ML12129A036

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Inservice Inspection Program Fourth Ten-Year Interval 10 CFR 50.55a Request No. RR-2-3, Response to Request for Additional Information
ML12129A036
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 04/30/2012
From: Jordan A
Dominion, Dominion Energy Kewaunee
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RR-2-3
Download: ML12129A036 (6)


Text

Dominion Energy Kewaunee, Inc.

N490 Hwy 42, Kewaunee, WI 54216 ~Dominiolnl Web Address: www.domn.coni April 30, 2012 ,&cieA &2r'5)oQ ATTN: Document Control Desk Serial No. 12-319A U. S. Nuclear Regulatory Commission LIC/JG/RO 11555 Rockville Pike Docket No.: 50-305 Rockville, MD 20852-2738 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-2-3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By application dated April 29, 2012 (Reference 1), Dominion Energy. Kewaunee, Inc.

(DEK), requested approval of 10 CFR 50.55a Request RR-2-3 for the Fourth Ten-year Interval of the Inservice Inspection (ISI) Program for Kewaunee Power Station (KPS).

10 CFR 50.55a Request RR-2-3 proposed a temporary deviation from the requirements of ASME Section XI, Appendix IX, Article IX-1000, Paragraph (c)(2), which prohibits the use of clamping devices on "... portions of a piping system that forms the containment boundary" and ASME Section XI, Appendix IX, Article IX-6000(a), which states that the area immediately adjacent to the clamping device shall be examined using a volumetric method.

During a telephone conference call with DEK personnel on April 29, 2012, the Nuclear Regulatory Commission (NRC) staff requested additional information (RAI) regarding 10 CFR 50.55a Request RR-2-3. The RAI questions and associated DEK responses 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, Site Vic resident - Kewaunee Power Station AJ/LI

Serial No. 12-319A RAI Response RR-2-3 Page 2 of 2

Attachment:

1. Response to Request for Additional Information, 10 CFR 50.55a Request RR-2-3

References:

1. Letter from A. J. Jordan (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval 10 CFR 50.55a Request No. RR-2-3",

dated April 29, 2012.

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. 12-319A ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-3 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-319A RAI Response RR-2-3 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-3 During a telephone conference call with DEK personnel on April 29, 2012, the Nuclear Regulatory Commission (NRC) staff requested additional information (RAI) regarding 10 CFR 50.55a Request RR-2-3 (Reference 1).

The RAI questions are provided below, followed by the DEK response.

NRC Question 1 On page 3 of 7 in the reason for the request, the licensee stated that approximately 8 Rem of radiation dose is required for the first option. What is the radiological dose for the second option?

Response

The second option described in 10 CFR 50.55a Request RR-2-3 (Reference 1) is to perform a temporary repair of the RHR piping by installing a leak-limiting strong-back clamp to ensure structural integrity prior to making a MODE change from MODE 5 to MODE 4. The radiological dose estimate associated with installation and removal of the leak-dimiting strong-back clamp is 350 mRem.

NRC Question 2 The licensee stated on page 7 of 11 of the temporary modification that during sealant injection, the RHR heat exchanger outlet temperature will be maintained between 1500 and 200 0 F. It appears that an RHR temperature of 200' would cause the plant to violate the 195 0 F maximum RCS temperature administrative limit for MODE 5 stated in Reference 7 of the Enclosure (temporary modification) to RR-2-3.

Please clarify what the temperature operating band is during sealant injection.

Response

On page 7 of 11 of the temporary modification, the statement that discussed RHR heat exchanger outlet temperature being maintained between 1500 and 200'F, will be revised to state that during sealant injection, the maximum reactor coolant system

Serial No. 12-319A RAI Response RR-2-3 Page 2 of 3 temperature will not exceed 195°F as indicated by the hottest core exit thermocouple (CET) reading. Sealant injection will be performed in MODE 5. This process is controlled in accordance with plant procedures.

NRC Question 3 The licensee stated on page 9 of 11 in the temporary modification, in the constraining effects section, that the clamp will not constrain the pipe significantly during thermal expansion. Please provide in more detail your overall assessment of the thermal expansion effects, from the time of installation to the time of maximum system temperature. Please provide approximate maximum system temperature with the device installed.

Response

Constrainingeffects: The clamp holding the leak sealant enclosure is a single clamp band with a 3/16" fillet weld at the 3/4" pipe interface. The temperature increase experienced by the clamp from the point of installation until its removal will be no more than 95°F (From 150°F min to 245 0 F max). This temperature increase will result in a radial expansion of the 10" diameter pipe by no more than 0.005". The effect of this radial expansion on the strong-back bolts will be an increase in tensile stress of approximately 20%. The initial torque on the strong-back bolts is approximately 40% of the material yield. Therefore, the additional tensile stress on these bolts will remain within the yield point of the material.

There will also be a constraining effect on the 3/4" pipe due to the addition of the weld to the leak seal enclosure. If unrestrained, the thermal expansion from the center of the 10" pipe to the location of the new weld on the 3/4" pipe is approximately 0.007". Since the clamp materials have the same thermal expansion properties as the pipe materials it would also grow at the same rate. However, the clamp will be slightly cooler than the pipe due to the insulating effect of the sealant material around the 3/4" pipe. This minor difference in material temperatures will result in relatively small compressive loads on the 3/4" pipe shared with an increase in tensile loads on the strong-back bolts discussed above. The loads on the new weld are considered insignificant compared to the capacity of the weld (approximately 7400 Ibs).

In summary, the constraining effect of the leak sealant enclosure and strong-back will not significantly impact the piping stresses or the strong-back bolting.

Serial No. 12-319A RAI Response RR-2-3 Page 3 of 3 REFERENCE

1. Letter from A. J. Jordan (DEK) to Document Control Desk (NRC), "Inservice Inspection Program Fourth Ten-Year Interval 10 CFR 50.55a Request No. RR-2-3",

dated April 29, 2012.