NG-09-0646, Response to Request for Additional Information Regarding Section 2.3.3.11 of the Duane Arnold Energy Center License Renewal Application

Response to Request for Additional Information Regarding Section 2.3.3.11 of the Duane Arnold Energy Center License Renewal Application

ML092510455
Person / Time
Site:	Duane Arnold
Issue date:	09/03/2009
From:	Costanzo C NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-09-0646, TAC MD9769
Download: ML092510455 (10)

Text

NExTera ENEROY DUANE ARNOLD September 3, 2009 NG-09-0646 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 Response to Request for Additional Information Regarding Section 2.3.3.11 of the Duane Arnold Enerqv 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), "License Renewal Application, Supplement 1: Changes Resulting from Issues Raised in the Review Status of the License Renewal Application for the Duane Arnold Energy Center," dated January 23, 2009, NG-09-0059 (ML090280418)

3. Letter, Maurice L. Heath (USNRC) to Richard L. Anderson (FPL Energy Duane Arnold, LLC), "Request for Additional Information for the Review of the Duane Arnold Energy Center License Renewal Application

-Section 2.3.3.11 (TAC No. MD9769)," dated August 7, 2009 (ML092150209)

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

By Reference 3, the U.S. Nuclear Regulatory Commission (NRC) Staff requested additional information regarding Section 2.3 of the LRA.The enclosure to this letter contains the NextEra Energy Duane Arnold, LLC, (f/k/a FPL Energy Duane Arnold, LLC) responses to the Staff's request for additional information.

This letter contains no new commitments or changes to existing commitments.

If you have any questions or require additional information, please contact Mr. Kenneth Putnam at (319) 851-7238.NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

'174 Document Control Desk NG-09-0646 Page 2 I declare under penalty of perjury that the foregoing is true and correct.Executed on September 3, 2009.Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosure:

DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 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)NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 RAI 2.3.3.11-1 The following license renewal application (LRA) drawings show fire protection system components as out of scope (i.e., not colored in red): " BECH-M133 (3)-LR, "Fire Protection Hose Stations":

Valve V33-0337 at location 2C* BECH-M133 (5)-LR, "Fire Protection Sprinkler Systems":

Valve V33-0769 and the floor drain of sprinkler system No. 6 in the radioactive waste boiler area at location D4 The staff requests that the applicant verify whether the components listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an aging management review (AMR) in accordance with 10 CFR 54.21(a)(1).

If these components are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DAEC Response to RAI 2.3.3.11-1 Valve V33-0337 provides isolation for the East Warehouse sprinkler system and hose station. The East Warehouse is located remotely from plant buildings housing safety related equipment and does not present a fire hazard to safety related equipment.

Therefore it is not in the scope of license renewal. The branch connection to the main fire loop that supplies the East Warehouse sprinkler and hose stations has an upstream isolation valve V33-0238 located on drawing BECH-M133<1>-LR (E-5) that is subject to aging management review. Valve V33-0238 provides the capability to isolate the East Warehouse fire protection components from the portions of the fire protection system that are in scope and subject to aging management review. Therefore, valve V33-0337 is not in the scope of license renewal and is not subject to an AMR.Drain isolation V33-0769 and the floor drain for Sprinkler No. 6 protecting the radwaste boiler area do not support the fire protection function of Sprinkler No. 6. While these lines could contain water that could spray or leak, this sprinkler is located in an area that does not contain any safety related equipment.

Therefore, valve V33-0769 and the drain piping are not in the scope of license renewal and are not subject to an AMR.RAI 2.3.3.11-2 Section 4.3.1.e, "Automatic Water Fire Suppression Systems," of the safety evaluation report, dated June 1, 1978, states that "a total of seven sprinkler systems have been provided to cover specific and area hazards." These areas of coverage include portions of the turbine building, shop area, radwaste, and reactor building.The seven sprinkler systems have not been identified in detail in LRA Section 2.3.3.11,"Fire Protection." The staff requests that the applicant identify the locations of these Page 1 of 8 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 seven sprinkler systems on the drawings and verify whether these sprinkler systems installed in the above areas of the plant are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1).

