 of 7 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.
to NG-10-0258 Clarifications and LRA Revisions 4 of 7 In LRA Appendix A, Section 18.4, Table A-1 Duane Arnold License Renewal Commitments, Commitment 45 is revised to read as follows:
Item No.
- System, Component or Program Commitment Section Schedule
- 45.
ASME Class 1 Small-bore Piping Inspection Program Implement an ASME Code Class 1 Small-bore Piping Inspection Program The ASME Code Class 1 Small-bore Piping inspection program will include provisions that a destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations.
18.1.40 Prior to the period of extended operation 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.
to NG-10-0258 Clarifications and LRA Revisions 5 of 7 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 Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Volume 2 line Item Table 3.X.1 item Notes Pipe, pipe
- fittings, hoses,
- tubes, rupture disk Leakage boundary (spatial)
Stainless steel Treated water (internal)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program VII.E3-15 3.3.1-24 E
to NG-10-0258 Clarifications and LRA Revisions 6 of 7 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 Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Volume 2 line Item Table 3.X.1 item Notes
- Valve, damper Leakage boundary (spatial)
Stainless steel Treated water (internal)
Loss of material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program VII.E3-15 3.3.1-24 E
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.
to NG-10-0258 Clarifications and LRA Revisions 7 of 7 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 Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Volume 2 line Item Table 3.X.1 item Notes
Loss of material Lubricating Oil Analysis Program One-Time Inspection Program VII.F1-19 (AP-30) 3.3.1-14
- 202, A
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.
to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 1 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 1.
Buried Piping and Tanks Inspection Program Implement Buried Piping and Tank Program
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.7 Prior to the period of extended operation
- 2.
BWR Vessel Internals Program Perform an EVT-1 inspection of 5% of the top guide locations 18.1.14 Within six years of entering the period of extended operation
- 3.
BWR Vessel Internals Program Perform an EVT-1 inspection of an additional 5% of the top guide locations 18.1.14 Within 12 years of entering the period of extended operation
- 4.
Electrical Cables and Connections Program Implement an Electrical Cables and Connections Program and complete the first inspection prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.17 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 2 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 5.
Electrical Cables and Connections Used in Instrumentation Circuits Program Implement an Electrical Cables and Connections Used in Instrumentation Circuits Program and complete the first inspection prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.18 Prior to the period of extended operation
- 6.
Electrical Connections Program Implement an Electrical Connections Program and complete the one time inspection prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.19 Prior to the period of extended operation
- 7.
Electrical Penetration Assemblies Program Implement an Electrical Penetration Assemblies Program.
[Revised in DAEC letter NG-09-0764 in response to new Program Commitments RAI]
18.1.20 Prior to the period of extended operation
- 8.
External Surfaces Monitoring Program Revise the inspection program to address inspector qualifications, types of components, degradation mechanisms, aging effects, acceptance criteria, inspection frequency, and periodic reviews to determine program effectiveness. The 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]
18.1.21 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 3 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 9.
Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance procedure will be enhanced to include criteria for visual inspections of fire barrier wall, ceiling and floors to examine for any sign of degradation such as cracking, spalling and loss of 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]
18.1.22 Prior to the period of extended operation
- 10.
Fire Protection Program Enhance procedures to inspect the entire diesel driven fire pump fuel supply line for age related degradation.
18.1.22 Prior to the period of extended operation
- 11.
Fire Water System Program Implement maintenance activities to perform volumetric examinations for pipe wall thinning of fire protection piping periodically during the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.23 Prior to the period of extended operation
- 12.
Fire Water System Program Enhance procedures to include NFPA 25 criteria for sprinklers regarding replacing or testing 18.1.23 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 4 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 13.
Fire Water System Program Enhance procedures to perform visual inspection of fire hydrants annually 18.1.23 Prior to the period of extended operation
- 14.
Fuel Oil Chemistry Program Revise the program to require particulate testing of fuel oil samples from the diesel fire pump day tank 18.1.25 Prior to the period of extended operation
- 15.
