ML090760786

License Renewal Application Review, Request for Additional Information - Balance of Plant Scoping and Screening

ML090760786
Person / Time
Site:	Kewaunee
Issue date:	04/03/2009
From:	Hernandez-Quinones S License Renewal Projects Branch 1
To:	Christian D Dominion Energy Kewaunee
Hernandez S, NRR/DLR/REBB, 415-4049
References
TAC MD9408
Download: ML090760786 (23)

Text

April 3, 2009 Mr. David A. Christian 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 - BALANCE OF PLANT SCOPING AND SCREENING (TAC NO. MD9408)

Dear Mr. Christian:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application for renewal of Operating License DPR-43 for the Kewaunee Power Station (KPS).

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 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

April 3, 2009 Mr. David A. Christian 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 - BALANCE OF PLANT SCOPING AND SCREENING (TAC NO. MD9408)

Dear Mr. Christian:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application for renewal of Operating License DPR-43 for the Kewaunee Power Station (KPS).

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 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 ADAMS Accession Number: ML090760786 OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR NAME SFigueroa SHernandez DPelton DATE 03/21/09 03/31/09 04/03/09 OFFICIAL RECORD COPY

Letter to D. Christian from S. Hernandez, dated April 3, 2009 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO.

MD9408)

HARD COPY:

DLR RF E-MAIL:

PUBLIC B. Holian / S. Lee (RidsNrrDlr)

D. Pelton (RidsNrrDlrRpb1)

S. Hernandez S. Lopas E. Smith P. Tam M. Kunowski S. Burton P. Higgins V. Mitlyng

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 Madison, WI 53707-7854

KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION - BALANCE OF PLANT Request for Additional Information (RAI) 2.2-01

Background:

LRA Section 2.4.2.2, Administration Building, description states in part: The Administration Building is a multistory structure that interfaces with the Turbine Building. The basement of the Administration Building is classified as Class I... The remaining areas are Class III...

UFSAR Section 9.6.3, Auxiliary Building Ventilation Systems, Subsection 9.6.3.2 states in part:

The Administration Building is equipped with a multizone-type air conditioning system, arranged to receive outside air for makeup, to recirculate conditioned air, and to exhaust air to the Turbine Building and/or directly to atmosphere.

Issue:

LRA Table 2.2-2, Systems Not Within the Scope of License Renewal, includes the Administration Building Air Conditioning system.

Request:

Provide the reasoning for not including the administration building air conditioning system, which is inside a Class I and Class III structure, in Table 2.2-1, Systems Within the Scope of License Renewal.

RAI 2.3-01

Background:

Section 54.21(a)(1) of 10 CFR requires applicants to identify and list all components subject to an aging management review (AMR). The staff confirms inclusion of all components subject to AMR by reviewing the component types within the license renewal boundary.

Issue:

During the scoping and screening review process the continuation from one drawing to another could not be established. Drawing numbers and/or locations for the continuations were not identified, or could not be located where identified. In some cases drawings were not provided.

ENCLOSURE

LRA Section Continuation Location 2.3.3.3

• Drawing LRM-209-2, location B-1, shows a 2 line downstream of check valve MU1008 in scope in accordance with 10 CFR 54.4(a)(2). The continuation to the license renewal boundary on drawing LRM-208 at location A-10 could not be located. It appears that the correct location should be drawing LRM-218, location A-10.

2.3.3.6

• Drawing LRM-202-1, location F-2, downstream of valve SW-28B2.

• Drawing LRM-202-1, location F-4, downstream of valve SW-28B1.

• Drawing LRM-202-1, location F-6, downstream of valve SW-28A2.

• Drawing LRM-202-1, location F-8, downstream of valve SW-28A1.

• Drawing LRM-202-3, location C-9, two 3/4 lines downstream of valves SW2010A and SW2010B.

2.3.3.7

• Drawing LRXK-100-131, location F-7, component cooling water line coming into the waste evaporator.

• Drawing LRXK-100-131, location F-7, component cooling water line going out of the waste evaporator.

2.3.3.8

• Drawing LRM-213-4, location H-7, shows a continuation TO GENERATOR HYDROGEN PANEL as in scope for 10 CFR 54.4(a)(2).

