NG-10-0383, Supplemental Information Related to the License Renewal Application - Buried Piping

Supplemental Information Related to the License Renewal Application - Buried Piping

ML102140192
Person / Time
Site:	Duane Arnold
Issue date:	07/29/2010
From:	Costanzo C NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-10-0383, TAC MD9769
Download: ML102140192 (26)

Text

NEXTera M ENERGY~

~ DUANE ARNOLD

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July 29, 2010 NG-10-0383 10 CFR 54 I

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk .

Washington, DC 20555-0001 Duane Arnold Energy Center Docket 50-331 License No. DPR-49 Supplemental Information Related to the Duane Arnold Energy Center License Renewal Application - Buried Piping

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, Brian K. Harris (USNRC) to Christopher Costanzo (NextEra Energy Duane Arnold, LLC), "Request for Additional Information for the Review of the Duane Arnold Energy Center License Renewal Application - Buried Piping (TAC No. MD9769)," dated May 3,2010 (ML101050235)

4. Letter, Christopher Costanzo (NextEra Energy Duane Arnold, LLC) to Document Control Desk (USNRC), "Supplemental Information and Response to Request for Additional Information Related to the Duane Arnold Energy Center License Renewal Application," dated May 28,2010, NG-10-0309 (ML101520195)

By Reference 1, FPL Energy Duane Arnold, LLC submitted an application for a renewed Operating License (LRA) for the Duane Arnold Energy Center (DAEC). Reference 2 provided Supplement 1 to the application. By Reference 3, the Staff requested additional information regarding buried and underground piping. Reference 4 provided the DAEC response on May 28, 2010. Subsequently, additional operating experience and inspections have occurred at DAEC, as discussed in Enclosure 1.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-10-0383 Page 2 also addresses additional questions regarding buried piping which were provided by the Staff via electronic mail dated June 21, 2010, and discussed during conference calls on June 28 and July 27,2010.

Based on the recent DAEC operating experience, several changes have been made to the Buried Piping and Tanks Inspection Program. These changes are provided in . Enclosure 3 provides a revised LRA Appendix A, Section 18.4, Table A-1, Duane Arnold License Renewal Commitments, updated to reflect the license renewal commitment changes made in DAEC correspondence to date.

If you have any questions or require additional information, please contact Mr. Kenneth Putnam at (319) 851-7238.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 29, 2010.

Christopher R. Costanzo Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC

Enclosures:

1. DAEC Responses to Questions Related to Buried Piping

2. LRA Revisions

3. Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments cc: M. Rasmusson (State of Iowa)

Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping NRC Request 1 What length of pipe will be exposed in each of the planned inspections?

DAEC Response to Request 1 The length of pipe inspected during directed inspections will be 10 feet or greater unless the total installed length of the pipe segment is shorter or the physical configuration precludes excavation of a ten foot length.

The length of pipe inspected during opportunistic inspections will be based on the amount of exposed piping. The majority of buried piping at DAEC that is in the scope of license renewal is at a depth of greater than 6 feet below grade. A typical opportunistic excavation is for a valve mechanical repair or replacement. A trench to support this activity would normally expose at least 10 foot of piping for inspection. A small localized (keyhole) type excavation would not be credited for an opportunistic inspection, as it does not expose sufficient piping to reflect the pipe segment condition.

NRC Request 2 If high risk piping is identified but torsional guided wave does not yield susceptibility, will the pipe be inspected?

DAEC Response to Request 2 Torsional guided wave is used solely as a screening tool to assist in selecting the most susceptible locations for inspection. Regardless of the results of torsional guided wave, either visual or ultrasonic inspections will be performed on a minimum number of pipe segments associated with each material group (e.g., stainless steel, carbon steel, ductile iron, or cast iron) for which the buried piping and tank program is credited. The only concrete piping in scope for license renewal is large-diameter non-safety-related piping connecting the cooling tower basins to the circulating water pit. This piping is managed for aging by the Structures Monitoring Program. This concrete piping is not appropriate for external excavation due to the potential for damage. Internal ultrasonic inspection is not suitable for concrete pipe. Therefore, concrete pipe will be inspected using internal examinations for cracking, spalling, scaling and loss of bond. The function of this concrete pipe is to provide an additional inventory of water as a backup to the fire pump pit in the event of a loss of river water supply. This concrete pipe does not contain radiologically contaminated liquid and internal visual examinations would detect deterioration prior to a loss of intended function.

NRC Request 3 What is meant by "will be considered" in the revised program description?

