NG-12-0489, Response to NRC Requests for Additional Information Regarding the Fourth 10-Year Inservice Inspection Plan

Response to NRC Requests for Additional Information Regarding the Fourth 10-Year Inservice Inspection Plan

ML12356A185
Person / Time
Site:	Duane Arnold
Issue date:	12/21/2012
From:	Anderson R L NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-12-0489
Download: ML12356A185 (6)

Text

Enclosure to NG-12-0489 Page 1 of 4 REQUEST FOR ADDITIONAL INFORMATION NEXTERA ENERGY DUANE ARNOLD ENERGY CENTER FOURTH 10-YEAR INSERVICE INSPECTION PLAN (ME7246)

DOCKET NUMBER 50-331

By letter dated August 31, 2011, (Agencywide Document Access and Management

System (ADAMS) accession number ML11245A240) NextEra Energy Duane Arnold LLC (NextEra, the licensee) submitted a set of 15 Relief Requests (RRs) NDE-R001 through NDE-R015, less NDE-R004, among which several actions were requested individually or in combination including: (1) extension of the expiration date of the RR from that of the expiration of the original facility operating license (February 21, 2014) to the planned end of the fourth inservice inspection (ISI) interval (October 31, 2016); (2) request for approval of newly submitted RRs; (3) requests to confirm the approval status of RR submitted earlier; or (4) some combination of (1), (2) and (3)

NRC staff has reviewed and evaluated the information provided by the licensee and has determined that the following information is needed in order to complete its review of the RR.

Please contact Karl Feintuch (301-415-3079) by 11/14/2012 to confirm: (1) that the

items are clear to you and to the responsive NextEra staff without further discussion or (2) that a clarifying conference call is needed. Upon determination that the RAI items are clear and confirmation of when responses to these items are due, these draft RAI items will be considered to be in final form.

The RAI items are assigned the fo llowing tracking numbers. A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 B. ME7246-RAII-DORL-Feintuch-002-2012-11-12 C. ME7246-RAII-DORL-Feintuch-003-2012-11-12 A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 (1) Individually affirm all RRs, among NDE-R001 to NDE-R015, that are to be extended in effect until October 31, 2016. You may do this in the form of a Table similar to that on Section H, page 1 of 100, with the addition of column(s) in which you address each relief request. (2) Affirm that a time extension was not requested for NDE-R004 and for NDE-R015.

NextEra Energy Duane Arnold Response:

1) The following table summarizes the current status of Relief Requests for the Fourth 10-Year Interval of the Inservice Inspection Plan for the Duane Arnold Energy Center (DAEC).

Enclosure to NG-12-0489 Page 2 of 4 Relief Request # Title NRC Safety Evaluation Summary of Current Status NDE-R001 Use of the DAEC Technical Requirements Manual for Snubber Visual Examination & Testing ML070090357 1/31/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R002 Approved use of PDI for Overlays in lieu of Supplement 11 to Appendix

VIII ML070090357 1/31/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R003 Requested to use BWRVIP-05 recommendations for reduced circumferential vessel weld exams ML043270051 1/6/2005 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R004 Request use of ASME Code Case N-700 in lieu of the requirements specified in the ASME Code,Section XI for Class 1, 2,and 3 vessel welded attachments. ML071380183 6/12/07 This relief request is no longer required as Code Case N-700 has been incorporated into RG 1.147 NDE-R005 Risk Informed ISI for Class 1 B-F & B-J Welds and Class 2 C-F-2 Welds ML070090357 1/31/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R006 Request use of Code Case N-686 "Alternate Requirements for Visual Examinations" ML070090357 1/31/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R007 Alternative for pressure testing and visual examination of buried piping and components ML071380183 6/12/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R008 Request approval to use Appendix VIII examination for the Fourth 10-Year Interval reactor vessel-to-flange weld and head-to-flange weld in lieu of existing requirements to use Section V ML070090357 1/31/07 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R009 Request to allow use of the Provisions of IWA-4132 for stock rotation of Recirculation Pump Seal Flange Assemblies N/A This relief request was withdrawn from consideration on 3/20/07 (ML070890363) since it was determined not to be needed. NDE-R010 Limited Examination on Welds HCC-C001, CUA-J024, RMA-J004 ML101680600 7/6/2010 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R011 Request to use Code Cases N-504-2 and N-638-1 for Weld Overlay Repairs ML071110007 6/12/07 This relief request was for the installation of weld overlays on RRC-F002 and RRF-F002 welds. The weld overlays were installed in 2007 and no work is ongoing that requires additional relief for these welds. No extension of relief is requested.

