GO2-10-137, Response to Request for Additional Information License Renewal Application

Response to Request for Additional Information License Renewal Application

ML102660205
Person / Time
Site:	Columbia
Issue date:	09/15/2010
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-10-137
Download: ML102660205 (59)

Text

ENE R YE Sudesh K. Gambhir EIC ENERGY Vice President, Technical Services P.O. Box 968, Mail Drop PE04 N~JKI1VV ~I Ph Richland, WA 99352-0968 TPh.

509-377-8313 F. 509-377-2354 sgambhir@ energy-northwest.com September 15, 2010 G02-10-137 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION

References:

1) Letter, G02-1 0-011, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter dated July 15, 2010, NRC to WS Oxenford (Energy Northwest),

"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML101820636)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal.

Transmitted herewith in the Attachment is the Energy Northwest response to the Request for Additional Information (RAI) contained in Reference 2. Enclosure 1 contains Amendment 6 to the License Renewal Application (LRA) that was submitted in Reference 1. Enclosure 2 contains informational copies of revised License Renewal boundary drawings.

0o3'

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 No new commitments are included in this response.

If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Re pecqjuly)

IK'Gambhir Vice President, Technical Services

Attachment:

Response to Request for Additional Information :

License Renewal Application Amendment 6 :

License Renewal boundary drawings for information only (3 copies) cc:

NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EJ Leeds - NRC NRR EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn EH Gettys - NRC NRR (w/a)

BE Holian - NRC NRR RR Cowley - WDOH

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 1 of 39 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI 2.2-01

Background:

License renewal application (LRA) Section 2.1.1 states in part, "Consistent with NEI 95-10, the Columbia license renewal project scoping process establishes a listing of plant systems and structures, determines the functions they perform, and then determines which functions meet any one or more of the three criteria of 10 CFR 54.4(a)."

Issue:

The following Updated Final Safety Analysis Report (UFSAR) systems could not be located in LRA Table 2.2-1, Table 2.2-2 or Table 2.2-3.

FSAR Section System 8.3.1.1.4, 120/208-Volt Non-Class 1 E 120/208-Volt Non-Class 1 E Instrumentation Power System Instrumentation Power System 9.1.4 Fuel Handling System Fuel Handling System 9.5.3 Plant Lighting System Plant Lighting System 11.2 through 11.4 Radwaste Systems (Liquid, Gaseous & Solid) 11.6 Post Accident Sampling System Post Accident Sampling System Request:

Provide additional information to describe how the above systems were scoped for license renewal.

Energy Northwest Response:

Each of the following paragraphs addresses the systems listed above, in order. In every case, except the Plant Lighting System, the listed systems have been addressed in LRA Tables 2.2-1, 2.2-2, or 2.4-2, but not with the identical name as utilized in the Columbia FSAR.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 2 of 39 120/208 Volt Non-Class 1 E System:

The License Renewal Application (LRA) Table 2.2-2 listing 120V AC Electrical Distribution comprises all 120V AC systems. Therefore, LRA Table 2.2-2 listing of 120V AC Electrical Distribution includes FSAR 8.3.1.1.4 120/208-Volt Non-Class 1 E Instrumentation Power System.

The Fuel Handling System:

As discussed in LRA section 2.4.2 and in Table 2.4.2, Table 2.4-13. Table 3.3.1 Item 3.3.1-73, Table 3.5.2-2, Item 3, and Table 3.5.3-13 Item 76 and 94, the reactor building contains the Reactor Building Crane (and auxiliary hoist), Cavity In-Vessel Service Platform (CISP), the refueling floor jib cranes, the refueling platform, and telescoping mast and grapple. This equipment is in scope of the LRA. However, other than the CISP, the remainder of the reactor vessel and fuel servicing equipment is not within scope because the equipment does not perform a mechanical or structural function that meets the criteria of 10 CFR 54.4(a). They are stored in a safe condition during normal plant operation and do not present any seismic Il/I concerns. The Material Handling System Inspection Program will manage the loss of material for the cranes at Columbia.

