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MONTHYEARML14031A1462014-01-29029 January 2014 Update to NextEra Energy Duane Arnold, Llc'S Response to NRC Request for Additional Information Associated with Near-Term Task Force Recommendations Project stage: Response to RAI ML14162A1762014-06-17017 June 2014 Staff Assessment of the Flooding Walkdown Report Supporting Implementation of Near-Term Task Force Recommendation 2.3 Related to the Fukushima DAI-ICHI Nuclear Power Plant Accident Project stage: Other 2014-01-29
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Category:Letter
MONTHYEARL-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) NG-23-0010, Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-12-0606 December 2023 Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule NG-23-0009, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment NG-23-0006, Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-05-23023 May 2023 Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update ML23137A1672023-05-11011 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report NG-23-0004, 2022 Annual Radioactive Material Release Report2023-04-25025 April 2023 2022 Annual Radioactive Material Release Report NG-23-0003, 2022 Annual Exposure Report - Form 5s2023-04-21021 April 2023 2022 Annual Exposure Report - Form 5s NG-23-0002, 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report2023-03-27027 March 2023 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report NG-23-0001, 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report2023-03-27027 March 2023 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023 and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22339A0012022-12-22022 December 2022 Acceptance of Requested Licensing Action Amendment Request for Common Emergency Plan IR 05000331/20220032022-12-13013 December 2022 NRC Inspection Report No. 05000331/2022003 (Drss) ML22285A0072022-10-13013 October 2022 NRC Analysis of NextEra Energy Duane Arnold'S Decommissioning Funding Status Report, Docket No. 50-331 IR 05000331/20220022022-07-13013 July 2022 NRC Inspection Report Nos. 05000331/2022002(DNMS) and 07200032/2022002(DNMS) ML22090A1922022-05-26026 May 2022 Letter to B. Coffey, FPL from M. Doell - Duane Arnold Post Shutdown Activities Report Review Letter ML22132A2872022-05-24024 May 2022 ISFSI DQAP Approval Letter ML22111A0332022-05-20020 May 2022 Operating License Page Correction Letter to B. Coffey, Florida Power and Light, from M. Doell NG-22-0055, Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan2022-05-20020 May 2022 Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan ML22089A0492022-05-12012 May 2022 Sfmp Review Letter NG-22-0053, 2021 Annual Radiological Environmental Operating Report2022-05-0606 May 2022 2021 Annual Radiological Environmental Operating Report NG-22-0052, Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative2022-05-0404 May 2022 Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative IR 05000331/20224012022-04-27027 April 2022 Decommissioning Security Inspection Report 05000331/2022401 NG-22-0050, Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 02022-04-26026 April 2022 Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 0 NG-22-0049, 2021 Annual Radioactive Material Release Report2022-04-26026 April 2022 2021 Annual Radioactive Material Release Report L-2022-068, NextEra Energy Duane Arnold Quality Assurance Topical Report (FPL-3) Revision 22022-04-25025 April 2022 NextEra Energy Duane Arnold Quality Assurance Topical Report (FPL-3) Revision 2 ML22066A7632022-04-25025 April 2022 ISFSI-Only Emergency Plan License Amendment Approval NG-22-0035, Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 02022-04-13013 April 2022 Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 0 NG-22-0047, Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2022-04-11011 April 2022 Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool NG-22-0042, Registration of Independent Spent Fuel Installation Storage Casks2022-04-0808 April 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0041, and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report2022-03-31031 March 2022 and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-22-0031, 2021 Annual Exposure Report - Form 5s2022-03-23023 March 2022 2021 Annual Exposure Report - Form 5s NG-22-0030, Registration of Independent Spent Fuel Installation Storage Casks2022-03-23023 March 2022 Registration of Independent Spent Fuel Installation Storage Casks ML22080A1822022-03-22022 March 2022 Letter to B. Coffey from M. Doell - Duane Arnold ISFSI QAPD RAI Letter L-2022-012, Florida Power & Light Company Nuclear Property Insurance - 10 CFR 50.54(w)(3)2022-03-16016 March 2022 Florida Power & Light Company Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML22059A7462022-03-10010 