ML13126A036: Difference between revisions

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| number = ML13126A036
| number = ML13126A036
| issue date = 05/03/2013
| issue date = 05/03/2013
| title = 2013/05/03 NRR E-mail Capture - MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)
| title = NRR E-mail Capture - MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)
| author name = Feintuch K D
| author name = Feintuch K
| author affiliation = NRC/NRR/DORL
| author affiliation = NRC/NRR/DORL
| addressee name = Byrne T
| addressee name = Byrne T
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:1NRR-PMDAPEm ResourceFrom:Feintuch, KarlSent:Friday, May 03, 2013 4:47 PMTo:Byrne, ThomasCc:Jones, Heather; Faria-Ocasio, CarolynSubject:MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)Attachments:Duane Arnold RAI.4.30.2013.docxIn a letter dated November 13, 2012, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12318A286, NextEra Energy Duane Arnold, LLC (NextEra, the licensee) requested a revision to License Condition C.12 to clarify wording concerning the completion dates of certain programs and activities before the period of expended operation (PEO). During its review NRC staff has determined that additional information is necessary to complete its review. As a consequence on 4/30/2013, a conference call was held between NRC staff (Karl Feintuch and Heather Jones) and NextEra staff (Thomas Byrne) to enable an accurate articulation by NRC staff of the addition information to be requested.
{{#Wiki_filter:NRR-PMDAPEm Resource From:                       Feintuch, Karl Sent:                       Friday, May 03, 2013 4:47 PM To:                         Byrne, Thomas Cc:                         Jones, Heather; Faria-Ocasio, Carolyn
Below and attached is the resulting draft Request for Additional Information (RAI). During the conference call the response was requested within 30 days. If there is no need by NextEra for clarification the RAI becomes firm with a response in 30 days from May 6, 2013, requested. 
=============== Request for Additional Information (RAI) follows ================  DRAFT REQUEST FOR ADDITIONAL INFORMATION  REGARDING LICENSE AMENDMENT REQUEST  TO REVISE LICENSE CONDITION C.12  NEXTERA ENERGY DUANE ARNOLD, LLC  DUANE ARNOLD ENERGY CENTER  DOCKET NO. 50-331  TAC MF0075  The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI): 


==Background==
==Subject:==
The renewed facility operating license condition (RFOLC) C.12 currently states: "The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, "Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center," dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when 2activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.Consistent with Revisions 1 and 2 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR]," (ADAMS Accession Nos. ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection. Issue The licensee proposes to remove "in accordance with Appendix A of NUREG-1955, "Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center," dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010" from the second sentence in RFOLC C.12 to be replaced with "no later than February 21, 2014." The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:
MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)
"The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future programs and activities to be completed before the period of extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59.However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.  
Attachments:                Duane Arnold RAI.4.30.2013.docx In a letter dated November 13, 2012, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12318A286, NextEra Energy Duane Arnold, LLC (NextEra, the licensee) requested a revision to License Condition C.12 to clarify wording concerning the completion dates of certain programs and activities before the period of expended operation (PEO). During its review NRC staff has determined that additional information is necessary to complete its review. As a consequence on 4/30/2013, a conference call was held between NRC staff (Karl Feintuch and Heather Jones) and NextEra staff (Thomas Byrne) to enable an accurate articulation by NRC staff of the addition information to be requested.
Below and attached is the resulting draft Request for Additional Information (RAI). During the conference call the response was requested within 30 days. If there is no need by NextEra for clarification the RAI becomes firm with a response in 30 days from May 6, 2013, requested.
                    =============== Request for Additional Information (RAI) follows ================
DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE LICENSE CONDITION C.12 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 TAC MF0075 The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI):
 
===Background===
The renewed facility operating license condition (RFOLC) C.12 currently states:
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when 1
 
activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.
Consistent with Revisions 1 and 2 of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR], (ADAMS Accession Nos. ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection.
Issue The licensee proposes to remove in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010 from the second sentence in RFOLC C.12 to be replaced with no later than February 21, 2014. The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future programs and activities to be completed before the period of extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59.
However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.
RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.
                                  =================== End RAI =================
2


RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.
Hearing Identifier:     NRR_PMDA Email Number:           686 Mail Envelope Properties     (Karl.Feintuch@nrc.gov20130503164600)
=================== End RAI =================
Hearing Identifier: NRR_PMDA Email Number: 686   Mail Envelope Properties   (Karl.Feintuch@nrc.gov20130503164600)  


==Subject:==
==Subject:==
MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI) Sent Date:   5/3/2013 4:46:43 PM Received Date: 5/3/2013 4:46:00 PM From:   Feintuch, Karl Created By:   Karl.Feintuch@nrc.gov Recipients:     "Jones, Heather" <Heather.Jones@nrc.gov> Tracking Status: None "Faria-Ocasio, Carolyn" <Carolyn.Faria-Ocasio@nrc.gov> Tracking Status: None "Byrne, Thomas" <Thomas.Byrne@nexteraenergy.com>
MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)
Tracking Status: None Post Office:     Files     Size     Date & Time MESSAGE   4633     5/3/2013 4:46:00 PM Duane Arnold RAI.4.30.2013.docx   35730   Options Priority:     Standard   Return Notification:   No   Reply Requested:   No   Sensitivity:     Normal Expiration Date:     Recipients Received:
Sent Date:             5/3/2013 4:46:43 PM Received Date:         5/3/2013 4:46:00 PM From:                   Feintuch, Karl Created By:             Karl.Feintuch@nrc.gov Recipients:
DRAFT REQUEST FOR ADDITIONAL INFORMATION  REGARDING LICENSE AMENDMENT REQUEST  TO REVISE LICENSE CONDITION C.12  NEXTERA ENERGY DUANE ARNOLD, LLC  DUANE ARNOLD ENERGY CENTER  DOCKET NO. 50-331  TAC MF0075  The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI): 
"Jones, Heather" <Heather.Jones@nrc.gov>
Tracking Status: None "Faria-Ocasio, Carolyn" <Carolyn.Faria-Ocasio@nrc.gov>
Tracking Status: None "Byrne, Thomas" <Thomas.Byrne@nexteraenergy.com>
Tracking Status: None Post Office:
Files                           Size                     Date & Time MESSAGE                         4633                     5/3/2013 4:46:00 PM Duane Arnold RAI.4.30.2013.docx                       35730 Options Priority:                       Standard Return Notification:           No Reply Requested:               No Sensitivity:                   Normal Expiration Date:
Recipients Received:


==Background==
DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE LICENSE CONDITION C.12 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 TAC MF0075 The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI):
The renewed facility operating license condition (RFOLC) C.12 currently states:  
 
"The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, "Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center," dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.Consistent with Revisions 1 and 2 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR]," (ADAMS Accession Nos.
===Background===
The renewed facility operating license condition (RFOLC) C.12 currently states:
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),
describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.
Consistent with Revisions 1 and 2 of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR], (ADAMS Accession Nos.
ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection.
ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection.
Issue The licensee proposes to remove "in accordance with Appendix A of NUREG-1955, "Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center," dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010" from the second sentence in RFOLC C.12 to be replaced with "no later than February 21, 2014." The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:   "The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),
Issue The licensee proposes to remove in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010 from the second sentence in RFOLC C.12 to be replaced with no later than February 21, 2014. The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:
describes certain future programs and activities to be completed before the period of extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59."
The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),
describes certain future programs and activities to be completed before the period of
 
extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59.
However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.
However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.
RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.
RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.}}
}}

Latest revision as of 05:10, 6 February 2020

NRR E-mail Capture - MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)
ML13126A036
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 05/03/2013
From: Feintuch K
Division of Operating Reactor Licensing
To: Byrne T
NextEra Energy Duane Arnold
References
TAC MF0075
Download: ML13126A036 (5)


Text

NRR-PMDAPEm Resource From: Feintuch, Karl Sent: Friday, May 03, 2013 4:47 PM To: Byrne, Thomas Cc: Jones, Heather; Faria-Ocasio, Carolyn

Subject:

MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)

Attachments: Duane Arnold RAI.4.30.2013.docx In a letter dated November 13, 2012, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12318A286, NextEra Energy Duane Arnold, LLC (NextEra, the licensee) requested a revision to License Condition C.12 to clarify wording concerning the completion dates of certain programs and activities before the period of expended operation (PEO). During its review NRC staff has determined that additional information is necessary to complete its review. As a consequence on 4/30/2013, a conference call was held between NRC staff (Karl Feintuch and Heather Jones) and NextEra staff (Thomas Byrne) to enable an accurate articulation by NRC staff of the addition information to be requested.

