ML13254A150
| ML13254A150 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 09/06/2013 |
| From: | Anderson R L NextEra Energy Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NG-13-0274 | |
| Download: ML13254A150 (7) | |
Text
NEXTeraENERG-7Y6 September 6, 2013NG-1 3-0274U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Duane Arnold Energy CenterDocket No. 50-331Renewed Op. License No. DPR-49License Renewal Commitment Changes
References:
- 1) NUREG-1955, "Safety Evaluation Report Related to the LicenseRenewal of Duane Arnold Energiy Center,"
dated November 30,2010 (ML103070013)
- 2) NUREG -1801, "Generic Agingi Lessons learned (GALL) Report,"Revision 2, December, 2010In Reference 1, the NRC Staff documented their safety review of the renewal ofthe Duane Arnold Energy Center (DAEC) Operating License.
Included in thisreview were a number of commitments requiring NextEra Energy Duane Arnold,LLC, hereafter NextEra Energy Duane Arnold, to implement aging management programs.
These commitments were subsequently incorporated into the NextEraEnergy Duane Arnold Updated Final Safety Analysis Report (UFSAR) inaccordance with 10 CFR 50.71(e).
The Staff has updated the generic guidance for aging management as reflected in Reference
- 2. NextEra Energy Duane Arnold has identified several instances where the existing commitments in the NextEra Energy Duane Arnold UFSAReither require clarification to ensure proper implementation, or warranted updating to reflect later guidance contained in Reference
- 2. These changeshave been evaluated in accordance with our commitment control procedures andin accordance with 10 CFR 50.59.The enclosure to this letter provides a summary of these commitment changes.N EfuNextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 XIJV[X'-'
Document Control DeskNG-13-0274 Page 2 of 2If you have any questions or require additional information, please contact KenPutnam at 319-851-7238.
- ichard L. Andke ZsoVice President, Duane Arnold Energy CenterNextEra Energy Duane Arnold, LLCEnclosure cc: Regional Administrator, USNRC, Region IIIResident Inspector, USNRC, Duane Arnold Energy CenterProject Manager, USNRC, Duane Arnold Energy Center Attachment to NG-1 3-0274Summary of Commitment Chanqes to the Aqingi Management ProgramsRequired Per NUREG-1955 4 pages follow Enclosure to NG-1 3-0274Commitment 36: Thermal Aging and Neutron Irradiation Embrittlement of CastAustenitic Stainless Steel (CASS) Program, XI.M13Existing Commitment:
Implement a Thermal Aging and Neutron Irradiation Embrittlement of CastAustenitic Stainless Steel (CASS) Program.Reason for Commitment Change:Generic Aging Lessons Learned (GALL) Rev.1 included a program for ThermalAging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel,XI.M13. GALL Rev. 2 incorporated into the XI.M9, BWR Vessel Internals Program inspections for degradation of wrought and cast reactor vessel internalcomponents due to neutron and thermal embrittlement using VT-1 inspections.
The inspections of the susceptible Cast Austenitic Stainless Steel components will be performed under the Augmented ISI Program.
Previous inspections ofthese components were limited to the weld area. The first exams fully consistent with the enhanced program will be performed during the 2014 refueling outage. Astandalone CASS Program will not be implemented as the inspections areperformed under another aging management program.Revised Commitment:
Enhance the Augmented Inspection procedures for the BWR Vessel Internals Program implementing procedures to include inspection for thermal and/orneutron embrittlement in susceptible Cast Austenitic Stainless Steel (CASS)components.
Commitment 52: Buried Piping and Tanks Inspection
- Program, XI.M34Existinq Commitment:
Enhance the Buried Piping and Tanks Inspection Program to include inspection of at least a minimum number of pipe segments in each material group (onestainless steel, two carbon steel, one cast iron, and two ductile iron) prior to entryinto the period of extended operation and each ten-year period after entry intothe period of extended operation.
Where torsional guided wave data indicates significant susceptibility, inspections will be performed on associated locations.
The sample locations for directedinspections will preferentially select higher risk locations.
Piping that normallycontains hazardous materials will be prioritized in the inspection locationselection process.
The diesel fuel oil piping will be inspected prior to entry intothe period of extended operation.
These directed inspections will be performed Enclosure to NG-1 3-0274with sufficient excavation to expose at least ten linear feet of piping aspracticable, including the pipe bottom. Inspections of coated carbon steel pipingwill include the coating and backfill in the vicinity of the piping for material thatcould cause coating damage. The uncoated stainless steel, ductile iron and castiron piping will be externally inspected for corrosion, and the fill in the vicinity ofthe piping will be inspected for material that could cause external damage to thestainless steel, ductile iron or cast iron pipe.Reason for Commitment Changqe:The applicable section of GALL Rev. 2, under the XI.M41, Buried andUnderground Piping and Tanks allows the inspection of buried and underground piping and tanks to be hydrostatically tested or examined internally by a methodcapable of determining pipe wall thickness instead of excavation of 10 linear feetof piping. The alternate inspection methods ensure piping is capable ofperforming its intended function without the need for extensive excavation andbackfill and may be a more appropriate inspection for some piping.Revised Commitment:
Enhance the Buried Piping and Tanks Inspection Program to include inspection of at least a minimum number of pipe segments in each material group (onestainless steel, two carbon steel, one cast iron, and two ductile iron) prior to entryinto the period of extended operation and each ten-year period after entry intothe period of extended operation.