March 2022 ISFSI-Only Physical Security Plan License Amendment Approval NG-22-0025, Registration of Independent Spent Fuel Installation Storage Casks2022-03-0808 March 2022 Registration of Independent Spent Fuel Installation Storage Casks IR 05000331/20220012022-03-0404 March 2022 Subject: NRC Inspection Report Nos. 05000331/2022001(DNMS) and 07200032/2022001(DNMS) NG-22-0021, Registration of Independent Spent Fuel Installation Storage Casks2022-02-24024 February 2022 Registration of Independent Spent Fuel Installation Storage Casks ML22007A2722022-02-11011 February 2022 Cover Letter - NRC Duane Arnold Exemption Issuance NG-22-0014, Registration of Independent Spent Fuel Installation Storage Casks2022-02-10010 February 2022 Registration of Independent Spent Fuel Installation Storage Casks ML22028A2822022-02-0303 February 2022 Defueled Physical Security Plan License Amendment Approval ML22033A0802022-02-0202 February 2022 Supplement to License Amendment Request (TSCR-188): Proposed Change to the Physical Security Plan for the Post-Shutdown and Permanently Defueled Condition IR 05000331/20210012022-01-25025 January 2022 NRC Inspection Report Nos. 05000331/2021001(DNMS); 07200032/2021001(DNMS); and 07200032/2021002(DNMS) - Duane Arnold Energy Center ML21172A2172022-01-21021 January 2022 Issuance of License Amendment to Adopt ISFSI-Only Technical Specifications NG-22-0009, Registration of Independent Spent Fuel Installation Storage Casks2022-01-20020 January 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0001, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister2022-01-0606 January 2022 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister NG-21-0038, Registration of Independent Spent Fuel Installation Storage Casks2021-12-22022 December 2021 Registration of Independent Spent Fuel Installation Storage Casks NG-21-0035, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-12-10010 December 2021 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister 2024-01-25
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML22005A0862022-01-0404 January 2022 1-4-2022 Email Communication to Duane Arnold Regarding Its ISFSI Related Exemption Request on Supplemental Information Needed ML21335A0712021-12-0101 December 2021 Request for Additional Information - Duane Arnold Energy Center ISFSI Only Emergency Plan ML21335A0702021-12-0101 December 2021 Cover Letter to B. Coffey from K. Conway - Duane Arnold Energy Center RAI Re License Amendment Request for ISFSI Only Emergency Plan ML21250A3002021-09-0808 September 2021 Defueled Physical Security Plan RAI Cover Letter ML21006A4052021-01-0606 January 2021 NRR E-mail Capture - Final RAI - Duane Arnold - Post-Shutdown Decommissioning Activities Report ML20316A0212020-11-10010 November 2020 NRR E-mail Capture - Final RAI - Duane Arnold - Duane Arnold Amendment for Proposed Defueled EP and EAL Scheme ML20153A3772020-05-28028 May 2020 NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center Quality Assurance Topical Report (FPL-3) - EPID L-2020-LLQ-0002) ML20141L8132020-05-19019 May 2020 NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center (DAEC) - Exemption Request for Security Training Requirements Due to COVID-19 Pandemic - EPID L-2020-LLE-0042 to 45, L-2020-LLE-0051 ML20133K0482020-05-14014 May 2020 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection ML20127H8662020-05-0505 May 2020 NRR E-mail Capture - Duane Arnold Energy Center (DAEC) - Request for Additional Information (RAI) - Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 1O CFR 50.75(h)(1)(iv) - EPID L-2020-LLE-0011 ML19280A0352019-10-0404 October 2019 NRR E-mail Capture - Final - RAI Related to License Amendment Request (TSCR-182) for Proposed Changes to the Emergency Plan for Permanently Defueled Conditions at Duane Arnold Energy Center (DAEC) - L-2019-LLA-0075 ML18283B0522018-10-0909 October 2018 NRR E-mail Capture - Final Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420 ML18255A2922018-09-11011 September 2018 NRR E-mail Capture - Draft Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420 ML18247A2002018-08-21021 August 2018 E-Mailed Request for Information for Duane Arnold, Dated 08/21/18 (DRS-M.Holmberg) ML18166A2982018-06-15015 June 2018 NRR E-mail Capture - Draft Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 - EPID L-2017-LLA-0420 ML18088A0102018-03-28028 March 2018 NRR E-mail Capture - Final RAI for Duane Arnold (DAEC) 5th-10 Year ISI (RR-05) ML18058A0522018-02-27027 February 2018 Enclosurequest for Additional Information (Letter: RAI Regarding Florida Power and Light/Nextera Decommissioning Funding Plan Updates for St. Lucie, Units 1 & 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach, Units 1 and 2) ML18037B0032018-02-0606 February 2018 NRR E-mail Capture - Draft Request for Additional Information - Duane Arnold Energy