Therefore, the Fuel Handling System (other than the tools and short-lived equipment) is within the scope of license renewal (LR) and is addressed in Section 2.4.2 of the LRA, the Reactor Building structure evaluation.

The Plant Lighting System:

The plant lighting system consists of four systems: normal AC lighting, normal-emergency AC lighting, emergency DC lighting, and battery-pack emergency lighting.

For the purpose of the LRA, these four systems are divided as follows:

" Normal Lighting - normal AC lighting.

Emergency Lighting - normal-emergency AC lighting, emergency DC lighting, and battery-pack emergency lighting.

The normal lighting supplied from either the main generator or offsite power is designed to provide adequate lighting for normal plant operation and associated plant access routes, and for control and maintenance of equipment. Therefore, Normal Lighting does not support any LR functions and is not in scope.

The emergency lighting supplied from onsite power is designed to provide adequate lighting for safe shutdown of the plant and for associated plant access routes during the full spectrum of accidents, transients, and special events. Emergency Lighting supports LR functions and is, therefore, in scope as indicated in LRA Table 2.2-2.

An updated to LRA Table 2.2-2 is provided in Enclosure 1.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 3 of 39 The Radwaste Systems:

The Radwaste Systems (Liquid, Gaseous, and Solid) are described in Sections 11.2, 11.3, and 11.4 (r6spectively) of the FSAR. The Radwaste System components are primarily located in the Radwaste Control Building at Columbia. The radwaste systems are not necessary for safe shutdown of the reactor. The radwaste systems are scoped in for LR only in locations where they meet the criterion of 10 CFR 54.4(a)(2), with respect to nonsafety-related (NSR) systems whose failure could prevent the satisfactory accomplishment of a safety function, as described in 10 CFR 54.4(a)(1). For Columbia, this involves radwaste system locations in the Reactor Building.

Liquid Radwaste System Portions of the Liquid Radwaste System are within the scope of LR for Columbia, but are identified by their specific system names rather than being generically identified as the liquid radwaste system.

LIQUID RADWASTE SYSTEMS Name Acronym LRA section Boundary DWG LRA Table Condensate Processing CPR 2.3.3.2 LR-M523-1 Table'2.2-1 Radioactive (Rev. 0) system Equipment LR-M537 (Rev.

Drains raive EDR 2.3.3.21

0) LR-M539 Table 2.2-1 Radioactive(R v0) system (Rev. 0),

Floor Drain LR-M539 (Rev.

Radioactive FDR 2.3.3.24 RM9 Table 2.2-1 system 0),

Miscellaneous Waste Radte MWR 2.3.3.27 M539 (Rev. 0 Table 2.2-1 Radioactive system GASEOUS and SOLID RADWASTE SYSTEM Name Acronym LRA Section Boundary DWG LRA Table Off-Gas OG Not in scope Not in scope Table 2.2-1 System Solid Waste N/A Not in scope Not in scope Table 2.2-1 System

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 4 of 39 The Post-Accident Sampling System:

The Post-Accident Sampling System (PASS) as described in Section 11.6 of the FSAR, provides the post accident sampling function for the Process Sampling Radioactive (PSR) System. The LR evaluation of the PASS is addressed in LRA section 2.3.34 and Table 2.2-1, as part of the PSR system. The PASS is a plant function that uses the components of the PSR system to obtain the required gaseous and liquid samples from locations in the drywell, the suppression pool atmosphere, the secondary containment atmosphere, the jet pump pressure instrument system (the reactor coolant system), and the residual heat removal system samples. The PASS sampling components are shown in Table 2.3.3-33 of the LRA. The LR boundaries of the PASS are shown on drawing LR-M896 (Rev. 0). Therefore, the Post-Accident Sampling System is within the scope of LR for Columbia.