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping DAEC Response to Request 3 Where torsional guided wave results indicate a significant susceptibility, the piping will be scheduled for either visual or ultrasonic examination. If no pipe segment in a material group is found to be susceptible by torsional guided wave exam, the minimum inspections will be selected from the higher risk piping in the material group.

NRC Request 4 What does applicant believe in regard to the condition of their cathodic protection system?

DAEC Response to Request 4 The cathodic protection system was installed in association with original plant construction and verified to be providing appropriate protection for the associated buried piping and tanks during construction acceptance testing by measuring system voltage, currents and pipe to soil potentials. While no historic quantification of availability exists, the system has been subjected to periodic preventive maintenance activities that have monitored rectifier voltage, current and individual anode currents. In 1994, all the system anodes were replaced and readings of the rectifier voltage, current and anode currents were documented with the preventative maintenance program to ensure proper operation of the system. Since the 1994 anode replacement, periodic rectifier voltage, current and anode current readings have been taken and documented through the plants preventative maintenance program. While these readings did not provide pipe to soil potential values, they did provide information that the cathodic protection rectifiers were operating properly and that the connected anodes were intact and providing some degree of protection. In addition, periodic reviews of the system performance using NACE qualified reviewers have been performed since 2003. These system reviews employed NACE specified potential measurements at approximately 50 foot intervals of buried pipe or tank utilizing a portable reference electrode to measure the soil to buried structure potentials. Each of these reviews has identified actions needed to optimize system performance. These actions have been entered into the corrective action process. Corrective actions included system wiring repairs and/or replacement of depleted anodes. Typically less than 5 percent of the pipe-to-soil potential readings were less than the NACE specification of -850 millivolts and many of these readings were just slightly below the specification. During the 2009 system survey, one of the five rectifiers was found to be damaged. Although it was still in operation, the pipe-to-soil potentials for the piping served by this rectifier were found to be below the -850 millivolt NACE specification. This rectifier is being planned for replacement. The remaining four rectifiers were found to be operating normally.

Fire protection piping design does not include direct cathodic protection.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping NRC Request 5 Given the minimal testing of the cathodic protection system, what is the basis of the station that they have a reasonable assurance of buried piping integrity?

DAEC Response to Request 5 The RAI response dated May 28, 2010 (NG-10-0309) discussed operating experience at DAEC involving buried piping. The response stated that buried piping leaks identified at DAEC in the last ten years involved buried well water piping that is not within the scope of License Renewal. In July, after the submittal of that response, a leak was identified in buried fire protection piping that is within the scope of license renewal. This piping is ductile cast iron that is not wrapped, externally-coated, nor directly cathodically protected. Preliminary investigation indicates that the cause is external pitting corrosion. Based on this recent operating experience, supplemental focused inspection is planned for piping in this category, as discussed in new Commitment 52.

As discussed above, in response to Request 4, periodic reviews of the cathodic protection system performance have been performed since 2003. Another cathodic protection system survey is planned for 2010. Periodic maintenance work orders check individual anode currents and rectifier current and voltage every two months. Currently a rectifier and anode are out of service and are being planned for replacement. Piping associated with this rectifier and anode is scheduled for inspection in 2010. Several opportunistic inspection results to date have found buried piping in good condition.

As discussed in new Commitment 53, Cathodic Protection System annual availability will be maintained 90%. The availability will be demonstrated by having no more than six months of rectifier out of service time in any twelve month period. Duane Arnold has five rectifiers in the Cathodic Protection System. Each rectifier provides a single field of protection for buried piping and tanks for a total of five fields. Six months of rectifier out of service time in any twelve month period equals a loss of 10% of the cathodic protection system availability. If the availability for any twelve month period is less than 90%, it will be entered into the site corrective action program to determine appropriate actions. Annual surveys of the Cathodic Protection System will continue to be performed in accordance with NACE Standard Practice.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping NRC Request 6 Is the applicant aware of industry experience with false assurance from torsional guided wave data? What actions has the station taken to ensure screening by torsional guided wave will not give a false assurance of buried pipe integrity?

DAEC Response to Request 6 DAEC is aware of industry operating experience with false assurance from torsional guided wave data. The DAEC program does not rely on torsional guided wave exams as the basis for piping integrity but rather uses it as a tool in selecting more susceptible areas. Regardless of the results of torsional guided wave exams, each material group will have a minimum number of locations inspected using either UT or visual examination both before entry into the period of extended operation and in each ten year period after entry into the period of extended operation.

NRC Request 7 What is the applicant going to do for inspecting the following?