Enclosure to NG-12-0489 Page 3 of 4 Relief Request # Title NRC Safety Evaluation Summary of Current Status NDE-R012 Request to allow use of Post Qualifying Seal Weld Procedures for Target Rock Valves ML081680709 7/2/08 ML082040206 8/4/08 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R013 Request to use Code Case N-702 for Nozzle-to-Vessel Welds and Inner Radius Sections ML082040046 8/29/08 This relief request will remain in effect through the end of the 4 th 10 year interval (October 31, 2016). NDE-R014 Relief Request for Alternative to ASME Section XI Requirements to Use Structural Weld Overlay Repairs as an Alternative Repair Technique ML11235A935 9/6/11 This relief request was for the installation of a weld overlay on RRA-F002A and RRA-J003 welds. The weld overlay was installed in 2010 and no work is ongoing that requires additional relief for these welds. No extension of relief is requested. NDE-R015 Request for Authorization of Alternative Regarding Pressure Test Requirements ML11237A105 9/6/11 This relief request was a one-time-only alternative for PSV 4402 during RFO 22 (2010). No extension of relief is requested.

2) As noted in the Table above, an extension is not required for either NDE-R004 or NDE-R015.

B. ME7246-RAII-DORL-Feintuch-002-2012-11-12 NRC staff noted within* your letter dated August 31, 2011, where it appears that the Inservice Inspection Plan ceases to be in effect after February 21, 2014, whereas the relief authorized by NRC staff (approved on 1/31/2007 for NRE-R001, for example) contains no limitation other than being in effect for the entire ten-year interval ending on

October 31, 2016.

Please affirm that:

(1) the Inservice Inspection Plan is technically valid for the entire ten-year interval ending on October 31, 2016; (2) all references to the effective dates of the Inservice Inspection Plan have been or will be amended to show that the plan remains in effect until October 31, 2016;

and (3) any reference to ending the effectiveness of the Inservice Inspection Plan on February 21, 2014, is attributable to the expiration of the original facility operating license on February 21, 2014, and not a technical limit on the validity of the plan.

• See for example, on Section A, page 1 of 14, Subsection 1.0 (2) first sentence where

you state that:

"This Inservice Inspection Plan will be effective from November 1, 2006 through and including February 21, 2014, which represents the fourth ten-Enclosure to NG-12-0489 Page 4 of 4 year interval of the Inservice Inspection Program for DAEC. The interval ends on February 21, 2014 to coincide with the end of the current [original facility operating] license, thus making the interval duration of approximately 99 months as opposed to the standard 120 months."

NextEra Energy Duane Arnold Response:

The Fourth 10-Year ISI Interval for the DAEC was originally scheduled to end on February 21, 2014 to coincide with the expiration of the original Operating License (OL), which resulted in a foreshortened duration of 99 months (approx 8 years) for the Fourth ISI Interval. Subsequently, NextEra Energy Duane Arnold has been granted a License Renewal, with the new OL to expire in 2034.

Consequently, the Fourth 10-Year ISI Interval has been adjusted for a true 10 year interval that will now expire on October 31, 2016.

1) The ISI Plan is technically valid for the entire ten year interval ending on October 31, 2016. 2) All references to the effective dat es in the DAEC ISI Plan document, and key implementing/supporting documents, will be amended to show that the Plan remains in effect until October 31, 2016. 3) Any reference to the Plan ending on February 21, 2014 is attributable to the original OL expiration date and is not a technical limit on the validity of the

Plan. C. ME7246-RAII-DORL-Feintuch-003-2012-11-12 NDE-R011 requested relief from the ASME Section XI repair requirements for weld overlay repairs for components RRC-F002 and RRF-F002 using Code Cases N-504-2 and N-638-1 as alternatives. This relief was granted for refueling outage RFO-20 in a SE by NRC staff dated June 12, 2007 (ADAMS Accession No. ML071110007) under TAC number MD4466.

Clarify if a time extension is needed for relief request NDE-R011. If a time extension is needed, explain why the time extension is needed given that the weld overlay repairs for components RRC-F002 and RRF-F002 have been completed and the original SE was granted for RFO-20 only.

NextEra Energy Duane Arnold Response:

As noted in the Table for the response to RAI A. ME7246-RAII-DORL-Feintuch-001-2012-11-12 above, no extension is requested for NDE-R011.