• Drawing LRM-213-4, location E-7, shows a continuation TO HYDROGEN GAS DRYER as in scope for 10 CFR 54.4(a)(2).

• Drawing LRM-213-4, location C-5, shows a continuation TO TURNING GEAR as in scope for 10 CFR 54.4(a)(2).

• Drawing LRM-213-5, location B-7, shows a continuation TO CONTAINMENT AIRLOCK.

• Drawing LRM-213-5, location F-2, shows a continuation HRSR TO SAMPLE ROOM EQUIP.

• Drawing LRM-213-5, location F-5, shows a continuation TO RADWASTE DRUMMING STATION.

• Drawing LRM-213-6, location F-2, shows a continuation TO HOT CHEM LAB FUME HOOD.

• Drawing LRM-213-7, location C-5, shows a continuation TO CAUSTIC CONTROL STATION.

• Drawing LRM-213-7, location B-9, shows a continuation TO WATER TREATMENT CONTROLS.

• Drawing LRM-213-8, location A-8, shows a continuation TO GRIPPER.

• Drawing LRM-213-8, location D-8, shows a continuation TO A S/G NOZZLE DAM CONTROL PANEL.

• Drawing LRM-213-8, location E-6, shows a continuation TO B S/G NOZZLE DAM CONTROL PANEL.

2.3.3.19

• Drawing LRM-220, location C-8, shows a continuation 11/2 Drain To Waste (typ).

LRA Section Continuation Location 2.3.3.22

• Drawing LRXK-100-131, location C-2, show a 3 line from reactor coolant pump #3 seal leakoffs as within scope for license renewal per 10 CFR 54.4(a)(2).

• Drawing LRXK-100-400, location H-9, shows a 11/2 line TO WASTE HOLDUP TANK VIA SUMP TANK within scope for license renewal in accordance with 10 CFR 54.4(a)(2).

• Drawing LRM-217, locations E-8 and G-8, shows two 1/2 lines from containment spray pumps 1A and 1B mechanical seals to waste as within scope for license renewal in accordance with 10 CFR 54.4(a)(2).

2.3.3.24

• Drawing LRXK-100-36, location A-12, shows a line coming in from LRM-209-2, location A-10, in scope for license renewal for 10 CFR 54.4(a)(2).

The location of this line on the drawing LRM-209-2 could not be located.

• Drawing LRM-209-2, location B-1, shows a 2 line going to LRM-208, location A-10, in scope for license renewal for 10 CFR 54.4(a)(2). The location of this line on drawing LRM-208 could not be located.

• Drawing LRM-209-2, location B-5, downstream of valve DW5100-33 TO NEW CHEM LAB. (Note: valve number provided but the valve is not shown on drawing.)

• Drawing LRM-209-2, location B-7, downstream of valve DW128 TO INSTRU. LAB. SINK.

• Drawing LRM-209-2, location A-7, downstream of valve DW123 TO SAMPLE ROOM EQUIP.

• Drawing LRM-209-2, location A-7, downstream of valve DW125 TO HOT CHEM. LAB. EQUIP.

• Drawing LRM-209-2, location A-7, downstream of valve DW126 TO FUME HOOD IN HOT. CHEM. LAB.

• Drawing LRM-209-2, location A-7, downstream of valve DW127 TO HOT INSTRU. LAB. SINK.

• Drawing LRM-209-2, location E-11, downstream of valve DW280 TO WASTE EVAP. CONC. PUMP SAMPLE TROUGH.

LRA Section Continuation Location 2.3.3.26

• Drawing LRM-350, location G-9, shows continuation of a 2 line downstream of relief valve WG-305A off of Deaerated Drain Tanks TO WASTE GAS COMP. PKGS.

• Drawing LRM-539, location C-2, shows 2 line, down/up stream of valve WG-320A, as in scope for license renewal for 10 CFR 54.21(a)(1).

However this 2 line continues into the reactor building wall and a continuation was not provided.

• Drawing LRM-202-2, location F-1, 6 roof drain coming in to gage glass.

• Drawing LRM-202-2, location G-3, 1 DRAIN DOWNSTREAM OF SW(R20)-5 TO DRAINS (TURB. BKDG. SUMP).

• Drawing LRM-211, location H-1, MISC. FLOOR DRAINS coming in to turbine building sump.

• Drawing LRM-219, location H-9, 2 DRAIN TO TURBINE BLDG SUMP.