Below and attached is the resulting draft Request for Additional Information (RAI). During the conference call the response was requested within 30 days. If there is no need by NextEra for clarification the RAI becomes firm with a response in 30 days from May 6, 2013, requested.

========= Request for Additional Information (RAI) follows ==========

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE LICENSE CONDITION C.12 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 TAC MF0075 The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI):

Background

The renewed facility operating license condition (RFOLC) C.12 currently states:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when 1

activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

Consistent with Revisions 1 and 2 of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR], (ADAMS Accession Nos. ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection.

Issue The licensee proposes to remove in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010 from the second sentence in RFOLC C.12 to be replaced with no later than February 21, 2014. The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future programs and activities to be completed before the period of extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59.

However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.

RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.

============= End RAI ===========

2

Hearing Identifier: NRR_PMDA Email Number: 686 Mail Envelope Properties (Karl.Feintuch@nrc.gov20130503164600)

Subject:

MF0075 - DAEC - Revise License Condition C.12 - Request for Additional Information (RAI)

Sent Date: 5/3/2013 4:46:43 PM Received Date: 5/3/2013 4:46:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients:

"Jones, Heather" <Heather.Jones@nrc.gov>

Tracking Status: None "Faria-Ocasio, Carolyn" <Carolyn.Faria-Ocasio@nrc.gov>

Tracking Status: None "Byrne, Thomas" <Thomas.Byrne@nexteraenergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 4633 5/3/2013 4:46:00 PM Duane Arnold RAI.4.30.2013.docx 35730 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE LICENSE CONDITION C.12 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 TAC MF0075 The Nuclear Regulatory Commission (NRC) staff is reviewing the information provided by NextEra Energy Duane Arnold, LLC (the licensee) for Duane Arnold Energy Center (DAEC) in its license amendment request (LAR) dated November 13, 2012, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML12318A286), and has determined that additional information is necessary to complete its review. Please provide a response which addresses the following request for additional information (RAI):

Background

The renewed facility operating license condition (RFOLC) C.12 currently states:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

describes certain future activities to be completed prior to and/or during the period of extended operation (PEO). The licensee shall complete these activities in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010. The licensee shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

Consistent with Revisions 1 and 2 of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants [SRP-LR], (ADAMS Accession Nos.

ML052110007 and ML103490036), the primary purpose of RFOLC C.12 is to ensure that certain license renewal programs and activities are implemented and/or completed prior to the period of extended operation consistent with Appendix A commitments, and that the NRC receive notification of completion to enable verification by NRC inspection.

Issue The licensee proposes to remove in accordance with Appendix A of NUREG-1955, Safety Evaluation Report Related to the License Renewal of Duane Arnold Energy Center, dated November 2010, as supplemented by letter from the licensee to the NRC dated November 23, 2010 from the second sentence in RFOLC C.12 to be replaced with no later than February 21, 2014. The licensee also proposes to add language in RFOLC C.12 to clarify that changes to the UFSAR which includes the Appendix A list of commitments be governed by 10 CFR 50.59 criteria. The licensee proposed RFOLC C.12 to state:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

describes certain future programs and activities to be completed before the period of

extended operation. NextEra Energy Duane Arnold, LLC shall complete these activities no later than February 21, 2014 and shall notify the NRC in writing when implementation of these activities is complete. Following incorporation into the UFSAR, the need for prior Commission approval of any changes will be governed by 10 CFR 50.59.

However, it is not clear how RFOLC C.12 will explicitly ensure that commitments from Appendix A of NUREG-1955 are completed prior to the period of extended operation.

RAI State how RFOLC C.12 will apply to the commitments from Appendix A of NUREG-1955 that are due to be completed before entering the PEO.