ML091880555

Request for Additional Information Regarding the Review of the Kewaunee Power Station License Renewal Application - Structures Scoping/Fire Protection

ML091880555
Person / Time
Site:	Kewaunee
Issue date:	07/16/2009
From:	Hernandez-Quinones S License Renewal Projects Branch 1
To:	Heacock D Dominion Energy Kewaunee
Hernandez S, NRR/DLR/RPB1, 415-4049
References
TAC MD9408
Download: ML091880555 (12)

Text

July 16, 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:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION -

STRUCTURES SCOPING/FIRE PROTECTION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc., submitted an application for renewal of operating license DPR-43 for the Kewaunee Power Station. The staff of the U.S.

Nuclear Regulatory Commission (NRC or 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.

Items in the enclosure were discussed with Mr. Paul Aitken, of your staff, and a mutually agreeable date for the response is within 30 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

July 16, 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:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION -

STRUCTURES SCOPING/FIRE PROTECTION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc., submitted an application for renewal of operating license DPR-43 for the Kewaunee Power Station. The staff of the U.S.

Nuclear Regulatory Commission (NRC or 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.

Items in the enclosure were discussed with Mr. Paul Aitken, of your staff, and a mutually agreeable date for the response is within 30 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 DISTRIBUTION:

See next page ADAMS Accession Number: ML091880555 OFFICE PM:RPB1:DLR LA:RPOB:DLR BC:RPB1:DLR PM:RPB1:DLR NAME SHernandez SFigueroa DPelton SHernandez (DAshley for) (Signature)

DATE 07/15/09 07/09/09 07/16/09 07/16/09 OFFICIAL RECORD COPY

Letter to David A. Heacock from Samuel Hernandez dated July 16, 2009

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION -

STRUCTURES SCOPING/FIRE PROTECTION (TAC NO. MD9408)

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

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S. Hernandez S. Lopas P. Tam S. Burton K. Barclay M. Kunowski V. Mitlyng I. Couret S. Burton P. Higgins F. Farzam N. Iqbal

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 Dominon 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

KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION STRUCTURES SCOPING/FIRE PROTECTION Request for Additional Information (RAI) 2.4-1

Background:

As stated in Section 5.2.1.23.2, Electrical Penetrations, of the Kewaunee Power Station (KPS) updated safety analysis report (USAR), all components of the electrical penetration assemblies are designed to withstand, without damage or interruption of operations, the forces resulting from an earthquake, in addition to the normal and accident design requirements. Table 2.4.1-1, Reactor Containment Vessel, of the license renewal application (LRA) only includes the electrical penetration nozzles. Section 2.4.1 of the LRA (Page 2-206) refers to Section 2.5 for the evaluation of electrical penetration assemblies. Section 2.5 of the LRA states that all reactor containment vessel electrical penetration assemblies are within the scope of the environmental qualification (EQ) program and the subject of a time-limited aging analysis (TLAA).

Issue:

As stated in Section 2.4.1, Reactor Containment Vessel, of the LRA and the KPS USAR, the electrical penetration assemblies are welded to the end of the reactor containment vessel penetration nozzle. Table 2.4.1-1 of the LRA does not list the structural components [e.g.,

welds between the canister and the nozzle, and canister support (as shown in USAR Figure 5.2-8)] that support the intended functions of the penetration assembly.

Request:

If these components are not included due to an oversight, please provide a description of the scoping and aging management review (AMR). If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-2 Request:

Table 2.4.1-1 of the LRA does not list the concrete/grout fill supporting the reactor containment vessel. If this component is not included due to an oversight, please provide a description of the scoping and AMR. If it is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-3 Request:

Section 2.4.1 of the LRA states that masonry block walls are installed to provide enclosure for equipment. In contrary, Table 2.4.1-1 of the LRA lists the intended function of masonry block walls as structural support. Please discuss the intended function(s) of masonry block walls.

ENCLOSURE

RAI 2.4-4 Request:

As stated in Section 2.4.2.1, Shield Building, of the LRA, the double interlocked doors for the shield building personnel access openings are evaluated for AMR with miscellaneous structural commodities. Table 2.4.2-13, Miscellaneous Structural Commodities, does not list the double interlocked doors for shield building personnel access openings. If these components are not included due to an oversight, please provide a description of the scoping and AMR. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-5 Request:

Figure 9.5-2 of KPS USAR shows personnel airlock, shield building airlock and removable precast concrete panel. Table 2.4.2-1 of the LRA only lists equipment opening door and support framing. If the personnel airlock precast concrete panel and support framing is not included due to an oversight, please provide a description of the scoping and AMR. If these components are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-6 Request:

Based on a review of Section 2.4.2.3, Auxiliary Building, of the LRA and Table 2.4.2-3, it is not clear if the following items have been included in the scope of license renewal and subject to an AMR:

1. Missile shields for service water system piping, and

2. Fuel transfer canal stainless steel liner If these components are not included due to an oversight, please provide a description of the scoping and AMR. If they are covered somewhere else in the LRA, please indicate the location.

