ML093260003

Wcp AMP Audit Report Regarding the Kewaunee Power Station License Renewal Application

ML093260003
Person / Time
Site:	Kewaunee
Issue date:	12/14/2009
From:	Hernandez-Quinones S License Renewal Projects Branch 1
To:	Heacock D Dominion Energy Kewaunee
Hernandez S, NRR/DLR, 415-4049
References
TAC MD9408
Download: ML093260003 (12)

Text

December 14, 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:

WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Kewaunee Power Station (KPS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). Dominion amended its application by letter dated September 25, 2009; the amendment included substantial changes to the information presented in the original application. In the amendment, Dominion indicated that the Work Control Process (WCP) aging management program (AMP) had been modified to make it consistent with the recommendations contained in the Generic Aging Lessons Learned (GALL) Report.

As a result of Dominions statement about the WCP AMP being consistent with the GALL Report, the NRC staff conducted an audit to verify the claim of consistency made by the applicant. On October 20, 2009, an NRC team completed the audit of the WCP AMP. The audit report is enclosed.

If you have any questions, please contact Samuel Hernandez at 301-415-4049 or by e-mail at Samuel.Hernandez@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

As stated cc w/encl: See next page

December 14, 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:

WORK CONTROL PROCESS AGING MANAGEMENT PROGRAM AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Kewaunee Power Station (KPS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). Dominion amended its application by letter dated September 25, 2009; the amendment included substantial changes to the information presented in the original application. In the amendment, Dominion indicated that the Work Control Process (WCP) aging management program (AMP) had been modified to make it consistent with the recommendations contained in the Generic Aging Lessons Learned (GALL) Report.

As a result of Dominions statement about the WCP AMP being consistent with the GALL Report, the NRC staff conducted an audit to verify the claim of consistency made by the applicant. On October 20, 2009, an NRC team completed the audit of the WCP AMP. The audit report is enclosed.

If you have any questions, please contact Samuel Hernandez at 301-415-4049 or by e-mail at Samuel.Hernandez@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

See next page ADAMS Accession Number: ML093260003 OFFICE PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR SHernandez NAME SHernandez SFigueroa BPham (Signature)

DATE 11/ /09 11/24/09 12/11/09 12/14/09 OFFICIAL RECORD COPY

Letter to David A. Heacock from Samuel Hernandez dated December 14, 2009

SUBJECT:

WORK CONTROL PROCESS AMP AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (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

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL Docket No: 050-305 License No: DPR-43 Licensee: Dominion Energy Kewaunee, Inc.

Facility: Kewaunee Power Station Location: Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Dates: October 19-20, 2009 Reviewers: S. Hernandez, Project Manager, Division of License Renewal (DLR)

A. Hiser, Senior Level Service, DLR D. Pelton, Branch Chief, DLR J. Medoff, Sr. Mechanical Engineer, DLR ENCLOSURE

Introduction A two-day audit was conducted by an U.S. Nuclear Regulatory Commission (NRC) team at Dominion Energy Kewaunee, Inc.s (Dominion) Headquarters in Richmond, Virginia on October 19-20, 2009. The purpose of this audit was to examine the applicants Work Control Process (WCP) Aging Management Program (AMP) documentation for the Kewaunee Power Station (KPS) and to verify the applicants claim of consistency with the corresponding Generic Aging Lessons Learned (GALL) AMP. In its September 25, 2009, amendment letter, Dominion indicated that the WCP AMP had been revised to make sure it sure consistent with two GALL AMPs. The two GALL AMPs referenced by Dominion are: Section XI.M32, "One-Time Inspection," and Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." Exceptions to the GALL AMP elements will be evaluated separately as part of the NRC staffs review of KPS license renewal application (LRA) and documented in the staffs Safety Evaluation Report (SER).

The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) provides the staff guidance for reviewing a LRA. The Standard Review Plan allows an applicant to reference in its LRA the AMPs described in the GALL Report. By referencing the GALL AMPs, the applicant concludes that its AMPs correspond to those AMPs which are reviewed and approved in the GALL Report, and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL program. The applicants determination should be documented in an auditable form and maintained on-site.

During this audit, the staff audited program Elements 1-6, and program Element 10, (operating experience), of the WCP AMP, which the applicant claimed to be consistent with the GALL Report against the related elements of the associated AMP described in the GALL Report.

Elements 7-9 which address corrective actions, confirmation process, and administrative controls were audited by another NRC project team during the Scoping and Screening Methodology audit and are evaluated separately.

In performing this audit, the staff examined the applicants program bases documents and related references for the WCP AMP. The NRC project team also interviewed KPS representatives to obtain additional clarification related to the KPS WCP AMP. This report documents the staff activities during this audit.

