NG-12-0489, Response to NRC Requests for Additional Information Regarding the Fourth 10-Year Inservice Inspection Plan

Response to NRC Requests for Additional Information Regarding the Fourth 10-Year Inservice Inspection Plan

ML12356A185
Person / Time
Site:	Duane Arnold
Issue date:	12/21/2012
From:	Richard Anderson NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-12-0489
Download: ML12356A185 (6)

Text

NEXTera M ENERGY~

~ DUANE

/ ARNOLD December 21,2012 NG-12-0489 10 CFR 50.55a u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No: 50-331 Renewed Op. License No: DPR-49 NextEra Energy Duane Arnold, LLC's Response to NRC Requests for Additional Information Regarding the Fourth 10-Year Inservice Inspection Plan for the Duane Arnold Energy Center

References:

1) Letter, Peter Wells (NextEra Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "Fourth 10-Year Inservice Inspection Plan,"

dated August 31,2011, NG-11-0320 (ML11245A240)

2) Electronic Mail, Karl Feintuch (USNRC) to Tony Browning (NextEra Energy Duane Arnold), "ME7246 - DAEC - Fourth 1O-year Inservice Inspection Plan (Ur NG-11-0320) - Request for Additional Information," dated November 12, 2012 (ML12339A042)

In the Reference 1 letter, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) requested that the expiration date for selected relief requests, previously approved pursuant to 10 CFR 50.55a and contained in the Fourth 10-Year Inservice Inspection (lSI) Plan for the Duane Arnold Energy Center (DAEC), be extended to coincide with the actual end date of the fourth 1O-year interval. The current expiration date for these relief requests is February 28,2014, the end date of the original DAEC Operating License. As a result of the Commission's granting a renewal of the Operating License for the DAEC (ML102930524), these relief requests will prematurely expire prior to reaching the true end of the Fourth 10-Year lSI interval, October 31, 2016. Hence, the Reference 1 request for extension.

During the review of the Reference 1 request, the Staff has determined that additional information is required to support this licensing action. Reference 2 transmitted those requests for additional information (RAls).

The Enclosure to this letter contains the NextEra Energy Duane Arnold responses to the Staff's RAls.

This letter makes no new commitments or changes to any existing commitments.

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

Document Control Desk NG-12-0489 Page 2 of 2 If you have any questions or require additional information, please contact Tom Byrne, Manager, Nuclear Licensing (acting) at (319) 851-7929.

Sincerely, rc~ Ocf Richard L.

J Ander~

Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure

Enclosure to NG-12-0489 Page 1 of 4 REQUEST FOR ADDITIONAL INFORMATION NEXTERA ENERGY DUANE ARNOLD ENERGY CENTER FOURTH 10-YEAR INSERVICE INSPECTION PLAN (ME7246)

DOCKET NUMBER 50-331 By letter dated August 31, 2011, (Agencywide Document Access and Management System (ADAMS) accession number ML11245A240) NextEra Energy Duane Arnold LLC (NextEra, the licensee) submitted a set of 15 Relief Requests (RRs) NDE-R001 through NDE-R015, less NDE-R004, among which several actions were requested individually or in combination including: (1) extension of the expiration date of the RR from that of the expiration of the original facility operating license (February 21, 2014) to the planned end of the fourth inservice inspection (ISI) interval (October 31, 2016); (2) request for approval of newly submitted RRs; (3) requests to confirm the approval status of RR submitted earlier; or (4) some combination of (1), (2) and (3)

NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review of the RR.

Please contact Karl Feintuch (301-415-3079) by 11/14/2012 to confirm: (1) that the items are clear to you and to the responsive NextEra staff without further discussion or (2) that a clarifying conference call is needed. Upon determination that the RAI items are clear and confirmation of when responses to these items are due, these draft RAI items will be considered to be in final form.

The RAI items are assigned the following tracking numbers.

