ML093630034

Request for Additional Information for the Review of the Duane Arnold Energy Center License Renewal Application - Batch 3

ML093630034
Person / Time
Site:	Duane Arnold
Issue date:	01/06/2010
From:	Harris B License Renewal Projects Branch 1
To:	Costanzo C NextEra Energy Duane Arnold
Harris B, NRR/DLR, 415-2277
References
TAC MD9769
Download: ML093630034 (11)

Text

January 6, 2010 Mr. Christopher Costanzo Vice President, Nuclear Plant Support NextEra Energy Duane Arnold, LLC P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION -BATCH 3 (TAC NO. MD9769)

Dear Mr. Costanzo:

By letter dated September 30, 2008, as supplemented by letter dated January 23, 2009, FPL Energy Duane Arnold, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center. The staff of the U.S. Nuclear Regulatory Commission (the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review from August 10, 2009, through August 14, 2009, the staff has identified areas where additional information is needed to complete the review. The staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Ken Putnam, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-2277 or by e-mail at Brian.Harris2@nrc.gov.

Sincerely, /RA/ Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

As stated cc w/encl: See next page January 6, 2010 Mr. Christopher Costanzo Vice President, Nuclear Plant Support NextEra Energy Duane Arnold, LLC P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION -BATCH 3 (TAC NO. MD9769)

Dear Mr. Costanzo:

By letter dated September 30, 2008, as supplemented by letter dated January 23, 2009, FPL Energy Duane Arnold, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center. The staff of the U.S. Nuclear Regulatory Commission (the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review from August 10, 2009, through August 14, 2009, the staff has identified areas where additional information is needed to complete the review. The staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Ken Putnam, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-2277 or by e-mail at Brian.Harris2@nrc.gov. Sincerely, /RA/ Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-331

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION

See next page ADAMS Accession No.: OFFICE: PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR NAME: BHarris SFigueroa BPham BHarris (Signature) (BPham for) DATE: 12/29/09 12/29/09 1/5/10 1/6/10 OFFICIAL AGENCY RECORD Letter to Christopher Costanzo from Brian K. Harris dated January 6, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION - BATCH 3 (TAC NO. MD9769)

DISTRIBUTION

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B. Harris C. Eccelston K. Feintuch M. Spencer, OGC Duane Arnold Energy Center cc: Mr. M. S. Ross Vice President and Associate General Counsel Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Ms. Marjan Mashhadi Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW Suite 220 Washington, DC 20004

Mr. Steven R. Catron Manager, Regulatory Affairs Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324

U.S. Nuclear Regulatory Commission Resident Inspector

=s Office Rural Route #1 Palo, IA 52324 Mr. Mano Nazir Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Mr. D. A. Curtland Plant Manager Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785

Abdy Khanpour Vice President, Engineering Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Ms. Melanie Rasmussen Radiation Control Program Director Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319-0075

Chairman, Linn County Board of Supervisors 930 1st Street SW Cedar Rapids, IA 52404 Mr. Raj Kundalkar, Vice President Fleet Organizational Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. McHenry Cornell Director, Licensing and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 ENCLOSURE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION

RAI B.3.4-6

Background

The U. S. Nuclear Regulatory Commission has previously issued Information Notices (IN) 2006-01 and IN 92-20 concerning problems associated with the Boiling Water Reactor (BWR)

Mark I torus.

IN 2006-01 was issued to inform the owners of BWR Mark I containments about the occurrence and potential causes of the through-wall cracking of a torus in a BWR Mark I containment. Recipients were expected to review the information for applicability to their facilities and consider appropriate actions to avoid similar problems.

IN 92-20 was issued to inform the holders of operating licenses for nuclear plants about problems involving local leak rate testing (LLRT) of containment penetrations under Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50), Appendix J. One of the reasons for failures of LLRT of containment penetrations identified was the leakage thru the containment penetration bellows.

Issue: It is not clear from the review of Duane Arnold Energy Center (DAEC) license renewal application (LRA) if the applicant has reviewed and addressed the issues identified in IN 2006-01 and IN 92-20.

Request: Provide operating experience and explain what actions were taken at DAEC to address issues identified in IN 2006-01 and IN 92-01. The staff needs the above information to confirm that the effects of aging of the DAEC torus and containment penetration bellows will be adequately managed so that that it's intended function will be maintained consistent with the current licensing basis for the period of extended operation as required by 10 CFR 54.21(a)(3).

