Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060

ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

AUG 30 2H1?

Serial No. 12-508 LIC/JG/RO Docket No.: 50-305 License No.: DPR-43

DOMINION ENERGY KEWAUNEE. INC. KEWAUNEE POWER STATION REACTOR VESSEL INTERNALS INSPECTION PLAN REVIEW REQUEST SUPPLEMENT AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

By application dated December 12, 2011 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK), requested approval, pursuant to the provisions of Renewed Operating License DPR-43, of the inspection plan for reactor vessel internal (RVI) components at Kewaunee Power Station (KPS). This inspection plan submittal was to fulfill certain requirements of Renewed Operating License DPR-43, Section 2.C(1 5)(b); specifically, Commitment Items 1 and 2 of Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011. The inspection plan was supplemented on June 28, 2012 (Reference 2). Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the inspection plan (Reference 3). The NRC questions were discussed with NRC staff to obtain clarification, during a telephone conference on July 23, 2012. The DEK response is provided in Attachment 1 to this letter. Attachment 2 provides revised RVI components inspection plan tables. If you have questions or require additional information, please feel free to contact Mr. Jack Gadzala at 920-388-8604. Very truly yours,

J. AI

rice

Vice President - Nuclear Engineering Attachments: 1. Response to Request for Additional Inspection Plan Review Request Information Reactor Vessel Internals

2. Supplement to Reactor Vessel Internals Inspection Plan Review Request, Table 3 (Revision 1)

/A07

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References: 1. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Reactor Vessel Internals Inspection Plan Review Request," dated December 12, 2011. 2. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Reactor Vessel Internals Inspection Plan Review Request, Supplement and Response to Request for Additional Information," dated June 28, 2012. 3. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7727 Kewaunee - Request for Additional Information Re: RVI components Inspection Plan - Follow-up RAI to response provided for RAI item Cher-006," dated July 17, 2012.

Commitments made by this letter: NONE

cc:

Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No. 12-508

ATTACHMENT 1

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL INTERNALS INSPECTION PLAN REVIEW REQUEST

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-508 Attachment 1 Page 1 of 6 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION INSPECTION PLAN FOR THE AUGMENTED INSERVICE INSPECTION PROGRAM FOR EXAMINATION OF REACTOR VESSEL INTERNALS On July 17, 2012, the NRC transmitted to Dominion Energy Kewaunee, (DEK) a request for additional information (RAI) (Reference 1) concerning the inspection plan for reactor vessel internal (RVI) components at Kewaunee Power Station (KPS). This inspection plan submittal was to fulfill certain requirements of Renewed Operating License DPR43, Section 2.C(1 5)(b); specifically, Commitment Items 1 and 2 of Appendix A of NUREG-1958, "Safety Evaluation Report Related to the Kewaunee Power Station," dated January 2011. The inspection plan was supplemented on June 28, 2012 (Reference 2). The NRC staff reviewed DEK's June 28, 2012 supplement (Reference 2), specifically as it responds to NRC question ME7727-RAII-EVIB-CHER-006-2012-05-09, and has some concerns regarding the aging degradation in Alloy X-750 clevis insert bolts. Consequently, the NRC staff developed a follow-up question (below) on the issue. This question was discussed with NRC staff to obtain clarification during a telephone conference on July 23, 2012. During the conference, NRC staff requested that DEK state whether a VT-3 inspection is required by ASME Section XI (because the clevis insert bolts are a reactor vessel internals structure). The staff also requested a qualitative analysis regarding the minimum number of clevis insert bolts (and the dowel pin) that must be functional. The RAI question is provided below, followed by the DEK response. NRC Question ME7727-RAII-EVIB-Cher-017-2012-07-17 According to Section A.1.4 in MRP-175, "Materials Reliability Program: PWR Internal Aging Degradation Mechanism Screening Threshold Values," susceptibility to stress corrosion cracking (SCC) in Nickel Base Alloy X-750 depends on the type of heat treatment that is performed on the alloy. The high temperature heat treatment (HTH) process that is used on Alloy X-750 offers better resistance to SCC than the other age hardened heat treatment processes. Previous operating experience in a US PWR unit indicates that the Alloy X-750 clevis insert bolts experienced cracking. In Table 4-9 of the MRP-227-A report, the MRP identified only wear as an aging mechanism for the clevis insert bolts. A - Based on the operating experience as stated above, the staff believes that cracking should also be included as an active aging degradation in the clevis insert bolts. Therefore, the staff requests that the licensee confirm that Alloy X-750 material in HTH condition was used for clevis insert bolts at KPS.