If any system is excluded from the scope of license renewal and is not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

DAEC Response to RAI 2.3.3.11-2 The seven sprinkler systems that were installed at the time of the safety evaluation report, dated June 1, 1978, are provided in the following table. All of these sprinkler systems have been highlighted on license renewal drawing BECH-M133<5>-LR, indicating they are in the scope of license renewal and are subject to an AMR. The principal components are addressed in LRA Table 2.3.3-11 as component types Piping and Valve body.Sprinkler Plant Location Plant Equipment BECH-M133<5>

System Protected -LR Coordinate Sprinkler Turbine Building Turbine Clean & Dirty F-1 System 1 Lube Oil Tanks Sprinkler Turbine Building Diesel Generator Day F-5 System 2 Tank 1T-37B Sprinkler Turbine Building Diesel Generator Day System 3 Tank 1T-37A F-3 Sprinkler Turbine Building Area Under the Turbine D-1 System 4 Building Operating Floor Sprinkler Turbine Building Plant Heating Boiler Room D-2 System 5 Sprinkler Radwaste Radwaste Baler Area D-4 System 6 Building Sprinkler Pump House Diesel Fire Pump Day D-5 System 7 Tank Room RAI 2.3.3.11-3 Table 3.13-2, "Required Fire Hose Stations," of the Duane Arnold Energy Center (DAEC) safety evaluation report, dated June 1, 1978, lists the following 11 required hose stations:

Hose Stations # 7, 21, 22, 23, 24, 25, 26, 27, 28, 29, and 35. LRA drawing BECH-M133 (3)-LR highlighted only fire hose station # 7. The staff requests that the applicant indicate on which LRA drawing(s) of the control building and reactor building the remaining 10 fire hose stations are located.Page 2 of 8 "117 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 DAEC Response to RAI 2.3.3.11-3 The remaining 10 fire hose stations are also located on LRA drawing BECH-M133<3>-

LR and are highlighted to indicate they are subject to AMR. The stations are downstream of the following hose station isolation valves at the indicated drawing coordinates:

Hose Station BECH-M133<3>-LR Number Coordinate 21 V33-0474 B-5 22 V33-0506 C-5 23 V33-0507 B-5 24 V33-0494 F-5 25 V33-0469 B-6 26 V33-0496 B-6 27 V33-0495 C-6 28 V33-0515 C-6 29 V33-0465 0-6 35 V33-0484 F-5 RAI 2.3.3.11-4 Section 3.2.4, "Control Room Fire Hazards," of the DAEC safety evaluation report supplement, dated February 10, 1981, states that "...Other proposed modifications for the control room area include: upgrading the glass partition wall between the computer room and the control room to minimum one-hour fire-rated design..." The glass partition in Section 2.3.3.11 of the LRA or in the LRA drawings is apparently not within the scope of the license renewal and not subject to an AMR. The staff requests that the applicant verify whether the upgraded glass partition wall between the computer room and the control room is within the scope of license renewal in accordance with 10 CFR 54.4(a) and whether it is subject to an AMR in accordance with 10 CFR 54.21(a)(1).

If it is excluded from the scope of license renewal and is not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Page 3 of 8

\/Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 DAEC Response to RAI 2.3.3.11-4 The DAEC current licensing basis for Fire Protection includes the Control Room Complex, the Cable Spreading Room located below the Control Room, and the Control Building HVAC Room located above the Control Room as parts of one Fire Area (Fire Area CB1). Fire Areas are defined as areas of the plant that are separated by fire barriers.

