ML101050235

Request for Additional Information for the Review of the Duane Arnold Energy Center License Renewal Application - Buried Piping

ML101050235
Person / Time
Site:	Duane Arnold
Issue date:	05/03/2010
From:	Harris B License Renewal Projects Branch 1
To:	Costantino C NextEra Energy Duane Arnold
Harris B
References
TAC MD9769
Download: ML101050235 (5)

Text

May 3, 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 - BURIED PIPING (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 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 May 3, 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 - BURIED PIPING (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 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.:ML101050235 OFFICE: PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR NAME: BHarris IKing BPham (BBrady for) BHarris DATE: 04/19/10 04/29/10 04/29/10 05/03/10 OFFICIAL AGENCY RECORD Letter to Christopher Costanzo from Brian K. Harris dated May 03, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION - BURIED PIPING (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 Nazar Executive Vice President Nuclear and Chief Nuclear 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. Gene St. Pierre Vice President, Fleet Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. Larry Nicholson Director of Licensing Florida Power and 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 3.7.1-X Background The license renewal application (LRA) states that aging management program (AMP) B.3.7, Buried Piping and Tanks Inspection Program, is a new program with one exception to the program elements in Generic Aging Lessons Learned (GALL) AMP XI.M34. This AMP addresses buried piping, i.e. piping in direct contact with soil. The description of the operating experience (OE) attribute for this AMP does not discuss specific OE at Duane Arnold Energy Center (DAEC) or from the industry. Instead, it states that "plant operating experience for this program will be gained as it is implemented during the period of extended operations, and will be factored into the program via the confirmation and corrective action elements of the DAEC 10 CFR 50 Appendix B quality assurance program."

The LRA also states that AMP B.3.21, External Surfaces Monitoring Program, is an existing program with enhancement. This AMP is also credited for managing the aging of the external surfaces of piping exposed to air.

Issue There have been a number of recent industry events involving leakage from buried and underground piping, where the causes have included coating damage during backfill of piping, failure of fiberglass piping, failure of buried piping in and around piping penetrations, and failure of piping in trenches. In light of this recent industry OE, the staff is concerned about the susceptibility of buried and/or underground piping that are within the scope of 10 CFR 54.4 and subject to aging management for license renewal. In reviewing the AMP's cited above, along with the applicable aging management review items associated with them, the staff is not clear whether the components addressed by these AMPs would include both buried and underground piping (piping which is below grade and contained in a vault or other structure where it is exposed to air and where access is limited), and also if such programs would be sufficient and effective in managing the aging effects of buried and underground piping.

Request Please provide information regarding how DAEC will incorporate the recent industry OE into its aging management reviews and programs in order to adequately and effectively manage the effects of aging, specifically for systems and components that are in scope for license renewal and include buried and underground piping.