ML102520078

Inservice Inspection Program Fourth Ten-Year Interval 10 CFR 50.55a Request No. RR-2-2

ML102520078
Person / Time
Site:	Kewaunee
Issue date:	09/07/2010
From:	Price J Dominion, Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
10-131
Download: ML102520078 (9)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 September 7, 2010 ATTN: Document Control Desk Serial NO.1 0-131 U. S. Nuclear Regulatory Commission L1C/CDS/R6 Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION INSERVICE INSPECTION PROGRAM FOURTH TEN-YEAR INTERVAL 10 CFR 50.55a REQUEST NO. RR-2-2 Pursuant to the provisions of 10 CFR 50.55a(a)(3)(i), Dominion Energy Kewaunee, Inc.

(DEK) hereby requests NRC approval of the attached proposed 10 CFR 50.55a request (RR-2-2) for the Fourth Ten-year Interval of the Inservice Inspection Program for Kewaunee Power Station (KPS). This 10 CFR 50.55a request would establish alternate test requirements for the KPS large-bore hydraulic snubbers. The currently applicable ASME/OM codes for these snubbers could possibly require unplanned functional testing of one or both large-bore snubbers. The proposed alternate test requirements are intended to eliminate the potential for unplanned functional testing of these snubbers while providing an acceptable level of safety and quality.

The details of 10 CFR 50.55a Request No. RR-2-2 are provided in Attachment 1 to this letter.

If you have questions or require additional information, please feel free to contact Mr.

Craig Sly at 804-273-2784.

Very truly yours,

Serial No.10-131 10 CFR 50.55a Request RR-2-2 Page 2 of 2

Attachment:

1. Kewaunee Power Station Fourth Ten-year Interval Inservice Inspection Program 10 CFR 50.55a Request No. RR-2-2

References:

None Commitments made by this letter: None cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No.10-131 ATTACHMENT 1 KEWAUNEE POWER STATION FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM 10 CFR 50.55a REQUEST NO. RR-2-2 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial NO.1 0-131 10 CFR 50.55a Request RR-2-2 Page 1 of 6 Kewaunee Power Station Fourth Ten-Year Intervallnservice Inspection Program 10 CFR 50.55a Request No. RR-2-2

1. ASME Code Components Affected Class 2 Steam Generator 1A and Steam Generator 1B 900 KIP Large-Bore Hydraulic Snubbers Drawing Description M-1206 Steam Generator 1A 900 KIP Large-Bore Hydraulic Snubber RC-H86 Steam Generator 1B 900 KIP Large-Bore Hydraulic Snubber RC-H8?

2. Applicable Code Edition and Addenda

ASME Boiler and Pressure Vessel Code 1998 Edition, 2000 Addenda and ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4.

3. Applicable Code Requirement

Examination and Testing per ASME Boiler and Pressure Vessel Code,Section XI, 1998 Edition, 2000 Addenda, Article IWF-5000, Sub-article IWF-5300 in accordance with ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4.

4. Reason for Request

Background Kewaunee Power Station (KPS) submitted the Inservice Inspection (lSI) Program for the Fourth Ten-year Inspection Interval 2004-2014 to the Nuclear Regulatory Commission on December 16, 2003 (reference 1). The NRC completed their review of the KPS lSI Fourth Ten-year Inspection Interval 2004-2014 on September 23, 2005 (reference 2). The KPS lSI Fourth Ten-year Inspection Interval, Appendix F, "Augmented Examination Programs," addresses the hydraulic snubber program.

Specifically, Appendix F, Section 2.f requires all safety related hydraulic shock suppressors be visually examined and tested in accordance with the requirements of KPS Technical Specification (TS) Section 4.14, "Testing and Surveillance of Shock Suppressors (Snubbers)." KPS TS Section 4.14.b states, in part, that the hydraulic snubbers used on the steam generators (SG) are exempt from functional testing requirements. Prior to 198?, this statement was interpreted to mean that no functional testing of the SG large-bore hydraulic snubbers was required.

Serial No.10-131 10 CFR 50.55a Request RR-2-2 Page 2 of 6 However, based on discussions in 1987 between the previous license holder for Kewaunee and the NRC staff during a meeting associated with IE Bulletin 79-14, "Seismic Analyses for As-Built Safety-Related Piping Systems," the licensee decided to develop a testing program for the KPS SG large-bore hydraulic snubbers.

Subsequently, a SG hydraulic snubber testing program was developed and the commitment was met. Currently, the KPS steam generator 900 KIP large-bore hydraulic snubbers (one per steam generator for a total of two 900 KIP large-bore hydraulic snubbers) are visually examined and functionally tested in accordance with this program. The current KPS SG large-bore hydraulic snubber testing program requires the following:

1. A VT-3 visual examination of each installed steam generator 900 KIP large-bore hydraulic snubber each refueling outage; and

2. A functional test of each installed steam generator 900 KIP large-bore hydraulic snubber once during the Ten-year lSI Inspection Interval.

