ML12129A279
| ML12129A279 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/04/2012 |
| From: | Jordan A Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 12-324A | |
| Download: ML12129A279 (43) | |
Text
9 Dominion Dominion Energy Kewaunee, Inc.
N490 Hwy 42, Kewaunee, WI 54216 Web Address: www.dom.com May 4, 2012 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Serial No. 12-324A LIC/JG/R2 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-2-4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By application dated May 3, 2012 (Reference 1), Dominion Energy Kewaunee, Inc.
(DEK), requested approval of 10 CFR 50.55a Request RR-2-4 for the Fourth Ten-year Interval of the Inservice Inspection (ISI) Program for Kewaunee Power Station (KPS).
10 CFR 50.55a Request RR-2-4 proposed a temporary deviation from the requirements of ASME Section Xl, 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 Xl, Appendix IX, Article IX-6000(a), which states that the area immediately adjacent to the clamping device shall be examined using a volumetric method.
On May 3, 2012, the Nuclear Regulatory Commission (NRC) staff requested additional information (RAI) regarding 10 CFR 50.55a Request RR-2-4. On May 4, 2012, the NRC staff clarified the original set of questions, provided on May 3, 2012. The RAI questions and associated DEK responses are provided in Attachment I 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 A. J. Jokd Site Vice r-Kewaunee Power Station
Serial No. 12-324A RAI Response RR-2-4 Page 2 of 2
Attachment:
- 1. Response to Request for Additional Information, 10 CFR 50.55a Request RR-2-4 Enclosures (5)
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-2-4",
dated May 3, 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 O8-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station
Serial No. 12-324A ATTACHMENT I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
Serial No. 12-324A Page 1 of 13 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 During discussions with Dominion Energy Kewaunee (DEK) personnel on May 3, 2012, the Nuclear Regulatory Commission (NRC) staff requested additional information (RAI) regarding 10 CFR 50.55a Request RR-2-4 (Reference 1).
The RAI questions are provided below, followed by the DEK response.
NRC Question 1 This question was deleted per the clarified questions sent on May 4, 2012.
NRC Question 2 DEK's Request RR-2-4, Attachment 2, page 7, final bullet discusses a temporary plugging device.
The staff is trying to understand the specific purpose of the temporary plugging device that will be staged at the work location.
If leakage develops, does the licensee intend to install the plug to prevent leakage from coming out of the hole and then reroute the leakage to higher vents while weld repair activities continue?
Response
Yes, if leakage develops, the intent is to install the temporary plug to minimize leakage.
It will not be used to reroute leakage to higher vents. The temporary plugging device is a safety measure to address the development of boundary leakage after the system has been breached. The plug is not designed to facilitate welding.
This purpose of the device is to restrict flow through the open section of the affected piping.
The temporary plugging device will be staged at the work location.
The temporary plugging device will be test fit using a mockup to ensure proper fit and to familiarize the workers to its use. If leakage does develop while the piping is breached for repair, LCO 3.4.13 will be reviewed and associated actions implemented as written.
See enclosed photographs (Enclosure 1) of temporary plugging devices.
As noted in the response to question 20, the isolation procedure is written to remove pressure sources if leakage develops.
Additionally, the tag clearance process will ensure boundary valves remain in their required positions.
DEK does not expect to need to install this device because maintenance will not be allowed to start until ultrasonic testing has confirmed the absence of leakage.
Serial No. 12-324A Page 2 of 13 NRC Question 3 How does DEK intend to meet the friction requirements of ASME Code, Article IX, 3200(d), with the proposed designs in the temporary modifications provided (Request RR-2-4, Enclosure 1, Att. 3, p. 9 of 12 and Enclosure 2, Att. 3, p. 9 of 13);
or, does the structural restraint satisfy the Article IX, 3200(d) friction requirements?
