ML092120546
| ML092120546 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/28/2009 |
| From: | Hernandez-Quinones S License Renewal Projects Branch 1 |
| To: | Heacock D Dominion Energy Kewaunee |
| Hernandez S, NRR/DLR/RPB1, 415-4049 | |
| References | |
| TAC MD9408 | |
| Download: ML092120546 (23) | |
Text
August 28, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center - 2SW 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW RESULTS (TAC NO. MD9408)
Dear Mr. Heacock:
By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc., submitted an application for renewal of operating license DPR-43 for the Kewaunee Power Station. 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 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 301-415-4049 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
August 28, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center - 2SW 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW RESULTS (TAC NO. MD9408)
Dear Mr. Heacock:
By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc., submitted an application for renewal of operating license DPR-43 for the Kewaunee Power Station. 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 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 301-415-4049 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 DISTRIBUTION:
See next page ADAMS Accession Number: ML092120546 OFFICE PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR NAME SHernandez IKing DPelton SHernandez (EKeegan for) (Signature)
DATE 08/25/09 08/11/09 08/28/09 08/28/09 OFFICIAL RECORD COPY
Letter to David A. Heacock from Samuel Hernandez dated August 28, 2009
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION - AGING MANAGEMENT REVIEW RESULTS (TAC NO. MD9408)
DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
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________
S. Hernandez V. Perin P. Tam S. Burton K. Barclay M. Kunowski V. Mitlyng I. Couret S. Uttal, OGC
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 Mr. William D. Corbin Madison, WI 53707-7854 Director - Nuclear Engineering Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711
KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION AGING MANAGEMENT REVIEW RESULTS Request for Additional Information (RAI) 3.5.2.2.1.2-1
Background:
In the license renewal application (LRA) Section 3.5.2.2.1.2, the applicant stated that no significant variations in building settlement have been observed. The applicant also stated that the Structures Monitoring Program is used to inspect for visual cracks and distortion. Also, settlement readings are taken every five years.
Issue:
The staff is unable to verify the applicant claims due to lack of supporting data and/or information in the LRA in the following areas:
- What are the baseline and/or acceptable variances in building settlement?
- The latest of the settlement readings Request:
The applicant is requested to provide the support data/information for the above items.
RAI 3.5.2.2.1.4-1
Background:
In the LRA Section 3.5.2.2.1.4, the applicant stated that the reactor containment vessel is housed within the shield building. Also, concrete is designed in accordance with ACI 318-63 and ACI 201.2R-77 which provide a good quality, dense, well cured, and low permeability concrete.
Issue:
The staff is unable to verify the applicant claims due to lack of supporting data and/or information in the LRA in the following areas:
- Air-entrained value or water-cement ratio
- Data for water chemical analysis Request:
The applicant is requested to provide the support data/information for the above items.
ENCLOSURE
RAI 3.5.2.2.2.5-1
Background:
Standard Review Plan for Review of License Renewal Application for Nuclear Power Plants (SRP-LR) Section 3.5.2.2.2.5, which states that cracking due to stress corrosion cracking (SCC) and loss of material due to pitting and crevice corrosion could occur for Group 7 and 8 stainless steel tank liners exposed to standing water. The Generic Aging Lessons Learned (GALL)
Report recommends further evaluation of plant-specific programs to manage these aging effects.
Issue:
For the GALL Aging Management Program (AMP) XI.M29, Aboveground Steel Tanks Program, the applicant stated that the aging management reviews (AMR) did not identify the need for this AMP. The staff is unable to verify the applicant claims due to lack of supporting information in the LRA in the following areas:
- Are there any stainless steel tank liners exposed to standing water at Kewaunee Power Station (KPS)?
- If yes, then how its being managed to the end of the period of extended operation?
Request:
The applicant is requested to provide the support data/information for the above items.
RAI 3.5.2.2.2.6-1
Background:
LRA Section 3.5.2.2.2.6 states that the Structures Monitoring Program manages loss of material for steel structural components. For miscellaneous structural commodities the External Surfaces Monitoring and Fire Protection programs are used.
