ML093310443
| ML093310443 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 12/16/2009 |
| 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: ML093310443 (14) | |
Text
December 16, 2009 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 are included in the enclosure. Further requests for additional information may be issued in the future.
In addition, the staff noted that inconsistencies had been made while assigning numbers to several RAIs that were sent to you in letters dated November 20, 2009 and December 3, 2009.
This letter serves as a correction to the numbers of RAIs B2.1.3-4a, B2.1.31-5, and 3.3.2.3-1.
Please update your records to reflect the correct numbers for the RAIs as follows. The updated numbers for RAIs B2.1.3-4a, B2.1.31-5, and 3.3.2.3-1 are now B2.1.31-4a, B2.1.31-5a, and 3.4.2.3-1, respectively.
Items in the enclosure were discussed with Mr. Paul Aitken, of your staff, and a mutually agreeable date for the response is within 40 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
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:
HARD COPY:
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PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource S. Hernandez V. Perin J. Daily P. Tam S. Burton K. Barclay M. Kunowski V. Mitlyng I. Couret S. Uttal, OGC ADAMS Accession Number: ML093310443 OFFICE PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR NAME SHernandez SFigueroa BPham SHernandez (Signature)
DATE 12/ /09 12/09/09 12/ /09 12/16/09 OFFICIAL RECORD COPY
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 Dominon 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
ENCLOSURE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI 3.1.2.3-1
=
Background===
LRA Tables 3.1.2-1, 3.1.2-3 and 3.1.2-4 contain items which address the exterior surfaces of steel components exposed to uncontrolled indoor air. The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required. 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 air-indoor uncontrolled is defined in the GALL Report as an environment where condensation can occur, but only rarely. The staff also notes that, contrary to Note 4 of the application, the components under consideration may routinely have temperatures above 212oF (during operation) and at much lower temperatures approaching ambient (during outages). The staff further notes that in all cases the GALL Report recommends that the aging effect Loss of Material be considered when steel is exposed to uncontrolled indoor air.
Request Please select an AMP appropriate for the management of steel components exposed to uncontrolled indoor air as recommended by the GALL Report.
RAI 3.4.2.3-1
=
Background===
LRA Table 3.4.2-1 contains items which address the interior surfaces of steel components exposed to hydraulic oil. The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required. 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 for the material/environment combinations of steel and fuel oil as well as steel and lubricating oil, the GALL Report recommends the consideration of the aging effect loss of material. In each case the GALL Report recommends AMPs consisting of monitoring oil chemistry coupled with an inspection program. Based on these recommendations in the GALL Report, the staff must also consider that loss of material for steel components exposed to hydraulic oil may be possible.
Request Please select an AMP appropriate for the management of aging in steel components exposed to hydraulic oil or to justify why aging of steel components in hydraulic oil is not possible.
RAI 3.5.2.3-7
=
Background===
LRA Table 3.5.2-9 contains items which address steel sheet pile exposed to soil. The applicant proposes that there is no aging effect associated with this combination of material and environment and that no AMP is required. 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 for the material/environment combinations of steel and soil, the GALL Report recommends the consideration of the aging effect loss of material. Based on the information provided, it is not clear to the staff why steel sheet pile exposed to soil as part of the plants discharge structure would not experience loss of material due to corrosion.
Request Please select an AMP appropriate for the management of aging in steel sheet pile exposed to soil.
RAI 3.3.2.3-4
=
Background===
LRA Table 3.3.2-8 contains items which address loss of strength/hydrolysis from the exterior surfaces of non metallic filters and regulators exposed to dry air. The applicant proposes to manage this aging through the use of its 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 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 LRA AMP specifically addresses paper filter elements used in the compressed air system. The staff concurs with the applicants assertion that visual inspection, as included in the Work Control Process AMP, is sufficient to manage aging of these filters. The staff also notes, however, that the entry in Table 3.3.2-8 includes both filters and regulators and that the material is listed as Non Metallic rather than paper. While the staff suspects that this item refers only to paper filters, it could also refer to some unidentified non metallic material contained in either a filter or a regulator. Additionally, the staff noted that, with the exception of elastomeric materials, the scope of the Work Control Process is limited to the internal surfaces of components. This appears to be in conflict with the component under consideration as the environment is specified to be external. The staff assumes, but cannot confirm that the applicant is referring to the external surface of the filter but that the filter is contained in another, larger, enclosure which actually makes the external surface of the filter an internal surface of the filter assembly.
Request Please a) confirm that this item refers to only paper filters; b) if necessary, define the other materials and components included in this item; c) if necessary, justify the use of the Work Control Process AMP for these materials and components; d) confirm that the Work Control Process is used for this component because the external surface of the filter is an internal surface or a larger assembly; and, e) if necessary, justify the use of the Work Control Process for external surfaces.
RAI 3.3.2.3-5
=
Background===
LRA Tables 3.3.2-6 and 3.3.2-20 contain items which address loss of material due to MIC from the internal surfaces of stainless steel piping, piping components, and piping elements exposed to raw water. The applicant proposes to manage this aging through the use of its Work Control Process (LRA AMP B2.1.32) or its Open Cycle Cooling Water System (LRA B2.1.23) AMPs.