Response
The structural restraint is designed for a full circumferential severance of the % inch pipe. The friction requirements of Article IX-3200(d) was originally satisfied by the two
- 10-24 set screws in the first hub seal enclosure tightened to the % inch pipe. A 3/16 inch all-around fillet weld was added to the top of the first enclosure to the % inch pipe.
After this weld was not properly made, the structural restraint was installed. This was done to satisfy the original design of the set screws and weld, which was to ensure structural integrity of the % inch pipe socket weld.
NRC Question 4 If valve RHR-1 1 leaks by, how will DEK be able to remove the water that would flow into the 10-inch line?
Response
If valve RHR-1 1 leaks by prior to system breach, water would be removed from the 10-inch line through the path already established to drain the line. The system will not be breached until the system is drained and a stable water level is verified using ultrasonic techniques (UT). Monitoring will be performed at nominal 15 minute intervals for a minimum of one hour.
Once the system is breached, water level will be monitored at nominal 15 minute intervals for the period of time the system is breached.
Although response contingencies are planned, leakage is not expected because of the passive nature of the isolation boundaries and the positive means in place (valves tagged out with the respective breakers racked out) to prevent inadvertent isolation boundary valve repositioning.
If unexpected leakage is encountered after system breach, water from the 10-inch line will be removed by pumping it out through the sockolet. Water level in the 10-inch line can be lowered at any point throughout the repair window up to insertion of the new /
inch pipe for final welding. Mock-up training of the new weld with the welders assigned to perform the weld has shown that final welding should take less than 30 minutes.
Serial No. 12-324A Page 3 of 13 NRC Question 5 If the water leaks too fast into the 10-inch pipe, would the weld repair be able to be properly completed?
Response
No, if water leaks too fast into the 10-inch pipe the weld repair cannot be properly completed.
Leakage will be monitored prior to beginning work to ensure it can be completed. It is desired to maintain the water level in the 10-inch line 3 inches below the sockolet for welding activities.
This corresponds to pumping approximately 18 gallons out of the 10-inch pipe. The total volume of the 10-inch line below the weld area is approximately 68 gallons so valve leakage of approximately 50 gph could be accommodated while performing the repair.
NRC Question 6 Is the intention of the temporary plugging device a contingency to allow transitioning through to MODE 5 seeking regulatory relief and transitioning to defueling to affect a permanent ASME Code repair?
If leakage is expected, what is the maximum expected leakage and would that affect RHR availability/functionality?
Response
Yes, if necessary because of excessive leakage beyond the ability to perform a permanent repair or other unforeseen circumstances, a temporary plugging device will be used to facilitate transition to MODE 5.
A temporary plugging device in this application is expected to restore RHR availability. After reaching MODE 5, DEK will engage NRC in discussions to determine if regulatory relief is required within intent to transition to MODE 6 followed by defueling and a permanent ASME Code repair.
NRC Question 7 Please provide a reasonable time limit on the duration that may be needed to complete all associated activities that rely on Request RR-2-4 (time at which point RR-2-4 would expire).
Response
Once in MODE 4, isolating and repairing the portion of the RHR system with the leak will take approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, to accommodate unexpected delays, DEK
Serial No. 12-324A Page 4 of 13 proposes a maximum duration of seven days for the period that Request RR-2-4 is approved for.
NRC Question 8 DEK's Request RR-2-4, Enclosure 1, Attachment 1 (Temporary Modification 2012-11), shows the design drawing of the structural restraining clamp.
- 1. Provide dimensions of: clamps (Item 1); bolts (item 4); and steel plate (Item 2).
- 2. Provide stress calculation for: clamps (Item 1); bolts (item 4); and steel plate (Item 2). If this information is in the submittal, please specify the location.
- 3. Provide a detailed drawing (with dimensions) of the coupling (Item 3 on the drawing), on the top of valve RHR-600, that would limit the axial movement of the 3/4-inch pipe.