Issue:
NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 1, Generic Item T-30 recommends the Structures Monitoring Program to manage loss of material and general corrosion. The staff is unclear how the above mentioned programs meet or exceed the Structures Monitoring Program.
Request:
The staff requests that the applicant compare the above mentioned programs with the Structures Monitoring Program. Focus on how the programs will meet or exceed the requirements of the Structures Monitoring Program in relation to the aging effect loss of material/general and pitting corrosion.
RAI 3.5.2.3-4
Background:
LRA Table 3.5.2-10 proposes to manage loss of material/erosion of steel pipe in raw water environment for the discharge tunnel through the use of applicants Structures Monitoring Program. The applicant states that that the GALL Report does not present an aging effect for this component, material, and environment combination and thus assigns Standard Note H.
Issue:
In its review of LRA Table 3.5.2-10, the staff finds that the GALL Report recommends that this material, environmental, and aging effect be managed through the use of the AMP, Open Cycle Cooling Water System (XI.M20). The staff also notes that Generic Letter (GL) 89-13 applies to this component.
Request:
Please propose a program to manage the aging of the components under consideration which is consistent with the AMP recommended by the GALL Report and which meets all plant commitments relating to GL 89-13. Otherwise, justify why the proposed program is sufficient.
RAI 3.5.2.3-5
Background:
In LRA Table 3.5.2-14, the applicant proposes to use its External Surfaces Monitoring for Junction, Terminal, and Pull boxes to manage the aging effect of loss of material, pitting and crevice corrosion. For this AMR item the applicant has assigned the Standard Note E. GALL Report Vol. 1, Table 5, ID 50, recommends the program described in the GALL Report Section XI.S6, Structures Monitoring Program for managing the same aging effects.
Issue:
The applicants External Surfaces Monitoring Program does not monitor inside of the components and also does not include stainless steel. Also, inspection frequency and sampling method for these components are not clear in the applicants proposed program.
Request:
Justify the reason for using the External Surfaces Monitoring Program for managing the aging effect of loss of material, pitting and crevice corrosion of Junction, Terminal, and Pull boxes.
RAI 3.5.2.2.2.2.1-1
Background:
LRA section 3.5.2.2.2.2.1 specified the entrained air content of KPS concrete is between 3% -
7% and the water-cement ratio is between 0.41 - 0.52.
Issue:
GALL Report Vol. 1, Table 5, ID 14, 26, and 35 recommend further evaluations of programs to manage loss of material due to freeze-thaw for concrete structures and elements. The GALL Report further states that evaluation is required for plants that are located in moderate to severe weathering conditions. Documented evidence to confirm that existing concrete has air content of 3%-6% and water-cement ratio 0.35-0.45 and subsequent inspections which do not exhibit degradation related to freeze-thaw, should be considered as part of the evaluation. As stated in the LRA, the amount of entrained air and water-cement ratio are outside the range discussed in the GALL Report. Also, the strength of the various concrete for category I structures is not found in the LRA.
Request:
- 1. Provide the aging management actions that have been followed in the past and present to manage the aging effect i.e., loss of material (spalling, scaling) and cracking due to freeze-thaw.
- 2. What actions, other than opportunistic inspections, will be taken in the future to manage freeze-thaw in inaccessible regions?
- 3. If no additional action is required, provide justification in support of that conclusion.
RAI B2.1.5-5
Background:
In the KPS LRA, an AMR line item exists which references III.B1.1-4 of GALL which manages loss of material for reactor coolant pumps support: plates and structural shapes (columns, brackets, tie bars, etc.). However, no items could be found in the LRA which reference III.B1.1-3 of the GALL Report, even though the two share the same component, material, and environment descriptions. The exclusion of Item III.B1.1-3 leads to the assumption that the associated aging effect, Cracking due to Stress Corrosion Cracking for the component, material, and environment combination is not experienced at KPS. Plant-Specific Note 1, which is listed with LRA AMR Item III.B1.1-4, states that cracking due to SCC is not an aging effect for this component since the bolt is hand tightened and is not under any stress.