• Drawing LRM-539, location D-9, 3 line downstream of relief valve WG-305B TO WASTE.

• Drawing LRM-539, locations G-4 and G-5, lines coming in from CHARGING PUMPS 1A, 1B & 1C STUFFING BOX LEAK-OFFS.

• Drawing LRM-539, locations H-5 and H-6, lines coming in from SAFETY INJECTION PUMPS 1A, & 1B SEAL LEAKOFFS.

• Drawing LRM-539, location H-3, lines coming in from CONTAINMENT SPRAY 1A, & 1B SHAFT SEAL LEAKOFFS.

• Drawing LRM-539, location H-4, 1 line downstream of control valve MD(R) 280A TO WASTE.

2.3.3.27

• Drawing LRXK-100-37, locations B-1, B-3, and B-4, show lines to the plant vent within scope for 10 CFR 54.4(a)(1). The continuation to the LRA boundary could not be located.

2.3.4.1

• Drawing LRM-202-3, location D-4, shows a continuation of a pipe section (SW-3100) in scope for 10 CFR 54(a)(2) belonging to the service water system to drawing OPERM-209-5, location A-1. Drawing OPERM-209-5 was not submitted as a part of the LRA.

• Drawing LRM-206, location A-9, shows a continuation of in scope 21/2 10 CFR 54.4(a)(2) pipe (without identification number) FROM TURBINE GLAND STEAM HDR.

• Drawing LRXK-101-24-1, locations D-9, F-9, F-10, H-9, and H-10 show continuations of in scope 10 CFR 54.4(a)(2) pipe lines.

• Drawing LRXK-101-24-2, location F-9, shows continuation of in scope 10 CFR 54.4(a)(2) pipe line from DRAIN RETURN.

• Drawing LRXK-101-24-1, location H-10, shows continuation of in scope 10 CFR 54.4(a)(2) pipe line to OIL TO GEN BRGS.

• Drawing LRXK-101-24-1, location H-10, shows continuation of in scope 10 CFR 54.4(a)(2) pipe line to HP SEAL OIL BACK UP.

LRA Section Continuation Location 2.3.4.2

• Drawing LRM-211, location C-12, shows continuation of a 10 CFR 54.4(a)(1) pipe 10 EXHAUST STM FROM TURB DRIVEN AUX F. W.

STEAM RING DRAIN.

• Drawing LRM-211 locations B-4 through B-6, C-4 through C-6, and A-6 show continuations of 10 CFR 54.4(a)(2) pipe sections from drawings X-K101-17 and X-K101-17A, respectively, without grid locations.

• Review of drawings X-K101-17 and X-K101-17A could not locate the continuations to drawing LRM-211. Also, note at location A-6 refers to drawing X-K101-174. Drawing X-K101-174 was not submitted with the LRA.

• Drawing LRM-211, location A-7, shows continuation of 10 CFR 54.5(a)(2) pipe sections TURBINE CONNECTION 28 from drawing X-K101-15.

Drawing X-K101-15 was not submitted with the LRA.

• Drawing LRM-211, locations B-6 and B-7, show continuations of 10 CFR 54.4(a)(2) pipe sections DRAINS FROM CYLINDER HEATING STEAM SUPPLY SYSTEM.

• Drawing LRM-212, locations C-11 through C-12, show continuation of 10 CFR 54.4(a)(2) GLAND STEAM SUPPLY pipe.

2.3.4.3

• Drawing LRM-206, location E-3, 11/2 DRAIN TO TURBINE RM. SUMP downstream of 14 piping.

• Drawing LRM-206, location E-3, 11/2 DRAIN TO TURBINE RM. SUMP downstream of 10 piping.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100B3.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100B2.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100B1.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100A1.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100A2.

• Drawing LRM-206, location B-1, 2 DRAIN TO TURBINE BLDG SUMP downstream of valve HRS100A3.

• Drawing LRM-206, location B-3, 11/2 DRAIN TO TURBINE RM. SUMP downstream of 14 piping.

• Drawing LRM-206, location B-3, 11/2 DRAIN TO TURBINE RM. SUMP downstream of 10 piping.

• Drawing LRM-206, locations G-5 and G-7, condenser VENT BLOW-OFF TO ATMOS., upstream of valves BS244 and BS144.