- 4. Item 4 in the bill of material indicates that it is a 1-inch pipe; however, in the drawing, it appears that it is a bolt or nuts. Clarify how Item 4 (1-inch pipe) is constructed.
Response
- 1. Dimensions of clamps (Item 1); bolts (item 4); and steel plate (Item 2).
" Clamps (Item 1): The enclosed Anvil International (Grinnell) Fig. 295 datasheet (Enclosure 2) contains dimensions of the 10-inch double bolt pipe clamp used for this Temporary Modification.
" Bolts (item 4): The six 1 inch diameter bolts (3 per clamp) come as part of the Anvil International (Grinnell) Fig. 295 double bolt pipe clamp. See the Fig. 295 datasheet for dimensions.
- Steel plate (item 2): The plate is 1/2/2 inch ASTM A240-88C Type 316 stainless steel. Plate dimensions are shown on Attachment 1, titled "TM2012-11 Structural Restraining Clamp" in the Temporary Modification 2012-11, Rev. 4.
- 2. Stress calculations for clamps (Item 1); bolts (item 4); and steel plate (Item 2).
An analysis of the structural restraining clamp assembly is included as an attachment to Temporary Modification 2012-11, Rev. 4 as shown in Reference 19.
- 3. A detailed drawing (with dimensions) of the coupling (Item 3 on the drawing), on the top of valve RHR-600, that would limit the axial movement of the 3/4-inch pipe.
0 Serial No. 12-324A Page 5 of 13 No detailed drawings of the machined coupling were developed for this Temporary Modification.
The coupling is a standard 6000 lb ASTM A182 F304 1-1/4 inch coupling with socket welding ends. The center hub of this coupling was machined out so that the tubing downstream of RHR-600 could be reattached after the restraint was installed. Standard dimensions for a welded socket end coupling of this size and pressure rating are 2.50" OD, 1.675" ID, and 1.88" total length.
- 4. Clarify how Item 4 (1-inch pipe) is constructed.
Refer to "Section A-A" of Attachment 1 in Temporary Modification 2012-11, Rev. 4 and the Anvil International (Grinnell) Fig. 295 datasheet (Enclosure 2).
The 1 inch pipe (Item 4) passes through the 1-3/8 inch hole in the stainless steel plate (Item 2). The pipe is centered within the hole of item 2 and is welded on both sides of the plate with a 1/8 inch all around weld. Then the 1 inch diameter top bolt (supplied with the Fig. 295 clamp) passes through the clamp and the 1 inch diameter pipe, with a nut added to the end of the bolt to make up the connection.
NRC Question 9 DEK's Request RR-2-4, Enclosure 2, (Temporary Modification 2012-12), page 10 discusses the pipe hangers and supports (RHR-H9 and RHR-H29) in the vicinity of valve RHR-600 and the degraded % inch pipe.
- 1. Provide a drawing showing the location of the hangers and pipe supports in the vicinity of valve RHR-600. The drawing should show the distance of the pipe supports from the % inch pipe and the direction of the support (hangers or lateral supports). Discuss whether RHR-H9 and RHR-H29 are rigid hangers or spring hangers.
- 2. It is not clear whether enclosure 2 includes the stress analysis for the parts/components in the second mechanical clamp enclosure. The stress analysis in Enclosure 2 appears to be for the original mechanical clamp enclosure design (TM 2012-11). Clarify or identify where the stress analysis for the second mechanical clamp design is.
Response
- 1. Isometric drawing M-962-2, Rev. A shows the configuration of the 10-inch RHR piping including the supports in the vicinity of valve RHR-600.
This drawing and support drawings MS-34-78, Rev. A (Support RHR-H29), drawing MS-34-79, Rev. B (Support RHR-Hg) and MS-34-6, Rev. E (Support RHR-H55) have been provided.
Supports RHR-H9 and RHR-H29 are both rigid hangers and support RHR-H55 is a non-supporting rigid horizontal restraint.