Issue:
Although the staff agrees that bolted connections which are not under stress are not at risk of experiencing cracking due to SCC, the staff does not have sufficient information to determine whether there are indeed no stresses applied to the bolt. Residual stresses existent from fabrication, installation process, and operational effects may all contribute to a stress level which meets the threshold for possibility of cracking due to SCC to occur.
Request:
Please provide further justification and analyses on the stress levels experienced by these bolts by providing details on the bolts purpose, hand tightening installation procedure, and consideration of residual stresses in the bolt.
RAI 3.4.2.3.1-1
Background:
Table 3.0-1, Service Environments, states that moisture and water pooling are not assumed in a hydraulic oil environment. In LRA Table 3.4.2-1, it states that components fabricated of copper alloy and stainless steel exposed to hydraulic oil (internal) does not have an aging effect requiring management.
Issue:
The applicant did not provide a basis for its statements that (1) moisture and water pooling are not assumed in a hydraulic oil environment and (2) copper alloy and stainless steel components exposed to hydraulic oil do not have an aging effect requiring management.
Request:
Please provide your basis for the statements made in the LRA pertaining to copper alloy and stainless steel components exposed to hydraulic oil (internal). Please provide any applicable reference sources to support these statements or provide an appropriate program to manage the effects of aging for these components exposed to hydraulic oil (internal).
RAI 3.3.2.3.10-1
Background:
In LRA Table 3.3.2-10, the LRA states that copper alloy tubing (which cite a Note H), which are exposed to air - indoor controlled (internal) do not have an aging effect requiring management; therefore an AMP is not applicable.
Issue:
The applicant did not provide the justification for determining these components are not subject to an aging effect requiring management when exposed to air-indoor controlled (internal). The staff is concerned the internal environment may contain contaminants and stagnant air which is not the same as freely circulating air-indoor controlled on the external surface.
Request:
Please describe in detail, the environmental conditions that exist in the internal environment in the component described above and how it compares to the external environment. Also please justify why these components do not experience an aging effect requiring management.
RAI 3.3.2.2.8-1
Background:
LRA and SRP-LR Sections 3.3.2.2.8 refer to LRA and SRP-LR Tables 3.3.1-19. These tables address the loss of material due to general, pitting, crevice, and microbiologically influenced corrosion (MIC) of steel (with or without coating or wrapping) piping, piping components, and piping elements exposed to soil. These tables recommend further evaluation on the part of the staff. Both the applicant and the GALL Report propose to manage this aging process through the use of the AMP, Buried Piping and Tanks Inspection (LRA B.1.3 and XI.M34).
The applicant proposes that the AMR items associated with Table 3.3.1-19 are either fully consistent with the GALL Report or are consistent in all respects except the component is different (Generic Note C).
Issue:
In its review of LRA Table 3.3.1-19, the staff noted that despite the fact that the component mentioned in Table 3.3.1-19 is steel (with or without coating or wrapping), the buried piping and tanks inspection program recommended by the GALL Report includes only steel pipe that has been coated or wrapped. Given that coatings or wrappings significantly reduce the corrosion of buried piping and given that the buried piping and tanks inspection program is not designed to manage the aging associated with bare steel piping, if bare steel piping exists a more comprehensive AMP will be required. The staff also noted that the application did not contain any AMR items associated with Table 3.3.1-19 for the open cycle cooling water system (GALL Report Volume 2 Table VII.C1-18). The staff questions the absence of piping associated with this table.
Request:
Please confirm that all buried steel piping is coated or wrapped or propose an AMP appropriate for bare steel piping. The staff also requests that the applicant confirm that the plant has no buried piping meeting the criteria of GALL Report Volume 2 Table VII.C1-18.