The upgraded wire-embedded glass partition between the Control Room office area and the Control Room front panel area, and the wall constructed with gypsum board that separates the Control Room computer area from the Control Room front panel area, are smoke and heat resistant partitions and not rated fire barriers that separate fire areas. Therefore, these partitions are not in the scope of license renewal and are not subject to an AMR.RAI 2.3.3.11-5 Section 4.3.1, "Water Systems," of the safety evaluation report, dated June 1, 1978, states the following:

Fire water is obtained from a common wet pit in the pump houses which is supplied from the Cedar River and the cooling tower basins. The 400,000 gallon capacity wet pit cooling tower basin [is] supplied by four 6,000 gpm pumps taking suction from the Cedar River. Water is released from a reservoir to maintain the river at an acceptable water level. The wet pit has adequate capacity to meet the requirement of the fire water system.Section 2.3.3.11 of the LRA discusses requirements for the fire water supply system but does not mention trash racks and traveling screens for the fire pump suction water supply. Typically, trash racks and traveling screens are located upstream of the fire pump suction and are considered to be passive, long-lived components.

Both the trash racks and traveling screens are located in a fresh or raw water/air environment and are typically constructed of carbon steel.Carbon steel in a fresh or raw water environment or in a water/air environment is subject to loss of material, pitting, crevice formation, and microbiologically influenced corrosion and fouling.If trash racks and traveling screens are components used at DAEC, the staff requests that the applicant explain why it has excluded the trash racks and traveling screens that are located upstream of the fire pump suctions from the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21 (a)(1).Page 4 of 8 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 DAEC Response to RAI 2.3.3.11-5 The river water supply intake traveling screens are safety related components with an intended function to remove debris from the water supply to the safety related emergency service water and residual heat removal service water pumps. As discussed in LRA Section 2.3.3.16, Intake and Traveling Screens, the river water supply traveling screens are in the scope of license renewal and are subject to aging management review. The river water supply trash racks are located upstream of the traveling screens and provide a non safety related function to minimize the potential for large debris from entering the traveling screen bays. However, the trash racks are not required to filter out postulated river water debris in order to enable the traveling screens to perform their function.A search of DAEC operating experience identified no previous history of aging or damage to the intake structure trash racks. As a preventive measure, the racks were removed and coated with an anti-fouling coating in 1996 after approximately 25 years of operation.

The racks were found to be in excellent condition.

A search of industry operating experience did identify plants that had incurred damage to their intake trash racks. One plant identified debris that had entered its intake structure after a portion of the trash racks had corroded and failed. Another plant had a failure of a trash rack due to high differential pressure from the accumulation of gracilaria on the bottom of the rack. Both of these plants had trash racks that were exposed to a harsh sea water environment.

In addition, both of these plants had high rate flow from circulating water drawn through the trash racks. The high flow rates at those plants would result in a greater potential for debris to be entrained and carried to the trash racks than would be experienced at the low flow rates through the trash racks at DAEC.The DAEC trash racks are exposed to river water and atmosphere environments and pass water at relatively low flow rates, either to make up for cooling tower evaporation and drift or to supply the Emergency Service Water and Residual Heat Removal Service Water Systems during emergency conditions.

The required flow for emergency service water and residual heat removal service water is provided by one river water supply pump per train. The flow rate of 6000 gallons per minute would provide an approach velocity to each traveling screen of only approximately 0.375 feet per minute at minimum river levels. One river water supply pump can also provide the rated flow of both installed fire pumps in the unlikely event additional water volume is needed beyond the wet pit. The low approach velocity at the required intake flow rate minimizes the potential for large debris to be drawn into the river water intake and ensures that even a hypothetical failure of a trash rack would not impair the operation of the downstream safety related river water supply traveling screens.Therefore, the non safety related trash racks do not provide a license renewal intended function as defined in 10 CFR 54.4(a)(1), (a)(2) or (a)(3), and are not subject to aging management review.Page 5 of 8 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 RAI 2.3.3.11-6 Table 2.3.3.11 of the LRA excludes the following fire protection components that appear in the safety evaluation report, dated June 1, 1978:* hose stations* hose connections" hose racks* pipe supports* couplings* tubing* tank(s)* fire hydrants (casing)* sprinkler heads" nozzles* passive components in diesel engines for fire water pumps* fire retardant coating for structural steel* dikes and curbs for oil spill confinement The staff requests that the applicant determine whether Tables 2.3.3-11 and 3.3.2-11 should include each component listed above and, if not, justify the exclusion.