Serial No. 12-324A Page 6 of 13
- 2. Each of the mechanical clamp enclosures has its own specific stress analysis. The first analysis is contained as an attachment to TM 2012-11 as shown in Reference 12 and is indicated as "Engineering Order #: 91511. The second enclosure analysis is contained in TM 2012-12 as shown in Reference 12 and is indicated as Engineering Order#: 91672EM, Rev. 1.
NRC Question 10 Please provide DEK's stress analysis of the bolts in the structural restraint.
Response
The bolts in the structural restraint were supplied with the safety-related pipe clamps.
These safety-related pipe clamps were supplied by the vendor (Anvil International; previously ITT Grinnell) with a specified load rating of 3240 lbs. This load was verified as acceptable in the attachment to TM 2012-11 Reference 19 entitled, "Evaluation of Pipe Clamp Assembly Components."
NRC Question 11 Please provide the isometric drawings for all piping discussed in Request RR-2-4,.
Response
The following isometric drawings are provided in Enclosure 3 depicting the piping discussed in Request RR-2-4, Attachment 2:
" M-938-1, Rev. E, SI-From Cntmt Pen. 10 to Reactor & From Acmtr 1 B to Loop B Cold Leg
" M-938-2, Rev. E, SI-From Cntmt Pen. 10 to Reactor & From Acmtr 1B to Loop B Cold Leg
" M-961-1, Rev. B, RHR-From Anchors thru RSDL HX 1NI1B to Pens 10, 48 &
RHR-SFP Interconns
" M-962-2, Rev. A, RHR-From Anchors thru RSDL HX 1A/1B to Pens 10, 48 &
RHR-SFP Interconns M-1 360, Rev. B, CVC-From Regen. HX. 1A and Point Near Vlv. LD-60 To Cntmt.
Pen. 11
Serial No. 12-324A Attachment I Page 7 of 13
" M-1534, Rev. B, CC-To RHR Pumps Suction Line 10-AC-601R-5 M-1 539, Rev.0, CC-From Line 1 0-AC-601 R-1 1 to / inch Line for Local Sample Point NRC Question 12 Please provide an estimate of the heat generation currently being removed by the reactor coolant system (decay heat and pump heat). Please include the following information.
" The current approximate RCS water volume.
" The current approximate steam generator (secondary side) water volume.
Response
Estimated heat generation currently being removed by the RCS is 7.02 MBTU/hr at 680 hours0.00787 days <br />0.189 hours <br />0.00112 weeks <br />2.5874e-4 months <br /> shutdown.
RCS volume including pressurizer at full power is 6297 cubic feet. The zero power SG Secondary Side Water volume is 3381 cubic feet corresponding to 44% nominal narrow range level.
NRC Question 13 Is the temporary plugging device that is discussed in RR-2-4, Attachment 2, intended to allow DEK to continue the weld repair if excessive leakage is encountered?
Response
No, the temporary plugging device is not intended to be used to continue the weld repair.
NRC Question 14 If the temporary plugging device needs to be used, will DEK proceed to MODE 6 to effect repairs (with a functional and available RHR system)?
Response
Yes, if necessary because of excessive leakage beyond the ability to perform a permanent repair or other unforeseen circumstances, a temporary plugging device will
Serial No. 12-324A Page 8 of 13 be used to facilitate transition to MODE 5.
A temporary plugging device in this application Is expected to restore RHR availability. After reaching MODE 5, DEK will engage NRC in discussions to determine if regulatory relief is required within intent to transition to MODE 6 followed by defueling and a permanent ASME Code repair.
NRC Question 15 Regarding Request RR-2-4, Attachment 2, page 2 ("Pressure and Temperature Range for Proposed Repair"), please provide additional detail on how RCS leakage will be monitored. RR-2-4 states "No RCS leakage is expected into the affected section of piping and the ASME Code repair will commence."