RAI 3.3.2.2.10.7-1
Background:
LRA and SRP-LR Sections 3.3.2.2.10.7 refer to LRA and SRP-LR Tables 3.3.1-29. These tables address the loss of material due to pitting and crevice corrosion of stainless steel piping, piping components, and piping elements exposed to soil. These tables recommend further evaluation on the part of the staff. The applicant proposes to manage this aging process through the use of its AMP Buried Piping and Tanks Inspection (LRA B2.1.7). The GALL Report recommends that this aging process be managed through the use of a plant-specific AMP. The applicant proposes that the AMR items associated with Table 3.3.1-29 are consistent with the GALL Report in terms of material, environment, and aging effect but a different AMP is credited (Generic Note E).
Issue:
In its review of LRA Table 3.3.1-29, the staff noted that the Buried Piping and Tanks Inspection AMP contained in the GALL Report does not include stainless steel. The staff also noted that the corrosion characteristics of stainless steel differ from carbon steel sufficiently so some of the recommendations contained in the recommended AMP could be counterproductive for stainless steel, e.g., stainless steel relies on oxygen to maintain passivity so coating or wrapping stainless steel may be harmful. The staff further noted that the proposed AMP includes coated or wrapped stainless steel but does not mention uncoated stainless steel.
Request:
Please confirm whether the buried stainless steel piping is wrapped, coated, or bare and, if coated or wrapped, justify how the proposed AMP will adequately manage its aging.
RAI 3.3.2.3.20-1
Background:
LRA Table 3.3.2-20 contains items which address loss of material due to MIC of stainless steel piping, piping components and piping elements exposed to soil. The applicant proposes to manage this aging process through the use of its AMP, Buried Piping and Tanks Inspection (LRA B2.1.7). 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 LRA Table 3.3.2-20, the staff noted that the Buried Piping and Tanks Inspection AMP contained in the GALL Report does not include stainless steel. The staff also noted that the corrosion characteristics of stainless steel differ from carbon steel sufficiently so some of the recommendations contained in the recommended AMP could be counterproductive for stainless steel, e.g., stainless steel relies on oxygen to maintain passivity so coating or wrapping stainless steel may be harmful. The staff further noted that the proposed AMP includes coated or wrapped stainless steel but does not mention uncoated stainless steel.
Request:
Please confirm whether the buried stainless steel piping is wrapped, coated, or bare and, if coated or wrapped, justify how the proposed AMP will adequately manage its aging.
RAI 3.2.2.2.3.1-1
Background:
LRA and SRP-LR Sections 3.2.2.2.3.1 refer to LRA and SRP-LR Tables 3.2.1-3. These tables address the loss of material due to pitting and crevice corrosion of stainless steel and aluminum piping, piping components, and piping elements exposed to treated water. These tables recommend further evaluation on the part of the staff. The GALL Report recommends managing this aging process through the use of the AMP Water Chemistry and One-Time Inspection (GALL Report Volume 2 Chapter XI.M2 and XI.M32). The applicant states that components included in the definition of this table have not been evaluated using this table but rather have been evaluated with the associated mechanical system.
Issue:
In its review of LRA Table 3.2.1-3, the staff noted that the GALL Report recommends the use of Water Chemistry and One-Time Inspection AMPs for components included in this table. The staff also noted that for some mechanical systems where stainless steel and aluminum components are exposed to treated water, the GALL Report only recommends the use of the Water Chemistry AMP. The staff concludes that if the proposed method of evaluation is followed, a high probability exists that AMPs will not be properly applied and that the management of aging of the components under consideration will not be properly addressed.
Request:
Please evaluate components meeting the definition of this table under the guidance of this table as opposed to including these components in their parent mechanical system for evaluation.
