ML083290275
| ML083290275 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 12/11/2008 |
| From: | Brian Holian Division of License Renewal |
| To: | Richard Anderson Duane Arnold |
| Heath, M, NRR/DLR/RLRA, 415-3137 | |
| References | |
| Download: ML083290275 (5) | |
Text
December11, 2008 Mr. Richard L. Anderson Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324
SUBJECT:
REVIEW STATUS OF THE LICENSE RENEWAL APPLICATION FOR THE DUANE ARNOLD ENERGY CENTER
Dear Mr. Anderson:
By letter dated September 30, 2008, FPL Energy Duane Arnold, LLC submitted an application for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center (DAEC).
The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. Although the staff has not made an acceptance determination, the staff has identified a number of deficiencies. A description of these deficiencies are included in the Enclosure.
In accordance with NUREG-1800, an applicant can modify (i.e., supplement) its application.
The staff requests that FPL Energy Duane Arnold, LLC supplement the license renewal application to address the deficiencies described in the Enclosure and submit the supplement to the NRC for review. Additionally, the staff requests that the application be re-reviewed to identify and correct similar deficiencies that may exist elsewhere in the application. The staff can then complete its review of the application and make a determination as to whether the application is acceptable for docketing. Should the staff find the supplemented application acceptable for docketing, we will establish a review schedule based on the receipt date of your supplement.
Please respond within 14 days of the receipt of this letter to inform the staff of your plans for resolving the deficiencies identified in the Enclosure and supplementing the license renewal application. As a reminder, the provisions of 10 CFR 2.109(b) require a licensee to file a sufficient license renewal application at least five years before the expiration date of the current operating license. If you have any questions on this matter, please contact David Pelton, License Renewal Branch Chief, at 301-415-2307 or Maurice Heath, the DAEC License Renewal Project Manager, at 301-415-3137.
Sincerely,
\\RA\\
Brian Holian, Director Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-331
Enclosure:
As stated cc w/encl: See next page
December11, 2008 Mr. Richard L. Anderson Vice President, Duane Arnold Energy Center FPL Energy Duane Arnold, LLC 3277 DAEC Road Palo, Iowa 52324
SUBJECT:
REVIEW STATUS OF THE LICENSE RENEWAL APPLICATION FOR THE DUANE ARNOLD ENERGY CENTER
Dear Mr. Anderson:
By letter dated September 30, 2008, FPL Energy Duane Arnold, LLC submitted an application for renewal of Operating License No. DPR-49 for the Duane Arnold Energy Center (DAEC).
The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants. Although the staff has not made an acceptance determination, the staff has identified a number of deficiencies. A description of these deficiencies are included in the Enclosure.
In accordance with NUREG-1800, an applicant can modify (i.e., supplement) its application.
The staff requests that FPL Energy Duane Arnold, LLC supplement the license renewal application to address the deficiencies described in the Enclosure and submit the supplement to the NRC for review. Additionally, the staff requests that the application be re-reviewed to identify and correct similar deficiencies that may exist elsewhere in the application. The staff can then complete its review of the application and make a determination as to whether the application is acceptable for docketing. Should the staff find the supplemented application acceptable for docketing, we will establish a review schedule based on the receipt date of your supplement.
Please respond within 14 days of the receipt of this letter to inform the staff of your plans for resolving the deficiencies identified in the Enclosure and supplementing the license renewal application. As a reminder, the provisions of 10 CFR 2.109(b) require a licensee to file a sufficient license renewal application at least five years before the expiration date of the current operating license. If you have any questions on this matter, please contact David Pelton, License Renewal Branch Chief, at 301-415-2307 or Maurice Heath, the DAEC License Renewal Project Manager, at 301-415-3137.
Sincerely, Brian Holian, Director Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-331
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See next page Adams Accession No.:ML083290275 OFFICE PM:RBP1 LA:
BC:RPB1 OGC nlo w/comments D: DLR NAME MHeath IKing DPelton MBaty BHolian (SLee for)
DATE 12/9/08 11/28/08 12/9/08 12/10/08 12/11/08 OFFICIAL RECORD COPY
DESCRIPTION OF DEFICIENCIES FOUND IN DUANE ARNOLD ENERGY CENTER LICENSE RENEWAL APPLICATION The following are examples of deficiencies in the LRA:
(1)
Quality Assurance (QA) of Application Table 3.1.2-1 of the application contains information on the reactor vessel (RV) that is not consistent with the plants current licensing basis documentation. General Electric Capsule Report No. GE-NE-B1100716, Revision 0, for Duane Arnold, which was submitted to the NRC in accordance with 10 CFR 50, Appendix H, identifies that the RV has four RV shells: an upper shell, an upper intermediate shell, a lower intermediate shell, and a lower shell. However, Table 3.1.2-1 of the application only lists three shells for the RV: an upper shell, an intermediate shell, and a lower shell. Furthermore, of these three shells, the application only identifies the RV intermediate shell as within the beltline of the RV. However, the Capsule Report identifies the RV lower intermediate shell and the RV lower shell as within the RV beltline region.