Where torsional guided wave data indicates significant susceptibility, inspections will be performed on associated locations.
The sample locations for directedinspections will preferentially select higher risk locations.
Piping that normallycontains hazardous materials will be prioritized in the inspection locationselection process.
The diesel fuel oil piping will be inspected prior to entry intothe period of extended operation.
These directed inspections will be performed with sufficient excavation to expose at least ten linear feet of piping aspracticable, including the pipe bottom. Inspections of coated carbon steel pipingwill include the coating and backfill in the vicinity of the piping for material thatcould cause coating damage. The uncoated stainless steel, ductile iron and castiron piping will be externally inspected for corrosion, and the fill in the vicinity ofthe piping will be inspected for material that could cause external damage to thestainless steel, ductile iron or cast iron pipe.As alternatives to direct external inspections involving excavation, the buriedpiping inspections may be performed by a hydrostatic test on at least 25% of thecode class/safety-related or hazmat piping or both constructed from the materialunder consideration on an interval not to exceed 5 years. Or, similarly, at least25% of the code class/safety-related or hazmat piping or both constructed fromthe material under consideration will be internally inspected by a method capableof precisely determining pipe wall thickness on an interval not to exceed 5 years.
Enclosure to NG-13-0274 Commitment 55- One-Time Inspection
- Program, XI.M32Existinq Commitment:
The sample selection for the DAEC One-Time Inspection program will include arepresentative sample of approximately 20% of the population (defined as having thesame material environment combination) or a maximum of 25 components with theexception of carbon steel and cast iron in a fuel oil environment.
Existing maintenance records that document component condition will be used as part of the sample.Reason for Commitment Change:During implementation of the One Time Inspection Program it was recognized that therewas ambiguity in the commitment with respect to what constituted a separate groupingof material and environment combinations with respect to calculating the sample size ofrequired inspections for aging. The following commitment change eliminates thatambiguity.
The specified number of required inspections is consistent with a target ofapproximately 20% of the population (defined as having the same material environment combination) or a maximum of 25 components with the exception of carbon steel andcast iron in a fuel oil environment.
The table clarifies the separate environmental groupings and material combinations with respect to selecting the sample of requiredinspections for aging that will be used. Since the aging effects of Carbon Steel andStainless Steel are the same in Sample Group 3 and Sample Group 4 the requirednumber of inspections for both groups were added together totaling 57.Revised Commitment:
The sample selection for the DAEC One-Time Inspection program will include arepresentative sample of the population.
Existing maintenance records that documentcomponent condition will be used as part of the sample. The material environment combinations and the number of required inspections for the sample group will be asshown in the following table:Sample Group Materials in the Sample Group Environment Number ofRequired Environment Inspections.
Sample Group 1- Carbon Steel and Cast Iron 6Fuel Oil Stainless SteelSample Group 2- Aluminum alloy 38Lube Oil Carbon Steel and Cast IronCopper Alloy including Admiralty BrassStainless Steel including Cast Austenitic Stainless SteelSample Group Copper Alloy, Copper, Admiralty Brass, Brass 573/4-Steam and Carbon Steel, Low Alloy Steel and Cast IronTreated Water, Stainless Steel Including Cast Austenitic Reactor Coolant Stainless Steel Stainless Steel Cladding of Lowand Sodium Alloy Steel with Carbon Steel and Nickel AlloyPentaborate I
Enclosure to NG-13-0274 ATTACHMENT 1(Revised Commitments for Table 18-1 of UFSAR)Item No.1System7, Component
- .. or Commitment.
Section Schedule:
Program36. (Thermal Aging Implement a Thermal Aging and Neutron Irradiation 18.1.38 Prior to theand Neutron Embrittlement of Cast Austenitic Stainless Steel period ofIrradiation (CASS) Program.
extendedEmbrittlement of operation Cast Austenitic
[Revised in DAEC letter NG-09-0764 in response toStainless Steel New Program Commitment RAI](CASS) Program)52. (Buried Pipingand TanksInspection Program)Enhance the Buried Piping and Tanks Inspection Program to include inspection of at least a minimumnumber of pipe segments in each material group(one stainless steel, two carbon steel, one cast iron,and two ductile iron) prior to entry into the period ofextended operation and each ten-year period afterentry into the period of extended operation.
Wheretorsional guided wave data indicates significant susceptibility, inspections will be performed onassociated locations.
The sample locations fordirected inspections will preferentially select higherrisk locations.
Piping that normally containshazardous materials will be prioritized in theinspection location selection process.
The dieselfuel oil piping will be inspected prior to entry into theperiod of extended operation.
These directedinspections will be performed with sufficient excavation to expose at least ten linear feet ofpiping as practicable, including the pipe bottom.Inspections of coated carbon steel piping willinclude the coating and backfill in the vicinity of thepiping for material that could cause coatingdamage. The uncoated stainless steel, ductile ironand cast iron piping will be externally inspected forcorrosion, and the fill in the vicinity of the piping willbe inspected for material that could cause externaldamage to the stainless steel, ductile iron or castiron pipe.18.1.7Prior to theperiod ofextendedoperation
[Added in letter NG-10-0383]
[Revised in letter NG-10-0427]
- 55. (One-Time The sample selection for the DAEC One-Time 18.1.32 Prior to theInspection Inspection program will include a representative period ofProgram) sample of the population.
Existing extendedmaintenance records that document component operation condition will be used as part of the sample.[Revised in DAEC letter NG-09-0764 in response toNew Program Commitments RAI]