Center (DAEC) - License Amendment Request (TSCR-170), Revision to Technical Specification 3.5.1, ECCS-Operating - EPID L-2017-LLA-0288 ML17347A8752017-12-12012 December 2017 NRR E-mail Capture - Second Round of Request for Additional Information - Duane Arnold Energy Center (DAEC) - LAR to Adopt TST-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829 ML17277A3652017-10-0404 October 2017 NRR E-mail Capture - Final Request for Additional Information - Duane Arnold - Application to Revise Technical Specifications to Adopt TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control - CAC No. MF9829 ML17240A0082017-08-25025 August 2017 NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center (DAEC) - Fifth Ten Year Service Inspection Interval - Relief Request No. RR-04, Rev. 0 - Proposed Alternative for Seal Weld Procedure Qualification - MF937 ML17220A3332017-08-0808 August 2017 NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center - Relief Request No. RR-03 - Alternative Requirements for Nozzle Inner Radius and Nozzle-To-Shell Welds - CAC No. MF9374 ML17159A7962017-06-0707 June 2017 17 Duane Arnold Energy Center - Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection (Mxg) ML17068A0632017-03-0808 March 2017 NRR E-mail Capture - Final - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - Revision to Staff Augmentation Times in the Duane Arnold Energy Center (DAEC) Emergency Plan (Eplan) - MF8390 ML16333A4622016-11-28028 November 2016 NRR E-mail Capture - Final Request for Additional Information - Duane Arnold Energy Center - LAR - SFP Criticality - MF7486 ML16326A0092016-11-18018 November 2016 NRR E-mail Capture - Request for Additional Information Re. Nextera/Fpl LAR to Adopt TSTF-545 - CACs MF8203, MF8204, MF8208, and MF8209 ML16313A0742016-11-0808 November 2016 NextEra Audit Plan Nov 2016 (DAEC SFP Criticality LAR) ML16075A0032016-03-14014 March 2016 NRR E-mail Capture - Request for Additional Information - Duane Arnold Energy Center - LAR to Reduce the Reactor Steam Dome Pressure Specified in the Technical Specifications 2.1.1, Reactor Core Safety Limits - MF6618 ML16074A3142016-03-14014 March 2016 NRR E-mail Capture - Second Round RAIs - Duane Arnold Energy Center - LAR (TSCR-143) to Extend Containment Leakage Test Frequency - MF6619 ML16022A0092016-01-21021 January 2016 NRR E-mail Capture - Request for Additional Information - LAR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617 ML16021A0122016-01-21021 January 2016 Request for Additional Information by the Containment & Ventilation Branch and PRA Licensing Branch License Amendment Request - Extension of the 10 CFR 50 Appendix J Containment Type a & Type C Test Intervals ML16014A6962016-01-0707 January 2016 E-Mail: Duane Arnold, MOD/50.59 Inspection Request for Information (Jsp) ML16005A6082015-12-24024 December 2015 E-Mail: Duane Arnold Request for Information; December 24, 2015 (AAS) ML15175A0652015-06-23023 June 2015 Ltr. 06/23/15 Duane Arnold Energy Center - Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000331/2015003 (Axd) ML14057A7562014-02-25025 February 2014 14 Duane Arnold CDBI Request for Information ML14031A1462014-01-29029 January 2014 Update to NextEra Energy Duane Arnold, Llc'S Response to NRC Request for Additional Information Associated with Near-Term Task Force Recommendations ML13323B4432013-11-26026 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13255A1982013-09-16016 September 2013 Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) ML13175A3932013-06-27027 June 2013 Request for Additional Information for Review Regarding License Amendment Request to Adopt National Fire Protection Association Standard 805 ML13154A5112013-06-0404 June 2013 Rai'S Following Ifib Analysis of NextEra Energy'S 2013 Decommissioning Funding Status Reports for Duane Arnold Energy Center and Point Beach Units 1 and 2 ML12107A0592012-04-11011 April 2012 NRR E-mail Capture - ME7246 - DAEC - Request for Additional Information (RAI) Relief Requests NDR-R003, R010, R011, R014, R015 ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML1201203182012-01-17017 January 2012 Request for Additional Information Amendment to Change Emergency Action Levels ML12011A0602012-01-0404 January 2012 NRR E-mail Capture - ME6508 - DAEC - Emergency Action Level (EAL) Changes ML1132105812011-11-28028 November 2011 Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, Mitigating Strategies. ML11147A1142011-06-0808 June 2011 Request for Additional Information Regarding License Amendment Request for Approval of Cyber Security Plan 2022-01-04
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NExTera ENERGY4 ARNOLD January 29, 2014 NG-14-0016 10 CFR 50.54(f)U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Update to NextEra Enerqy Duane Arnold, LLC's Response To NRC Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Floodinq -Review of Available Physical Marqin (APM) Assessments