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 in the majority, but not all instances, the applicant states that the AMP Open Cycle Cooling Water is used for safety-related systems and the AMP Work Control Process is used for nonsafety-related systems. The staff also noted that MIC is only one of the appropriate corrosion mechanisms which could lead to loss of material in stainless steel piping exposed to raw water. Irrespective of the corrosion mechanism leading to the loss of material, the staff has no objection to the use of the Open Cycle Cooling Water AMP for systems to which Generic Letter 89-13 applies (safety systems) because this is the AMP recommended by the GALL Report. Also, irrespective of the corrosion mechanism leading to the loss of material, the staff has no objection to the use of the Work Control Process AMP for nonsafety systems because this AMP contains procedures for visual inspection of the interiors of pipes which are appropriate for the detection of loss of material due to exposure to raw water. However, it is not clear to the staff that this distinction will be met in all cases. It is also not clear to the staff whether the applicant is inferring that MIC is the only corrosion mechanism which is possible in this case or whether the applicant is using these items in conjunctions with other AMR items such as 3.3-1 ID 78 and/or 79.
Request Please confirm that the Open Cycle Cooling Water AMP will be used for all safety-related systems and that the Work Control Process AMP will be used only for nonsafety-related systems.
RAI 3.3.2.3-8
=
Background===
LRA Table 3.3.2-8 contains items which address loss of material due to general and pitting corrosion from the internal surfaces of steel piping, piping components, and piping elements exposed to moist air. The applicant proposes to manage this aging through the use of its 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 noted that the aging effect identified by the applicant is applicable for this combination of component, material, and environment. The staff also noted that in its original application, the applicant included these components in LRA Table 3.3.1, item 3.3.1-53 using Generic Note E. The staff further noted that, for SRP Table 3.3-1 ID 53, the GALL Report recommends the use of the Compressed Air Monitoring AMP. The staff finally noted that the components under consideration are included in the station and instrument air system. The staff acknowledges that both the Compressed Air Monitoring AMP recommended by the GALL Report and the Work Control Process AMP as proposed by the applicant contain inspection procedures appropriate for the detection of loss of material due to corrosion on the internal surfaces of piping. The staff notes, however, that the Compressed Air Monitoring program contains many aspects in addition to piping inspections to manage aging. Given the additional aging management controls contained in the Compressed Air Monitoring program, it is not clear to the staff that the aging of these compressed air components can be adequately managed solely through the visual inspections contained in the Work Control Process program.
Request Please justify the use of the Work Control Process AMP for compressed air system components or adopt an AMP containing all aspects of the Compressed Air Monitoring AMP recommended by the GALL Report.
RAI B2.1.8-3a
=
Background===
In its review, the staff noted that the applicants program did not specify a monitoring frequency for nitrate levels in the component cooling water system, which utilizes a nitrite/molybdate corrosion control program. Energy Power Research Institute (EPRI) Report 1007820, Revision 1 specifies that nitrate levels for such systems be monitored on a monthly basis for both Tier 1 and Tier 2 systems. Consequently, the staff requested in RAI B2.1.8-3 dated July 13, 2009, that the applicant provide a justification for not performing monthly monitoring of the nitrate levels in the closed cooling water system.
In its response dated August 17, 2009, the applicant stated that, as an alternative to monthly monitoring of nitrate levels, nitrite levels are monitored on a monthly basis and ammonia levels on a quarterly basis. The applicant also stated that these monitoring activities verify chemistry stability and verify that unacceptable levels of nitrates, which would be produced by nitrifying bacteria, are not present in the closed-cycle cooling water system.
Issue The staff notes that, in nitrite-treated systems, nitrates are produced by nitrifying bacteria while ammonia is produced by denitrifying bacteria. Either or both of these bacteria types may be present in a closed water system, and the absence of one type does not necessarily indicate the absence of the other. Thus the periodic sampling for ammonia may be used to verify the absence or control of denitrifying bacteria, but it provides no assurance that nitrifying bacteria are not present. For this reason, EPRI 1007820 recommends monitoring for both nitrates and ammonia on a monthly basis for Tier 1 and 2 systems.
Request Indicate how current monitoring procedures provide assurance that excessive levels of nitrifying bacteria are not present in the closed water system.
RAI 3.5.2.3-6a
=
Background===
By letter dated Oct 13, 2009, the staff issued RAI 3.5.2.3-6 requesting that the applicant identify the specific material under consideration and justify why this material is not subject to aging under the conditions being considered.
The applicant responded by letter dated Nov 13, 2009. In that response the applicant addressed potential aging effects on both the internal and external surfaces of each of the non-metallic materials under consideration.