Does DEK have specific acceptance criteria for leakage prior to allowing permanent repair to commence?
Does DEK have specific acceptance criteria for leakage during the repair activities?
Response
Yes, DEK does have acceptance criteria for leakage prior to, and during, repair activities.
For purposes of this repair, DEK will consider leakage at the temporary clamp(s) to be RCS pressure boundary leakage.
No leakage will be allowed.
The primary method for quantification is the performance of a primary leak rate via OSP-RCS-001, "Reactor Coolant System Leak Rate Check." This surveillance provides guidance on leakage evaluations. Additionally, as noted in response to Question 4, the breached system will be monitored on a nominal frequency of every 15 minutes. The in-leakage rate will be verified to be less than that required to complete the repair activities. Once the system is drained, a series of stable UT readings at the weld line will be used to verify the boundary valves are leak tight. There is a Shift Manager and Engineering sign off in the maintenance operating procedure to evaluate UT results for acceptability. The leakage acceptance criteria after system breach is explained in the response to Question 4.
NRC Question 16 Regarding "Preventing Pressure Boundary Leakage", in RR-2-4, Attachment 2, page 3, is valve RHR-701 another valve that is being used for isolation to affect permanent repair. If yes, please provide a discussion on this valve for this purpose.
If not, why is it not needed for isolation?
Response
No, per the ASME standard, RHR-701 is a code relief valve for overpressure protection and would not be intentionally isolated as part of a boundary. Tagging practices within the Dominion Fleet do not consider relief valves as a component that can be positioned
Serial No. 12-324A Attachment I Page 9 of 13 with override capability. Currently, there have been no identified issues for RHR-701 and no open corrective work orders.
NRC Question 17 Please provide additional information regarding the statement in RR-2-4, Attachment 2, page 4, that "The affected portion of piping will be depressurized and water level will be monitored."
Specifically, details are needed on how water level will be monitored and what leakage acceptance criteria have been established. Include the following in the above discussion.
" Are the vent valves referred to in RR-2-4 normally closed in MODE 4 (how does this affect containment requirements)?
" Will both sides of RHR-1 I be monitored for leakage?
Response
Following system draining per OP-KW-MOP-RHR-010, "Isolating and Draining RHR To Repair RHR-600," boundary leakage will be determined when the water level in the RHR Train A stabilizes.
Once draining stops and no water level changes occur in the drained system, the boundary is known to be leak tight. If gross RCS leakage occurs, the RCS leak rate will be identified and evaluated against LCO 3.4.13. The water level is required to be monitored by UT inspection prior to tuming over to perform maintenance. There is a Shift Manager and Engineering sign off in the maintenance operating procedure to evaluate UT results for acceptability.
If in-leakage is identified by water level not stabilizing the clearance boundary valves will be checked. As a contingency, the maintenance operating procedure also contains steps to depressurize the downstream side of RHR-1 1 and SI-302A inside containment if these valves are suspected of leaking. These valves are normally closed and capped.
However, this alignment does not allow a path outside of containment. To satisfy LCO 3.6.3, RHR-1 1 and SI-302A are administratively closed and controlled.
Additional protection is offered by approximately a 12 ft column of water on the upstream side of RHR-1 1 and SI-302A. Therefore, if leakage across RHR-1 1 or SI-302A is suspected, both sides of these valves will be monitored prior to allowing work to proceed.
NRC Question 18 Request RR-2-4, Attachment 2, page 4, states "If leakage into the affected section of piping develops while the piping is breached for repair activities, TS LCO 3.4.13
Serial No. 12-324A Page 10 of 13 would be evaluated." Please clarify whether leakage into the affected section of piping would be treated as identified, unidentified, or pressure boundary leakage.
Response
Leakage into the affected section of piping while the piping is breached will be treated as pressure boundary leakage and Condition B of TS LCO 3.4.13 would apply.