RAI 3.2.2.2.8.2-1
Background:
LRA and SRP-LR Sections 3.2.2.2.8.2 refer to LRA and SRP-LR Tables 3.2.1-15. These tables address the loss of material due to general, pitting and crevice corrosion on the internal surfaces of steel containment isolation piping, piping components and piping elements exposed to treated water. These tables recommend further evaluation on the part of the staff. The GALL Report recommends managing this aging process through the use of the AMP Water Chemistry and One-Time Inspection (GALL Report Volume 2 Chapter XI.M2 and XI.M32).
The applicant states that components included in the definition of this table have not been evaluated using this table but rather have been evaluated with the associated mechanical system.
Issue:
In its review of LRA Table 3.2.1-15, the staff noted that the GALL Report recommends the use of Water Chemistry and One-Time Inspection AMPs for components included in this table. The staff also noted that for some mechanical systems where steel components are exposed to treated water, the GALL Report only recommends the use of the Water Chemistry AMP. The staff concludes that if the proposed method of evaluation is followed, a high probability exists that AMPs will not be properly applied and that the management of aging of the components under consideration will not be properly addressed.
Request:
Please evaluate components meeting the definition of this table under the guidance of this table as opposed to including these components in their parent mechanical system for evaluation.
RAI 3.1.2.2.14-1
Background:
LRA Section 3.1.2.2.14 addresses the wall thinning due to Flow-Accelerated Corrosion for steam generators feedwater inlet ring and supports. The staff reviewed LRA 3.1.2.2.14 against the criteria of SRP-LR Section 3.1.2.2.14. In LRA Section 3.1.2.2.14, the applicant concludes that this item is not applicable to its steam generators. These components were redesigned and installed during the steam generator replacement project in 2001. It further stated that no AMP is necessary for these components.
Issue:
The staff reviewed LRA Section 3.1.2.2.14 and LRA Section B2.1.30, as well as Information Notice 91-19, Steam Generator Feedwater Distribution Piping Damage. The IN documented operating experience of degradation in feedwater inlet ring and supports, and recommends modification and redesign of feedwater inlet ring and supports. The staff noted that the applicant identified causal factors described in IN 91-19. In LRA Section B2.1.30, the applicant provided description of some modifications in the upper steam generator. However, the staff found that more information is needed to understand why the aging effect of wall thinning due to flow-accelerated corrosion is not expected to occur.
Request:
Please provide further information about the new design and construction of the steam generators feedwater inlet ring and supports explaining why the wall thinning due to flow-accelerated corrosion is not expected. Please explain why no AMP is necessary, at least in order to verify whether the expectations about the absence of the flow-accelerated corrosion aging effect are met during the operating experience.
RAI B2.1.30-14
Background:
LRA Table 3.1.1-72 addresses AMR items of cracking due to outer diameter stress corrosion cracking (ODSCC) and/or intergranular attack for nickel alloy steam generator tubes and sleeves exposed to secondary feedwater/steam. The staff reviewed LRA Table 3.1.1-72 against the criteria of SRP-LR Table 3.1.1-72. The GALL report differentiates the cracking due to intergranular attack (Item IV.D1-22) from the cracking due to ODSCC (Item IV.D1-23).
Issue:
In its review of LRA Table 3.1.1-72, the staff noted that the applicant did not credit the GALL Report AMR, Item IV.D1-23, in LRA Table 3.1.2-4 for cracking due to ODSCC as an aging effect/mechanism for nickel alloy steam generator tubes and sleeves exposed to secondary feedwater/steam. Only the cracking due to intergranular attack is addressed in the LRA. Based on the information provided, the staff would need further information in order to evaluate the sufficiency of the AMR proposed and the possible AMPs, which could arise.
Request:
Please clarify why the ODSCC is an aging effect that does not need to be managed for your steam generators. If not, please precise what AMP you are applying for addressing this aging effect.
RAI B2.1.30-15
Background:
LRA Table 3.1.2-4 addresses AMR items of cracking due to SCC for nickel alloys components exposed to treated water and/or steam-secondary such as feedwater nozzle (and nickel alloy cladding), feedwater nozzle thermal sleeve and steam nozzle flow restrictor.