RAI B.3.28 (Revised November 18, 2009)

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Background===

The LRA Section AMP (Aging Management Program ) B.3.28, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program," commits to consistency with the Generic Aging Lessons Learend (GALL) Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," with no exceptions or enhancements. GALL Report AMP XI.M38 is applicable to steel (carbon steel) components, in an internal environment such as indoor controlled air, condensation, and steam, to detect material degradation, evidence of corrosion to indicate possible loss of material with the use of visual inspections.

Issue: The applicant's LRA program basis documents and aging management review (AMR) line items stated that the LRA AMP B.3.28 is relied upon to manage the aging effect of loss of materials in materials beyond the scope of the GALL Report AMP XI.M38, including stainless steel, cast austenitic stainless steel, galvanized steel, bronze, brass, admiralty brass, copper and copper alloy, aluminum alloy, and nickel in a variety of environments, in particular, diesel exhaust. The DAEC LRA has also expanded the scope of aging effects managed by this AMP to include cracking in stainless steel components and heat transfer degradation. The proposed expansion of AMP B.2.28 is beyond the scope of GALL Report AMP XI.M38, which was meant for steel components and loss of material in an internal environment such as indoor controlled air, condensation, and steam. The staff is not convinced that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program using visual inspection per B.3.28 provides adequate aging management for these aging effects on these materials and environments.

Request:

• Provide justification that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is adequate for managing the aging effects of cracking in stainless steel, heat transfer degradation, and loss of material in the stainless steel, cast austenitic stainless steel, galvanized steel, bronze, brass, admiralty brass, copper and copper alloy, aluminum alloy, and nickel components in the environments including diesel exhaust as stated in the DAEC LRA.

• Identify and justify the inspection techniques used by this program that will be capable of detecting cracking for stainless steel components and heat transfer degradation added to the scope of this program or please provide an appropriate program to manage these aging effects for the applicable components.

Follow-up RAI B.3.37-2

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Background===

In letter NG-09-0764, dated October 13, 2009, the applicant responded to RAI B.3.37-2 related to the inspection interval of groundwater sampling conducted under the Structures Monitoring Program. The applicant explained that river and groundwater chemistry has been stable for many years and sampling results do not indicate an aggressive environment that might warrant more frequent monitoring.

Issue: The staff does not agree that historical values can be reliable indicators for future conditions, as chemistry conditions in the groundwater can change due to a various number of causes that are beyond the applicant's control or that cannot be readily verified. In addition, the proposed sampling interval of 10 years (over a 20-year period of extended operation) would only provide 2 data points--not enough to establish a trend. Most applicants are monitoring the groundwater chemistry at an interval between three months and five years.

Request:

Please supplement the application to propose a sampling frequency within a five-year interval, or provide rationale for how the applicant intends to ensure that groundwater chemistry will not change during the period of extended operation.

RAI 3.3.2.2.3.1.-1

Background

LRA and Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Table 3.3.1, Item 4 addresses cracking due to stress corrosion cracking (SCC) of stainless steel piping, piping components and piping elements of the BWR standby liquid control system exposed to sodium pentaborate solution greater than 60 oC. These items recommend further evaluation on the part of the staff and refer to LRA and SRP Sections 3.3.2.2.3.1. The applicant proposes to manage this aging process through the use of its AMPs "Water Chemistry" (LRA B.3.39) and American Society of Mechanical Engineers (ASME)Section XI, Subsections IWB, IWC, IWD In-service Inspection (LRA B.3.3). The GALL Report recommends that this aging process be managed through the use of "Water Chemistry" (GALL Vol. 2 XI.M2) and "One Time Inspection" (GALL Vol. 2 XI.M32) AMPs.

Issue:

The staff reviewed LRA Table 3.3.1, Item 4 in accordance with SRP-LR Section 3.3.2.2.3.1. In this review, the staff noted that both the LRA and the GALL Report propose using Water Chemistry AMPs. The staff also noted that the LRA proposes using the ASME in-service inspection program while the GALL Report recommends using one time inspection. The staff considers the in-service inspection program to be both more rigorous and more frequent than the one time inspection program and, therefore, has no objection to this substitution. However, in the conduct of its review, the staff was not able to find LRA Table 2 line items associated with Table 3.3.1, Item 4. Additionally the staff conducted a search of the LRA for "sodium pentaborate solution." This search identified several instances in the LRA where sodium pentaborate solution appeared but none were associated with cracking of stainless steel at temperatures above 60 oC. The lack of Table 2 items associated with Table 3.3.1, Item 4 could be interpreted to mean that this item is not applicable. Alternatively it could indicate items missing from the LRA.

Request: Please explain the apparent lack of Table 2 items associated with Table 3.3.1, Item 4 and provide any missing information.