RAI 2.3.3-01

Background:

License renewal rule 10 CFR 54.21 (a)(1) states, "For those systems, structures, and components within the scope of this part, as delineated in § 54.4, identify and list those structures and components subject to an aging management review." The staff reviews the full extent of the license renewal scoping boundary, along with the information contained in the LRA and other sources of plant-specific information to confirm that all component types subject to an aging management review (AMR) have been identified.

Issue:

For the drawing locations identified in the table below, the continuation of piping in scope for license renewal could not be found.

License Renewal

[Drawing Number and Continuation Issue System and Item #

ILocation 2.3.3.5 Containment Instrument Air (CIA) System A

LR-M556-1, zone K/9 1 "CIA (54)-l line after the relief valve CIA-RV-6A ends without a continuation note provided.

B LR-M556-1, zone J/7 1/2"CIA (3)-2-3 and 1/2"CIA (3)-2-30 lines downstream of valves CIA-V-93A and CIA-V-93B respectively end without continuation I notes provided.

2.3.3.10 Control Air (CAS) System C

LR-M510-2 at H-1 1 3A"(a)(2) line after the valve CAS-V-1 74 to test vent ends without a continuation provided.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 5 of 39 License Renewal Drawing Number and Continuation Issue System and Item #

Location 2.3.3.24 Floor Drain Radioactive (FDR) System D

LR-M539, zone D/15

• Section of (a)(2) piping, continues to the floor drain collector tank on drawing LR-M531. Drawing LR-M531 was not submitted as part of the application.

• Section of (a)(2) piping, continues to the chemical waste tanks on drawing LR-M533-1.

Drawing LR-M533-1 was not submitted as part of the application.

• Section of (a)(2) piping, continues to the detergent drain tanks on drawing LR-M533-1. Drawing LR-M533-1 was not submitted as part of the application.

2.3.3.27 Miscellaneous Waste Radioactive (MWR) System E

LR-M539, zone D/15 3"FDR (52)-i continued to drawing LR-M538 (E/3). Drawing LR-M538 was not submitted as part of the application.

2.3.4.3 Condensate Nuclear) (COND) System F

LR-527-1, zone D-6 3/4" piping downstream of valve COND-V-675 is in scope and ends without a continuation note provided.

Request:

Provide additional information to locate the license renewal boundary. If the continuation cannot be shown on license renewal boundary drawings, then provide additional information describing the extent of the scoping boundary and verify that there are no additional component types between the continuation and the termination of the scoping boundary. If the scoping classification of a section of piping changes over a continuation, provide additional information to clarify the change in scoping classification.

Energy Northwest Response:

The table provided in the issue description is duplicated with the last column annotated to describe the LR boundary, including the extent of component types within that boundary and to address scoping classification changes over a continuation, where applicable.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 6 of 39 2.3.3.5 conrainment instrument Air bysrem A

LR-M556-1, zone Issue - The 1 "CIA (54)-i line after the relief K/9 valve CIA-RV-6A ends without a continuation note provided.

Response - There is no continuation note necessary for the relief valve discharge line, because the line does not continue to another location. This Containment Instrument Air (CIA)

System (common header) relief valve discharges to the Reactor Building environment.

B LR-M556-1, zone Issue - 1/2"CIA (3)-2-3 and 1/2"CIA (3)-2-30 lines J/7 downstream of valves CIA-V-93A and CIA-V-93B respectively end without continuation notes provided.

Response - As shown on LR-M556-1 (Zone J7),

the lines continue to solenoid pilot valves RRC-SPV-85A & 85B. Valves RRC-V-85A & 85B, and associated solenoid pilot valves RRC-SPV-85A & 85B, are shown on LR-M530-1 (Zones C11 and C6, respectively). These solenoid pilot valves are normally deenergized (ND) and deenergize to close (DC).

The CIA scoping boundary drawing revision is provided in Enclosure 2, to more accurately include the tubing and solenoid pilot valves.