LRA Section Continuation Location 2.3.4.4

• Drawing LRM-205, locations E-10 and F-10, show 10 CFR 54.4(a)(2) 1 drain lines from the condensate pump warm-up piping downstream of valves FW202A and FW202B to continuations labeled as DRAIN TO WASTE.

2.3.4.5

• Drawing LRM-204, locations D-9 and E-9, show 10 CFR 54.4(a)(2) drain lines downstream from the feedwater pump relief valves C18A and C18B to continuations labeled as TO WASTE.

• Drawing LRM-204, locations D-3, shows 6 drain line downstream from the condensate storage tanks 1A and 1B continuation labeled as 6 DRAIN TO CIRC. WATER DISCH. SEE OPERM-209-1. OPERM-209-1 was not provided with the LRA.

2.3.4.6

• Drawing LRM-436, location A-3, 1 piping downstream of relief valve BT 1055A To Waste.

• Drawing LRM-436, location B-4, 1 piping downstream of relief valve C 1055A1 To Waste.

• Drawing LRM-436, location B-5, 1 piping downstream of relief valve C 1055A2 To Waste.

• Drawing LRM-436, location A-7, 2 piping downstream of relief valve BT 1065A To Waste.

• Drawing LRM-436, location F-4, 1 piping downstream of relief valve BT 1055B To Waste.

• Drawing LRM-436, location G-4, 1 piping downstream of relief valve C 1055B1 To Waste.

• Drawing LRM-436, location G-5, 1 piping downstream of relief valve C 1055B2 To Waste.

• Drawing LRM-436, location F-7, 2 piping downstream of relief valve BT 1065B To Waste.

• Drawing LRM-436, location F-10, 3/4 piping downstream of valve BT 52A-3 to D.

• Drawing LRM-436, location G-10, 3/4 piping downstream of valve BT 52A-1 to D.

• Drawing LRM-436, location G-10, 3/4 piping downstream of valve BT 52B-1 to D.

• Drawing LRM-436, location H-10, 3/4 piping downstream of valve BT 52B-3 to D.

• Drawing LRM-436, location F-11, 3/4 piping downstream of valve BT 54A-1 to D.

• Drawing LRM-436, location G-11, 3/4 piping downstream of valve BT 54A-3 to D.

• Drawing LRM-436, location G-11, 3/4 piping downstream of valve BT 55-1 to D.

LRA Section Continuation Location

• Drawing LRM-436, location G-11, 3/4 piping downstream of valve BT 54B-3 to D.

• Drawing LRM-436, location H-11, 3/4 piping downstream of valve BT 54B-1 to D.

• Drawing LRM-436, location H-8, 3/4 piping downstream of valve BT 65 to D.

• Drawing LRM-436, location F-10, 1/2 piping downstream of valve BT 52A-2 to V.

• Drawing LRM-436, location G-10, 1/2 piping downstream of valve BT 52B-2 to V.

• Drawing LRM-436, location F-11, 1/2 piping downstream of valve BT 54A-2 to V.

• Drawing LRM-436, location G-11, 3/4 piping downstream of valve BT 54B-2 to V.

• Drawing LRM-436, location G-8, 8 piping downstream of valve BT 75 Vent to Atmosphere.

2.3.4.7

• Drawing LRM-204,locations A-5, A-7 and A-8 show 10 CFR 54.4(a)(2) pipe lines continued to 21/2 TO WASTE. The continuation was not provided and could not be located.

2.3.4.8

• Drawing LRM-203, location C-12, 10 CFR 54.4(a)(2) piping to the M212 RELIEF TO ATMOS.

• Drawing LRXK-101-17, location F-2, piping downstream of air exhauster AR-300A & AR-300B to the Air Exhauster.

2.3.4.9

• Drawing LRM-219, location A-10, 10 CFR 54.4(a)(2) piping from the HEATER DRAIN PUMPS DISCHARGE.

2.3.4.10

• Drawing LRM-605-1, location A-2, after valve HS406, shows a continuation to drawing LRM-601, location G-9, TO VENT DUCT. However, review of drawing LRM-601 could not locate the continuation from LRM-605-1. Also, similar extensions TO VENT DUCT at location A-3 after valve HS403 to LRM- 601, location G-9, and at location B-3 after the boric acid evaporator condensate return tank to LRM-601, location G-8, could not be located.