The condensation service environment is not consistently characterized in the application. For example, for the compressed air system, Table 3.3-1 of the application indicates that condensation is wet air/gas. Table 3.3.2-27 indicates that it is air/gas.
Table 3.0-1, under wet air/gas, indicates that condensation is considered raw water.
However, under raw water in Table 3.0-1, it does not discuss condensation.
Metal fatigue of non-Class 1 components is not addressed as time-limited aging analysis (TLAA) as indicated in the application. For example, Sections 3.3.2.2.1 and 3.3.3 indicate that metal fatigue of the auxiliary system is evaluated in Section 4.3 of the application. However, Section 4.3 only addresses metal fatigue of the reactor vessel, Class 1 piping, and core plate rim hold-down bolts.
Information in Appendix C, Responses to BWRVIP Application Action Items, is not consistent with that in the application. For example, Item 4 in Table C-4 states, The DAEC SBLC nozzle has been evaluated for fatigue and shown to be acceptable for 60 years. See Section 4 of this application. However, the staff could not find this information in Section 4 of the application. For another example, Item 4 in Table C-7 states, Of these, fatigue is a TLAA for the CRD stub tube and housing and was determined to be acceptable for 60 years. See Section 4 of this application. However, Table 4.3-2 of the application indicates that these components are exempted.
Chapter 3 of the application contains inconsistent documentation of the potential degradation of heat transfer capability due to fouling for heat exchanger or air cooler surfaces that are exposed to raw water. Sometimes fouling is indicated as an applicable aging effect and sometimes it is not.
(2)
Information that is Too General Chapter 3 of the application identifies the plant water environment as either treated water or raw water. However, the specific water environment, such as reactor coolant, closed-cycle cooling, and borated water (for the standby liquid control system), and specific environmental details, such as water temperature and fluence level, affect the assessment of potential aging effects and aging management. The applicants generalization of water environment causes technical information ambiguities in the application. For example, the application identifies cracking as a potential aging effect for some stainless steel components in treated water but not for others, creating inconsistencies with no explanation.
(3)
Insufficient Information Section 2.0 of the application indicates that the plants integrated plant assessment methodology follows the approach recommended in NEI 95-10. However, NEI-95-10, Section 3.3, Documenting the Scoping Process, indicates that the applicant should identify systems, structures, and components functions that meet the requirements of 10 CFR 54.4(b) and therefore are intended functions. The application does not contain this information for specific systems, structures, and components. It merely repeats the rule language in 10 CFR 54.4(a). The staff sampled sections of the FSAR and often could not determine why a system is or is not within the scope of license renewal based on the FSAR description.
Section 4.7, Other Plant-Specific TLAAs, of the application contains mostly concluding statements of TLAA evaluations. For example, Section 4.7.4, Evaluation of thermal Fatigue Effects on Steam Lead and Inlet to RPV, states that the temperature cycles have been increased by 1.5 and backflow cycles have been added. It then states that the additional cycles during a 60 year life can be tolerated. There is no justification for the assumptions, such as the factor 1.5 and the number of backflow cycles. It also does not discuss the current status, such as the number of cycles experienced, and the acceptance criteria for the TLAA evaluation. Furthermore, no reference for the TLAA is provided in the application.
(4)
Lack of Recent Renewal Review Experience The application does not identify any aging effects for rubber, elastomer, or thermoset polymer for system components.
Duane Arnold Energy Center cc:
Mr. J. A. Stall Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mr. M. S. Ross Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Ms. Marjan Mashhadi Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW Suite 220 Washington, DC 20004 T. O. Jones Vice President, Nuclear Operations Mid-West Region Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Steven R. Catron Manager, Regulatory Affairs Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U.S. Nuclear Regulatory Commission Resident Inspector=s Office Rural Route #1 Palo, IA 52324 Mr. Mano Nazar Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Mr. D. A. Curtland Plant Manager Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785 Abdy Khanpour Vice President, Engineering Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 Daniel K. McGhee Iowa Department of Public Health Bureau of Radiological Health 321 East 12th Street Lucas State Office Building, 5th Floor Des Moines, IA 50319-0075 Chairman, Linn County Board of Supervisors 930 1st Street SW Cedar Rapids, IA 52404 Peter Wells, Acting Vice President, Nuclear Training and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mark E. Warner Vice President, Nuclear Plant Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420