LRA AMP B2.1.32, Work Control Process In the KPS LRA, the applicant identified that AMP B2.1.32 is an existing program plant-specific AMP for the LRA. In a letter dated September 25, 2009, the applicant amended the WCP to define the AMP as a new program that will be consistent with program element criteria in the GALL Report, as follows:

• For those AMR items in which the WCP is used to confirm the preventative or mitigative monitoring effectiveness of either the Primary Water Chemistry Program (LRA AMP B2.1.24), Secondary Water Chemistry Program (LRA AMP B2.1.28), Closed-Cycle Cooling Water Program (LRA AMP B2.1.8), Fuel Oil Program (LRA AMP B2.1.14), or Lubricating Oil Analysis Program (LRA AMP B2.1.17), consistent with the program element criteria in GALL AMP XI.M32, One-Time Inspection, with an enhancement of the program.

• For the remaining AMR items in which the WCP will be used for aging management, consistent with the program element criteria in GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, with exceptions and an enhancement of the program.

On September 19-20, 2009, the NRC performed a supplemental audit of the WCP in order to review the change in aging management approach for the program and to audit the degree of consistency of the WCP program elements with GALL AMPs XI.M32, One-Time Inspection, and XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

During its audit, the staff reviewed the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report KLR- License Renewal Project Aging Management Program: Work Revision 3 1336 Control Process, Kewaunee Power Station 9/24/2009

2. Nuclear Fleet Process Work Management Description WM-AA-10

3. Nuclear Fleet Work Management Administrative Procedure WM-AA-100

4. Nuclear Fleet Guidance Work Management Process and Reference Document WM-KW-100-1001

5. Nuclear Fleet Guidance Preventative Maintenance (PM) Basis Document and Reference Document ER-AAPRS-1010

6. KPS General Nuclear Preventative Maintenance Optimization Program Instructions Procedure GNP-08.07.01

7. EPRI Report No. Age-Related Degradation Inspection Method and April 1998 TR-107514 Demonstration, In Behalf of Calvert Cliffs Nuclear Power Plant License Renewal Application

In comparing the seven program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.32 are consistent with GALL AMP XI.M32 program elements, as supplemented by the following program element areas that need further clarification and that are discussed in the paragraphs that follow. The staff also verified that the program elements contained in AMP B2.1.32 are consistent with GALL AMP XI.M38 program elements, as supplemented by the following program element areas that need further clarification and that are discussed in the paragraphs that follow. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.M32 and in GALL AMP XI.M38.

The staff noted that, at the time of the audit, the applicants letter of September 25, 2009 updated the Updated Safety Analysis Report (USAR) supplement summary description for the WCP to reflect the change in the status of the program, making the program consistent with the guidance in GALL AMP XI.M32 One-Time Inspection, when subjected to an enhancement and applied as a one-time condition verification program for water chemistry and oil analysis preventative monitoring programs, with the guidance GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, with noted exceptions and when subject to an enhancement and applied as a periodic condition monitoring program. The staff also noted that the applicants letter of September 25, 2009 updated the commitment for the WCP, as reflected in Commitment No. 25 of the LRA. The staff evaluates the acceptability of USAR supplement summary description for the WCP and LRA Commitment No. 25 in the SER.

Additional Clarifications on the Degree of Consistency with the Program Elements in GALL AMP XI.M32, One-Time Inspection Scope of Program:

The staff noted that, for the aging management review (AMR) item components or commodity groups in which the Primary Water Chemistry Program (LRA AMP B2.1.24), Secondary Water Chemistry Program (LRA AMP B2.1.28), Closed-Cycle Cooling Water Program (LRA AMP B2.1.8), Fuel Oil Program (LRA AMP B2.1.14), or Lubricating Oil Analysis Program (LRA AMP B2.1.17) is used as a preventative or mitigative monitoring AMP, the WCP is credited as the program that will implement a one-time inspection of the preventative or mitigative monitoring program in order to verify that either the aging effect of concern in the AMR item is not occurring, the aging effect of concern is progressing at a very slow rate; or the time to initiation of aging effect involves an extremely long incubation time.

The staff verified that, for these AMR item components or commodity groups, the applicant intent to use the WCP for this purpose conforms to the staffs aging management guidance in GALL AMP XI.M32 on when a one-time inspection basis can be applied as the program and process for aging management.

Detection of Aging Effects, Monitoring and Trending, and Acceptance Criteria:

The staff noted that the inspection methods for managing loss of material, cracking and loss of heat transfer function inducing mechanisms were consistent with those listed in the inspection method table in GALL AMP XI.M32. As a result the staff noted that the inspection methods for the various aging effects and mechanisms managed by the program conformed to the condition monitoring methods recommended in GALL AMP XI.M32.

The staff also noted that, for one-time inspection purposes, the applicant is applying the WCP as a sampling based one-time condition monitoring program. The staff also noted applicant identifies that, for those AMR item components or commodity groups in which the Primary Water Chemistry Program (LRA AMP B2.1.24), Secondary Water Chemistry Program (LRA AMP B2.1.28), Closed-Cycle Cooling Water Program (LRA AMP B2.1.8), Fuel Oil Program (LRA AMP B2.1.14), or Lubricating Oil Analysis Program (LRA AMP B2.1.17) are used as a preventative or mitigative monitoring basis, and for which the WCP will be used to verify the program effectiveness of the specific preventative or mitigative monitoring program, the applicant states that the WCP will perform a one-time examination on a representative sample of the population of components as based on the premise that inspections of those areas with greater susceptibility to aging can be used to confirm performance in less susceptible areas without the need for further inspections, and on the basis that the specific lead inspection locations will be identified by considering the time in service of the components, the severity of operating conditions, and identifying those components with the lowest design margins.