Serial No. 12-508 Attachment 1 Page 2 of 6

B - If the Alloy X-750 material is not in HTH condition, the staff requests that the licensee include verification of aging degradation due to cracking in its inspection and evaluation guidelines for these bolts at KPS. C -VT-3 examination of the bolts every 10 years would detect completely failed or missing bolts but not partially cracked bolts. Therefore, the staff requests the licensee to provide: (1) Justification that VT-3 technique would be adequate for monitoring the cracking issue in the clevis insert bolts before it fails; (2) Information on the number of clevis insert bolts that are necessary for maintaining their function during the extended period of operation; and, (3) Information on the number of clevis insert bolts that are currently present at KPS. Response: The primary function of the core barrel is to support the core. Lateral support for the core is provided at the upper and lower core plate locations and at intermediate positions during a seismic and LOCA event. During a seismic and LOCA event, the core may impact the baffle/former assembly that is supported by the core barrel (Reference 3). The core rests directly on the lower core plate that is ultimately supported by the core barrel. The lower core plate is attached at its periphery to the core barrel inside diameter and supported by lower support columns that are attached to the lower support forging. The lower support forging is welded at its edge to the bottom end of the core barrel. Four alignment pins located at 900 intervals are welded to the core barrel and engage the upper core plate. These pins restrain the lateral motion of the upper core plate. The baffle/former assembly is bolted to the core barrel and forms an outer envelope for the core. Four radial keys located at 900 intervals are attached to the core barrel at the lower support forging level. The radial keys restrain large transverse motions of the core barrel, but at the same time allow unrestricted radial and axial thermal expansions. Each radial key fits into the keyway of its corresponding clevis, which is welded to the reactor vessel (Figure 1). The lower core barrel is restrained laterally and torsionally by these uniformly spaced radial keys. The radial keys, along with the matching clevis inserts, are designed to limit the tangential motion between the lower end of the core barrel and the vessel. At

Serial No. 12-508 Attachment 1 Page 3 of 6 assembly, as the internals are lowered into the vessel, the keys engage the keyways of the inserts in the axial direction. With this design, the core barrel is provided with a support at the farthest extremity and may be viewed as a beam fixed at the top and guided at the bottom. With the radial key and inserts, the radial and axial expansions of the core barrel are accommodated, but circumferential movement (i.e., rotation) of the core barrel is restricted. The thickness of the clevis inserts is customized to have the optimum gap sizes. Each clevis is welded to the inside wall of the reactor vessel at 900 intervals to align with the four radial keys. The clevis inserts are attached to the clevis with eight bolts and one dowel pin. Each bolt is restrained by a bolt-head locking bar that prevents it from vibrating out of its threaded receptacle. The locking bar is attached with a tack weld on each end. The clevis inserts are retained within the clevis by friction (interference fit). Therefore, the clevis bolting is a designed redundancy to the friction fit (Figure 2). The function of the dowel pin is to offload any shear from the bolts for a case where a load is acting vertically upward on the clevis insert. A loose parts evaluation of a clevis insert bolt that experienced cracking at another utility (performed by Westinghouse Electric Company) determined that the separated heads will remain captured in the clevis insert counter-bores and will not impact operation. No safety or operability concerns were identified during this evaluation (Reference 4). The core barrel and its radial support keys are classified as core support structures. The clevis inserts are classified as reactor vessel internals structures and are also one of the components that form the interface between core supports and internals structures. CLM IS INSERT

Top view of
expanded section Expanded view at right FORGING
Figure 1

Serial No. 12-508 Attachment I Page 4 of 6

Locking Mechanism (tab across bolt head) Clevis Insert Bolt Head 0 Dowel Pin Clevis Clevis Insert

Clevis Insert
(Section A-A Figure 1 above) View towards reactor vessel interior wall