2.3.3.10 Control Air (CAS) System C

LR-M510-2 at H-Issue - 3/*" (a) (2) line after the valve CAS-V-1 74 11 to test vent ends without a continuation provided.

Response - There is no continuation downstream of valve CAS-V-1 74, only the free end of test vent pipe. The test vent pipe is within LR scope to the free end, as part of a NSR component attached to a safety related (SR) component.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 7 of 39 2.3.3.24 Floor Drain Radioactive (FDR) System D

LR-M539, zone Issue - Section of (a)(2) piping, continues to the D/1 5 floor drain collector tank on drawing LR-M531.

Drawing LR-M531 was not submitted as part of the application.

Response - A LR boundary drawing was submitted for drawing M-531 as part of Amendment 1 to the LRA. The FDR scoping boundary is revised as shown in Enclosure 2 to this response, to provide clarification that valves FDR-V-223 and FDR-V-626, downstream of valves FDR-V-220 and FDR-V-222, and just upstream of the first seismic anchors in the Radwaste building, were evaluated within scope of LR.

Issue - Section of (a)(2) piping, continues to the chemical waste tanks on drawing LR-M533-1.

Drawing LR-M533-1 was not submitted as part of the application.

Response - The continuation to the chemical waste tanks is from SR valve MWR-V-121.

Consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR RRC piping includes the portions of the subject NSR piping downstream of MWR-V-121 up to and including the equivalent anchor. The anchor is located in the corridor between the Reactor and Radwaste buildings, before the piping enters the Radwaste building. Therefore, the continuation of the line shown on M533-1 is not within the boundary and the drawing is not required.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 8 of 39 2.3.3.24 Floor Drain Radioactive (FDR) System (cont)

D (cont.)

LR-M539, zone D/1 5 Issue - Section of (a)(2) piping, continues to the detergent drain tanks on drawing LR-M533-1.

Drawing LR-M533-1 was not submitted as part of the application.

Response - The continuation to the detergent drain tanks is from SR valve MWR-V-120.

Consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR RRC piping includes the portions of the subject NSR piping downstream of MWR-V-120 up to and including the equivalent anchor. The anchor is located in the corridor between the Reactor and Radwaste buildings, before the piping enters the Radwaste building. Therefore, the continuation of the line shown on M533-1 is not within the boundary and the drawing is not required.

2.3.3.27 Miscellaneous Waste Radioactive (MWR) System is E

LR-M539, zone D/1 5 Issue - 3"FDR (52)-i is continued to drawing LR-M538 (E/3). Drawing LR-M538 was not submitted as part of the application.

Response - The reactor building exhaust stack drain piping is NSR and is in scope of LR based on spatial considerations (i.e., that the piping may contain a liquid). The scoping boundary for 3"FDR (52)-i ends at the building boundary between the Reactor Building and the Turbine (Generator) Building, and includes only pilping.

Therefore, a LR boundary drawing was not required or developed for drawing M538.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 9 of 39 2.3.4.3 Condensate (Nuclear) (COND) System F

LR-527-1, zone D-6 Issue - 3/4" piping downstream of valve COND-

• V-675 is in scope and ends without a continuation note provided.

Response - This line does not continue to another location; rather piping downstream of COND-V-675 extends to the free end of the pipe, and therefore no continuation note.is provided.

This line is within LR scope to the free end, as part of a NSR component attached to a SR component.

The following table defines the changes needed for boundary drawings LR-M556-1, LR-M530-1, and LR-M531.

,-xblsun kygreen) n111gntFLgn1ng should end on downstream side of SR valves CIA-V-93A &

93B, with the downstream tubing and continuation text highlighted as in scope for 10 CFR 54.4(a)(2), spatial.

Change highlighting downstream of valves CIA-V-93A & 93B to magenta (Zone J6/7).