• Drawing LRM-605-1, location E-7, shows a continuation of 10 CFR 54.4(a)(2) 3 pipe section after valve HS590 to drawing LRM-505, location A-10. However, drawing LRM-505 was not provided as a part of LRA. A similar reference to LRM-505, location E-8, at location E-5 could not be located.

2.3.4.12

• Drawing LRM-219, location C-1, 1 line attached to valve MU500-3 in-scope for 10 CFR 54.4(a)(2).

• Drawing LRM-204, location D-3, shows a 2 line downstream of valve MU200 in scope for 10 CFR 54.4(a)(2). The continuation to the LRA boundary on Drawing LRM-605-2, location D-10, could not be located.

LRA Section Continuation Location 2.3.4.14

• Drawing LRM-211, locations H-1 and H-3, 10CFR54.4(a)(2) pipes from MISCELLANEOUS FLOOR DRAINS and 3/4 SAMPLE CONNECTION respectively.

• Drawing LRM-211, location C7, 10 CFR 54.4(a)(2) pipes TURBINE CONNECTION 25 FOR CONT. SEE TO DWG. X-K101-17.

Request:

Provide additional information to locate the license renewal boundaries.

Section 2.3.3.6, Service Water System The following requests for additional information (RAIs) were generated as part of the scoping and screening review for the service water system for the Kewaunee Power Station LRA.

RAI 2.3.3.6-01

Background:

LRA Section 2.3.3.6, Service Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-3, location F-11, shows the 12 line out of the turbine oil cooler as in scope for license renewal for 10 CFR 54.4 (a)(2), whereas the 3 line connected to this line and going to the fan coil units is shown as not in scope. However, the continuation of this 3 line on drawing LRM-606, location A8, shows this line is in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawing LRM-202-3 and LRM-606.

RAI 2.3.3.6-02

Background:

LRA Section 2.3.3.6, Service Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, location H-9, shows valve SW(T)251 in scope for 10 CFR 54.4(a)(1). However, the same valve on drawing LRM-394, location E-7, is shown in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-394.

RAI 2.3.3.6-03

Background:

LRA Section 2.3.3.6, Service Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, locations D-9 and D-10, shows 11/2 lines downstream of valves SW1260 and SW1263 as in scope for 10 CFR 54.4(a)(2). However, the continuations of these 11/2 lines on drawing LRM-606, locations G-10 and G-11, are shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-606.

RAI 2.3.3.6-04

Background:

LRA Section 2.3.3.6, Service Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-202-2, locations C-5 and C-6, shows 11/2 lines downstream of valves SW850 and SW853 as in scope for 10 CFR 54.4(a)(2). However, the continuations of these 11/2 lines on drawing LRM-606, locations B-5 and B-6, are shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-202-2 and LRM-606.

Section 2.3.3.7, Component Cooling System The following RAI was generated as part of the scoping and screening review for the component cooling system for the Kewaunee Power Station LRA.

RAI 2.3.3.7-01

Background:

LRA Section 2.3.3.7, Cooling Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, restricting flow, and heat transfer.

Issue:

License renewal drawing LRXK-100-20, location E-2, shows the distillate cooler and evaporator condenser in scope for 10 CFR 54.4(a)(2) while the pipelines entering and leaving the distillate cooler and evaporator condenser are shown in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3).

Request:

1. Confirm the piping attached to the distillate cooler and evaporator condenser is in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3), or

2. Provide additional information explaining why there is a difference in scope classification between the attached piping and the distillate cooler and evaporator condenser.

Section 2.3.3.8, Station and Instrument Air System The following RAIs were generated as part of the scoping and screening review for the station and instrument air system for the Kewaunee Power Station LRA.

RAI 2.3.3.8-01

Background:

LRA Section 2.3.3.8, Station and Instrument Air System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), or 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-4, location G-4, shows a continuation To POS. FOR CV-31396 SHEET 3 D1 as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-3, location D-1, does not show this section of piping to be in scope.

Request:

Provide additional information to clarify the scoping classification of this section of piping.

RAI 2.3.3.8-02

Background:

LRA Section 2.3.3.8, Station and Instrument Air System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-3, location A-3, downstream of valve SA-201 shows a continuation to LRM-213-1, location B-5, as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-1, location B-5, is not in scope.