The applicant stated that the non-metallic material in LRA Table 3.5.2-12 which has no aging effect is fiberglass. The external surfaces of this material are exposed to uncontrolled indoor air. The internal surfaces of this material are exposed to raw water. The applicant also stated that this material is not exposed to ultraviolet radiation, ozone, or high voltage current which could result in loss of strength. The applicant conducted an operating experience search for this combination of material and environments and failed to find any instances of aging for either the internal or external environment. The results of this search are consistent with the staffs knowledge of this material and the external environment.
Issue The staffs assessment of the interaction between raw water and fiberglass differs from that proposed by the applicant. The staff is aware that fiberglass may undergo significant blistering as a result of exposure to water. This is particularly true in fiberglass boats. Blistering can become sufficiently severe to result in structural degradation of the material. Given the fact that fiberglass boast blister, the staff finds it difficult to accept the concept that, for the component under consideration, no aging exists.
Request Please propose an AMP for fiberglass exposed to water or to justify why the fiberglass component under consideration should be considered to have no aging effect.
7 RAI - 3.3.2.1-4
=
Background===
LRA Tables 3.2.2-2, 3.3.2-9, 3.3.2-11, and 3.3.2-19 list combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that the referenced items in the GALL Report do not correspond with the AMP proposed by the applicant. The staff does not understand the applicants description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Vol 2 Table 1 Item Notes 3.2.2-2 Valves Enclosures Steel (I) Air-moist Loss of Material/general, pitting, crevice and Boric acid corrosion Work Control Process EP-043 3.2.1-46 A;4 3.3.2-11 Damper Housings Steel (I) Air-moist Loss of material/general, pitting, crevice, and (for drip pans and drain lines) microbiologically influenced corrosion Work Control Process VII.F2-03 3.3.1-72 A;1 3.3.2-11 Ductwork Steel (I) Air-moist Loss of material/general, pitting, crevice, and (for drip pans and drain lines) microbiologically influenced corrosion Work Control Process VII.F2-03 3.3.1-72 A;1 3.3.2-11 Fan/Blower Housings Steel (I) Air-moist Loss of material/general, pitting, crevice, and (for drip pans and drain lines) microbiologically influenced corrosion Work Control Process VII.F2-03 3.3.1-72 A;1
8 Request Please, specify if the correct footnote for the referenced items is Note A, and justify how that conclusion was reached.
RAI - 3.3.2.1-5
=
Background===
LRA Table 3.3.2-19 lists combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables, the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that the referenced items in the GALL Report do not correspond with the AMPs proposed by the applicant. The staff does not understand the applicants description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Vol 2 Table 1 Item Notes 3.3.2-19 Compressor Casings Steel (I) Air-moist Loss of material/general, pitting, and crevice corrosion Compressed Air Monitoring VII.H2-21 3.3.1-71 A;2 3.3.2-19 Expansion Tanks Steel (E) Air-Outdoor Loss of material/general, pitting, and crevice corrosion External Surfaces Monitoring VII.H1-11 3.3.1-40 A;1 Request Please, specify if the correct footnote for the referenced items is Note A, and justify how that conclusion was reached.
9 RAI - 3.3.2.1-6
=
Background===
LRA Tables 3.3.2-9, 3.3.2-13 and 3.3.2-14 list combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by placing Note A on them. A review of these items against the GALL Report showed that for the referenced items the GALL Report proposes a plant-specific review and do not recommends a particular AMP. The staff does not understand the applicants description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Vol 2 Table 1 Notes 3.3.2-13 Heating Coils Copper Alloys (E) Air-indoor uncontrolled Loss of material/pitting and crevice corrosion External Surfaces Monitoring VII.F2-14 3.3.1-25 A;1 3.3.2-14 Tubing Copper Alloys (E) Air-indoor uncontrolled Loss of material/pitting and crevice corrosion External Surfaces Monitoring VII.F3-16 3.3.1-25 A
Request Please, specify if the correct footnotes for the referenced items are Note A, and justify how that conclusion was reached.
10 RAI - 3.3.2.1-2
=
Background===
LRA Tables 3.3.2-6 and 3.3.2-20 list combinations of components, materials environments and aging effects among other parameters for items which are in scope for license renewal.
Issue In its review of these tables the staff noted that the applicant claims consistency for the items described below, by assigning Notes B and E. The staff is unable to verify the consistency of these items with the GALL Report because the applicant did not include references to Table 1 or to the GALL Report. The staff does not understand the applicants description of consistency with the GALL Report.
Table Subcomponent Material Environment Aging Effect AMP GALL Vol 2 Table 1 Notes 3.3.2-6 Filter Housings(
SW to chlorination pumps)
Stainless Steel (I) Raw water Loss of material/microbiologically influenced corrosion Work Control Process E
3.3.2-20 Valves Stainless Steel (I) Raw water Loss of material/microbiologically influenced corrosion Open-Cycle Cooling Water System B;2 3.3.2-20 Valves Stainless Steel (I) Raw water Loss of material/microbiologically influenced corrosion Work Control Process E;2 Request Please, provide the references to Table 1 or to the GALL Report, and specify if the footnotes for the referenced items are correct.