NRC Question 19 Regarding the "Sequence of Activities" in Request RR-2-4, Attachment 2, page 6, will leak monitoring, to verify that leakage is below established criteria, take place prior to breaching the affected pipe by RHR-600?
Response
Yes, leak monitoring will be performed to ensure leakage is below established criteria as discussed in the response to Question 5 above.
NRC Question 20 Describe, in detail, the draindown process for draining the piping in the affected area for establishing the conditions for effecting ASME Code class repairs.
Response
The process for isolating and draining the RHR Train A for RHR-600 repair is governed by maintenance operating procedure OP-KW-MOP-RHR-010.
A prerequisite for procedure performance is RHR Train A is aligned for standby per KPS normal operating procedures. In this alignment, RHR Train A will be in the cool down mode. However, RHR-1 1 will be closed and RHR Train A system temperature will be cooled down to less than 2000F. Once in the maintenance operating procedure, RHR Pump A will be placed in pullout and RHR-1 1, SI-302A, and LD-60 will be verified closed and power will be removed. The downstream side of the RHR Train A heat exchanger will be closed via RHR-9A.
The RHR Train cross-connect will be closed via RHR-10A.
The RHR recirculation line will be closed via RHR-500A. In this alignment the section of piping to be drained is isolated from the RHR Train A Heat Exchanger and Pump, the RHR Train B system, the RCS via RHR-1 1 and SI-302A, Letdown via LD-60 and RHR Pump A suction via RHR-500A. The status of these valves will be controlled via the KPS tag clearance process.
The high point vents, for draining, are at RHR-501A and RHR-43. The drain path will be at RHR-41. This section of line contains approximately 214 gallons that can be drained and approximately 18 gallons will need to be evacuated from the system once work is
Serial No. 12-324A Page 11 of 13 allowed to begin. During the system draining pipe level will be monitored. If leakage through RHR-1 1 or SI-302A is detected, the maintenance operating procedure will open vent valves outside of the clearance boundary to reduce the pressure and potential source of leakage at the RHR-1 1 and SI-302A boundaries.
This method ensures containment boundary remains intact.
During the entire evolution RCS leakage will be monitored.
Technical Specification LCO 3.4.13, RCS Operational Leakage, is applicable. The contingencies for relieving pressure contain steps for measurement of leakage.
Following draining, the procedure contains guidance for checking acceptable draining of the pipe to perform work at RHR-600. This will be performed using UT inspections. If pipe water levels are determined not to be acceptable the system will not be breached.
NRC Question 21 How does the licensee know that the 10-inch discharge pipe will be maintained in the condition to effect a permanent repair before the % inch pipe is cut and how will that be maintained while the permanent repair is being performed?
Response
level in the system will be verified prior to cutting into the pipe as described in the response to Question 4.
Once the system is breached, water level will be monitored at nominal 15 minute intervals for the period of time the system is breached.
Although response contingencies are planned, leakage is not expected because of the passive nature of the isolation boundaries and the positive means in place (valves tagged out with the respective breakers racked out) to prevent inadvertent isolation boundary valve repositioning.
If unexpected leak by is encountered after system breach, water from the 10-inch line will be removed by pumping it out through the sockolet. Water level in the 10-inch line can be lowered at any point throughout the repair window up to insertion of the new %
inch pipe for final welding. Mock-up training with the welders assigned to perform the weld has shown that final welding will take less than 30 minutes.
It is desired to maintain the water level in the 10-inch line 3 inches below the sockolet for welding activities to ensure a successful weld.
This corresponds to pumping approximately 18 gallons out of the 10-inch pipe. The total volume of the 10-inch line below the weld area is approximately 68 gallons so valve leak by of approximately 50 gph could be accommodated while performing the repair.
Serial No. 12-324A Attachment I Page 12 of 13 NRC Question 22 Please explain how the structural restraining clamp fits with the hub clamp (reference DWG F-003143).