Request:

Provide additional information to clarify the scoping classification for this section of piping.

RAI 2.3.3.8-03

Background:

LRA Section 2.3.3.8, Station and Instrument Air System, states that component are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), or 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filtration, and heat transfer.

Issue:

LRA drawing LRM-213-5, location A-12, shows a continuation To POS. FOR CV-31120 SHT 2 D6 as in scope for 10 CFR 54.4(a)(2). The continuation on LRM-213-2, location D-6, shows this section of piping to be in scope for 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(3).

Request:

Provide additional information to clarify the scoping classification of this section of piping.

Section 2.3.3.19, Diesel Generator System The following RAI was generated as part of the scoping and screening review for the diesel generator system for the Kewaunee Power Station LRA.

RAI 2.3.3.19-01

Background:

LRA Section 2.1.3.6.2, NS Piping Attached to SR Piping, states in part The NS piping up to and including the structural anchors were included in scope per 10 CFR 54.4(a)(2). In the event an equipment connection is credited for providing restraint in one or more of the orthogonal directions, the credited component and its associated supports were included in the scope of license renewal per 10 CFR 54.4(a)(2).

Issue:

License renewal drawing LRM-213-9, locations B-1, B-2, B-3, B-4, B-5, B-7, B-8, B-10, B-11, and B-12, show non-safety related piping connected to safety-related components at valves SA2020A-1, SA2020A-2, SA2020A-3 SA2020A-4, SA2020B-1, SA2020B-2, SA2020B-3, and SA2020B-4 and traps downstream of After Coolers 166-021 and 166-022 to floor drains.

Request:

Provide the location of the seismic anchor for the non safety related 3/4" lines connected to the safety-related valves and traps.

Section 2.3.3.22, Liquid Waste Processing and Discharge System The following RAIs were generated as part of the scoping and screening review for the liquid waste processing and discharge system for the Kewaunee Power Station LRA.

RAI 2.3.3.22-01

Background

LRA Section 2.3.3.22, Liquid Waste Processing and Discharge System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2),

and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue LRA drawing LRXK-100-131, location A-7, shows the laundry and hot shower tank 1A within scope for license renewal per 10 CFR 54.4(a)(2). The attached blind flange on the overflow connection near Note 14 is shown as not in scope (the same flange on tank 1B is shown as in-scope).

Request Provide a justification for not including the blind flange on laundry and hot shower tank 1A within scope for license renewal.

RAI 2.3.3.22-02

Background

Section 54.21(a) of 10 CFR requires applicants to list all component types subject to an AMR.

The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue LRA drawing LRXK-100-44, location E-8, shows a sample sink and a line to the fume hood sampler (Hi-RAD RC sample) as not within scope for license renewal. All piping entering and exiting the sink, including the drain to the waste holdup tank which is shown as belonging to the liquid waste processing and discharge system, is shown as within scope for 10 CFR 54.4(a)(2).

Request Explain why the sample sink and sample line to the fume hood sampler are not in scope for 10 CFR 54.4(a)(2).

Section 2.3.3.24, Makeup and Demineralized Water System The following RAI was generated as part of the scoping and screening review for the makeup and demineralized water system for the Kewaunee Power Station LRA.

RAI 2.3.3.24-01

Background:

LRA Section 2.3.3.24, Makeup and Demineralized Water System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-209-2 sheet 1, location B-1, shows a 11/2 line in scope for license renewal for 10 CFR 54.4 (a)(2). However, the continuation of this 11/2 line on drawing LRM-385, location G7, shows this line is not in scope for license renewal.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Section 2.3.3.25, Service Water Pretreatment System The following RAIs were generated as part of the scoping and screening review for the service water pretreatment system for the Kewaunee Power Station LRA.

RAI 2.3.3.25-01

Background:

LRA Section 2.3.3.25, Service Water Pretreatment System, states that component types are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-394, location F-10, shows a 4 line downstream of valve SW(T)404 as not in scope for license renewal for 10 CFR 54.4(a). However, the continuation of this 4 line on drawing LRM-211, location G-1, is shown as in scope for license renewal for 10 CFR 54.4(a)(2).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-394 and LRM-211.

