ML092580409

Request for Additional Information Regarding Use of Boral Neutron Absorbing Material in Spent Fuel Pool Racks and the Protective Coating Monitoring and Maintenance Program

ML092580409
Person / Time
Site:	Duane Arnold
Issue date:	09/24/2009
From:	Harris B License Renewal Projects Branch 1
To:	Costanzo C Florida Power & Light Co, Duane Arnold
HARRIS B, NRR/DLR/RPB1 415-2277
References
TAC MD9769
Download: ML092580409 (9)

Text

September 24, 2009 Mr. Christopher Costanzo Vice President, Nuclear Plant Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS AND THE PROTECTIVE COATING MONITORING AND MAINTENANCE PROGRAM (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 for renewal of operating license DPR-49 for the Duane Arnold Energy Center. The staff of the U.S. Nuclear Regulatory Commission (NRC or 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, the staff has identified areas where additional information is needed to complete the review. The staffs 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

September 24, 2009 Mr. Christopher Costanzo Vice President, Nuclear Plant Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS AND THE PROTECTIVE COATING MONITORING AND MAINTENANCE PROGRAM (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 for renewal of operating license DPR-49 for the Duane Arnold Energy Center. The staff of the U.S. Nuclear Regulatory Commission (NRC or 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, the staff has identified areas where additional information is needed to complete the review. The staffs 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.: ML092580409 OFFICE: PM:RPB1:DLR LA:DLR BC:RPB1:DLR PM:RPB1:DLR NAME: BHarris SFigueroa DPelton BHarris (Signature)

DATE: 09/22/09 09/22/09 09/22/09 09/24/09 OFFICIAL AGENCY RECORD

Letter to Christopher Costanzo from Brian K. Harris dated September 24, 2009

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING USE OF BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS AND THE PROTECTIVE COATING MONITORING AND MAINTENANCE PROGRAM (TAC No. MD9769)

DISTRIBUTION:

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B. Harris C. Eccelston M. Spencer K. Feintuch

Duane Arnold Energy Center cc:

Mr. M. S. Ross Ms. Melanie Rasmussen Vice President and Associate Radiation Control Program Director General Counsel Bureau of Radiological Health Florida Power & Light Company Iowa Department of Public Health P.O. Box 14000 Lucas State Office Building, 5th Floor Juno Beach, FL 33408-0420 321 East 12th Street Des Moines, IA 50319-0075 Ms. Marjan Mashhadi Senior Attorney Chairman, Linn County Florida Power & Light Company Board of Supervisors 801 Pennsylvania Avenue, NW 930 1st Street SW Suite 220 Cedar Rapids, IA 52404 Washington, DC 20004 Mr. Raj Kundalkar, Vice President Mr. Steven R. Catron Fleet Organizational Support Manager, Regulatory Affairs Florida Power & Light Company Duane Arnold Energy Center P.O. Box 14000 3277 DAEC Road Juno Beach, FL 33408-0420 Palo, IA 52324 Mr. McHenry Cornell U.S. Nuclear Regulatory Commission Director, Licensing and Performance Resident Inspector=s Office Improvement Rural Route #1 Florida Power & Light Company Palo, IA 52324 P.O. Box 14000 Juno Beach, FL 33408-0420 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

DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION Request for Additional Information (RAI) 3.3.2.2.6

Background:

The applicant states that aging effects due to sustained irradiation of Boral is insignificant, and therefore the implementation of an aging management program (AMP) is not required.

Issue:

Boral has been used at Duane Arnold Energy Center (DAEC) for over 30 years with no evidence of bulging, reduction in neutron absorbing capacity, and/or loss of material. In addition, DAEC, performed spent fuel pool coupon inspections in 2005 and found the results to be consistent with previous staff findings regarding aging effects of Boral. However, this justification is not sufficient in stating that there will not be any bulging, reduction in neutron absorbing capacity, and/or loss of material during the period of extended operation. The staff requires more information in order to determine if an AMP would be required.

Request:

1. Please provide details regarding the operating experience of the Boral at DAEC. With regards to verifying minimum B-10 areal density in Boral, please also include the following:

a. Describe the racks currently in the spent fuel pool at DAEC. Include manufacturer(s) and time spent in spent fuel pool in the description.

b. For each manufacturer and/or age of rack, describe how the neutron absorbing capacity of the Boral is verified such that the minimum B-10 areal density is maintained for the criticality analysis of record.

c. If the method used to verify minimum B-10 areal density utilizes Boral coupons, please answer the following:

i. What is the location of coupons relative to the spent fuel racks? What exposure do the coupons receive relative to the range of neutron fluxes given off by the fuel assemblies? Describe how the coupons are mounted. Are they fully exposed to the spent fuel pool water, e.g., fully submerged or bolted to a wall?

ii. What specific testing procedures are used for determining areal density, verifying surface corrosion and examining for blister formation?