RAI BF101-1

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Background===

The GALL Report, Table 5, indicates that stainless steel penetration sleeves, penetration bellows, dissimilar metal welds, and vent line bellows exposed to uncontrolled air may undergo SCC. Issue: The DAEC LRA Supplement 1, Section 3.5.2.2.1.7, indicates that stainless steel penetration sleeves, penetration bellows, dissimilar metal welds, and vent line bellows can potentially undergo SCC. However, the same section also indicates that aging management is not needed for SCC for the air/gas environment because the environment is not aggressive and the material temperature is below 60°C [140 °F]. Because these statements are conflicting, it is not clear to the staff whether the applicant will manage the aging effect of SCC for stainless steel components described in Section 3.5.2.2.1.7.

Request: Provide additional information that indicates whether the applicant will be using an aging management program to manage SCC of the above stainless steel components exposed to uncontrolled air as described in Section 3.5.2.2.1.7. If these materials will not be managed under an aging management program, provide additional information on how these materials may be protected from corrosive environments contacting their surface.

RAI BF76-1

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Background===

In LRA Supplement 1, Section 3.3.2.2.11, pp. 3.3-42 and 3.3-43, the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is credited to manage loss of material due to pitting, crevice, and galvanic corrosion for copper alloy piping, piping components, and piping elements exposed to a treated water environment.

Issue: SRP-LR Section 3.3.2.2.11 states that loss of material due to pitting, crevice, and galvanic corrosion could occur for copper alloy piping, piping components, and piping elements exposed to treated water. The GALL Report recommends managing the aging effect using the Water Chemistry Program augmented by the One-Time Inspection Program to verify the effectiveness of the chemistry control program.

Request: Provide justification for the effectiveness of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program in managing the aging effect of loss of material in the identified copper alloy components exposed to a treated water environment.

RAI BF76-2

Background

In LRA Supplement 1, Section 3.4.2.2.7.1, pages 3.4-9 and 3.4-10, the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is credited to manage loss of material due to crevice and pitting corrosion for stainless steel and copper alloy components exposed to treated water or steam.

Issue: SRP-LR Section 3.4.2.2.7.1 states that loss of material due to pitting and crevice corrosion could occur for stainless steel, aluminum, and copper alloy piping, piping components and piping elements; and stainless steel tanks and heat exchanger components exposed to treated water. The GALL Report recommends the use of the Water Chemistry Program augmented by the One-Time Inspection Program to manage the aging effect.

Request:

Provide justification for the effectiveness of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program in managing the aging effect of loss of material due to crevice and pitting corrosion in the identified stainless steel and copper alloy components exposed to treated water or steam.

RAI BF76-3

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Background===

In LRA Supplement 1, Table 3.2.2-4, pages 3.2-47, for heat exchanger, condenser, cooler, and fan coil made of brass or bronze in a lubricating oil environment, no aging effects requiring management are identified. The LRA uses Note I, along with a plant-specific note that states "the component does not have the potential for water contamination."

Issue: The GALL Report recommends the use of the Lubricating Oil Analysis Program augmented by the One-Time Inspection Program to manage the aging effect of loss of material due to pitting and crevice corrosion of copper alloy piping, piping components, and piping elements exposed to lubricating oil (e.g., GALL Item V.D2-22). Loss of material due to pitting and crevice corrosion in a lubricating oil environment is not addressed.

Request: Provide additional information that demonstrates brass or bronze is not subject to pitting and crevice corrosion in a lubricating oil environment.

RAI BF76-4

Background

In LRA Supplement 1, Tables 3.3.2-1, 3.3.2-6, 3.3.2-18, 3.3.2-23, 3.3.2.-28, and 3.3.2-32, the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is credited to manage loss of material for many carbon steel components exposed to a treated water environment. The LRA uses Note E, which indicates that the AMR results are consistent with the GALL Report for material, environment, and aging effect, but a different Aging Management Program (AMP) is credited.

Issue:

The GALL Report recommends the use of the Water Chemistry Program augmented by the One-Time Inspection Program to manage the aging effect of loss of material due to various corrosion mechanisms for steel components in treated water (e.g., GALL Items VII.E3-18 and VIII.E-40). The One-Time Inspection Program provides measures to verify the effectiveness of the Water Chemistry Program. It is not clear to the staff how the applicant's Internal Surfaces in Miscellaneous Piping and Ducting Components Program is consistent with the GALL Report and how the credited AMP provides adequate aging management for this aging effect in these components.

Request: Provide justification for the effectiveness of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program in managing the aging effect of loss of material in the identified steel components exposed to a treated water environment.