Figure 2

Basis for VT-3 Examination of Clevis Bolts Since the clevis insert bolts are a reactor vessel internals structure (and a component that forms the interface between core supports and internals structures), a VT-3 inspection is required by ASME Code, Section XI. These inspections are covered under an existing ASME Xl program and not under MRP-227 (Existing Program Items, Item B13.70 (formerly identified as Item B13.10), VT-3 examination of the clevis bolting). Based on the staff's concern, DEK has revised this item to include "loss of material (wear) and cracking" (in Table 3, Reactor Vessel Internals Inspection Plan (Reference 5)). The Alloy X-750 clevis insert bolts at KPS did not undergo the HTH treatment process. Based upon time of manufacturing and shipping, Westinghouse Electric Company indicates that the X-750 clevis insert bolts are supplied as Condition BH: * Hot worked, " Solution treatment at 980'C for 1 hour, air cooled, then, " Aged at 704'C for 20 hours, air cooled; or, 7300 C for 8 hours with a furnace cool followed by 620 0 C for 8 hours with an air cool. The proposed inspection and evaluation guidelines for these components are adequate to ensure that degradation would be indentified prior to loss of the redundant restraining function of the bolts. Because the bolts are restrained, the potential for loose parts from

Serial No. 12-508 Attachment 1 Page 5 of 6 a bolt failure is not significant. Therefore, the planned VT-3 inspection of these bolts every 10 years, as required by ASME Code, Section XI, is adequate for verification of their condition. Three previous VT-3 inspections have verified that the clevis bolts are installed and that the locking bar and tack welds are in place. Degradation of the clevis insert bolts would not result in a loss of intended function due to the nature of the design. A significant change in this support would be recognized by comparing changes from baseline neutron noise data from the excore detectors, thus providing a means for observing core barrel motion and the frequencies and mode shapes governing such motion. Moreover, to reach this stage, two additional components would have to fail. Therefore, the effects of primary water stress corrosion cracking (PWSCC) of the clevis insert bolts are not considered significant (Reference

3).
As discussed above, each of the four clevis inserts is secured to its support via eight bolts and one dowel pin. Therefore, a total of 32 clevis insert bolts and four dowel pins are in place to provide their restraining function. Since the clevis inserts are retained in place by means of an interference fit and dowel pin, the bolting is a designed redundancy. The function could reasonably be expected to be maintained (and reactor operation could safely continue) even with failure of multiple clevis bolts, since failed bolting would remain in place due the locking mechanism. Additionally, the close fit of the radial key (when the core barrel is in place) would prevent any bolt (and any dowel pin) from backing out of its housing. Even if a bolt completely cracked and its associated locking bar concurrently failed, the cracked bolt would not actually be released until the core barrel was subsequently removed. The primary consequence of a clevis bolt failure (should it occur) would be potentially to increase local wear between the radial keyways and clevis inserts. Failure of multiple bolts would likely lead to an increase in that wear potential. The presence of the dowel pin will provide some support to shear loads, thereby limiting the potential wear. In an extreme postulated case, if a loose clevis insert would be able to dislodge from the clevis (e.g., during a refueling outage when lifting the core barrel for the 10-year ISI), this could create a concern for loose parts and excessive motion of the lower internals. Multiple physical constraints exist to prevent this from occurring, even in the case of failed bolts. In the basic installation of the clevis insert, the insert is captured on each side by the clevis, such that it cannot become dislodged by moving in the right or left direction. Due to the close proximity of the radial key, lower internals, and vessel, the clevis insert is unable to become dislodged in the radial direction. Additionally, the clevis insert has a flange on the top that rests on the top side of the clevis. This ledge will prevent the clevis insert from becoming dislodged vertically downward. The only potential direction not constrained by significant lower internals and vessel structures is in the vertically upward direction (which is constrained by gravity). For the clevis insert to become dislodged upward, the bolts and dowel pins would all have to fail flush at the bolting surface between the clevis insert and vessel lug, which is unlikely. Based on the lock bar wear identified at another utility, it is more likely that the bolts would fail at the

Serial No. 12-508 Attachment 1 Page 6 of 6 head to shank radius. If failure did occur at the head to shank radius, the remaining shank provides an additional defense against the clevis insert dislodging vertically upward. As such, no additional inspections to assure the function of the clevis insert bolts are needed during the period of extended operation. As stated above, DEK has revised the KPS Reactor Vessel Internals Inspection Plan, Existing Program Items, Item B13.70, VT-3 examination of the clevis insert bolting, to include "loss of material (wear) and cracking". The revised Reactor Vessel Internals Inspection Plan Table 3 showing this change is provided in Attachment 2 to the letter transmitting this response.