High Pressure Coolant Injection Standby Gas Treatment Emergency Service Water Fire Protection Table 3.3.2-29 Standby Diesel Generator accumulator, low pressure tank/piping Condensate and demineralized water system DAEC Response to Request 7 The requested information is provided in the following table. Also, for completeness, buried piping in systems not specifically included in the Staffs request is also addressed in the table.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping Planned Inspections Credited Prior to the Period of Extended Operation Number of System or Planned Material Comments Component Direct Inspections Emergency This pipe is in close proximity to the RHRSW System piping. A planned Carbon Service Water None excavation at a location screened by torsional guided wave inspections will Steel (ESW) examine the coatings and backfill of RHRSW system.

RWS, RHRSW, ESW, SBGT, and portions of FP are constructed of Standby Gas Carbon wrapped and coated carbon steel with similar backfill. RHRSW and RWS Treatment None Steel have been selected by torsional guided wave screening for excavation and (SBGT) direct inspection.

A minimum of one excavation at a location screened by torsional guided River Water Carbon 1 wave has been planned to visually inspect the piping coating and backfill in Supply (RWS) Steel the pipe vicinity.

Residual Heat A minimum of one excavation at a location screened by torsional guided Removal Carbon 1 wave has been planned to visually inspect the piping coating and backfill in Service Water Steel the pipe vicinity.

(RHRSW)

The components to which Table 3.3.2-29 refers are 1T035, Standby Diesel Generator Fuel Oil Storage Tank, and fuel oil piping. The inspections Table 3.3.2-29 performed on the tank are discussed in the RAI response dated May 28, Standby Diesel 2010. This buried tank had an internal visual and ultrasonic (UT) 1 Generator, Carbon inspection in 2001 and was found to be in excellent condition. It is (Internal Visual accumulator, Steel scheduled for an internal visual and UT inspection again in 2012 by the

& UT) low pressure inspection requirements of the Fuel Oil Chemistry Program. The limited tank/piping amount of fuel oil piping is of the same wrapped and coated carbon steel material and in similar backfill and location as the RHRSW piping and has not been selected for excavation.

Approximately 10 opportunistic visual inspections have indicated this uncoated cast iron pipe to be in good condition with a sand backfill containing no material that could damage the exterior of the piping. Some Fire Protection Cast Iron See Comments of these inspections were on portions of the Fire Protection system not in the scope of license renewal; however, the pipe is of the same material and soil and backfill of the same material.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping Number of System or Planned Material Comments Component Direct Inspections In July 2010, a leak developed on a section of buried ductile cast iron fire protection piping. Preliminary investigation indicates that the cause is 2

Fire Protection Ductile Iron external pitting corrosion. Under the DAEC corrective action program, an See Comments extent of condition is being performed which requires inspection of similar piping and analysis of soil.

RWS, RHRSW, ESW, SBGT, and portions of FP are constructed of Carbon wrapped and coated carbon steel with similar backfill. RHRSW and RWS Fire Protection None Steel have been selected by torsional guided wave screening for excavation and direct inspection.

An internal visual inspection will be performed on the concrete pipe section from the cooling tower basins to the circulating water pit to check for Miscellaneous cracking, spalling, scaling or loss of bond. External inspection is not Concrete 1 Yard Structures appropriate for this piping due to the potential for piping damage. As discussed in the response to Request 2, this piping is managed for aging by the Structures Monitoring Program.

This piping is of the same material and in close proximity to the HPCI Condensate &

Stainless System piping (See HPCI comments below). One excavation will visually Demineralized See Comments Steel inspect a segment of at least one of these systems and the associated Water backfill.

This piping is in close proximity and of the same material as the High Pressure Stainless Condensate and Demineralized Water System piping. (See Condensate &

Coolant See Comments Steel Demineralized comments above). One excavation will visually inspect a Injection (HPCI) segment of at least one of these systems and the associated backfill.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping Notes:

1. The term direct inspection refers to a visual and/or UT inspection of the external coating and/or surface of an excavated buried pipe or the visual and UT inspection of the internal surface of a buried tank.

2. All planned excavations prior to the period of extended operation will expose at a least 10 feet of pipe as practicable including the pipe bottom for inspection.

3. Inspections of carbon steel piping will include a coating inspection as well as backfill in the vicinity of the pipe coating to verify no large fill material is present that could damage the coating.

4. Uncoated piping excavations will inspect the pipe for corrosion. Backfill inspections in the vicinity of the uncoated piping provide additional data on overall backfill conditions of the site.

5. DAEC UFSAR Section 2.5 contains information concerning filling and backfilling operations that were performed during the construction of the DAEC. This section indicates that the preferred backfill material was compacted granular material.