The staff noted that the applicants sampling basis is consistent with the sampling basis statement for one-time inspections, as given in the detection of aging effects program element in GALL AMP XI.M32. However, the staff also noted that the applicants aging management basis for sampling did not clearly establish what the applicants sampling basis would be because in the AMR items of the LRA, the AMP is credited with aging management of multiple material-environment-aging effect combinations, and because the applicant did not clearly establish whether the sampling basis would be on the conglomerate of material-environment-aging effect combinations that the program manages or on a representative sample of components for each of the material-environment-aging effect combination that the program manages. In addition, the staff felt that additional explanations were needed on the type of conditions that would be used to factor in which component locations would be inspected under the program (e.g., loss of material due to corrosion could be expected to occur more readily in stagnant areas or creviced regions, etc.). The staff will consider issuing an request for additional information (RAI) to request additional information on the bases for these sampling based matters.

Additional Clarifications on the Degree of Consistency with the Program Elements in GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Scope of Program and Parameters Monitored/Inspected:

The staff noted that, for the AMR item components or commodity groups in which the WCP was credited as a new periodic condition monitoring program, the applicants basis document states that the WCP will perform visual examinations of the internal surfaces of components during scheduled maintenance or surveillance activities, and that additionally, the program will perform

inspections of the external surfaces of electrical box gaskets, the spent fuel gate seals and hoses, and reactor cavity seal ring. The staff verified that the applicant did identify the inclusion of additional materials, environments, and aging effects in the WCP as specific exceptions to the program elements in GALL AMP XI.38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. The staff evaluates these exceptions in the SER.

Detection of Aging Effects:

The staff noted that the detection of aging effects element in GALL AMP XI.M38 states that the applicant should identify and justify the inspection technique used for detecting the aging effects of concern, and that, for examinations performed on metallic components for cracking by stress-corrosion cracking, the applicant indicated the visual inspection techniques would be enhanced VT-1 examinations. However, the inspectors noted that the applicant did not clarify which type of specific visual inspection techniques would be used to monitor for loss of material or for reduction of heat transfer capability by fouling. The staff will consider issuing an RAI to request clarification on the type of visual examination techniques that will be credited for loss of material and reduction of heat transfer inducing mechanisms.

The staff noted that the detection of aging effects element in GALL AMP XI.M38 states that the locations for inspection should be chosen to include conditions likely to exhibit the aging effects.

The staff noted that the applicant states that the internal inspection locations are performed during normal SRs and PMs, that the locations will be selected based on component manufacturer recommendations and operating experience, and that a technical and plant-specific operating experience review will be performed on plant components and structures to pick locations likely to exhibit aging effects. However, the staff also noted that the applicants aging management basis for sampling did not clearly establish what the applicants sampling basis would be because in the AMR items of the LRA, the AMP is credited with aging management of multiple material-environment-aging effect combinations, and because the applicant did not clearly establish how the results of inspections performed on those components that receive periodic maintenance activities would be applied to those components that are not actually inspected under the program. The staff will consider issuing an RAI to request additional information on the bases for these sampling based matters.

Acceptance Criteria:

The staff noted that the acceptance criteria element in GALL AMP XI.M38 states, in part, that the acceptance criteria are established in the maintenance and surveillance procedures or other established plant procedures, and that, if the results are not acceptable, the corrective action program is implemented to assess the material condition and determine whether the component intended function is affected. The staff noted that the applicants basis document states, in part, that acceptance criteria will be established in the preventative maintenance and periodic surveillance procedures of the license renewal trailer when the program is implemented and that the acceptance criterion is no unacceptable wear, corrosion, cracking, change in material properties (for materials and non-metallics) or significant fouling. The staff noted that the phrase no unacceptable wear, corrosion, cracking, change in material properties (for materials and non-metallics) or significant fouling could be interpreted to mean either that no detected degradation would be allowed or that a certain amount of degradation would be allowed so long as the amount of degradation was within the bounds of the acceptance criteria established for

the new AMP. The staff will consider issuing an RAI to seek clarification on meaning of the terminology no unacceptable wear, corrosion, cracking, change in material properties (for materials and non-metallics) or significant fouling.

Operating Experience:

The staff noted that the WCP is now defined as a new, GALL-based AMP that has yet to be implemented at the facility. The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

Thus, the WCP does not have any operating experience (OE) that has been detected through implementation of this program as a license renewal AMP for the facility. The staff noted however, that the applicant did provide three examples of OE that had been detected through implementation of the WCP in order to demonstrate that the AMP is capable of generating relevant OE for the facility and of detecting and correcting any aging effects that are detecting through implementation of this program. The staff evaluates the acceptability of the operation experience program element for the WCP in the SER.

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 Dominion 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 ENCLOSURE

Kewaunee Power Station cc:

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