ENCLOSURE

iii. Provide a summary of the test results for the coupons, including areal density measurements. What are the acceptance criteria for these results?

iv. Discuss the correlation between measurements of the physical properties of Boral coupons and the integrity of the Boral panels in the storage racks.

v. After removal from the pool for inspection, are the coupons inserted back at the same locations in the pool?

vi. How is the potential degradation during the time in between surveillance periods accounted for in the criticality analysis of record?

vii. Describe the corrective actions implemented if coupon test results are not acceptable.

viii. Discuss the past testing frequency of the coupons.

d. If the method used to verify that minimum B-10 areal density does not utilize Boral coupons, please answer the following:

i. What specific testing procedures are used for determining areal density, verifying surface corrosion, examining for blister formation, and changes in dimensions?

ii. What are the parameters tested and acceptance criteria for test results covered under question (i) above?

iii. How is the potential degradation during the time in between surveillance periods accounted for in the criticality analysis of record?

iv. Describe the corrective actions implemented if test results are not acceptable.

v. Discuss the past testing frequency.

2. Confirm that a method to verify minimum B-10 areal density will continue to be in place during the period of extended operation. Also, please address the following:

a. For each manufacturer and/or age of rack, describe how the neutron absorbing capacity of the Boral will be verified such that the minimum B-10 areal density is maintained for the criticality analysis of record through the period of extended operation.

b. If the method used to verify minimum B-10 areal density will utilize Boral coupons, please answer the following:

i. Confirm that DAEC has sufficient Boral coupon samples to maintain the sampling frequency through the period of extended operation.

ii. What will be the location of coupons relative to the spent fuel racks?

What exposure will the coupons receive relative to the range of neutron fluxes given off by the fuel assemblies?

iii. Describe how the coupons will be mounted. Will they be fully exposed to the spent fuel pool water, e.g., fully submerged or bolted to a wall?

iv. What specific testing procedures will be used for determining areal density, verifying surface corrosion and examining for blister formation?

v. What will be the acceptance criteria for test results covered under question (iv) above?

vi. Discuss the correlation between measurements of the physical properties of Boral coupons and the integrity of the Boral panels in the storage racks.

vii. After removal from the pool for inspection, will the coupons be inserted back at the same locations in the pool?

viii. How will the potential degradation during the time in between surveillance periods be accounted for in the criticality analysis of record?

ix. Describe the corrective actions implemented if coupon test results are not acceptable.

x. Discuss the schedule for coupon removal and testing during the period of extended operation to demonstrate continued Boral performance.

c. If the method used to verify minimum B-10 areal density will not utilize Boral coupons, please answer the following:

i. What specific testing procedures will be used for determining areal density, verifying surface corrosion, examining for blister formation, and changes in dimensions?

ii. What will be the acceptance criteria for test results covered under question (i) above?

iii. How will the potential degradation during the time in between surveillance periods be accounted for in the criticality analysis of record?

iv. Describe the corrective actions implemented if coupon test results are not acceptable.

v. Discuss the schedule for testing during the period of extended operation to demonstrate continued Boral performance.

3. Operating experience has shown that Boral may experience degradation. For example, Seabrook (ML032880525) and Beaver Valley Unit 1 (ML090220216) recently experienced blistering and/or bulging of aluminum cladding in their Boral. How does the Boral surveillance program at DAEC address plant specific and industry operating experience with Boral?

4. On page 3.3-37, of Section 3.3.2.2.6, of the DAEC license renewal application (LRA), the licensee states, The potential for aging effects due to sustained irradiation of Boral was previously evaluated by the staff (Brookhaven National Lab-NUREG-25582 [BNL-NUREG-25582], dated January 1979; NUREG-1787, (Virgil C. Summer Safety Evaluation Report [VC Summer SER]), paragraph 3.5.2.4.2, page 3-408) and determined to be insignificant. Please justify the applicability of BNL-NUREG-25582 and the VC Summer SER to DAEC in determining the significance of aging effects of Boral in the spent fuel pool during the period of extended operation.

5. Please discuss if holes have been drilled in the spent fuel pool racks at DAEC.

6. On page 9.1-7, of Section 9.1.2.2.1, of the DAEC Final Safety Analysis Report dated October 2003, the licensee states, the only non-stainless steel material utilized in the rack is the neutron absorber material which is a boron carbide aluminum cement manufactured under a US patent and sold under the brand name Boral by AAR Advanced Structures, Livonia, Michigan. Please clarify if the cement means cermet.

RAI B.2.2:

LRA Section: B.2.2, Table B.2.2-1 Aging Management Program Correlation

Background:

XI.S8 Protective Coating Monitoring and Maintenance Program Issue:

This program in the licensees application is cited as not applicable for aging management.

However, NUREG-1801, Generic Aging Lessons Learned Report, states that Proper maintenance of protective coatings inside containment is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Licensees should assure proper maintenance of the protective coatings in containment, such that they will not degrade and become a debris source that may challenge the emergency core cooling systems performance. Therefore the staff requires the following additional information:

Request:

1. On page B-11 of the application (ML082980481), line item XI.S8 states that the NUREG-1801 program is not applicable to DAEC. Please justify why NUREG-1801 XI.S8 does not apply to DAEC.

2. Please describe in detail the Coatings Program at DAEC. How will the program ensure that there will be proper maintenance of the protective coatings inside containment and ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system in the extended period of operation? Also, describe the frequency and scope of the inspections, acceptance criteria, and the qualification of personnel who perform containment coatings inspections.