Representative compaction test reports from construction indicate the predominant backfill material was sand. On 6-30-2010 and 7-1-2010, fifteen test holes were dug to obtain soil samples for chemical analysis per the fleet buried piping program. Seven test holes were in the vicinity of in-scope buried piping and confirmed that the backfill material is sand with no rocks found at the test hole locations.

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Enclosure 1 to NG-10-0383 DAEC Responses to Questions Related to Buried Piping NRC Request 8 What commitment changes is the applicant considering?

DAEC Response to Request 8 In LRA Appendix A, Section 18.4, Duane Arnold License Renewal Commitments, new license renewal commitments are provided, as follows:

Item System, Commitment Section Schedule No. Component or Program

52. Buried Piping Enhance the Buried Piping and Tanks Inspection 18.1.7 Prior to the and Tanks Program to include inspection of at least a minimum period of Inspection number of pipe segments in each material group (one extended Program stainless steel, two carbon steel, one cast iron, and operation two ductile iron) prior to entry into the period of extended operation and each ten year period after entry into the period of extended operation. Where torsional guided wave data indicates significant susceptibility, inspections will be performed on associated locations. The sample locations for directed inspections will preferentially select higher risk locations. These directed inspections will be performed with sufficient excavation to expose at least ten linear feet of piping as practicable, including the pipe bottom. Inspections of coated carbon steel piping will include the coating and backfill in the vicinity of the piping for material that could cause coating damage. The uncoated stainless steel, ductile iron and cast iron piping will be externally inspected for corrosion, and the fill in the vicinity of the piping will be inspected for material that could cause external damage to the stainless steel, ductile iron or cast iron pipe.

53. Buried Piping Cathodic Protection System annual availability will be 18.1.7 Prior to the and Tanks maintained 90%. The availability will be period of Inspection demonstrated by having no more than six months of extended Program rectifier out of service time in any twelve month operation period. Annual surveys will continue to be performed in accordance with NACE Standard Practice.

NRC Request 9 The applicant did not address inspections during the PEO, what are their plans?

DAEC Response to Request 9 As noted above, examinations will continue during each ten year period after entry into the period of extended operation.

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Enclosure 2 to NG-10-0383 LRA Revisions In Appendix A, Section 18.1.7 Buried Piping and Tanks Inspection Program is revised in its entirety to read as follows:

The Buried Piping and Tanks Inspection Program includes provisions for visual inspections of the protective wraps and coatings on buried carbon and low-alloy steel, piping and tanks and visual inspections of external surfaces of ductile iron, cast iron and stainless steel pipe in scope for license renewal. The visual inspections for damage are performed when the carbon, low-alloy steel, ductile iron, cast iron and stainless steel components are excavated during maintenance and when a component is dug up and inspected for any reason. If damage to the protective wraps and coatings of carbon and low alloy steel is found, the outer surface of the pipe or tank is inspected for loss of material. This DAEC program contains inspections for buried pipe that is not coated. Uncoated ductile iron, cast iron and stainless steel piping will be inspected for loss of material.

The Program is consistent with the ten elements of NUREG-1801 XI.M34 with one exception. The Program expands the NUREG-1801 XI.M34 requirements to include inspections for loss of material of uncoated ductile iron, cast iron and stainless steel pipes.

Cathodic Protection System annual availability will be maintained 90%. The availability will be demonstrated by having no more than six months of rectifier out of service time in any twelve month period. Duane Arnold has five rectifiers in the Cathodic Protection System. Each rectifier provides a single field of protection for buried piping and tanks for a total of five fields. Six months of rectifier out of service time in any twelve month period equals a loss of 10% of the cathodic protection system availability. Annual surveys of the Cathodic Protection System will continue to be performed in accordance with NACE Standard Practice.

In Appendix B, B.3.7 Buried Piping and Tanks Inspection Program, Section B.3.7.1 Program Description is revised in its entirety to read as follows:

The DAEC Buried Piping and Tanks Inspection Program is a new program. The program manages the aging effects of corrosion on the pressure-retaining capacity of buried piping and tanks.

In-scope buried carbon and low-alloy steel piping and tanks have external coatings and wrappings. In-scope buried ductile iron, cast iron and stainless steel piping do not have external coatings and wrappings.

The program includes provisions for visual inspections of the protective wraps and coatings on buried carbon, and low-alloy steel, piping and tanks in scope for license renewal. The program also includes provisions for inspections for loss of material on buried uncoated ductile iron, uncoated cast iron and uncoated stainless steel piping in scope for license renewal. The inspections for damage and loss of material are performed when the carbon, low alloy steel, uncoated ductile iron, 1 of 2

Enclosure 2 to NG-10-0383 LRA Revisions uncoated cast iron and uncoated stainless steel pipes and tanks are excavated and exposed for any reason.

If damage to the protective wraps and coatings of carbon and low-alloy steel is found, the outer surface of the pipe or tank is inspected for loss of material due to general corrosion, pitting, and crevice corrosion, and Microbiologically-Influenced Corrosion (MIC). Buried stainless steel will be inspected for loss of material due to pitting, crevice corrosion, and MIC. Buried ductile iron and cast iron pipe will be evaluated for general corrosion, pitting, crevice corrosion, and MIC.

At DAEC, buried pipes and tanks are not routinely uncovered during maintenance activities. However, the program requires opportunistic or focused inspection of at least a minimum number of pipe segments in each material group (one stainless steel, two carbon steel, one cast iron, and two ductile iron) be performed prior to entering the period of extended operation and each ten-year period thereafter.

The DAEC Buried Piping and Tanks Inspection Program uses risk ranking of buried components per the guidelines of EPRI 1016456, Recommendations for an Effective Program to Control the Degradation of Buried Piping. Torsional guided wave technology is used as a screening tool, where appropriate, to determine susceptible locations for further evaluation. Locations identified by the risk ranking and susceptible locations identified by the torsional guided wave exams will be considered for additional inspections beyond the minimum defined in NUREG-1801 XI.M34.

Cathodic Protection System annual availability will be maintained 90%. The availability will be demonstrated by having no more than six months of rectifier out of service time in any twelve month period. Duane Arnold has five rectifiers in the Cathodic Protection System. Each rectifier provides a single field of protection for buried piping and tanks for a total of five fields. Six months of rectifier out of service time in any twelve month period equals a loss of 10% of the cathodic protection system availability. Annual surveys of the Cathodic Protection System will continue to be performed in accordance with NACE Standard Practice.

Section B.3.7.3 Exceptions to NUREG-1801 is revised in its entirety to read as follows:

The DAEC program takes one exception to the guidance as stated in NUREG-1801 XI.M34. This exception affects the following elements of NUREG-1801 XI.M34.

• Scope of Program NUREG-1801 states: The program relies on preventive measures such as coating, wrapping and periodic inspection for loss of material caused by corrosion of the external surface of buried steel piping and tanks. The DAEC program will expand the NUREG-1801 XI.M34 requirements for inspection of coated pipes to include inspections for loss of material of uncoated ductile iron, cast iron and stainless steel pipes.

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

1. Buried Piping and Tanks Implement Buried Piping and Tank Program 18.1.7 Prior to the Inspection Program period of extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

2. BWR Vessel Internals Perform an EVT-1 inspection of 5% of the top guide locations 18.1.14 Within six Program years of entering the period of extended operation

3. BWR Vessel Internals Perform an EVT-1 inspection of an additional 5% of the top 18.1.14 Within 12 Program guide locations years of entering the period of extended operation

4. Electrical Cables and Implement an Electrical Cables and Connections Program and 18.1.17 Prior to the Connections Program complete the first inspection prior to the period of extended period of operation. extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

Page 1 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

5. Electrical Cables and Implement an Electrical Cables and Connections Used in 18.1.18 Prior to the Connections Used in Instrumentation Circuits Program and complete the first period of Instrumentation Circuits inspection prior to the period of extended operation. extended Program operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

6. Electrical Connections Implement an Electrical Connections Program and complete the 18.1.19 Prior to the Program one time inspection prior to the period of extended operation. period of extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

7. Electrical Penetration Implement an Electrical Penetration Assemblies Program. 18.1.20 Prior to the Assemblies Program period of

[Revised in DAEC letter NG-09-0764 in response to new extended Program Commitments RAI] operation

8. External Surfaces Revise the inspection program to address inspector 18.1.21 Prior to the Monitoring Program qualifications, types of components, degradation mechanisms, period of aging effects, acceptance criteria, inspection frequency, and extended periodic reviews to determine program effectiveness. The operation program will also specifically address inaccessible areas and include inspections of opportunity for possible corrosion under insulation.

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.21-2]

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

9. Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance 18.1.22 Prior to the procedure will be enhanced to include criteria for visual period of inspections of fire barrier wall, ceiling and floors to examine for extended any sign of degradation such as cracking, spalling and loss of operation material caused by freeze-thaw, chemical attack and reaction with aggregates by fire protection qualified inspectors.