On August 24, 2009, Dominion Energy Kewaunee (DEK) submitted a license amendment request to convert the KPS TS to an industry standard version based on NUREG 1431, "Standard Technical Specifications - Westinghouse Plants" (reference 3). The proposed conversion of the KPS TS includes a change that will eliminate the current KPS TS 4.14 requirements to visually and functionally test safety-related hydraulic snubbers. Therefore, the current allowance in TS 4.14.b that exempts the hydraulic suppressors (snubbers) used on the steam generators from functional testing requirements, will not be retained in the proposed conversion to standard technical specifications.

Although the current snubber testing requirements will be removed from the KPS TS, visual inspections and functional testing of snubbers will still be required and performed in accordance with the KPS Snubber Test Program. DEK plans to maintain the snubber test program in the KPS Technical Requirements Manual (TRM). The KPS Snubber Test Program implements the requirements of ASME Boiler and Pressure Vessel Code, 1998 Edition, 2000 Addenda and ASME/ANSI OM

- 1987 Edition, 1988 Addenda, Part 4. Upon removal of the current KPS TS 4.14 related to snubber testing, the specific requirements of the ASME/OM codes above will continue to apply to future testing.

However, DEK believes that strict compliance with the ASME/OM codes could result in unnecessary and unwarranted testing of the SG large-bore hydraulic snubbers during the current lSI program ten-year interval. Under the currently applicable versions of the ASME/OM codes, the SG large-bore hydraulic snubbers are considered to be within the same grouping (or population) as other plant hydraulic snubbers. The requirements of ASME/ANSI OM-1987 Edition, 1988 Addenda, Part 4, Paragraph 3.2.3.1 (the 10% testing sampling plan) could require functional testing of the SG large-bore hydraulic snubbers at a greater frequency than is currently required under the KPS lSI Augmented Examination Program without a

Serial No.10-131 10 CFR 50.55a Request RR-2-2 Page 3 of 6 commensurate increase in the reliability or performance of the snubbers.

Specifically, if future functional test failures of hydraulic snubbers occur within the initial 10% sample population (or subsequent test populations that may be required as a result of a functional test failure), the requirement to expand the scope of functional testing to a larger snubber population could potentially require one or both*

SG large-bore snubbers be functionally tested because they are included in the overall snubber population. Therefore, under the current applicable version of the ASME/OM codes, DEK could potentially be required to perform unplanned functional testing of one or both SG large-bore hydraulic snubbers prior to exiting a refueling outage.

DEK believes that the possibility of requiring unplanned functional testing of one or both SG large-bore hydraulic snubbers under the currently applicable ASME/OM codes is excessive and unnecessary. Unlike functional testing of smaller hydraulic snubbers, functional testing of the SG large-bore hydraulic snubbers must be performed during a refueling outage; and, compared to testing of smaller hydraulic snubbers:

1. Requires more extensive preplanning;

2. Is more costly and time consuming; and,

3. Requires the use of an outside vendor.

Therefore, DEK is proposing alternate testing requirements for the SG large-bore hydraulic snubbers. The proposed alternate testing requirements are essentially the same as the existing requirements in the KPS SG hydraulic snubber testing program. DEK believes the proposed alternate testing requirements are appropriate for the following reasons:

1. The alternate test requirements are reasonable and establish a predictable testing schedule for the SG large-bore hydraulic snubbers, thus allowing for efficient planning and use of resources.

2. Approval of the alternate test requirements will establish a licensing basis for the testing of the SG large-bore hydraulic snubbers analogous to the current requirements in TS 4.14.b that the SG large-bore hydraulic snubbers are exempt from functional testing requirements.

Please note that during development of this 10 CFR50.55a request, DEK discovered that the name of the SG 900 KIP large-bore hydraulic snubbers is misspelled in KPS TS 4.14 as "Anchor Holth" suppressors. However, the correct spelling of the manufacturer of these suppressors is "Anker Holth". Therefore, this request identifies them as Anker Holth suppressors.

Serial No.10-131 10 CFR 50.55a Request RR-2-2 Page 4 of 6 Summary ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4 requires performance of a visual examination of 100% of hydraulic snubbers "at least each refueling outage" and a functional test of 10% of hydraulic snubbers "each refueling outage." KPS has two large-bore 900 KIP hydraulic snubbers, one located on each steam generator.

The requirements of ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4, paragraph 3.2.3.1 (the 10% testing sampling plan) could potentially require functional testing of the SG large-bore 900 KIP hydraulic snubbers (Le., Anker Holth suppressors) at a greater frequency than is currently required under the KPS lSI Augmented Examination Program without a commensurate increase in the reliability or performance of the snubbers.

Functional testing of KPS 900 KIP large-bore hydraulic snubbers is performed by an outside vendor at a cost of approximately $50,000 per hydraulic snubber. The cost of functional testing noted above does not include the additional costs associated with scaffold erection, craft labor support, or additional radiation exposure.