REFERENCES 1. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK) et al, "ME7727 Kewaunee - Request for Additional Information Re: RVI components Inspection Plan - Follow-up RAI to response provided for RAI item Cher-006," dated July 17, 2012. 2. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Reactor Vessel Internals Inspection Plan Review Request, Supplement and Response to Request for Additional Information," dated June 28, 2012. 3. Letter from Christopher I. Grimes (NRC) to Roger A. Newton (Westinghouse Owners Group), "Acceptance for Referencing of Generic License Renewal Program Topical Report Entitled, 'License Renewal Evaluation: Aging Management for Reactor Internals', WCAP-14577, Revision 1, October 2000," dated February 10, 2001. 4. Westinghouse InfoGram IG-10-1, "Reactor Internals Lower Radial Support Clevis Insert Cap Screw Degradation," dated March 31, 2010. 5. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Reactor Vessel Internals Inspection Plan Review Request," dated December 12, 2011.

Serial No. 12-508

ATTACHMENT 2

SUPPLEMENT TO REACTOR VESSEL INTERNALS INSPECTION PLAN REVIEW REQUEST

TABLE 3 (REVISION 1)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-508

Table 3 (Revision 1) Reactor Vessel Internals Inspection Plan MRP-227 Westinghouse Plants Existing Programs Components (3 pages)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 12-508

Reactor Vessel Internals

B13,70 Core Barrel Assembly Core Barrel Flange Attachment Figure 4 XK-67866 B13.70 Upper Internals Assembly Upper Support Ring or Skirt Attachment Figure 4 and Figure 5 XK-67866 B13.70 Lower Internals Assembly Lower Core Plate Attachment Figure 4 and Figure 5 XK-67866 B13.70 Lower Internals Assembly Lower Core Plate Attachment Figure 4 and Figure 5 XK-67866 B13.70 Alignment and Interfacing Components Upper Core Plate Alignment Pins Attachment Figure 2 XK-67866 Reactor Vessel Upper Internals Assembly Upper Support Ring or Skirt Reactor Vessel Lower Internals Assembly Lower Core Plate Reactor Vessel Lower Internals Assembly Lower Core Plate Reactor Vessel Upper Internals Upper Core Plate Alignment Pins Y X X Y X X X X VT-3 examination. Cracking (IASCC, Fatigue) Reactor Vessel Core Barrel Y X
x2

VT-3 examination. Loss of material (wear).

VT-3 examination of the lower core plate to detect evidence of distortion and/or loss of bolt integrity. Cracking (IASCC, Fatigue) VT-3 examination. Loss of material (wear).

VT-3 examination. Loss of material (wear).

Category Notes: 1. 2. End of Original License is December 21, 2013. Examinations are performed when the core barrel is removed typically once per interval.

Table 3, Page 1 of 3

Serial No. 12-508

Reactor Vessel Internals

B13.70 Alignment and Interfacing Components Clevis Insert Bolts Attachment Figure 4 Reactor Vessel Internals Y X VT-3 examination once per interval when the lower internals are removed. Loss of material (wear) and cracking (Note 4). Eight bolts per clevis; four clevis at 900

Iintervals.

Category Notes: 1. 2. 3. 4. End of Original License is December 21, 2013. The clevis insert bolts are located on the reactor vessel below the lower internals. Per B-N-3, the structure shall be removed from the reactor for examination. Clevis insert bolts were screened in because of stress relaxation and associated potential for cracking; however, wear of the clevis/insert is the primary reason for the inspection.

Table 3, Page 2 of 3

Serial No. 12-508

Reactor Vessel Internals IEB 88-09 Reactor Vessel Bottom Mounted Instrumentation System Flux Thimble Tubes Flux Thimble Tubes (36) Y X Eddy Current Examination of the Flux Thimble Tubes Once Every Five Years

Category Notes: 1. End of Original License is December 21, 2013.

Table 3, Page 3 of 3