RAI 2.3.3.25-02

Background:

LRA Section 2.3.3.25, Service Water Pretreatment System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) and have intended functions of providing a pressure boundary and filtration.

Issue:

License renewal drawing LRM-394, location E-4, shows the valve SW(T)242 as in scope for license renewal for 10 CFR 54.4(a)(2). However, the same valve on drawing LRM-202-2, location H8, is shown in scope for 10 CFR 54.4(a)(1).

Request:

Provide additional information explaining why there is a difference in scope classification between drawings LRM-394 and LRM-202-2.

Section 2.3.3.26, Miscellaneous Drains and Sumps System The following RAIs were generated as part of the scoping and screening review for the miscellaneous drains and sumps system for the Kewaunee Power Station LRA.

RAI 2.3.3.26-01

Background:

LRA Section 2.1.3.6.2, NS Piping Attached to SR Piping, states in part The NS piping up to and including the structural anchors were included in scope per 10 CFR 54.4(a)(2). In the event an equipment connection is credited for providing restraint in one or more of the orthogonal directions, the credited component and its associated supports were included in the scope of license renewal per 10 CFR 54.4(a)(2).

Issue:

License renewal drawing LRM-350, locations D-5, D-6, and D-10, show non-safety-related piping connected to safety-related piping components at valves MD(R)-250A&B, MD(R)-

251A&B, MD(R)-260, MD(R)-261, MD(R)-270, MD(R)-271, MD(R)-272, MD(R)-273, and MD(R)-

262.

Request:

Provide the location of the seismic anchor for the non-safety-related 1" lines connected to the safety-related residual heat exchangers #1A and #1B, the letdown exchanger, and seal water heat exchanger piping.

RAI 2.3.3.26-02

Background:

Section 54.21(a) of 10 CFR requires applicants to list all component types subject to an AMR.

The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.

Issue:

License renewal drawing LRM-350, locations H-6 and H-7, shows the 3 and 2 lines, downstream of the residual heat removal (RHR) pump flushing outlets, as in scope for license renewal for 10 CFR 54.21(a)(2). However part of the 2 line is shown as not in scope for license renewal.

The 2 line upstream of valve MD(R) 280B, location H-7, is continued to LRM-539, location H-5, where it is shown as in scope for license renewal while it is shown as not in scope for license renewal on LRM-350

Request:

Provide additional information to establish the license renewal boundary for the 3 and 2 lines shown as not in scope for license renewal.

Provide additional information explaining why there is a difference in scope classification between the main drawing LRM-350 and the continuation on LRM-539 for the 2 line upstream of valve MD(R) 280B.

Section 2.3.4.1, Turbine System The following RAI was generated as part of the scoping and screening review for the turbine system for the Kewaunee Power Station LRA.

RAI 2.3.4.1-01

Background:

LRA Section 2.3.4.1, Turbine System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-202-3, location H-7, shows a continuation of in scope 2 10 CFR 54.4(a)(2) pipe from drawing LRM-204, location A5. Review of drawing LRM-204 found a continuation (2 to standpipe) at A5, however, this line is included in scope for 10 CFR 54.4(a)(1).

Request:

Confirm that the located continuations are correct and provide additional information to justify the different criteria for the continuing sections of the same pipe.

Section 2.3.4.2, Main Steam and Steam Dump System The following RAI was generated as part of the scoping and screening review for the main steam and steam dump system for the Kewaunee Power Station LRA.

RAI 2.3.4.2-01

Background:

LRA Section 2.3.4.2, Main Steam and Steam Dump System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, restricting flow, equipment qualification (EQ) barrier, and jet impingement shield.

Issue:

License renewal drawing LRM-203 location H-3, shows a section of safety-related 10 CFR 54.4(a)(1) pipe connecting tachometer element readout and the turbine driven auxiliary feed

water pump both of which are in the scope for 10 CFR 54.4 a (1). However, this connecting pipe section is not included in scope.

Request:

Provide additional information explaining why this section of safety-related piping is not within the scope of license renewal.

Section 2.3.4.5, Condensate System The following RAI was generated as part of the scoping and screening review for the condensate system for the Kewaunee Power Station LRA.

RAI 2.3.4.5-01

Background:

LRA Section 2.3.4.5, Condensate System, states that component types are within the scope of license renewal per 10 CFR 54.4(a)(2) or 10 CFR 54.4(a)(3) and have an intended function of providing a pressure boundary.

Issue:

LRA drawing LRM-204, locations B-1 and B-2, show partially highlighted 10 CFR 54.4(a)(3) sampling line downstream from condensate storage tanks 1A/1B to valves MU40A/B. This drawing does not match the partially highlighted 10 CFR 54.4(a)(3) section of piping on drawing LRM-219, location B-1.

Request:

Provide additional information to clarify the scoping classification for these pipe sections.

Section 2.3.4.6, Steam Generator Blowdown Treatment System The following RAI were generated as part of the scoping and screening review for the steam generator blowdown treatment system for the Kewaunee Power Station LRA.

RAI 2.3.4.6-01

Background

LRA Section 2.3.4.6, Steam Generator Blowdown Treatment System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, spray pattern, restricting flow, filtration, and heat transfer.

Issue:

LRA drawing LRM-368, location H-7, shows 2 piping downstream of valve WD41 as in scope for 10 CFR 54.4(a)(2). This drawing does not match the same section of piping on drawing LRXK-100-131, location H-10.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Section 2.3.4.7, Auxiliary Feedwater System The following RAI were generated as part of the scoping and screening review for the auxiliary feedwater system for the Kewaunee Power Station LRA.

RAI 2.3.4.7-01

Background

LRA Section 2.3.4.7, Auxiliary Feedwater System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, heat transfer, flow restriction, and filtration.

Issue:

Drawing LRM-204, location A-5, shows a 10 CFR 54.4(a)(1) pipe line continued to 2 to standpipe on LRM-202-3, location H-7. The continuation on LRM-202-3, location H-7, shows this section of pipe as in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

RAI 2.3.4.7-02

Background

LRA section 2.3.4.7, Auxiliary Feedwater System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2), 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, heat transfer, flow restriction, and filtration.

Issue:

Drawing LRM-205, location G-6 shows a 10 CFR 54.4(a)(1) pipe line continued to 11/2 Recirc.

Line (typ) on LRM-204, location A-6. The continuation on LRM-204, location A-6, shows this section of pipe as not in scope. This is typical for all three AFW pumps.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Section 2.3.4.8, Air Removal System The following RAI was generated as part of the scoping and screening review for the air removal system for the Kewaunee Power Station LRA.

RAI 2.3.4.8-01

Background

LRA Section 2.3.4.8, Air Removal System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-204 location G-1, shows a section of air removal system 3 piping, not included in scope, continuing from drawing LRM-212, location D-6, where it was included in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Section 2.3.4.9, Heater and Moisture Separator Drains System The following RAI was generated as part of the scoping and screening review for the heater and moister separator drains system for the Kewaunee Power Station LRA.

RAI 2.3.4.9-01

Background

LRA Section 2.3.4.9, Heater and Moisture Separator Drains System, states that components are within the scope of license renewal per 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

Drawing LRM-207, locations C-1 and D-1, show two instruments lines (DPS 16431 and DPS 16432) not in scope continued to instrument lines on feedwater heater 15B on LRM-206, location H-2. The continuation on LRM-206, location H-2, shows this section of instrument lines as in scope for 10 CFR 54.4(a)(2).

Request:

Provide additional information to clarify the scoping classification for this pipe section.

Section 2.3.4.10, Heating Steam System The following RAIs were generated as part of the scoping and screening review for the heating steam system for the Kewaunee Power Station LRA.

RAI 2.3.4.10-01

Background:

LRA Section 2.3.4.10, Heating Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-605-1, location A-1, shows a section of heating steam pipe to/from a control valve (31105/HS476) within scope for 10 CFR 55.4(a)(2). However, the same section of pipe is not included in scope on drawing LRXK-100-38, location D-8.

Request:

Provide additional information to clarify the scoping classification for this pipe section.

RAI 2.3.4.10-02

Background:

LRA Section 2.3.4.10, Heating Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and have an intended function of providing a pressure boundary.

Issue:

License renewal drawing LRM-605-1, location E-8, shows the caustic dilution water heat exchanger as not in scope. Failure of this heat exchanger casing may affect the intended function of providing a pressure boundary.

Request:

Provide additional information explaining why the caustic dilution water heat exchanger is not included in scope per 10 CFR 54.4(a)(2).