Response
The structural restraint clamp is installed separately from either of the two seal enclosures shown on TEAM Industrial Services drawing F-003143.
The structural clamp was designed to fit over the top of valve RHR-600 and span across the seal enclosures and attach to pipe clamps spaced approximately 30 inches apart on the 10-inch RHR piping. There is no physical connection of the structural restraint clamp to the seal enclosure or to their associated strongback clamps.
Refer to enclosed photographs (Enclosure 5).
NRC Question 23 How will any potential leakage be monitored prior to removing the clamp/defective pipe and how will DEK assure that no untoward condition (wetness) in the weld area occurs?
Response
Once the system is breached, water level will be monitored at nominal 15 minute intervals for the period of time the system is breached.
Although response contingencies are planned, leakage is not expected because of the passive nature of the isolation boundaries and the positive means in place (valves tagged out with the respective breakers racked out) to prevent inadvertent isolation boundary valve repositioning.
If unexpected leak by is encountered after system breach, water from the 10-inch line will be removed by pumping it out through the sockolet. Water level in the 10-inch line can be lowered at any point throughout the repair window up to insertion of the new %
inch pipe for final welding. Mock-up training of the new weld with the welders assigned to perform the weld has shown that final welding will take less than 30 minutes.
It is desired to maintain the water level in the 10-inch line 3 inches below the sockolet for welding activities to ensure a successful weld.
This corresponds to pumping approximately 18 gallons out of the 10-inch pipe. The total volume of the 10-inch line below the weld area is approximately 68 gallons so valve leak by of approximately 50 gph could be accommodated while performing the repair.
Serial No. 12-324A Page 13 of 13 NRC Question 24 (TM 2012-12) Attachment 3, page 2 of 13, states that vendor provided no torque specifications for the bolting. Please explain.
Response
The vendor did not specify a torque for the bolts between the sealant enclosure and the strongback clamp since it was not critical that these bolts have a specific pre-stress induced in them. These particular bolts only need to be secured firmly. Therefore, a nominal "wrench tight" condition was specified by plant engineering.
NRC Question 25 This question was deleted per the clarification questions sent on May 4, 2012.
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-2-4",
dated May 3, 2012.
Serial No. 12-324A ENCLOSURE I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PERTAINING TO QUESTION 2 RESPONSE 3 PHOTOGRAPHS OF TEMPORARY PLUGGING DEVICES KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
orary Plugging vice
Figure 3: Example Alternate Temporary Plugging Device. Procured plugging device has solid shaft and stainless steel construction for wetted parts.
Serial No. 12-324A ENCLOSURE 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PERTAINING TO QUESTIONS 8 and 10 RESPONSES ANVIL (GRINNELL) FIG. 295 DATASHEET KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
[STEE PIP CLAPS b
Fig. 295 Size "anc 3/4" through 36W Motvakh Carbon steel Fie Plain or Galvanized Serlice Recommended for suspension of pipe requiring Insulation within the limitation of temperature and loads shown below.
Maxnutmn Temperwur Plain 750" F, Galvanized 450a F Approvals Complies with Federal Specification A-A-1192A (Type 3), WW-H-1-7-E (*ype 3, ANSVMSS SP-69 and MSS SP-58 (Type 3).
kIaataIiow. Attachment to the clamp may be made with a welded eye rod Fig. 278, page 89 or the weldless eye nut Fig. 290. see page 93.
Featumm Sizes 6" and above accommodate up to 4" thick insulation, Double Bolt Pipe Clamp SFigure 41SD will accommodate larger Insulatton thicknesses, loads and dimensions.
OrderlIng Specify pipe size, figure number, name and finish.
Not This picture Is representative of a typc Fi"ure 295, Distance between clamp eks beneath pipe mna or may not be equal to upper gap.
FIG. 29S: LOADS (1.5) a WEIGHT (L.S) a DIMENSONS (IN)
MaU Lowd PPi
'Mi ForkrvlUo.