DAEC Response to RAI 2.3.3.11-6 The listed components are included in the DAEC license renewal application tables and are subject to aging management review. The components were grouped with standardized generic component types such as pipe, accumulator, heat exchanger and structure.

Most of the components are addressed in LRA Tables 2.3.3-11 and 3.3.2-11.Some, however, were evaluated as civil/structural components, and are addressed in the civil/structural tables of the LRA.The following table lists the generic component type grouping with which each listed component was evaluated and identifies the terminology used to identify the components in the various LRA tables.Component LRA 2.3/2.4 Table Listing LRA 3.3/3.4 Table Listing Component Type Grouping Piping Pipe, pipe fittings, hoses, Hose Stations Pipe (2.3.3-11) tubes, rupture discs (3.3.2-11)

Hose Piping Pipe, pipe fittings, hoses, Connections Pipe (2.3.3-11) tubes, rupture discs (3.3.2-11)

Page 6 of 8 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 Component Component LRA 2.3/2.4 Table Listing LRA 3.3/3.4 Table Listing CompnentType Grouping Fasteners, spring hangers, Hose Racks guides, stops, supports, and Support new fuel storage racks, Non-ASME Support Pipe Supports panels, carbon steel air- (3.5.2-10) indoor uncontrolled (2.4-10)Piping Pipe, pipe fittings, hoses, Couplings Pipe (2.3.3-11) tubes, rupture discs (3.3.2-11)

Piping Pipe, pipe fittings, hoses, Tubing Pipe (2.3.3-P1) tubes, rupture discs (3.3.2-11)

Pressure Vessel Accumulator, pulsation Tanks Accumulator (2.3.3-11) damper, low pressure tank (3.3.2-11)

Piping Pipe, pipe fittings, hoses, Fire Hydrant Pipe (2.3.3-11) tubes, rupture discs FCsirnts P(3.3.2-11)

Valve Valve Body Valve, damper (2.3.3-11)

(3.3.2-11)

Sprinkler PPiping Pipe, pipe fittings, hoses, Heads Pipe (2.3.3-11) tubes, rupture discs (3.3.2-11)

Piping Pipe, pipe fittings, hoses, Nozzles Pipe Piping tubes, rupture discs (2.3.3-11)(3.3.2-11)

Passive Heat Exchanger Heat exchanger, Components Heat Exchanger (2.3.3-11) condenser, cooler, fan in Diesel (3.3.2-11)

Engines for Heat exchanger, Fire Water Pipe Piping condenser, cooler, fan Pumps (2.3.3-11)

(3.3.2-11)

Structural steel fire Fire Structure proofing air-indoor Structural steel fireproofing Retardant uncontrolled (3.5.2.2)Coating for (2.4.2)Structural Structural steel fire Steel Structure proofing air-indoor Structural steel fireproofing uncontrolled (3.5.2.2)(2.4.2)Page 7 of 8 Enclosure to NG-09-0646 DAEC Response to NRC Requests for Additional Information Regarding LRA Section 2.3.3.11 Component Component LRA 2.3/2.4 Table Listing LRA 3.3/3.4 Table Listing CompnentType Grouping Concrete air-indoor Concrete Structure uncontrolled (2.4-2) (3.5.2-2)Concrete air-indoor Concrete Dikes and Structure uncontrolled (3.5.2-8)Curbs for Oil (2.4-8)Spill Concrete air-indoor Concrete Confinement Structure uncontrolled (3.5.2-9)(2.4-9)Concrete air-indoor Concrete Structure uncontrolled (3.5.2-11)

(2.4-11) (3.5.2-11)

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