ML091120199

RAI, Review of the License Renewal Application - Scoping & Screening Methodology

ML091120199
Person / Time
Site:	Kewaunee
Issue date:	04/30/2009
From:	Hernandez-Quinones S License Renewal Projects Branch 1
To:	Christian D Dominion Energy Kewaunee
Hernandez S, NRR/DLR/REBB, 415-4049
References
TAC MD9408
Download: ML091120199 (6)

Text

April 30, 2009 Mr. David A. Christian 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 - SCOPING AND SCREENING METHODOLOGY (TAC NO. MD9408)

Dear Mr. Christian:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application for renewal of Operating License DPR-43 for the Kewaunee Power Station (KPS).

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. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information are included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with 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 301-415-4049 or by e-mail at samuel.hernandez@nrc.gov.

Sincerely,

/RA/

Samuel Hernández, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

As stated cc w/encl: See next page

April 30, 2009 Mr. David A. Christian 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 - SCOPING AND SCREENING METHODOLOGY (TAC NO. MD9408)

Dear Mr. Christian:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application for renewal of Operating License DPR-43 for the Kewaunee Power Station (KPS).

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. During its review, the staff has identified areas where additional information is needed to complete the review. The staffs requests for additional information are included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with 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 301-415-4049 or by e-mail at samuel.hernandez@nrc.gov.

Sincerely,

/RA/

Samuel Hernández, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

As stated cc w/encl: See next page ADAMS Accession Number: ML091120199 OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:RER2 BC:RPB1:DLR NAME SFigueroa SHernandez RAuluck DPelton DATE 04/ 23/09 04/28/09 04/29/09 04/30/09 OFFICIAL RECORD COPY

Letter to D. Christian from S. Hernandez, dated April 30, 2009 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - SCOPING AND SCREENING METHODOLOGY (TAC NO. MD9408)

HARD COPY:

DLR RF E-MAIL:

PUBLIC B. Holian / S. Lee (RidsNrrDlr)

D. Pelton (RidsNrrDlrRpb1)

S. Hernandez S. Lopas B. Rogers P. Tam M. Kunowski S. Burton P. Higgins V. Mitlyng

Kewaunee Power Station cc:

Resident Inspectors Office Mr. Paul C. Aitken U.S. Nuclear Regulatory Commission Supervisor - License Renewal Project N490 Hwy 42 Innsbrook Technical Center - 3NE Kewaunee, WI 54216-9510 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Chris L. Funderburk Director, Nuclear Licensing and Mr. David A. Sommers Operations Support Supervisor - Nuclear Engineering Dominion Resources Services, Inc. Innsbrook Technical Center - 2SE Innsbrook Technical Center - 2SE 5000 Dominion Boulevard 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Glen Allen, VA 23060-6711 Ms. Lillian M. Cuoco, Esq.

Mr. Thomas L. Breene Senior Counsel Dominon Energy Kewaunee, Inc. Dominion Resources Services, Inc.

Kewaunee Power Station 120 Tredegar Street N490 Highway 42 Riverside 2 Kewaunee, WI 54216 Richmond, VA 23219 Mr. Michael J. Wilson, Director Mr. Stephen E. Scace Nuclear Safety & Licensing Site Vice President Dominion Energy Kewaunee, Inc. Dominion Energy Kewaunee, Inc.

Kewaunee Power Station Kewaunee Power Station N490 Highway 42 N490 Highway 42 Kewaunee, WI 54216 Kewaunee, WI 54216 Mr. William R. Matthews Mr. David R. Lewis Senior Vice President - Nuclear Operations Pillsbury Winthrop Shaw Pittman, LLP Innsbrook Technical Center - 2SE 2300 N Street, N.W.

5000 Dominion Boulevard Washington, DC 20037-1122 Glen Allen, VA 23060-6711 Mr. Ken Paplham Mr. Alan J. Price E 4095 Sandy Bay Rd.

Vice President - Nuclear Engineering Kewaunee, WI 54216 Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Mr. Jeff Kitsembel, P.E.

Glen Allen, VA 23060-6711 Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854

KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION SCOPING AND SCREENING METHODOLOGY Request for Additional Information (RAI) 2.1-1

Background:

10 CFR 54.4(a)(2) requires that all nonsafety-related systems, structures, and components (SSCs) whose failure could prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1)(i-iii) be included within the scope of license renewal LRA Section 2.1.1, Introduction, states that scoping and screening were performed consistent with the guidelines presented in NEI 95-10 [the LRA discussed two clarifications concerning the application of NEI 95-10, neither of which were applicable to determining nonsafety-related SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a)(2)].

LRA Section 2.1.3.6.1, Spatially Oriented NS SSCs Not Directly Attached to SR SSCs, states, in part:

NS components containing or potentially containing moderate or low energy fluids (i.e.,

200°F or 275 psig) were also included in license renewal scope unless both 2(a) and 2(b) below applied:

(a) The NS component could not directly leak or spray on SR components in the immediate area because one of the following conditions existed:

• The NS component was located in a room, cubicle, enclosure, tunnel, or enclosed corridor, which did not contain any SR mechanical or electrical components.

• The NS component was located in an open space, but was separated from SR mechanical or electrical components by solid physical barriers such as walls, floors, ceilings and/or major plant equipment (e.g., the main condenser).

• The NS component was located in an open space, was maintained at or near atmospheric pressure, and there were no SR mechanical or electrical components located within the collapse envelope of the NS component.

(b) The fluid contents of the NS components could not flow from the area through doorways, grating, or floor penetrations, and then drain or drip on or flood SR mechanical or electrical components in adjacent areas, unless an analysis demonstrated that the SR components would not be adversely impacted.

ENCLOSURE

Issue:

The staff has determined that the concept of a collapse envelope is not addressed in NEI 95-10, Appendix F, as a basis for not including fluid filled non-safety related SSCs, in the proximity of safety-related SSCs, within the scope of license renewal. In addition, during the NRC scoping and screening methodology audit performed March 10-13, 2009, the staff performed a walkdown of two nonsafety-related systems, in the proximity of safety-related SSCs, which were not included within the scope of license renewal based on the concept of the collapse envelope.

The staff determined that in addition to the use concept of the collapse envelope there were additional mitigative features not discussed in the LRA (dikes and enclosures).

Request:

The staff requests that the applicant provide a discussion which states that an exception was taken to guidance of NEI 95-10 and provide the basis for the exception (the collapse envelope),

for not including nonsafety-related SSCs, within the proximity of safety-related SSCs, within the scope of license renewal. The discussion should include a definition of collapse envelope and the rationale for the application of the collapse envelope as the basis to not include specific nonsafety-related SSCS within the scope of license renewal. In addition, discuss the use of any mitigative features used in conjunction with the collapse envelope and whether the mitigative features were included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

As part of your response, please address the extent of condition - the number and location of nonsafety-related SSCs, within the proximity of safety-related SSCs but not within the scope of license renewal in accordance with 10 CFR 54.4 (a)(2), based on the concept of a collapse envelope and any associated mitigative features. Indicate whether any associated mitigative features were included within the scope of license renewal.

List any additional SSCs which were included within the scope of license renewal as a result of your review performed in response to this RAI and list those structures and components for which aging management reviews were conducted. For each additional structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.