RAI BF76-5

Background

In LRA Supplement 1, Tables 3.3.2-9, 3.3.2-13, and 3.3.2-21, for pipe, pipe fitting, hoses, tubes, and rupture disk made of poly vinyl chloride (PVC) exposed to a raw water or air-indoor uncontrolled environment, no aging effects requiring management are identified. The LRA uses Note J, along with a plant-specific note that states "non-metallic (fiberglass, PVC, CPVC [Chlorinated Poly vinyl chloride]) in this environment was evaluated and contained no aging effects."

Issue: The GALL Report indicates that aging effects of embrittlement, cracking, melting, discoloration, or swelling could occur in polymer and plastic electrical components (e.g., GALL Items VI.A-6 and VI.A-14). The LRA does not provide sufficient information to ensure that degradation of PVC plastic will not occur in a raw water or air-indoor uncontrolled environment.

Request: Provide information that demonstrates PVC/plastic is not subject to degradation resulting from various aging mechanisms identified in the GALL Report in a raw water or air-indoor uncontrolled environment.

RAI BF76-6

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Background===

In LRA Supplement 1, Table 3.3.2-27, pages 3.3-218 and 3.3-221, for filter, screens, strainer, valve, and damper made of zinc exposed to an air-indoor uncontrolled or dried air environment, no aging effects requiring management are identified. The LRA uses Note F, along with a plant-specific note that states "Material/environment combination and/or aging effect/mechanism not identified in NUREG-1801. The aging management program(s) referenced are appropriate for the aging effects/mechanisms identified and provide assurance that the aging effects/mechanisms are effectively managed through the period of extended operation."

Issue: The GALL Report recommends no aging effects requiring management for galvanized steel piping, piping components, and piping elements in an air-indoor uncontrolled environment (GALL Item VII.J-6) and for steel piping, piping components, and piping elements in dried air (GALL Item VII.J-22). A Justification was not provided for how these GALL items are applicable to the AMR items referenced above.

Request: Provide justification to explain how aging management of the galvanized steel and steel components in GALL Items VII.J-6 and VII.J-22 is applicable to the material/environment combinations identified above.

RAI BF75-1

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Background===

In LRA Supplement 1, Table 3.3.2-27, pages 3.3-218 and 3.3-221, for filter, screens, strainer, valve, and damper made of zinc exposed to an air-indoor uncontrolled or dried air environment, no aging effects requiring management are identified. The LRA uses Note F, along with a plant-specific note that states "Material/environment combination and/or aging effect/mechanism not identified in NUREG-1801. The aging management program(s) referenced are appropriate for the aging effects/mechanisms identified and provide assurance that the aging effects/mechanisms are effectively managed through the period of extended operation."

Issue: The GALL Report recommends no aging effects requiring management for galvanized steel piping, piping components, and piping elements in an air-indoor uncontrolled environment (GALL item VII.J-6) and for steel piping, piping components, and piping elements in dried air (GALL item VII.J-22). A Justification was not provided for how these GALL items are applicable to the AMR items referenced above. Request:

Provide justification to explain how aging management of the galvanized steel and steel components in GALL Items VII.J-6 and VII.J-22 is applicable to the material/environment combinations identified above.

RAI BF75-2

Background

The GALL Report, Table 2, Item 9, indicates that boiling water reactor/pressurized water reactor copper alloy heat exchanger tubes exposed to lubricating oil are subject to reduction of heat transfer due to fouling as an aging effect/mechanism. The GALL Report states that the aging effect/mechanism can be managed by the Lubricating Oil Analysis and One-Time Inspection Programs. The GALL Report, Table 3, Item 26, indicates that copper alloy components exposed to lubricating oil can result in loss of material due to pitting and crevice corrosion. The GALL Report indicates that this aging effect/mechanism can be managed by the Lubricating Oil Analysis and One-Time Inspection Programs.

Issue: The DAEC LRA, Supplement 1, Table 3.3.2-29, page 3.3-232, indicates that when brass heat exchangers, condensers, coolers, and fan coil components are exposed to external lubricating oil, both loss of material and heat transfer degradation will occur. Aging management programs include the Lubricating Oil Analysis, One-Time Inspection, and Selective Leaching of Materials Programs. However, neither the DAEC LRA, Supplement 1, Table 3.3.2-29, nor the DAEC LRA, Table 3.3.2-22, indicates any aging effects of copper alloy exposed to internal lubricating oil. The staff is unclear why the applicant does not include aging effect requiring management for internal lubricating oil environment.

Request: Provide additional information justifying why copper alloys exposed to internal lubricating oil do not have any aging degradation effect that requires an aging management program.