A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 B. ME7246-RAII-DORL-Feintuch-002-2012-11-12 C. ME7246-RAII-DORL-Feintuch-003-2012-11-12 A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 (1) Individually affirm all RRs, among NDE-R001 to NDE-R015, that are to be extended in effect until October 31, 2016. You may do this in the form of a Table similar to that on Section H, page 1 of 100, with the addition of column(s) in which you address each relief request.

(2) Affirm that a time extension was not requested for NDE-R004 and for NDE-R015.

NextEra Energy Duane Arnold Response:

1) The following table summarizes the current status of Relief Requests for the Fourth 10-Year Interval of the Inservice Inspection Plan for the Duane Arnold Energy Center (DAEC).

Enclosure to NG-12-0489 Page 2 of 4 Relief Title NRC Safety Summary of Current Status Request # Evaluation This relief request will remain in Use of the DAEC Technical ML070090357 effect through the end of the 4th NDE-R001 Requirements Manual for Snubber 1/31/07 10 year interval (October 31, Visual Examination & Testing 2016).

This relief request will remain in Approved use of PDI for Overlays in ML070090357 effect through the end of the 4th NDE-R002 lieu of Supplement 11 to Appendix 1/31/07 10 year interval (October 31, VIII 2016).

This relief request will remain in Requested to use BWRVIP-05 ML043270051 effect through the end of the 4th NDE-R003 recommendations for reduced 1/6/2005 10 year interval (October 31, circumferential vessel weld exams 2016).

Request use of ASME Code Case N-This relief request is no longer 700 in lieu of the requirements ML071380183 required as Code Case N-700 NDE-R004 specified in the ASME Code, Section 6/12/07 has been incorporated into RG XI for Class 1, 2,and 3 vessel welded 1.147 attachments.

This relief request will remain in Risk Informed ISI for Class 1 B-F & B- ML070090357 effect through the end of the 4th NDE-R005 J Welds and Class 2 C-F-2 Welds 1/31/07 10 year interval (October 31, 2016).

This relief request will remain in Request use of Code Case N-686 ML070090357 effect through the end of the 4th NDE-R006 Alternate Requirements for Visual 1/31/07 10 year interval (October 31, Examinations 2016).

This relief request will remain in Alternative for pressure testing and ML071380183 effect through the end of the 4th NDE-R007 visual examination of buried piping 6/12/07 10 year interval (October 31, and components 2016).

Request approval to use Appendix VIII examination for the Fourth 10- This relief request will remain in Year Interval reactor vessel-to-flange ML070090357 effect through the end of the 4th NDE-R008 weld and head-to-flange weld in lieu 1/31/07 10 year interval (October 31, of existing requirements to use 2016).

Section V This relief request was Request to allow use of the withdrawn from consideration Provisions of IWA-4132 for stock NDE-R009 N/A on 3/20/07 (ML070890363) rotation of Recirculation Pump Seal since it was determined not to Flange Assemblies be needed.

This relief request will remain in Limited Examination on Welds HCC- ML101680600 effect through the end of the 4th NDE-R010 C001, CUA-J024, RMA-J004 7/6/2010 10 year interval (October 31, 2016).

This relief request was for the installation of weld overlays on RRC-F002 and RRF-F002 Request to use Code Cases N-504-2 ML071110007 welds. The weld overlays were NDE-R011 and N-638-1 for Weld Overlay 6/12/07 installed in 2007 and no work is Repairs ongoing that requires additional relief for these welds. No extension of relief is requested.

Enclosure to NG-12-0489 Page 3 of 4 Relief Title NRC Safety Summary of Current Status Request # Evaluation ML081680709 This relief request will remain in Request to allow use of Post 7/2/08 effect through the end of the 4th NDE-R012 Qualifying Seal Weld Procedures for ML082040206 10 year interval (October 31, Target Rock Valves 8/4/08 2016).