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.22-1]

10. Fire Protection Program Enhance procedures to inspect the entire diesel driven fire 18.1.22 Prior to the pump fuel supply line for age related degradation. period of extended operation

11. Fire Water System Implement maintenance activities to perform volumetric 18.1.23 Prior to the Program examinations for pipe wall thinning of fire protection piping period of periodically during the period of extended operation. extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

12. Fire Water System Enhance procedures to include NFPA 25 criteria for sprinklers 18.1.23 Prior to the Program regarding replacing or testing period of extended operation Page 3 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

13. Fire Water System Enhance procedures to perform visual inspection of fire 18.1.23 Prior to the Program hydrants annually period of extended operation

14. Fuel Oil Chemistry Revise the program to require particulate testing of fuel oil 18.1.25 Prior to the Program samples from the diesel fire pump day tank period of extended operation

15. Fuel Oil Chemistry Enhance procedures to require sampling and testing of new fuel 18.1.25 Prior to the Program oil delivered to the diesel fire pump day tank; and to require that period of purchase orders and sampling procedures for diesel fuel extended delivered to and stored in the diesel fire pump day tank prohibit operation the delivery and use of biodiesel fuel.

[Revised in letter NG-09-0764 in response to RAI B.3.25-1]

16. Fuel Oil Chemistry Enhance procedures to perform periodic (10 year) draining, 18.1.25 Prior to the Program cleaning and visual inspection of the diesel fuel oil day tanks, period of diesel fire pump day tank, and diesel driven air start air extended compressor fuel oil tanks. operation

[Revised in letter NG-09-0764 in response to RAI B.3.25-4]

17. Fuel Oil Chemistry Implement procedures to require bottom thickness testing of the 18.1.25 Prior to the Program Standby Diesel Generator Day Tanks and the Diesel Fire Pump period of Day Tank. extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

18. Fuse Holders Program Implement a Fuse Holders Program and complete the first test 18.1.26 Prior to the prior to the period of extended operation. period of extended

[Revised in DAEC letter NG-09-0764 in response to RAI B.3.26- operation 1 and New Program Commitments RAI]

19. Inaccessible Medium Implement an Inaccessible Medium Voltage Cable Program and 18.1.27 Prior to the Voltage Cable Program complete the first inspection or test prior to the period of period of extended operation. extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

20. Inspection of Internal Implement an Inspection of Internal Surfaces in Miscellaneous 18.1.28 Prior to the Surfaces in Miscellaneous Piping and Ducting Components Program. period of Piping and Ducting extended Components Program [Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

21. Inspection of Overhead Enhance procedures to monitor for corrosion and wear of the 18.1.29 Prior to the Heavy Load and Light supporting steel and rails period of Load (Related to extended Refueling) Handling operation Systems Program

22. Inspection of Overhead Enhance procedures to record usage of the reactor building and 18.1.29 Prior to the Heavy Load and Light turbine building cranes period of Load (Related to extended Refueling) Handling operation Systems Program Page 5 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

23. Lubricating Oil Analysis Enhance procedures to include diesel fire pump 18.1.30 Prior to the Program period of extended operation

24. Metal Enclosed Bus Implement a Metal Enclosed Bus Program and complete the 18.1.31 Prior to the Program first inspection prior to the period of extended operation. extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

25. One-Time Inspection Implement a One-Time Inspection Program and complete the 18.1.32 Prior to the Program one-time inspections prior to the period of extended operation. period of extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

26. Reactor Vessel Implement a procedure to evaluate the BWRVIP ISP data as it 18.1.35 Prior to the Surveillance Program becomes available. period of extended

[Revised in DAEC letter NG-09-0764 in response to New operation Program Commitments RAI]

27. Reactor Vessel Revise the Reactor Vessel Surveillance Program to implement 18.1.35 Prior to the Surveillance Program the recommendations of BWRVIP-116 BWR Vessel and period of Internals Project Integrated Surveillance Program extended BWRVIP-74-A BWR PRV Implementation for License Renewal. operation Inspection and Flaw Evaluation Guidelines for License Renewal Page 6 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

28. Reactor Vessel Implement BWRVIP-116 with the conditions documented in 18.1.35 Prior to the Surveillance Program Sections 3 and 4 of the NRC Staff's SE dated March 1, 2006 for period of BWRVIP-116, including the following: extended operation NRC approval will be obtained for any change in the withdrawal schedules of the DAEC Reactor Vessel surveillance capsules.

If a standby capsule is removed from the DAEC Reactor Vessel without the intent to test it, the capsule will be stored in a manner which maintains it in a condition which would permit its future use, including during the period of extended operation, if necessary.