References:
- 1) NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ML12073A348)
- 2) NRC Letter to Nuclear Energy Institute, Endorsement of Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012 (ML12144A142)
- 3) Letter, R. Anderson (NextEra Energy Duane Arnold, LLC) to NRC, "Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding," NG-12-0461, dated November 27, 2012 (ML12342A004)
- 4) NRC Letter, "Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3 Flooding Walkdowns," dated December 23, 2013 (ML13325A891)
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 requesting information on several topics including information associated with Near-Term Task Force Recommendation 2.3, Flooding.
Per Reference 2, the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features." In Reference 3,!NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 Document Control Desk NG-14-0016 Page 2 of 2 NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold)provided the requested information.
NEI 12-07 required licensees to identify the available physical margin (APM)associated with each applicable flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. Following the NRC Staff's initial review of walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the Staff identified additional information, as documented in Reference 4, needed to complete its assessments.
The enclosure to this letter provides the information requested in Reference 4.This letter makes no new commitments or changes to existing commitments.
If you have any questions or require additional information, please contact Ken Putnam at 319-851-7238.
I declare under penalty of perjury that the foregoing is true and correct.Executed on January 29, 2014 N'hard L. Ander n Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure Enclosure to NG-14-0016 Update to NextEra Energy Duane Arnold, LLC's Response To NRC Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding -Review of Available Physical Margin (APM) Assessments 3 pages follow Update to NextEra Energy Duane Arnold, LLC's Response To NRC Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding -Review of Available Physical Margin (APM) Assessments NRC Request 1: Provide confirmation that the process for evaluating APM was reviewed.NextEra Energy Duane Arnold Response to Request 1: NextEra Energy Duane Arnold completed a review of the process used at Duane Arnold Energy Center to evaluate APMs.NRC Request 2: Provide confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.NextEra Energy Duane Arnold Response to Request 2: The original walkdown effort followed the guidance provided in NEI 12-07, including defining and documenting applicability of determined small margin issues. Additional actions were performed to ensure the process is consistent with the information in this RAI.NRC Request 3: Provide, if changes are necessary, a general description of any process changes to establish this consistency.
NextEra Energy Duane Arnold Response to Request 3: The NEI 12-07 walk down effort followed the guidance provided in NEI 12-07, including a definition for a small margin. However, a specific APM was not assigned to the seals in below grade walls associated with flood protection features.
These items have been addressed in accordance with the guidance provided in this RAI, and entered into the corrective action process for further action.NRC Request 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, Page 1 of 3 penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of"significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:* Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response.* Report the APM as "undetermined" and provide the CAP reference in the RAI response.Page 2 of 3 NextEra Enercv Duane Arnold Response to Request 4: Neither Approach A or B, as described above, were used to determine the APM values for seals in below grade walls/floors.
Seals in below grade walls/floors were inspected as part of the original walkdowns for signs of degradation, and corrective actions were initiated, if required.
As part of the actions taken to address this RAI, the seals in below grade walls/floors have been assigned an APM value of "undetermined" and have been entered into the CAP process (CR1934141) for further evaluation of their available physical margin. Implementation of interim actions will be pursued, if necessary.
Page 3 of 3 CARBON COPY LIST FOR NG-14-0016 January 29, 2014 Regional Administrator, USNRC, Region III Resident Inspector, USNRC, Duane Arnold Energy Center Project Manager, USNRC, Duane Arnold Energy Center
Subject:
Update to NextEra Energy Duane Arnold, LLC's Response To NRC Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding -Review of Available Physical Margin (APM) Assessments