ML093500306
| ML093500306 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 01/04/2010 |
| From: | Daily J NRC/NRR/DLR/RPOB |
| To: | Heacock D Dominion Energy Kewaunee |
| Daily J, NRR/DLR, 415-3873` | |
| References | |
| TAC MD9408 | |
| Download: ML093500306 (5) | |
Text
January 4, 2010 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center - 2SW 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW/AGING MANAGEMENT PROGRAM (TAC NO.
MD9408)
Dear Mr. Heacock:
By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. submitted an application for renewal of Operating License No. DPR-43 for the Kewaunee Power Station. The staff of the U.S. Nuclear Regulatory Commission (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. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information (RAIs) are included in the enclosure. Further RAIs may be issued in the future.
Items in the enclosure were discussed with Mr. Paul Aitken, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter.
If you have any questions, please contact me by telephone at 301-415-3873 or by e-mail at John.Daily@nrc.gov.
Sincerely,
/RA/
John Daily, Senior Project Manager Programs Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305
Enclosure:
As stated cc w/encl: See next page
January 4, 2010 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center - 2SW 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW/AGING MANAGEMENT PROGRAM (TAC NO.
MD9408)
Dear Mr. Heacock:
By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. submitted an application for renewal of Operating License No. DPR-43 for the Kewaunee Power Station. The staff of the U.S. Nuclear Regulatory Commission (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. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information (RAIs) are included in the enclosure. Further RAIs may be issued in the future.
Items in the enclosure were discussed with Mr. Paul Aitken, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter.
If you have any questions, please contact me by telephone at 301-415-3873 or by e-mail at John.Daily@nrc.gov.
Sincerely,
/RA/
John Daily, Senior Project Manager Programs Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
See next page ADAMS Accession Number: ML093500306 OFFICE PM:RPOB:DLR LA:RPOB:DLR BC:RPOB:DLR PM:RPOB:DLR NAME JDaily SFigueroa DVotolato JDaily (Signature)
DATE 01/04/10 12/29/09 01/04/10 01/04/10 OFFICIAL RECORD COPY
Letter to David A. Heacock from John Daily dated January 04, 2020
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW/AGING MANAGEMENT PROGRAM (TAC NO.
MD9408)
DISTRIBUTION:
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ENCLOSURE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI 3.3.2.1-3
=
Background===
License renewal application (LRA) Table 3.3.1 Item 3.3.1-80 and Standard Review Plant for Review of License Renewal Applications for Nuclear Power Plants Table 3.3-1, ID 80 address the loss of material due to pitting, crevice, and microbiologically influenced corrosion of stainless steel and copper piping, piping components and piping elements exposed to raw water. The applicant proposes to manage this aging process through the use of its aging management program (AMP), Structures Monitoring Program, (LRA B2.1.31). The Generic Aging Lessons Learned (GALL) Report recommends that this aging process be managed through the use of the AMP, Open Cycle Cooling Water System, (GALL AMP XI.M20). The proposed AMP is not consistent with the AMP proposed by the GALL Report. As a result, the applicant proposes that the aging management review items associated with LRA Item 3.3.1-80 are consistent with the GALL Report in terms of material, environment, and aging effect however a different AMP is credited (Generic Note E).
Issue In its review of LRA Item 3.3.1-80, the staff noted that there are two items subordinate to this LRA item. These items are sumps in the reactor containment vessels system (LRA table 3.5.2-
- 1) and trash grills anchorage in the intake structure system (LRA table 3.5.2-11). It is clear to the staff that the sumps addressed in Table 3.5.2-1 are structural and that these sumps would not benefit from the aging management activities contained in the open cycle cooling water program other than visual inspection, i.e., activities such as heat exchanger testing are not applicable to sumps. Since the structures monitoring program contains visual inspection procedures which are sufficient to address all aging effects which are applicable to sumps, the staff has no objection to the use of the structures monitoring program to manage this aging.
However, it is not clear to the staff that the trash grills anchorage addressed in LRA Table 3.5.2-11 would not benefit from the aging management activities associated with the Open Cycle Cooling Water AMP. For example, it is not clear to the staff that an accumulation of mussels or clams on these anchorages would not obstruct water flow to the trash grills. Therefore, it is not clear to the staff that these anchors should not be subject to biocide applications and detailed inspections for the presence of biofouling organisms as contained in the Open Cycle Cooling Water AMP.
Request Please provide sufficient information concerning the configuration of the trash grills anchorage to permit the staff to conclude that issues associated with biofouling or other degradation issues addressed by the Open Cycle Cooling Water AMP but not addressed by the Structures Monitoring Program AMP are not significant or propose to manage this aging using the Open Cycle Cooling Water or equivalent AMP.