[Revised in DAEC letter NG-09-0663 in response to RAI B.3.35-1]

29. Selective Leaching of Implement and complete a program to include one-time visual 18.1.36 Prior to the Materials Program inspection and hardness measurement of selected components period of susceptible to selective leaching extended operation

[Revised in DAEC letter NG-09-0764 in response to New Program Commitments RAI]

30. Structures Monitoring Enhance procedures to include structures and structural 18.1.37 Prior to the Program components not currently in Maintenance Rule Program period of extended operation Page 7 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

31. Structures Monitoring Enhance procedures to include periodic sampling of 18.1.37 Prior to the Program groundwater for pH, chloride and sulfate concentration on a 5 period of year periodicity. extended operation

[Revised in letter NG-10-0043 in response to Follow-up RAI B.3.37-2]

32. Structures Monitoring Enhance procedures to include a elastomer inspection to 18.1.37 Prior to the Program prevent leakage through containment penetration. period of extended operation

33. Structures Monitoring Enhance procedures to include a requirement to contact the 18.1.37 Prior to the Program proper personnel to allow opportunistic inspection of the buried period of concrete foundation. extended operation

34. Structures Monitoring Enhance procedures to include opportunistic inspections of the 18.1.37 Prior to the Program buried concrete foundation on a 10 year periodicity. period of extended operation

35. Metal Fatigue of Reactor Enhance procedures to incorporate the requirements of 18.2.2 Prior to the Vessel Coolant Pressure NUREG/CR-6260 locations into the implementing procedures. period of Boundary Program extended operation Page 8 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

36. Thermal Aging and Implement a Thermal Aging and Neutron Irradiation 18.1.38 Prior to the Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) period of Embrittlement of Cast Program. extended Austenitic Stainless Steel operation (CASS) Program [Revised in DAEC letter NG-09-0764 in response to New Program Commitment RAI]

37. Reactor Internals DAEC will ensure that aging of core plate hold down bolts is 18.1.14 Prior to appropriately addressed by completing one of the following entering the actions: 18.3.1.7 period of extended Install core plate wedges to eliminate the function of core operation plate hold down bolts.

Perform analysis of the core plate rim hold down bolts that demonstrates adequacy to perform their intended function including loss of pre-load in the period of extended operation including the effects of projected neutron fluence. Inspection of core plate hold down bolts will be performed in accordance with BWRVIP-25, or a deviation disposition will be developed/submitted in accordance with BWRVIP-94.

[Revised in DAEC letter NG-10-0091]

38. Reactor Vessel Submit a relief request to address the frequency requirements 18.3.1.4 Prior to the Circumferential Weld TLAA of the inservice inspection of the RPV circumferential welds. period of (BWRVIP-05). extended operation Page 9 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

39. Quality Assurance Expand the scope of its 10 CFR Part 50, Appendix B Quality UFSAR Prior to the Program (Corrective Assurance program to include non-safety-related structures and 17.1.2 period of Action, Confirmation components subject to an AMR for license renewal. extended Process, Administrative operation Controls)

40. Operating Experience Perform an operating experience review of extended power Prior to the uprate and its impact on aging management programs for period of systems, structures, and components (SSCs) before entering extended the period of extended operation. operation

41. Bolting Integrity Program Revise the implementing procedures for the ASME Section XI 18.1.6 Prior to the Inservice Inspection Subsections IWB, IWC, and IWD Program; period of ASME Section XI Inservice Inspection, Subsection IWF extended Program; External Surfaces Monitoring Program; Structural operation Monitoring Program; and Buried Piping and Tanks Program such that they specifically address the inspection of fasteners (bolting, washers, nuts, etc.) for signs of leakage, corrosion/loss of material, cracking, and loss of preload/loss of prestress, as applicable.

[Added in letter NG-09-0764 in response to RAI B.3.6-02]

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

42. BWR Penetrations The implementing document for the BWR Penetrations Program 18.1.10 Prior to the Program will be revised to specify that guidance in BWRVIP-14, -59 and - period of 60 will be used, as appropriate, depending on material, in the extended evaluation of crack growth in stainless steel, nickel alloys and operation low-alloy steels, respectively, when flaws are identified and evaluation required.

[Added in letter NG-09-0764 in response to RAI B.3.10-5]

[Revised in letter NG-10-0009]

43. Fire Protection Program The DAEC Fire Barrier Penetration Seal Inspection surveillance 18.1.22 Prior to the procedure will be enhanced to ensure a approximately 10% of period of each type of penetration seal is included in the 35 percent extended selection of fire penetration seals that are visually inspected at operation an 18 month interval.