The staff reviewed LRA Table 3.1.1-74 against the criteria of SRP-LR Table 3.1.1-74. SRP-LR indicates that the cracking due to SCC should be managed by the Steam Generator Tube Integrity and Secondary Water Chemistry AMP for chrome plated steel, stainless steel, nickel alloy steam generator anti-vibration bars exposed to secondary feedwater/steam. The applicant proposed to extend this aging management designed for anti-vibration bars to other components of the steam generators, in relation with the material, the environment and the aging effect. For most components, the applicant assigns these two AMPs.
However, for the three following components:
- Feedwater nozzle (and nickel alloy cladding)
- Steam nozzle flow restrictor LRA Table 3.1.2-4 related to the steam generator does not mention the Steam Generator Tube Integrity AMP. For these three components, the applicant credited only the Secondary Water Chemistry AMP while it stated that these items are consistent with the GALL Report in all aspects except a different AMP is credited (Note E).
Issue:
In its review of LRA Table 3.1.1-74, the staff noted that for the three components listed above the applicant did not cover all the AMPs recommended by the GALL Report in the Item IV.D1-14. In LRA Table 3.1.1-74, the applicant stated that the aging effects identified for the anti-vibration bars are managed by the Steam Generator Tube Integrity program and/or the Secondary Water Chemistry program. The GALL AMP XI.M19 about steam generator tube integrity states that the scope of program is specific to steam generator tubes, plugs, sleeves and tubes supports. The staff agrees that the three previous components do not belong to the components described in the scope of the GALL AMP XI.M19. Nevertheless, the applicant did not explain when and why it applies only one program amongst the two recommended by the GALL Report whereas it stated in its LRA that the item 3.1.1-74 is consistent with the GALL Report.
Request:
Please verify whether you need a Steam Generator Tube Integrity AMP for the three steam generator secondary side components listed above in consistency with the GALL Report.
Please also explain how the Item 3.1.1-74 of its LRA is consistent with the GALL Report, especially when it credits only one program amongst the two recommended by the GALL Report.
RAI XI.S8 - Protective Coating Monitoring and Maintenance Program Background/Issue:
This program in the licensees application is cited as not applicable for aging management.
However, NUREG-1801, Generic Aging Lessons Learned (GALL) Report, states that Proper maintenance of protective coatings inside containment is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Licensees should assure proper maintenance of the protective coatings in containment, such that they will not degrade and become a debris source that may challenge the emergency core cooling systems performance.
Request:
Describe, in detail, the Coatings Program at Kewaunee. How will the program ensure that there will be proper maintenance of the protective coatings inside containment, and ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system in the extended period of operation? Also, describe the frequency and scope of the inspections, acceptance criteria, and the qualification of personnel who perform containment coatings inspections.
RAI 4.7.4 TLAA Reactor Vessel Underclad Cracking Background/Issue:
LRA Section 4.7.4, "Reactor Vessel Underclad Cracking," states that the applicant compared the transients utilized in the WCAP-15338-A report, A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants, with the Kewaunee operational transients and determined that the WCAP-15338-A transients bound the Kewaunee transients.
Request:
Please elaborate on this comparison using a couple of examples (transients) to substantiate the conclusion.
Scoping Ventilation Request for Additional Information (RAI) 2.3-2 (Sealants)
Background:
Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.
Issue/Request:
For the following systems (Containment Vessel Internal Spray System, Control Room Air Conditioning System, Auxiliary Building Air Conditioning System, Auxiliary Building Special Ventilation and Steam Exclusion System, Auxiliary Building Ventilation System, Reactor Building Ventilation System, Turbine Building and Screenhouse Ventilation System, Shield Building Ventilation System, and Technical Support Center Ventilation System); clarify if
components types including: duct sealants, wall sealants, pressure boundary sealants, and auxiliary building freight elevator seals interfacing with control room pressure boundary, are within the scope of license renewal in accordance with 10CFR 54.4(a), and subject to aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3-3 (Pumps)
Background:
Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an aging management review (AMR). The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.