DEK believes that the activity planning burden of not knowing when functional testing might be required and the additional costs associated with performing functional testing of the KPS SG 900 KIP large-bore hydraulic snubbers in accordance with ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4, paragraph 3.2.3.1, does not provide a commensurate increase to their reliability or performance. Therefore, in accordance with the provisions of 10 CFR 50.55a(a)(3)(i), DEK proposes an alternative set of testing requirements. The proposed alternative testing requirements are consistent with the current applicable testing requirements and provide reasonable assurance that the SG large-bore hydraulic snubbers will continue to perform their intended safety function.

5. Proposed Alternative and Basis for Use.

Proposed Alternative

a. DEK proposes that the ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4 required visual examinations be performed each refueling outage during the Fourth Ten-year Interval for SG 1A Large-Bore 900 KIP Hydraulic Snubber RC-H86 and SG 1B Large-Bore 900 KIP Hydraulic Snubber RC-H8?

b. DEK proposes that the required ASME/ANSI OM-198? Edition, 1988 Addenda, Part 4 functional testing be performed once for SG 1A Large-Bore 900 KIP Hydraulic Snubber (RC-H86) and once for SG 1B Large-Bore 900 KIP Hydraulic Snubber (RC-H8?) during the Fourth Ten-year Interval.

c. DEK proposes that functional testing of the SG Large-Bore 900 KIP Hydraulic Snubbers (RC-H86 and RC-H8?) shall be performed at different refueling outages during the Fourth Ten-year Interval.

Serial NO.1 0-131 10 CFR 50.55a Request RR-2-2 Page 5 of 6

d. DEK proposes that if one 900-KIP SG large-bore hydraulic snubber fails a required functional test (i.e., during any scheduled refueling outage or during any additional functional testing required as a result of a failed visual examination, as described in the KPS Surveillance Procedure for steam generator hydraulic snubber testing) the other installed SG large-bore 900-KIP hydraulic snubber shall be functionally tested during the same refueling outage. Scope expansion due to the failure of a SG large-bore hydraulic snubber functional test will only be applied to the other SG large-bore snubber, and will not be applied to the small-bore snubbers in the DEK snubber program.

Bases for Use DEK has reviewed the testing history for these snubbers and has concluded that previous test results support approval of the proposed alternative testing. The KPS steam generator large-bore hydraulic snubber functional testing history is provided below:

a. During the 1988 refueling outage, the original eight (8) large-bore hydraulic snubbers were removed as part of a steam generator snubber reduction program. These snubbers were functionally tested, disassembled, inspected, rebuilt, retrofitted with modified valve blocks, reassembled and functionally tested with successful results. The steam generator snubber reduction program required one (1) large-bore hydraulic snubber to be reinstalled on each KPS steam generator.

b. During the 1996 refueling outage, the Steam Generator 1A Large-Bore Hydraulic Snubber was functionally tested with successful results.

c. During the 1998 refueling outage, the Steam Generator 1B Large-Bore Hydraulic Snubber was functionally tested with successful results.

d. During the 2001 refueling outage, both Steam Generator 1A and Steam Generator 1B Large-Bore Hydraulic Snubbers were removed, functionally tested, disassembled, inspected, rebuilt, reassembled and functionally tested with successful results.

e. During the 2008 refueling outage, the Steam Generator 1A Large-Bore Hydraulic Snubber was functionally tested with successful results.

f. During the 2009 refueling outage, the Steam Generator 1B Large-Bore Hydraulic Snubber was functionally tested with successful results.

The proposed alternative is justified based on the previously performed functional testing which found no evidence of failures. The proposed alternative of performing visual examinations at least each refueling outage and performing functional testing on each SG large-bore 900 KIP hydraulic snubber once during the Fourth 10-Year Interval provides reasonable assurance that these snubbers will continue to perform

Serial No.10-131 10 CFR 50.55a Request RR-2-2 Page 6 of 6 their intended safety function. Therefore DEK believes the proposed alternative provides an acceptable level of safety and quality.

6. Duration of Proposed Alternatives Kewaunee Power Station Fourth 10-Year Inservice Inspection (lSI) Program; June 16,2004 through'June 16, 2014.

7. Precedents None

8. References

1. Letter from Thomas Coutu (NMC) to Document Control Desk (NRC), "In-Service Inspection Program for Fourth Inspection Interval," dated December 16, 2003.

[ADAMS Accession No. ML033580733]

2. Letter from L. Raghavan (NRC) to Michael G. Gaffney (NMC), "Kewaunee Nuclear Power Plant - Fourth 10-Year Inservice Inspection Interval Program Requests for Relief (TAC NOS. MC2502, MC2508 AND MC2537)," dated September 23, 2005.

[ADAMS Accession No. ML052660057]

3. Letter from Leslie N. Hartz (DEK) to Document Control Desk (NRC), "License Amendment Request 249: Kewaunee Power Station Conversion to Improved Technical Specifications (TAC NO. ME02467)," dated August 24, 2009. [ADAMS Accession No's ML092440371, ML092440416 through ML092440435, and ML092440441]

4. Letter from A. Schwencer (NRC) to E.W. James (WPSC), "Kewaunee Nuclear Power Plant License Amendment 14," dated March 1, 1977. [ADAMS Accession No. ML020740235].