[Added in letter NG-09-0764 in response to RAI B.3.22-1]

44. Fire Protection Program The DAEC Surveillance Procedure for the CO2 Cardox System 18.1.22 Prior to the Operability Annual Test will be enhanced to include a step to period of perform an inspection for corrosion and mechanical damage to extended system components. operation

[Added in letter NG-09-0764 in response to RAI B.3.22-1]

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

45. ASME Class 1 Small-bore Implement an ASME Code Class 1 Small-bore Piping Inspection 18.1.40 Prior to the Piping Inspection Program Program period of extended DAEC will perform volumetric examination of a minimum of ten operation percent of the ASME Code Class 1 small-bore socket welds each inspection interval.

The ASME Code Class 1 Small-bore Piping inspection program will include provisions that a destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations.

[Added in letter NG-09-0764 in response to RAI B.3.3-2]

[Revised in letter NG-10-0258]

[Revised in letter NG-10-0309]

46. BWR Vessel Internals The BWR Vessel Internals Program will incorporate the crack 18.1.14 Prior to the Program growth rate evaluations specified in the BWRVIP-100-A report. period of Plant-specific inspection intervals will be developed for DAEC extended core shroud welds that are exposed to a neutron fluence value operation equal to or greater than 1 X 1021 n/cm2 (E > 1 MeV), as needed.

[Added in letter NG-09-0663 in response to RAI B.3.14-5]

47. Not Used

[Withdrawn in letter NG-10-0091]

48. Boral Surveillance Implement a Boral Surveillance Program and complete the first 18.1.41 Prior to the Program in-situ neutron attenuation test of the PaR spent fuel racks. period of extended

[Added in letter NG-10-0009]

operation Page 12 of 14

Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

49. Fire Protection Program Enhance procedures to inspect the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire rated gypsum 18.1.22 Prior to the board wall that separates the control room computer room area period of from the front panel area for aging due to cracking. extended operation

[Added in letter NG-10-0043]

50. ASME Section XI, Perform recoating of suppression pool interior surfaces below 18.1.4 Complete Inservice Inspection, the water line. recoating Subsection IWE Program prior to

[Added in letter NG-10-0091]

startup from the first refuel outage during the period of extended operation

51. Metal Fatigue of Reactor Future revisions/updates to the environmental fatigue 18.2.2 Upon Vessel Coolant Pressure calculations for the Recirculation Inlet Nozzle Safe End, calculation Boundary Program Feedwater Nozzle Safe End, and Core Spray Nozzle Safe End revision.

will use Fen data for Nickel Alloy from the methodology that is described in NUREG/CR-6909 in the determination of usage factors.

[Added in letter NG-10-0258]

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Enclosure 3 to NG-10-0383 Duane Arnold Energy Center License Renewal Application Updated LRA Section 18.4, Table A-1, Duane Arnold License Renewal Commitments TABLE A-1 DUANE ARNOLD LICENSE RENEWAL COMMITMENTS1 Item System, Component or Commitment2 Section Schedule No. Program

52. Buried Piping and Tanks Enhance the Buried Piping and Tanks Inspection Program to 18.1.7 Prior to the Inspection Program include inspection of at least a minimum number of pipe period of segments in each material group (one stainless steel, two extended carbon steel, one cast iron, and two ductile iron) prior to entry operation into the period of extended operation and each ten year period after entry into the period of extended operation. Where torsional guided wave data indicates significant susceptibility, inspections will be performed on associated locations. The sample locations for directed inspections will preferentially select higher risk locations. These directed inspections will be performed with sufficient excavation to expose at least ten linear feet of piping as practicable, including the pipe bottom.

Inspections of coated carbon steel piping will include the coating and backfill in the vicinity of the piping for material that could cause coating damage. The uncoated stainless steel, ductile iron and cast iron piping will be externally inspected for corrosion, and the fill in the vicinity of the piping will be inspected for material that could cause external damage to the stainless steel, ductile iron or cast iron pipe.

[Added in letter NG-10-0383]

Cathodic Protection System annual availability will be

53. Buried Piping and Tanks 18.1.7 Prior to the maintained 90%. The availability will be demonstrated by Inspection Program period of having no more than six months of rectifier out of service time in extended any twelve month period. Annual surveys will continue to be operation performed in accordance with NACE Standard Practice.

[Added in letter NG-10-0383]

1 Table is updated to reflect DAEC correspondence through 7/29/2010.

2 In the table, the term implement means that the program is described in an approved procedure or other approved formal document; the test, inspection or monitoring procedure has been developed and approved; and the first test, inspection or monitoring activity has been scheduled.

Page 14 of 14