If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-7 Request:

As stated in Section 2.4.2.5, Technical Support Center, of the LRA, the metal siding attached to the masonry block walls is not within the scope of license renewal. The levels above the basement of Technical Support Center (TSC) are designated as Class III* in Table B.2-1 of KPS USAR. As stated in Section 2.1.3.6.3 of the LRA, Class III* structural members are included in the scope of license renewal. Since there is no exception in Table B.2-1 for metal siding classification, please provide justification for its exclusion from the scope of license renewal.

RAI 2.4-8 Request:

Table B.2-1 and Figure 1.2-11 of KPS USAR refer to the TSC as a one story building (first floor at elevation 606 feet). Section 2.4.2.5 of the LRA refers to the TSC as a two-level building.

Please provide further explanation relative to the TSC building configuration.

RAI 2.4-9 Request:

Jet impingement barrier, located in the turbine building, is shown in Figure 10A.3-27 of KPS USAR. Table 2.4.2-6, Turbine Building, of the LRA does not list any jet impingement barrier or encapsulation sleeve. If these components are not included due to an oversight, please provide a description of the scoping and AMR. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-10 Request:

Section 2.6.2 of KPS USAR (Page 2.6-2) states the following:

The most recent occurrence of shore erosion was during construction of the plant in 1969.

Wave erosion during a severe storm undercut the bank at the promontory protruding into the lake at the southeast end of the site. The damage was repaired and the bank was stabilized with large riprap, which also serves to protect the circulating water discharge.

Section 2.4.2.8 of the LRA, Discharge Structure, states that the riprap stones paving the near-shore portion of the basin help serve the function of exit velocity dissipation and therefore do not serve a license renewal intended function. Since the riprap is installed for protection of the discharge structure as stated in KPS USAR, please provide further justification for exclusion of riprap paving the near-shore portion of the basin and the riprap installed outside the sheet pile walls from the scope of license renewal.

RAI 2.4-11 Request:

Section 2.4.2.10 of the LRA, Intake Structure, states that the inlet cones discharge their water through 6-foot diameter outlet pipes into a 10-foot diameter steel intake pipe. Section 2.4.2.10 of the LRA also states that the 10-foot diameter pipe is evaluated with the circulating water system. However, the staff found that the 6-foot outlet pipes are not included in Table 2.4.2-10 of the LRA. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-12 Request:

Section 10.2.2.8 of KPS USAR (Page 10.2-12) states that the plant intake is equipped with two auxiliary water intake tees 50 and 100 feet shoreward of the intake crib. Section 2.4.2.10 and Table 2.4.2-10 of the LRA do not list these components. If these components are not included due to an oversight, please provide a description of the scoping and AMR. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-13 Request:

Table 2.4.2-11, Screenhouse, of the LRA does not include the forebay overflow weir. If this component is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.4-14 Request:

Referring to LRA Table 2.4.2-13, please confirm if the following component types are covered somewhere else in the LRA. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

• Grout pads for building structural column base plates

• Vibration isolators

• Waterproofing membrane

• Waterstops

• Anchor bolts and expansion anchors

• Damper framing RAI 2.4-15 Request:

The foundations for reserve auxiliary and tertiary auxiliary transformers are included in the scope of license renewal as stated in Section 2.4.2.7, Yard Structures, of the LRA. Table B.2-1 of the KPS USAR lists other Class I and II transformers. If the support structures for these transformers are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.

RAI 2.3.3.18-1

Background:

For KPS, the staff reviewed the LRA; drawings; updated safety analysis report, Sections 7.7.5, 8.2.2, 9.6.1, and Table B.2-1; and the following fire protection current licensing basis documents listed in the KPS Operating License Condition 2.C(3):

Safety Evaluation Reports dated November 25, 1977, December 12, 1978, and supplement issued on February 13, 1981.

Issue:

The staff has identified that fire protection systems and components discussed in the following sections have been excluded from the scope of license renewal and an AMR. These systems and components were not included in the license renewal boundaries and appear to have fire protection intended functions required for compliance with Title 10 of the Code of Federal Regulations (CFR) 50.48, Fire protection, as stated in 10 CFR 54.4. Therefore, in order to complete our review, the staff requires responses to the following RAIs:

Request:

The LRA drawing LRM-202-3 show fire hose connections at locations F9, F10, F11, G9, G10, and G11 as out of scope (i.e., not colored in brown). The staff requests that the applicant verify whether the above fire hose connections are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If these hose connections are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-2 Request:

The LRA drawing LRM-208-1 shows fire hydrant and hose houses as being in the scope of license renewal and subject to an AMR. However, LRA drawing LRM-208-1 shows fire hose cabinets at locations G6 and H6 as out of scope (i.e., not colored in blue). The staff requests that the applicant verify whether the above fire hose cabinets are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If these cabinets are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-3 Request:

