ML090530003

Request to Supplement the Kewaunee Power Station License Renewal Application in Regards to the Use of the Work Control Process as an Aging Management Program

ML090530003
Person / Time
Site:	Kewaunee
Issue date:	03/23/2009
From:	David Pelton License Renewal Projects Branch 1
To:	Christian D Dominion Energy Kewaunee
Hernandez S, NRR/DLR/REBB, 415-4049
References
TAC MD9408
Download: ML090530003 (7)

Text

March 23, 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 TO SUPPLEMENT THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION IN REGARDS TO THE USE OF THE WORK CONTROL PROCESS AS AN AGING MANAGEMENT PROGRAM (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." The staff has identified an issue with the KPS license renewal application (LRA) that could potentially impact the staff's review. The KPS LRA includes aging management program (AMP) B2.1.32, "Work Control Process," which the LRA describes as a plant-specific AMP. The staff noted that the Work Control Process AMP program elements do not include (or in some cases do not clearly explain) the attributes discussed in NUREG-1800, Section A.1.2.3, "Aging Management Program Elements." Examples illustrating the differences between the KPS LRA and NUREG-1800 are included in the Enclosure.

The lack of detail in the Work Control Process AMP, impacts the staff's ability to effectively review the 1,200+ Aging Management Review (AMR) line items listed in Table 2 of the LRA, for which the Work Control Process AMP is credited (approximately 25% of the components within the scope of license renewal). It is unclear to the staff how this AMP, as described in the LRA, can be used to effectively manage such a broad range of component types, materials, environments, and aging effects. As a result, the staff requests that Dominion supplement the KPS LRA to address the issues described above.

Please respond within 30 days of the receipt of this letter to inform the staff of your plans for resolving the issues identified and for supplementing the KPS LRA. The staff is also available to discuss this matter in a public meeting. Upon receipt of the LRA supplement, the staff will assess the potential impact on the KPS LRA review schedule and will develop a custom LRA review schedule, as necessary.

D. Christian The contents of this letter were discussed with Paul Aitken, of your staff. If you have any questions on this matter, please contact Mr. Samuel Hernández, Project Manager for the review of the KPS license renewal application, by telephone at 301-415-4049 or by e-mail at samuel.hernandez@nrc.gov. Sincerely, /RA/

David L. Pelton, Chief Reactor 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

ML090530003 (letter) OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR DD:DLR NAME I.King S.Hernandez D.Pelton S.Lee DATE 02/24 /09 03/20/09 03/23/09 03/23/09 Work Control Process - Aging Management Program Kewaunee Power Station License Renewal Application (TAC No. MD9408)

Examples Illustrating How the Aging Management Program (AMP) B2.1.32, "Work Control Process," Described in the KPS LRA is Not Consistent with the Attributes Discussed in NUREG-1800, Section A.1.2.3, "Aging Management Program Elements."

(Please note that the Work Control Program AMP elements must address each of the 1,200+ AMR line items listed in Table 2 of the LRA, for which the Work Control Process AMP is credited.)

• Element 1: Scope of Program - The element does not include a listing of the specific structures and components of which the program manages the aging;

• Element 3: Parameters Monitored or Inspected - While the element lists some of the materials and associated aging effects that it applies to, it does not list any of the parameters that would be monitored (i.e., measurement of wall thickness, detection and sizing of cracks, dissolved oxygen levels, etc.) nor does the element establish a specific link between a structure or component's intended function and the parameter being monitored;

• Element 4: Detection of Aging Effects - As in Element 3, this element does not discuss the parameters to be monitored nor does it establish a link to an associated aging effect. While performing inspections on a representative sample of components and structures (as is discussed in the element) is acceptable, the element does not include the basis for 1) the breadth and depth of the selection process or 2) determining the appropriate frequency of the various inspections. The element states that Work Control Process performs visual inspections of various component types and structural elements. What is unclear is the type and extent of visual inspections that the Work Control Process will provide. What is also unclear is how visual inspections would be an appropriate detection tool under all circumstances. For example, visual inspections may not be an effective tool for detecting changes in material properties (e.g., fracture toughness, hardness, elastic properties, etc.);

• Element 5: Monitoring and Trending - The element discusses System Engineers periodically monitoring the performance of structures and components and the use of the Corrective Actions Program (CAP) as a means of trending performance issues. What the element does not discuss is the threshold that will be applied for the generation of a condition report (CR) and whether the CR database can be searched specifically for aging-related issues. Also, the element does not discuss how the Work Control Process inspections might be expanded (short term) based on the results of "extent of condition" reviews. Finally, the element does not address if/how trending data and operating experience will be used to make long term decisions regarding the scope and frequency of inspections performed using the Work Control Process; ENCLOSURE

• Element 6: Acceptance Criteria - The element does not discuss or provide a basis for the acceptance criteria to be applied for the various Work Control Process inspections.

• Element 10: Operating Experience - While the element lists a few examples of how the Work Control Process had been successfully applied in the past as an aging management program, this is insufficient for the staff to be able to evaluate whether operating experience had been appropriately considered, given the range of AMR line items for which the Work Control Process AMP is credited. Additionally, the element does not discuss the role operating experience will play on an on-going basis to periodically validate the scope and frequency of inspections performed using the Work Control Process.

Letter to D. Christian from D. Pelton dated March 23, 2009

SUBJECT:

REQUEST TO SUPPLEMENT THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION IN REGARDS TO THE USE OF THE WORK CONTROL PROCESS AS AN AGING MANAGEMENT PROGRAM (TAC NO. MD9408)

HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr RidsNrrDlrRer1 RidsNrrDlrRer2 RidsNrrDlrRpb1 RidsNrrDlrRpb2 _ _ _ _ _ _ _ _

S. Hernandez S. Lopas P. Tam S. Burton P. Higgens M. Kunowski V. Mitlyng

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 Dominon 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. William R. Matthews Senior Vice President - Nuclear Operations Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Alan J. Price Vice President - Nuclear Engineering 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

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. Washington, DC 20037-1122 Mr. Ken Paplham E 4095 Sandy Bay Rd.

Kewaunee, WI 54216 Mr. Jeff Kitsembel, P.E. Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854