Weight 0
Red Take F
M1iin
$pan R.
WFr TpD Oud E Width H
0.7 "As 2,
2W, 1%
1 7*
950 0.8 1 As 3
2%;
1 11 1Y 0.8 V/4 3%
2'1As 11A.
11/2 9
2.3 1 %
1*
4 %
4 1 11 2 "A 2
10"
- 2.
s 21A TrA T 5 2"/ u 21 11*
1,45 1,30 1.97 2%
6 1.h1 T
2 A
S 12" 2.17 27A 3/4 6A 03 4W W
220 6.7 I*
7 %
61/2 41/2 414" 2%0
,141V
-is1 7.0 3%*
8177 3%
'Y4 72 a
7 2,865 2,555 7.1 4 7A 1 1
9 8 1111 i'.53/41, 10 2r
- 2 19.8 22
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Serial No. 12-324A ENCLOSURE 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PERTAINING TO QUESTION 9 RESPONSE MS-34-78 Rev. A (Support RHR-H29)
MS-34-79 Rev. B (Support RHR-H9)
MS-34-6 Rev. E (Support RHR-H55)
KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
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Serial No. 12-324A ENCLOSURE 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PERTAINING TO QUESTION 11 RESPONSE M-938-1 Rev. E SI-From Cntmt Pen. 10 to Reactor & From Acmtr 1 B to Loop B Cold Leg M-938-2 Rev. E SI-From Cntmt Pen. 10 to Reactor & From Acmtr I B to Loop B Cold Leg M-961-1 Rev. B RHR-From Anchors thru RSDL HX IA/1B to Pens 10, 48 & RHR-SFP Interconns M-962-2 Rev. A RHR-From Anchors thru RSDL HX 1A/11B to Pens 10, 48 & RHR-SFP Interconns M-1360 Rev. B CVC-From Regen. HX. IA and Point Near VIv. LD-60 To Cntmt. Pen. 11 M-1534 Rev. B CC-To RHR Pumps Suction Line 10-AC-601R-5 M-1539 Rev.0 CC-From Line 10-AC-601R-11 to 3/4" Line for Local Sample Point KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
LEGEND
'ýI a110-UY sA mcm NOTES.
REFERENCE DWOS.
ANALYSIS DOCUMENTS IFOM &CUTR e To bOC ANALYTMCA PART NO.
SI 33 -00 I
-A
4-M u~
AhI O I1EEft EDUS ANAmmI OOCWENSISP AMSCS~SA""
91.3wr A
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ANALYTICALYSI PARTNO.
513-00
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A-1 CAP OX718-FOq *t Irn LEGEND Q SWUS ANALYS PMT~
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KSIRMETT PUEIMW
,TRUU ANALYSIS DOCUMENTS ANALYTICAL PART NO. RHR 004
MO w
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-- l' V ISwANT REFERENME DWGS.
ANALYSIS DOCUMENTS
~LL
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NI*ME PWN*
HqGR/RIEID ROSSTIST PIPE RUPTU RESTRAINT I
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RPFERENCE DW.S.
ANALYSIS DOCUMENTS R., ý REJOJI 445 AYTlCA_ PART NoMCVC-35-149I
I LEOEND 0
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LEGEND C
STRESS AMPLYSIS POINT SORPOR'r
,,ANG MAR*K NO.
DENOTES FIELD WALKDOWN DIMENSION OR ANGLE GUlSEITWO-WAY
.ISTFINT SNUBBER THREE-WAY RESTRAINT PIPE RFUILRE RESTRAINT NOTES-REFERENCE DWGS.
ANALYSIS DOCUMENTS
Serial No. 12-324A ENCLOSURE5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST NO. RR-2-4 FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PERTAINING TO QUESTION 22 RESPONSE 7 PHOTOGRAPHS OF STRUCTURAL RESTRAINT CLAMP KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
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