RAI 3.3.2.3-6
=
Background===
LRA Tables 3.3.2-3, 3.3.2-8, 3.3.2-9, 3.3.2-20, 3.3.2-21, 3.3.2-22, 3.3.2-25, and 3.3.2-26 contain items which address loss of material due to erosion from the internal or external surfaces of steel piping, piping components, and piping elements and heat exchanger components exposed to raw water. The applicant proposes to manage this aging through the use of its AMP, Work Control Process, (LRA AMP B2.1.32). The applicant proposes that for the component, material, and environment combination listed, the aging effect being considered is not included in the GALL Report (Generic Note H).
Issue In its review of these items, the staff notes that the portion of the Work Control Process (WCP)
AMP being employed is that which claims consistency with the GALL Report AMP, Inspection of Internal Surfaces of Miscellaneous Piping and Ducting. The staff also notes that the program description for the WCP AMP states that it is applicable to piping, piping components, and ducting. The scope of the GALL Report AMP states that it is also applicable to piping, piping elements, and ducting and components in an internal environment (such as indoor uncontrolled air, condensation, and steam). The staff further noted that some of the components under consideration are heat exchangers exposed to raw water. The staff finally noted that heat exchangers exposed to raw water fall outside the scope of both the WCP AMP and the GALL Report AMP. The staff has no technical issue with the inclusion of heat exchanger components as the inspection techniques necessary to identify erosion in piping will also identify erosion in heat exchangers. The staff does, however, have an administrative objection to the inclusion of heat exchanger components in this AMP. Just as the inclusion of materials beyond the scope of the GALL Report AMP required an exception to the WCP AMP, the inclusion of components outside the scope of the GALL Report AMP, also requires an exception be taken.
Also during its review of these items, the staff noted that Generic Letter 89-13 applies to some raw water systems. The aging of systems to which Generic Letter 89-13 applies must be managed using the Open Cycle Cooling Water AMP. Based on the information provided, it is readily apparent that most of the components under consideration, e.g., drain systems, are outside the scope of Generic Letter 89-13 and that the use of the WCP AMP is acceptable because it contains inspection techniques which will identify loss of material due to erosion. It is not, however, apparent that Generic Letter 89-13 does not apply to all of the components under consideration.
Request Please take an exception to the WCP AMP to include heat exchanger components in the scope of the AMP or justify why such an exception is unnecessary and confirm that Generic Letter 89-13 does not apply to any of the components under consideration.
RAI 3.3.2.3-7
=
Background===
LRA Tables 3.3.2-17 and 3.3.2-28 contain items which address loss of material due to general corrosion from the internal and external surfaces of steel components exposed to uncontrolled indoor air. The applicant proposes to manage this aging through the use of its WCP (LRA AMP B2.1.32). The applicant proposes that for the component, material, and environment combination listed, the aging effect being considered is not included in the GALL Report (Generic Note H).
Issue In its review of these items, the staff noted that the aging effect identified by the applicant is applicable for this combination of component, material, and environment. The staff also noted that the scope of LRA AMP for metallic materials is limited to internal surfaces. The staff further noted that the visual inspections included in the AMP are capable of detecting loss of material due to general corrosion. The staff, therefore, finds the applicants proposal to manage the loss of material from the internal surfaces of the components under consideration in Item 3.3.2-28 acceptable because the component is within the scope of the AMP and appropriate inspection methods are included in the proposed AMP. However, the staff questions the use of the WCP AMP for the management of loss of material from the external surfaces of the compressor included in Item 3.3.2-17 because external surfaces are not within the scope of the proposed AMP.
Request Please justify the use of the WCP AMP for external surfaces or select an AMP which is appropriate for use on external surfaces.
Kewaunee Power Station cc:
Resident Inspectors Office U.S. Nuclear Regulatory Commission N490 Hwy 42 Kewaunee, WI 54216-9510 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc.
Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc.
Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Mr. Michael J. Wilson, Director Nuclear Safety & Licensing Dominion Energy Kewaunee, Inc.
Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Mr. William R. Matthews Senior Vice President - Nuclear Operations Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Alan J. Price Vice President - Nuclear Engineering Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. William D. Corbin Director - Nuclear Engineering Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Paul C. Aitken Supervisor - License Renewal Project Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. David A. Sommers Supervisor - Nuclear Engineering Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Ms. Lillian M. Cuoco, Esq.
Senior Counsel Dominion Resources Services, Inc.
120 Tredegar Street Riverside 2 Richmond, VA 23219 Mr. Stephen E. Scace Site Vice President Dominion Energy Kewaunee, Inc.
Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Mr. David R. Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, N.W.
Washington, DC 20037-1122 Mr. Ken Paplham E 4095 Sandy Bay Rd.
Kewaunee, WI 54216 Mr. Jeff Kitsembel, P.E.
Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854