Issue/Request:
For the following systems (Containment Vessel Internal Spray System, and Control Room Air Conditioning System); the term pump is used to describe the component types in their respective systems. Please clarify what specific component is required to meet the intended function and subject to aging management review. For example, a valve body meets the intended function of pressure boundary for the component valve, as described in Chapter 2 of the LRA.
RAI 2.3-4 (Containment Isolation)
Background:
Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.
Issue/Request:
The staff could not find in the LRA a separate discussion about containment isolation, the staff is requesting that the applicant confirm that all components and any supporting systems that are meant for containment isolation are included in the scope of the LRA? Please confirm, with a brief description of how Dominion arrived to that conclusion.
RAI 2.3-5 (Screens)
Background:
Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.
Issue:
For the following systems (Containment Vessel Internal Spray System, Control Room Air Conditioning System, Auxiliary Building Air Conditioning System, Auxiliary Building Special Ventilation and Steam Exclusion System, Auxiliary Building Ventilation System, Reactor Building Ventilation System, Turbine Building and Screenhouse Ventilation System, Shield Building Ventilation System, and Technical Support Center Ventilation System); Screens to protect against any debris for air intake or air discharge, and emergency core cooling system pump suction strainers are not found listed in any of the tables for the above mentioned systems.
Request:
Clarify if components types screens and strainers, are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to aging management review in accordance with 10 CFR 54.21(a)(1). If these components are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these components are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3.2.1-1 (Containment Vessel Internal Spray System)
Background:
Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an AMR. The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.
Issue:
In LRA Drawing LRXK-100-131, it is not clear what components of the Containment Vessel Internal Spray System are in the scope of license renewal in accordance with 10 CFR 54.4(a),
and subject to an aging management review in accordance with 10 CFR 54.21(a)(1).
Request:
Please clarify what components, if any, are within scope and indicate the quadrant information.
RAI 2.3.3.10-1 (Control Room Air Conditioning System)
Background:
The Kewaunee Power Station Control Room Air Conditioning System is described in LRA Section 2.3.3.10, Table 3.3.2-10, and on LRA Drawings LRM-588, LRM-606, LRM-603, and LRM-605-1.
Issue:
LRA Tables 2.3.3.10 and 3.3.2-10 do not contain some components that are highlighted on the system drawings. Specifically, LRA Tables 2.3.3.10 and 3.3.2-10 do not list the component types for control room post accident recirculation filter assembly housings and filter element housings.
Request:
Clarify whether these component types are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3.3.11-1 (Auxiliary Building Air Conditioning System)
Background:
The Kewaunee Power Station Auxiliary Building Air Conditioning System is described in LRA Section 2.3.3.11, Table 3.3.2-11, and on LRA Drawings LRM-601, LRM-604, and LRM-606.
Issue:
LRA Tables 2.3.3.11 and 3.3.2-11 do not contain some components that are highlighted on the system drawings. Specifically, LRA Tables 2.3.3.11 and 3.3.2-11 do not list the component types for condenser tube sheets, condenser tubes, filter element housings for auxiliary building supply vent units, spent fuel pool exhaust filter assembly housings, heating coils, cooling coils and tubing.
Request:
Clarify whether these component types are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3.3.12-1 (Auxiliary Building Special Ventilation and Steam Exclusion System)
Background:
The Kewaunee Power Station Auxiliary Building Special Ventilation and Steam Exclusion System is described in LRA Section 2.3.3.12, LRA Table 3.3.2-12, and on LRA Drawings LRM-601, LRM-604, and LRM-606 and LRA Table 2.3.3-12.
Issue:
LRA Tables 2.3.3.12 and 3.3.2-12 do not contain some components that are highlighted on the system drawings. Specifically, LRA Tables 2.3.3.12 and 3.3.2-12 do not list the component types for filter element housings and zone special ventilation (SV) exhaust filter assembly housings.
