ML083470367

Draft RAI on Proposed Amendment Extension of 15-Year Containment ILRT

ML083470367
Person / Time
Site:	Kewaunee
Issue date:	12/12/2008
From:	Tam P Plant Licensing Branch III
To:	Breene T, Gadzala J Dominion Energy Kewaunee
Tam P
References
TAC MD9612
Download: ML083470367 (3)

Text

Accession No. ML083470367 From: Peter Tam Sent: Friday, December 12, 2008 7:57 AM To: 'Jack.Gadzala@dom.com'; Thomas Breene (thomas.l.breene@dom.com);

Craig.D.Sly@dom.com Cc: George Thomas; Brian Lee

Subject:

Kewaunee - Draft RAI re. ILRT interval extension amendment ( TAC MD9612)

Jack:

We are continuing our review of your 9/11/08 application regarding the subject proposed amendment. Our Mechanical and Civil Engineering Branch has developed the following RAI questions which we would like to discuss with you in a conference call.

1. Based on the application, the NRC staff finds that the root cause and reason for the proposed amendment to extend the Type A test interval beyond the approved 15 years is error on the licensees part in developing, interpreting and implementing the requirement in Technical Specifications (TS) Section 4.4.a and related sections. The language of the TS 4.4.a was subject to interpretation and was interpreted erroneously. The TS language, developed by the licensee, should be an accurate, complete, clear and stand-alone representation of the requirement(s) resulting from an LAR. The TS language should exhibit clarity in a manner that is not subject to interpretation and is not contradictory to or conflicting with other requirements in the same or related TS sections. The language of the proposed change to TS 4.4.a does not meet the above criteria, as explained below:

A TS requirement must be met in its entirety as written. The first two sentences of the second paragraph in TS 4.4.a appear to conflict with the proposed new third sentence, resulting in two conflicting requirements for the due date for the Type A test immediately following the April 1994 test. The staff notes that the TS 4.4.a requirement, as proposed in the submittal, can be met in its entirety only by complying with the more stringent of the two requirements, which is denoted in the first two sentences. In other words, the proposed requirement can be met only by performing the next test by April 2009, which is not any different from the existing TS requirement.

Thus, it appears that the licensee has neither addressed nor corrected the root cause of the error that resulted in the need for the subject LAR but has repeated the same practice that led to the error. While disregarding the root cause of the issue, the licensee has made several arguments in Sections 3.3.1, 3.3.2, and 4.4.3 in Attachment 1 of the reference LAR, in an attempt to justify them as compelling or unforeseen emergent reasons for an extension of the Type A test interval beyond the approved 15 years, which the NRC staff does not agree with. Therefore, in order for the NRC staff to complete its review of this LAR, the licensee is requested to provide information of corrective action(s) and commitment(s), including revised TS language that would eliminate such errors from happening in the future.

2. Attachment 1, Section 3.4.1 Local Leakage Rate Testing (LLRT), provided the combined as-found leakage results of the LLRTs performed since 2003 (in Table 2) and acceptance criteria in terms of maximum allowable combined leakage rate for all

penetrations, to special ventilation zone (Zone SV) and that which bypasses the SV zone. In the context of the information provided in the above stated section of the application: (i) Clarify whether the values provided, in standard cubic centimeters per minute (SCCM), for maximum allowable leakage are based on La value of 0.5 weight percent or based on La value of 0.2 weight percent; (ii) Explain the approximately two-fold increase in Maximum Pathway Leakage from All Penetrations and five-fold increase in Maximum Pathway Leakage to Zone SV in Table 2 for the period between 2006 and 2008 and actions taken, if any, to address the relatively significant increase in leakage.

3. With reference to the discussion in the last paragraph of page 18 in Section 3.4.2 of Attachment 1, explain how the intent of the requirement for visual examination in Regulatory Position C.3 in RG 1.163 (September 1995) is being implemented at Kewaunee considering the 15-year Type A test interval as opposed to the 10-year interval in the regulatory position. Indicate when the next such visual examination will be performed.

This e-mail aims solely to prepare you and others for the proposed conference call. This e-mail does not formally convey an NRC staff position, and does not formally request for additional information. However, with or without the proposed conference call, we plan to issue the above questions in a formal RAI by 12/19/08.

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451 E-mail Properties Mail Envelope Properties (C56E360E9D804F4B95BC673F886381E71827DC21FA)

Subject:

Kewaunee - Draft RAI re. ILRT interval extension amendment ( TAC MD9612)

Sent Date: 12/12/2008 7:57:10 AM Received Date: 12/12/2008 7:57:00 AM From: Peter Tam Created By: Peter.Tam@nrc.gov Recipients:

Jack.Gadzala@dom.com ('Jack.Gadzala@dom.com')

Tracking Status: None thomas.l.breene@dom.com (Thomas Breene (thomas.l.breene@dom.com))

Tracking Status: None Craig.D.Sly@dom.com (Craig.D.Sly@dom.com)

Tracking Status: None George.Thomas2@nrc.gov (George Thomas)

Tracking Status: None Brian.Lee@nrc.gov (Brian Lee)

Tracking Status: None Post Office:

HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 15878 12/12/2008 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: