ML101410322: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:May 27, 2010  
{{#Wiki_filter:May 27, 2010 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
 
Innsbrook Technical Center - 2SW 5000 Dominion Blvd.
Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc. Innsbrook Technical Center - 2SW 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
Glen Allen, VA 23060-6711  


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)  
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==


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. 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 staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.  
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. 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 301-415-3873 or by e-mail at John.Daily@nrc.gov.
Sincerely,
                                              /RA/ J. Robinson for John Daily, Sr. Project Manager Project Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305


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 301-415-3873 or by e-mail at John.Daily@nrc.gov. Sincerely,
==Enclosure:==
/RA/ J. Robinson for John Daily, Sr. Project Manager      Project Operations Branch      Division of License Renewal      Office of Nuclear Reactor Regulation Docket No. 50-305


==Enclosure:==
As stated cc w/encl: See next page


As stated cc w/encl:  See next page May 27, 2010 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc. Innsbrook Technical Center - 2SW 5000 Dominion Blvd. Glen Allen, VA 23060-6711  
May 27, 2010 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center - 2SW 5000 Dominion Blvd.
Glen Allen, VA 23060-6711


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)  
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)


==Dear Mr. Heacock:==
==Dear Mr. Heacock:==


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. 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 staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.  
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. 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 301-415-3873 or by e-mail at John.Daily@nrc.gov.
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 301-415-3873 or by e-mail at John.Daily@nrc.gov. Sincerely, /RA/ J. Robinson for John Daily, Sr. Project Manager       Project Operations Branch     Division of License Renewal       Office of Nuclear Reactor Regulation Docket No. 50-305  
Sincerely,
                                              /RA/ J. Robinson for John Daily, Sr. Project Manager Project Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305


==Enclosure:==
==Enclosure:==
As stated cc w/encl:  See next page DISTRIBUTION
: See next page ADAMS Accession Number:  ML101410322 OFFICE PM:RPOB:DLR LA:RPOB:DLR BC:RPOB:DLR PM:RPB1:DLR NAME JDaily (JRobinson for) YEdmonds JRobinson JDaily (JRobinson for)
DATE 5/27/10 5/27/10 5/27/10 5/27/10 OFFICIAL RECORD COPY Letter to David A. Heacock from John Daily dated May 27, 2010


==SUBJECT:==
As stated cc w/encl: See next page DISTRIBUTION:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION  (TAC NO. MD9408)  
See next page ADAMS Accession Number: ML101410322 OFFICE        PM:RPOB:DLR              LA:RPOB:DLR        BC:RPOB:DLR          PM:RPB1:DLR NAME          JDaily (JRobinson for) YEdmonds              JRobinson            JDaily (JRobinson for)
DATE          5/27/10                  5/27/10            5/27/10              5/27/10 OFFICIAL RECORD COPY


DISTRIBUTION
Letter to David A. Heacock from John Daily dated May 27, 2010
:
HARD COPY: DLR RF  E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource -------------- JDaily DDoyle PTam SBurton, RIII  KBarclay, RIII MKunowski, RIII VMitlyng, RIII ICouret, OPA SUttal, OGC Kewaunee Power Station cc:  Resident Inspectors Office U.S. Nuclear Regulatory Commission N490 Hwy 42 Kewaunee, WI  54216-9510 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc. Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc. Kewaunee Power Station N490 Highway 42 Kewaunee, WI  54216


Mr. Michael J. Wilson, Director Nuclear Safety & Licensing Dominion Energy Kewaunee, Inc. Kewaunee Power Station N490 Highway 42 Kewaunee, WI  54216 Mr. Daniel G. Stoddard Senior Vice President - Nuclear Operations Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Mr. William R. Matthews Senior Vice President - Nuclear Operations Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Mr. William D. Corbin Director - Nuclear Engineering Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Mr. Paul C. Aitken Supervisor - License Renewal Project Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Mr. David A. Sommers Supervisor - Nuclear Engineering Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA  23060-6711 Ms. Lillian M. Cuoco, Esq. Senior Counsel Dominion Resources Services, Inc. 120 Tredegar Street Riverside 2 Richmond, VA  23219
==SUBJECT:==
 
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)
Mr. Stephen E. Scace Site Vice President Dominion Energy Kewaunee, Inc. Kewaunee Power Station N490 Highway 42 Kewaunee, WI  54216 Mr. David R. Lewis Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, N.W.
DISTRIBUTION:
Washington, DC  20037-1122 Mr. Ken Paplham E 4095 Sandy Bay Rd. Kewaunee, WI  54216
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource
--------------
JDaily DDoyle PTam SBurton, RIII KBarclay, RIII MKunowski, RIII VMitlyng, RIII ICouret, OPA SUttal, OGC


Mr. Jeff Kitsembel, P.E. Public Service Commission of Wisconsin P. O. Box 7854 Madison, WI 53707-7854
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 Dominion 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. Daniel G. Stoddard                    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. William R. Matthews                    E 4095 Sandy Bay Rd.
Senior Vice President - Nuclear Operations 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


ENCLOSURE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI B2.1.7-3, Concerns Regarding Buried and Underground Piping and Tanks, Kewaunee LRA  
KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI B2.1.7-3, Concerns Regarding Buried and Underground Piping and Tanks, Kewaunee LRA


===Background===
==Background:==
:  The license renewal application (LRA) Section B2.1.7, Buried Piping and Tanks Inspection Program, states that it is an existing program with one enhancement and is consistent with the program elements in GALL AMP XI.M34. This AMP addresses buried piping, (i.e., piping in direct contact with soil). LRA Section B2.1.10, External Surfaces Monitoring Program, states that it is an existing program with enhancements. This AMP addresses aging management of the external surfaces of piping exposed to air, which would normally include underground inaccessible piping (i.e., piping not in direct contact with soil, but located below grade in a vault, pipe chase, or other structure where it is exposed to air and where access is limited).


The license renewal application (LRA) Section B2.1.7, Buried Piping and Tanks Inspection Program, states that it is an existing program with one enhancement and is consistent with the program elements in GALL AMP XI.M34. This AMP addresses buried piping, (i.e., piping in direct contact with soil). LRA Section B2.1.10, External Surfaces Monitoring Program, states that it is an existing program with enhancements. This AMP addresses aging management of the external surfaces of piping exposed to air, which would normally include underground inaccessible piping (i.e., piping not in direct contact with soil, but located below grade in a vault, pipe chase, or other structure where it is exposed to air and where access is limited).
There have been a number of recent industry events involving leakage from buried and underground piping and tanks.
There have been a number of recent industry events involving leakage from buried and underground piping and tanks.
Issue:
Issue:
In light of this recent industry Operating Experience (OE), the staff is concerned about the continued susceptibility to failure of buried and/or underground piping that are within the scope of 10 CFR 54.4 and subject to aging management for license renewal. In reviewing the AMPs cited above along with the applicable aging management review items associated with them, the staff is not clear on whether: (1) the components addressed by these AMPs clearly include both buried and underground piping (piping which is below grade and contained in a vault or other structure where it is exposed to air and where access is limited); and (2) whether such programs are being updated to incorporate lessons learned from these recent events as well as any OE from the applicant's own history.
In light of this recent industry Operating Experience (OE), the staff is concerned about the continued susceptibility to failure of buried and/or underground piping that are within the scope of 10 CFR 54.4 and subject to aging management for license renewal. In reviewing the AMPs cited above along with the applicable aging management review items associated with them, the staff is not clear on whether: (1) the components addressed by these AMPs clearly include both buried and underground piping (piping which is below grade and contained in a vault or other structure where it is exposed to air and where access is limited); and (2) whether such programs are being updated to incorporate lessons learned from these recent events as well as any OE from the applicants own history.
Request: 1. Provide a list and brief summary of any leaks or adverse conditions discovered during inspections (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within 6-inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried or underground piping or tanks at the station in the past five years that were entered in your corrective action program but are not included in your LRA. Describe how your current AMPs or proposed changes to the AMPs address these issues.
Request:
: 2. Provide a discussion of how the AMPs used in managing the aging of buried, underground, and limited access piping and tanks within the scope of license renewal will address recent industry OE as well as any OE from the applicant's own history.}}
: 1. Provide a list and brief summary of any leaks or adverse conditions discovered during inspections (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within 6-inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried or underground piping or tanks at the station in the past five years that were entered in your corrective action program but are not included in your LRA. Describe how your current AMPs or proposed changes to the AMPs address these issues.
: 2. Provide a discussion of how the AMPs used in managing the aging of buried, underground, and limited access piping and tanks within the scope of license renewal will address recent industry OE as well as any OE from the applicants own history.
ENCLOSURE}}

Latest revision as of 18:53, 13 November 2019

Request for Additional Information for the Review of the Kewaunee Power Station License Renewal Application
ML101410322
Person / Time
Site: Kewaunee Dominion icon.png
Issue date: 05/27/2010
From: Daily J
NRC/NRR/DLR/RPOB
To: Heacock D
Dominion Energy Kewaunee
Daily, John NRC/NRR/DLR/RPOB 415-3873
References
TAC MD9408
Download: ML101410322 (5)


Text

May 27, 2010 Mr. David A. Heacock 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 (TAC NO. MD9408)

Dear Mr. Heacock:

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. 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 301-415-3873 or by e-mail at John.Daily@nrc.gov.

Sincerely,

/RA/ J. Robinson for John Daily, Sr. Project Manager Project Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

As stated cc w/encl: See next page

May 27, 2010 Mr. David A. Heacock 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 (TAC NO. MD9408)

Dear Mr. Heacock:

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. 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 301-415-3873 or by e-mail at John.Daily@nrc.gov.

Sincerely,

/RA/ J. Robinson for John Daily, Sr. Project Manager Project Operations Branch 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: ML101410322 OFFICE PM:RPOB:DLR LA:RPOB:DLR BC:RPOB:DLR PM:RPB1:DLR NAME JDaily (JRobinson for) YEdmonds JRobinson JDaily (JRobinson for)

DATE 5/27/10 5/27/10 5/27/10 5/27/10 OFFICIAL RECORD COPY

Letter to David A. Heacock from John Daily dated May 27, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource


JDaily DDoyle PTam SBurton, RIII KBarclay, RIII MKunowski, RIII VMitlyng, RIII ICouret, OPA SUttal, OGC

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 Dominion 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. Daniel G. Stoddard 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. William R. Matthews E 4095 Sandy Bay Rd.

Senior Vice President - Nuclear Operations 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 RAI B2.1.7-3, Concerns Regarding Buried and Underground Piping and Tanks, Kewaunee LRA

Background:

The license renewal application (LRA) Section B2.1.7, Buried Piping and Tanks Inspection Program, states that it is an existing program with one enhancement and is consistent with the program elements in GALL AMP XI.M34. This AMP addresses buried piping, (i.e., piping in direct contact with soil). LRA Section B2.1.10, External Surfaces Monitoring Program, states that it is an existing program with enhancements. This AMP addresses aging management of the external surfaces of piping exposed to air, which would normally include underground inaccessible piping (i.e., piping not in direct contact with soil, but located below grade in a vault, pipe chase, or other structure where it is exposed to air and where access is limited).

There have been a number of recent industry events involving leakage from buried and underground piping and tanks.

Issue:

In light of this recent industry Operating Experience (OE), the staff is concerned about the continued susceptibility to failure of buried and/or underground piping that are within the scope of 10 CFR 54.4 and subject to aging management for license renewal. In reviewing the AMPs cited above along with the applicable aging management review items associated with them, the staff is not clear on whether: (1) the components addressed by these AMPs clearly include both buried and underground piping (piping which is below grade and contained in a vault or other structure where it is exposed to air and where access is limited); and (2) whether such programs are being updated to incorporate lessons learned from these recent events as well as any OE from the applicants own history.

Request:

1. Provide a list and brief summary of any leaks or adverse conditions discovered during inspections (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within 6-inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried or underground piping or tanks at the station in the past five years that were entered in your corrective action program but are not included in your LRA. Describe how your current AMPs or proposed changes to the AMPs address these issues.
2. Provide a discussion of how the AMPs used in managing the aging of buried, underground, and limited access piping and tanks within the scope of license renewal will address recent industry OE as well as any OE from the applicants own history.

ENCLOSURE