Request:
Clarify whether these component types are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the
LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3.3.13-1 (Auxiliary Building Ventilation System)
Background:
The Kewaunee Power Station Auxiliary Building Ventilation System is described in LRA Section 2.3.3.13, LRA Table 3.3.2-13, and on LRA Drawings LRM-601, LRM-588, LRM-601, LRM-603, LRM-604, LRM-605-1, and LRM-606.
Issue:
LRA Tables 2.3.3.13 and 3.3.2-13 do not contain some components that are highlighted on the system drawings. Specifically, LRA Tables 2.3.3.13 and 3.3.2-13 do not list the component types for filter element housings.
Request:
Clarify whether these component types are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.
RAI 2.3.3.14-1 (Reactor Building Ventilation System)
Background:
LRA Section 2.3.3.14-Reactor Building Ventilation System discusses the components that were considered in the scoping process of license renewal.
Issues/Requests:
- Note 1 in LRA Drawing LRM-403 states that the Containment Air Hydrogen analyzers are active components. Provide a brief description of the function of the analyzers and the reasoning for not including them in AMR. Include in the description, the calibration gas connecting lines and the associated valves, with reasons for not adding them to the scope of LRA.
- Please explain the reasons for not including ductwork on the suction side of Containment Fan Coil Units 1A and 1D in the scope of LRA (Ref: LRA Drawing LRM-602).
- Please indicate the location of applicable components for 18/RBV Reactor Building Ventilation - Containment Purge & Ventilation in LRA Drawing LRM-606, as noted in the legend of the same drawing.
- Clarify what part of a filter assembly meets the pressure boundary function.
RAI 2.3.3.15-1 (Turbine Building and Screenhouse Ventilation System)
Background:
LRA Section 2.3.3.15- Turbine Building and Screenhouse Ventilation System discusses the components that were considered in the scoping process of license renewal.
Issues/Requests:
- The description in Section 2.3.3-15 states that LRA Drawings LRM-215, LRM-602, LRM-603, and LRM-604 apply to this system and the drawings also indicate a legend for 16/TAV Turbine Building and Screenhouse Ventilation. However, the staff could not find any components in these drawings that are applicable to this system. Please clarify?
- Temperature elements are listed in Table 2.3.3-15, where as, they are not listed in any other ventilation systems. Please clarify the reasons for including temperature elements for this system and for not including them elsewhere?
RAI 2.3.3.16-1 (Shield Building Ventilation System)
Background:
LRA Section 2.3.3.16- Shield Building Ventilation System discusses the components that were considered in the scoping process of license renewal.
Issues/Requests:
- The components in Tables 2.3.3.16 and 3.3.2-16 should be identified in a manner where they reflect more specifically the components that is required to meet the intended functions and will go through an AMR. For example, shield building vent filter assembly is a term that is too general to reflect the intended function of pressure boundary. Clarify what part or parts of a filter assembly meet the pressure boundary function.
- Are the de-mister and electric heater included in the scope of LRA, if so, where are they reflected, and if not, why are they not included?
RAI 2.3.3.17-1 (Technical Support Center Ventilation System)
Background:
The Kewaunee Power Station Technical Support Center Ventilation System is described in LRA Section 2.3.3.17, LRA Table 3.3.2-17, and on LRA Drawing LRM-501.
Issue:
LRA Tables 2.3.3.17 and 3.3.2-17 do not contain some components that are highlighted on the system drawings. Specifically, LRA Tables 2.3.3.17 and 3.3.2-17 do not list the component types for battery room air compressor unit (ACU) cooling coils/fins, ACU compressor casings, and filter housings for filter elements.
Request:
Clarify whether these component types are within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to an aging management review in accordance with 10 CFR 54.21(a)(1). If these component types are in the scope of license renewal, update the LRA by providing the applicable information in the appropriate LRA tables. If these component types are excluded from the scope of license renewal and not subject to an AMR, provide justification for the exclusion.