Fuel Oil Chemistry Program Enhance procedures to require sampling and testing of new fuel oil delivered to the diesel fire pump day tank; and to require that purchase orders and sampling procedures for diesel fuel delivered to and stored in the diesel fire pump day tank prohibit the delivery and use of biodiesel fuel.
[Revised in letter NG-09-0764 in response to RAI B.3.25-1]
18.1.25 Prior to the period of extended operation
- 16.
Fuel Oil Chemistry Program Enhance procedures to perform periodic (10 year) draining, cleaning and visual inspection of the diesel fuel oil day tanks, diesel fire pump day tank, and diesel driven air start air compressor fuel oil tanks.
[Revised in letter NG-09-0764 in response to RAI B.3.25-4]
18.1.25 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 5 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 17.
Fuel Oil Chemistry Program Implement procedures to require bottom thickness testing of the Standby Diesel Generator Day Tanks and the Diesel Fire Pump Day Tank.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.25 Prior to the period of extended operation
- 18.
Fuse Holders Program Implement a Fuse Holders Program and complete the first test prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to RAI B.3.26-1 and New Program Commitments RAI]
18.1.26 Prior to the period of extended operation
- 19.
Inaccessible Medium Voltage Cable Program Implement an Inaccessible Medium Voltage Cable Program and complete the first inspection or test prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.27 Prior to the period of extended operation
- 20.
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Implement an Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.28 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 6 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 21.
Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program Enhance procedures to monitor for corrosion and wear of the supporting steel and rails 18.1.29 Prior to the period of extended operation
- 22.
Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program Enhance procedures to record usage of the reactor building and turbine building cranes 18.1.29 Prior to the period of extended operation
- 23.
Lubricating Oil Analysis Program Enhance procedures to include diesel fire pump 18.1.30 Prior to the period of extended operation
- 24.
Metal Enclosed Bus Program Implement a Metal Enclosed Bus Program and complete the first inspection prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.31 Prior to the extended operation
- 25.
One-Time Inspection Program Implement a One-Time Inspection Program and complete the one-time inspections prior to the period of extended operation.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.32 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 7 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 26.
Reactor Vessel Surveillance Program Implement a procedure to evaluate the BWRVIP ISP data as it becomes available.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.35 Prior to the period of extended operation
- 27.
Reactor Vessel Surveillance Program BWRVIP-74-A BWR PRV Inspection and Flaw Evaluation Guidelines for License Renewal Revise the Reactor Vessel Surveillance Program to implement the recommendations of BWRVIP-116 BWR Vessel and Internals Project Integrated Surveillance Program Implementation for License Renewal.
18.1.35 Prior to the period of extended operation
- 28.
Reactor Vessel Surveillance Program Implement BWRVIP-116 with the conditions documented in Sections 3 and 4 of the NRC Staffs SE dated March 1, 2006 for BWRVIP-116 18.1.35 Prior to the period of extended operation
- 29.
Selective Leaching of Materials Program Implement and complete a program to include one-time visual inspection and hardness measurement of selected components susceptible to selective leaching
[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]
18.1.36 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 8 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 30.
Structures Monitoring Program Enhance procedures to include structures and structural components not currently in Maintenance Rule Program 18.1.37 Prior to the period of extended operation
- 31.
Structures Monitoring Program Enhance procedures to include periodic sampling of groundwater for pH, chloride and sulfate concentration on a 5 year periodicity.
[Revised in letter NG-10-0043 in response to Follow-up RAI B.3.37-2]
18.1.37 Prior to the period of extended operation
- 32.
Structures Monitoring Program Enhance procedures to include a elastomer inspection to prevent leakage through containment penetration.
18.1.37 Prior to the period of extended operation
- 33.
Structures Monitoring Program Enhance procedures to include a requirement to contact the proper personnel to allow opportunistic inspection of the buried concrete foundation.
18.1.37 Prior to the period of extended operation
- 34.
Structures Monitoring Program Enhance procedures to include opportunistic inspections of the buried concrete foundation on a 10 year periodicity.
18.1.37 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 9 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 35.
Metal Fatigue of Reactor Vessel Coolant Pressure Boundary Program Enhance procedures to incorporate the requirements of NUREG/CR-6260 locations into the implementing procedures.
18.2.2 Prior to the period of extended operation
- 36.
Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Implement a Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
Program.
[Revised in DAEC letter NG-09-0764 in response to New Program Commitment RAI]
18.1.38 Prior to the period of extended operation
- 37.
Reactor Internals DAEC will ensure that aging of core plate hold down bolts is appropriately addressed by completing one of the following actions:
Install core plate wedges to eliminate the function of core 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]
18.1.14 18.3.1.7 Prior to entering the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 10 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 38.
Reactor Vessel Circumferential Weld TLAA Submit a relief request to address the frequency requirements of the inservice inspection of the RPV circumferential welds.
(BWRVIP-05).
18.3.1.4 Prior to the period of extended operation
- 39.
Quality Assurance Program (Corrective Action, Confirmation Process, Administrative Controls)
Expand the scope of its 10 CFR Part 50, Appendix B Quality Assurance program to include non-safety-related structures and components subject to an AMR for license renewal.
UFSAR 17.1.2 Prior to the period of extended operation
- 40.
Operating Experience Perform an operating experience review of extended power uprate and its impact on aging management programs for systems, structures, and components (SSCs) before entering the period of extended operation.
Prior to the period of extended operation
- 41.
Bolting Integrity Program Revise the implementing procedures for the ASME Section XI Inservice Inspection Subsections IWB, IWC, and IWD Program; ASME Section XI Inservice Inspection, Subsection IWF Program; External Surfaces Monitoring Program; Structural 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]
18.1.6 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 11 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 42.
BWR Penetrations Program The implementing document for the BWR Penetrations Program will be revised to specify that guidance in BWRVIP-14, -59 and -
60 will be used, as appropriate, depending on material, in the evaluation of crack growth in stainless steel, nickel alloys and 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]
18.1.10 Prior to the period of extended operation
- 43.
Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance procedure will be enhanced to ensure a approximately 10% of each type of penetration seal is included in the 35 percent selection of fire penetration seals that are visually inspected at an 18 month interval.
[Added in letter NG-09-0764 in response to RAI B.3.22-1]
18.1.22 Prior to the period of extended operation
- 44.
Fire Protection Program The DAEC Surveillance Procedure for the CO2 Cardox System Operability Annual Test will be enhanced to include a step to perform an inspection for corrosion and mechanical damage to system components.
[Added in letter NG-09-0764 in response to RAI B.3.22-1]
18.1.22 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 12 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 45.
ASME Class 1 Small-bore Piping Inspection Program Implement an ASME Code Class 1 Small-bore Piping Inspection Program.
The ASME Code Class 1 Small-bore Piping inspection program 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]
18.1.40 Prior to the period of extended operation
- 46.
BWR Vessel Internals Program The BWR Vessel Internals Program will incorporate the crack growth rate evaluations specified in the BWRVIP-100-A report.
Plant-specific inspection intervals will be developed for DAEC core shroud welds that are exposed to a neutron fluence value 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]
18.1.14 Prior to the period of extended operation
- 47.
Not Used
[Withdrawn in letter NG-10-0091]
- 48.
Boral Surveillance Program Implement a Boral Surveillance Program and complete the first in-situ neutron attenuation test of the PaR spent fuel racks.
[Added in letter NG-10-0009]
18.1.41 Prior to the period of extended operation to NG-10-0258 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments Page 13 of 13 TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item No.
System, Component or Program Commitment2 Section Schedule
- 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 board wall that separates the control room computer room area from the front panel area for aging due to cracking.
[Added in letter NG-10-0043]
18.1.22 Prior to the period of extended operation
- 50.
ASME Section XI, Inservice Inspection, Subsection IWE Program Perform recoating of suppression pool interior surfaces below the water line.
[Added in letter NG-10-0091]
18.1.4 Complete recoating prior to startup from the first refuel outage during the period of extended operation
- 51.
Metal Fatigue of Reactor Vessel Coolant Pressure Boundary Program Future revisions/updates to the environmental fatigue calculations for the Recirculation Inlet Nozzle Safe End, 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.
[Added in letter NG-10-0258]
18.2.2 Upon calculation revision.
1Table is updated to reflect DAEC correspondence through 4/28/2010.
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.