The LRA drawing LRM-208-3 shows fire department connections and associated components at locations B1, C1, and D1 as out of scope (i.e., not colored in blue). The staff requests that the applicant verify whether the fire department connections and associated components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-4 Request:

Section 4.3.1.5 of the KPS Safety Evaluation Report, dated December 22, 1978, states that Automatic water spray system[s] are provided on combustible liquid hazards in the turbine building (hydrogen seal oil unit, oil storage reservoirs), the heating boiler fuel oil pumps in the auxiliary building, and in the oil-filled transformer in the yard areas LRA drawing LRM-208-3

shows only the yard area oil-filled transformer automatic water spray system as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the automatic water spray systems for the hydrogen seal oil unit, oil storage reservoirs, and heating boiler fuel oil pumps are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-5 Request:

Section 4.3.1.5 of the KPS Safety Evaluation Report, dated December 22, 1978, states that wet pipe sprinklers [are provided] on safety-related electrical cable in fire area AX-32, in the hallway of the screenhouse (area SC70), and [there is a plan to] to convert the existing wet pipe system in the working material storage (auxiliary building) to a deluge system The wet pipe and deluge sprinkler systems do not appear in LRA Section 2.3.3.18 or LRA drawings as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the above wet pipe and deluge systems are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-6 Request:

Section 4.3.1.6 of the KPS Safety Evaluation Report, dated December 22, 1978, states that One portable foam nozzle and foam concentrate is available. The plant had no fixed foam system prior to this review; however, the licensee has installed an automatic foam suppression system on each of the two reactor coolant pumps The automatic foam suppression system for the two reactor coolant pumps does not appear in LRA Section 2.3.3.18 or LRA drawings as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the automatic foam system for reactor coolant pumps is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the foam system is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-7 Request:

The Safety Evaluation Report, dated December 22, 1978, listed various types of fire water suppression systems provided in the plant areas for fire suppression activities. The fire suppression systems in various areas are:

• Service Room (fire area AX-32) automatic wet pipe sprinkler system

• Turbine lube oil reservoirs deluge system

• Charcoal filter deluge system

The staff requests that the applicant verify whether the above fire suppression systems installed in the plant are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provides justification for the exclusion.

RAI 2.3.3.18-8

Background:

The interim Technical Specifications attached to a November 25, 1977 letter to Wisconsin Public Service Corporation, listed various areas of the plant as being protected with a low pressure CO2 fire suppression system. The CO2 fire suppression system serves the following areas:

• Adjacent to Steam Generator Blowdown Tank Room AX-20

• Adjacent to 4160 Volt Switchgear Room AX-21

• Adjacent to Special Ventilation Room AX-23

• Relay Room AX-30

• Adjacent to Service Room- AX-32

• Diesel Generator 1-A TU-90

• Diesel Generator 1-A, Day Tank Room TU-91

• Diesel Generator 1-B TU-92

• Diesel Generator 1-B, Day Tank Room TU-93

• Air Compressor and Pump Room TU-95

• Battery Room 1-A TU-97

• Battery Room 1-B TU-98 Issue:

The LRA, Section 2.3.3.18, states that, The CO2 storage tank primarily supplies CO2 for automatic total flooding protection for diesel generator rooms and also supplies CO2 to manual hose stations at various location in the Turbine Building and the Auxiliary Building It is not clear from review of Section 2.3.3.18 of the LRA that the total flooding automatic CO2 fire suppression system installed in all areas listed above is included within the scope of license renewal and subject to an AMR.

Request:

The staff requests that the applicant verify whether the total flooding automatic CO2 fire suppression system installed in above areas is in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If it is excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RAI 2.3.3.18-9 Request:

The LRA, Table 2.3.3.18, excludes several types of fire protection components that appear in the Safety Evaluation Report, dated December 22, 1978. These components are listed below:

• hose racks

• pipe fittings

• pipe supports

• dikes for oil spill confinement

• floor drains and curbs for fire water For each, determine whether the component should be included in Tables 2.3.3-18 and 3.3.2-18, and, if not, justify the exclusion.

RAI 2.3.3.18-10

Background:

The, LRA Section 2.3.3-18, states that, The water-based fire suppression subsystem, which takes water from Lake Michigan, consists of two fire pumps, a jockey pump, main and branch supply line piping Issue:

The LRA, Section 2.3.3.18, discusses requirements for the fire water supply system but does not mention trash racks and traveling screens for the fire pump suction water supply. Trash racks and traveling screens are located upstream of the fire pump suctions to remove any major debris from the fresh or raw water to prevent clogging of the fire protection water supply system.

Trash racks and traveling screens are typically considered to be passive, long-lived components. Both the trash racks and traveling screens are located in a fresh or raw water/air environment and are typically constructed of carbon steel. Carbon steel in a fresh or raw water environment or water/air environment is subject to loss of material, pitting, crevice formation, and microbiologically influenced corrosion and fouling.

Request:

Explain the apparent exclusion of the trash racks and traveling screens that are located upstream of the fire pump suctions from the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).