ML042300442
| ML042300442 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/05/2004 |
| From: | Coutu T Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-04-090 | |
| Download: ML042300442 (6) | |
Text
Nacn Committed to Nulear Exce~~
Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC August 5, 2004 NRC-04-090 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE No. DPR-43 Response To Request For Additional Information Related To Relief Reauest RR-MC-2
References:
- 1. Letter from Thomas Coutu (NMC) to Document Control Deck (NRC), "IN-SERVICE INSPECTION (ISI) PROGRAM RELIEF REQUEST NO. RR-MC-2 FOR CLASS MC", dated January 16, 2004.
- 2. E-mail from Carl F. Lyon (NRC) to Theodore L. Maloney - REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE NUCLEAR POWER PLANT RELIEF REQUEST RR-MC-2 FIRST TEN YEAR CONTAINMENT INSERVICE INSPECTION", dated June 15, 2004.
In reference 2, the Nuclear Regulatory Commission (NRC) staff requested additional information concerning the Nuclear Management Company, LLC (NMC) request for an Inservice Inspection Program relief request number RR-MC-2. (Reference 1). This letter is NMC's response to the NRC's request for additional information (RAI). to this letter contains the questions the NRC staff requested. Enclosure 2 to this letter contains the questions the NRC staff requested with NMC's response.
N490 Highway 42
- Kewaunee, Wisconsin 54216-9511 Telephone: 920.388.2562 01
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August 5, 2004.
Thomas Coutu Site Vice-President, Kewaunee Nuclear Power Plant Nuclear Management Company, LLC Enclosures(2) cc: Administrator, Region 111, USNRC Project Manager, Kewaunee Nuclear Power Plant, USNRC Senior Resident Inspector, Kewaunee Nuclear Power Plant, USNRC Electric Division, PSCW
ENCLOSURE 1 NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST RR-MC-2 REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE NUCLEAR POWER PLANT RELIEF REQUEST RR-MC-2 FIRST TEN YEAR CONTAINMENT INSERVICE INSPECTION
Reference:
Letter from Thomas Coutu (NMC) to NRC, unservice Inspection Program Relief Request No. RR-MC-2 for Class MC," January 16, 2004.
- 1. For the performance of leakage rate tests, the licensee is using performance based Option B of Appendix J of 10 CFR Part 50. Based on the performance of the individual components (except equipment hatches and air-locks), the licensee is permitted to extend the Type B leakage rate test interval to as high as 10 years. Such a test interval may not be adequate to ensure the integrity of the associated seals and gaskets.
Please provide the (1)Type B leak rate test interval for the three affected components; and (2)justification that the test interval is adequate for the assessment of the integrity of the seals and gaskets associated with these components.
- 2. In the "Alternative Method of Examination," the licensee states that it will perform VT-3 examination of the seals and gaskets of these components, if the components are disassembled for maintenance.
Since this is the only opportunity available to monitor the aging degradation of the seals and gaskets, please justify why a VT-3 examination is proposed when a component is disassembled, instead of a more detailed VT-1.
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ENCLOSURE 2 NRC RAI RESPONSE REGARDING RR-MC-2 KEWAUNEE NUCLEAR POWER PLANT REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE NUCLEAR POWER PLANT RELIEF REQUEST RR-MC-2 FIRST TEN YEAR CONTAINMENT INSERVICE INSPECTION
Reference:
Letter from Thomas Coutu (NMC) to NRC, unservice Inspection Program Relief Request No. RR-MC-2 for Class MC," January 16, 2004.
- 1. For the performance of leakage rate tests, the licensee is using performance based Option B of Appendix J of 10 CFR Part 50. Based on the performance of the individual components (except equipment hatches and air-locks), the licensee is permitted to extend the Type B leakage rate test interval to as high as 10 years. Such a test interval may not be adequate to ensure the integrity of the associated seals and gaskets.
Please provide the (1) Type B leak rate test interval for the three affected components; and (2)justification that the test interval is adequate for the assessment of the integrity of the seals and gaskets associated with these components.
NMC Response Kewaunee Nuclear Power Plant has implemented a Containment Leak Rate Test Program that includes .an allowance for a Type B or Type C test interval to be extended up to 60 months. With an eighteen-month operating cycle this becomes a nominal actual allowed test interval extension of 54 months (4.5 years.) This allowance of 10 CFR 50, Appendix J, Option B was first exercised during the 2001 refueling outage. In some cases the initial test interval extension is less than three refueling outages due to balancing of the overall test schedule.
The Type B Tests at Kewaunee Nuclear Power Plant have been performed as follows since the start of the 1 st Ten Year Interval September 9, 1996 through September 9, 2006 for Class MC for the requested penetrations.
- Penetration No. C-10: Performed refueling outages 1998, 2000 and 2003 and is scheduled to be performed every third refueling outage, subsequently (next performance in 2007.)
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- Penetration No. F-8: Performed during refueling outages 1998, 2000 and 2001 and is scheduled to be performed in 2004 and~then every third refueling outage, subsequently.
- Penetration No. 41 S/S: Performed during refueling outages 1998, 2000, 2001 and 2003 and scheduled to be performed in 2004. Due to other commitments made by the Pumps & Valves IST Program, this penetration is tested each refueling outage.
The extended test intervals are deemed adequate because the methodology used to determine if the Type B or Type C test interval for a particular component can be extended is established in the Containment Leak Rate Test Program. This methodology was approved for use by the NRC in Regulatory Guide 1.163, Performance-Based Containment Leak-Test Program, by reference to NEI 94-01, Industry Guideline For Implementing Performance-Based Option of 10 CFR 50, Appendix J. The plant-specific Containment Leak Rate Test Program incorporates the Regulatory Guide 1.163 position that a Type C test interval extension is limited to 60 months and conservatively applies this 60-month limitation to both Type C and Type B tests. As described in NEI 94-01, the justification for the acceptability of extending the test interval for a component is based upon an evaluation of the following performance factors: Past Component Performance, Design, Service, and Safety Impact. KNPP data for these three penetrations has shown acceptable local leak rate test results for every test conducted since 1998. These test results exceed the NEI 94-01 acceptability criteria for justification of the ten year interval.
- 2. In the uAltemative Method of Examination," the licensee states that it will perform VT-3 examination of the seals and gaskets of these components, if the components are disassembled for maintenance.
Since this is the only opportunity available to monitor the aging degradation of the seals and gaskets, please justify why a VT-3 examination is proposed when a component is disassembled, instead of a more detailed VT-1.
NMC Response VT-3 Examination was the Alternative Method of Examination, if disassembled for Maintenance, due to requirements stated in ASME Boiler and Pressure Vessel Code Section Xl 1992 Edition 1992 Addenda Article IWE-2500 Table IWE-2500-1 Category E-D Item No.
E5.1 0 and E5.20. Performance of a VT-1 Visual Examination could be performed but would be in excess of ASME Boiler and Pressure Vessel Code Section Xl 1992 Edition 1992 Addenda stated requirements.
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Even though a VT-1 Visual Examination would be in excess of ASME Boiler and Pressure Vessel Code Section Xl 1992 Edition 1992 Addenda, NMC will conduct a VT-1 examination of the seals and gaskets of these components, if the components are disassembled for maintenance, for the life of this relief request.
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