This relief request will remain in Request to use Code Case N-702 for ML082040046 effect through the end of the 4th NDE-R013 Nozzle-to-Vessel Welds and Inner 8/29/08 10 year interval (October 31, Radius Sections 2016).

This relief request was for the installation of a weld overlay on Relief Request for Alternative to RRA-F002A and RRA-J003 ASME Section XI Requirements to ML11235A935 welds. The weld overlay was NDE-R014 Use Structural Weld Overlay Repairs 9/6/11 installed in 2010 and no work is as an Alternative Repair Technique ongoing that requires additional relief for these welds. No extension of relief is requested.

This relief request was a one-Request for Authorization of ML11237A105 time-only alternative for PSV NDE-R015 Alternative Regarding Pressure Test 9/6/11 4402 during RFO 22 (2010). No Requirements extension of relief is requested.

2) As noted in the Table above, an extension is not required for either NDE-R004 or NDE-R015.

B. ME7246-RAII-DORL-Feintuch-002-2012-11-12 NRC staff noted within* your letter dated August 31, 2011, where it appears that the Inservice Inspection Plan ceases to be in effect after February 21, 2014, whereas the relief authorized by NRC staff (approved on 1/31/2007 for NRE-R001, for example) contains no limitation other than being in effect for the entire ten-year interval ending on October 31, 2016.

Please affirm that:

(1) the Inservice Inspection Plan is technically valid for the entire ten-year interval ending on October 31, 2016; (2) all references to the effective dates of the Inservice Inspection Plan have been or will be amended to show that the plan remains in effect until October 31, 2016; and (3) any reference to ending the effectiveness of the Inservice Inspection Plan on February 21, 2014, is attributable to the expiration of the original facility operating license on February 21, 2014, and not a technical limit on the validity of the plan.

• See for example, on Section A, page 1 of 14, Subsection 1.0 (2) first sentence where you state that:

This Inservice Inspection Plan will be effective from November 1, 2006 through and including February 21, 2014, which represents the fourth ten-

Enclosure to NG-12-0489 Page 4 of 4 year interval of the Inservice Inspection Program for DAEC. The interval ends on February 21, 2014 to coincide with the end of the current [original facility operating] license, thus making the interval duration of approximately 99 months as opposed to the standard 120 months.

NextEra Energy Duane Arnold Response:

The Fourth 10-Year ISI Interval for the DAEC was originally scheduled to end on February 21, 2014 to coincide with the expiration of the original Operating License (OL), which resulted in a foreshortened duration of 99 months (approx 8 years) for the Fourth ISI Interval. Subsequently, NextEra Energy Duane Arnold has been granted a License Renewal, with the new OL to expire in 2034.

Consequently, the Fourth 10-Year ISI Interval has been adjusted for a true 10 year interval that will now expire on October 31, 2016.

1) The ISI Plan is technically valid for the entire ten year interval ending on October 31, 2016.

2) All references to the effective dates in the DAEC ISI Plan document, and key implementing/supporting documents, will be amended to show that the Plan remains in effect until October 31, 2016.

3) Any reference to the Plan ending on February 21, 2014 is attributable to the original OL expiration date and is not a technical limit on the validity of the Plan.

C. ME7246-RAII-DORL-Feintuch-003-2012-11-12 NDE-R011 requested relief from the ASME Section XI repair requirements for weld overlay repairs for components RRC-F002 and RRF-F002 using Code Cases N-504-2 and N-638-1 as alternatives. This relief was granted for refueling outage RFO-20 in a SE by NRC staff dated June 12, 2007 (ADAMS Accession No. ML071110007) under TAC number MD4466.

Clarify if a time extension is needed for relief request NDE-R011. If a time extension is needed, explain why the time extension is needed given that the weld overlay repairs for components RRC-F002 and RRF-F002 have been completed and the original SE was granted for RFO-20 only.

NextEra Energy Duane Arnold Response:

As noted in the Table for the response to RAI A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 above, no extension is requested for NDE-R011.