Add magenta highlighting to continuation "to RRC-SPV-85A

... 85B".

LR-M530-1 RRC-SPV-85A & 85B are in Add magenta highlighting to scope for 10 CFR 54.4(a)(2),

RRC-SPV-85A & 85B (Zones spatial, and evaluated with the Cll, C6 respectively).

CIA System.

Add reference to LR Note F for RRC-SPV-85A & 85B (Zones Al1, A6 respectively).

Add LR Note - "F. RRC-SPV-85A & 85B are evaluated in the CIA System" (Zone A7/6).

LR-M531 Provide clarification that valves Add magenta highlighting to FDR-V-223 and FDR-V-626, FDR-V-223 and FDR-V-626 and downstream of valves associated piping (Zone E/D13).

FDR-V-220 and FDR-V-222 and just upstream of the first seismic anchors in the Radwaste building, were evaluated within scope of LR.

I Revised boundary drawings LR-M556-1, LR-M530-1, and LR-M531 are provided in.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 10 of 39 2.3.3 Auxiliary Systems 2.3.3.1 Circulating Water System RAI 2.3.3.1-01

Background:

License renewal rule 10 CFR 54.21(a)(1) states, "For those systems, structures, and components within the scope of this part, as delineated in § 54.4, identify and list those structures and components subject to an AMR." The staff reviews the full extent of the license renewal scoping boundary, along with the information contained in the LRA and other sources of plant-specific information to confirm that all component types subject to an AMR have been identified.

Issue:

Drawing LR-507-1, zones E/8 & F/7 show lines 144"I.D.CW(2)-1 and 36"TMU(1)-1 as not within scope per LR Note D: "Flowpath not required to fulfill LR function." This note appears to conflict with LR Note F "Components highlighted on this drawing are in scope for (a)(2)-functional. Therefore, only components in the main flow paths and branch lines to the first isolation valve are highlighted."

Reauest:

Provide additional information to locate the license renewal boundaries for these two branch lines to the first isolation valve.

Energy Northwest Response:

The Circulating Water (CW) and Tower Make-Up Water (TMU) Systems contain NSR components that perform the following 10 CFR 54.4(a)(1) function: Support the once-through cooling mode of the standby service water (SW) system to mitigate the consequences of a design basis tornado. During a tornado or high wind condition, if there is damage to the service water spray header, the Standby Service Water (SW)

System is aligned for feed and bleed. The feed is provided from the TMU System Make-up Water Pumps. The SW system is aligned to the CW System for bleed to the Cooling Towers.

The portions of lines 144"1.D. CW(2)-1 and 36"TMU(1)-1 were initially excluded from the system boundary because they are not credited for service during the tornado or high wind event. However, upon further review, consistent with Note F on LR-M507 the system boundaries have been revised to included the main branches of 144" I.D.

CW(2)-1 and 36"TMU(1)-l. The following table defines the changes in the boundary drawing LR-M507-1. The change to the boundary drawing does not require a change to the LRA text because the component types and the applicable material and

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 11 of 39 environment combinations are already addressed in the LRA. Revised boundary drawing LR-M507-1, showing the changes described above, is provided in Enclosure 2 Note F' Change Only components in main flow paths and branch line to the first isolation valve are highlighted.

Added green highlight to the continuation of pipe line 36" TMU(1)-1 up to weir box including sluice gate valve TMU-V-103B.

o Added green highlight to 36" TMU(1)-I 6" branch piping and branch isolation valve TMU-V-43.

o Added green highlight to 36" TMU(1)-I 1/2" branch piping and branch isolation valve 1/2" TMU-V-717.

o Added green highlight to 36" TMU(1)-I 1/2" branch piping and branch isolation valve 1/2" TMU-V-718.

o Added green highlight to 36" TMU(1)-1 4" branch piping and branch isolation valve 4" TMU-V-605(d).

o Added green highlight to branch piping including check valve TMU-V-832 and isolation valve TMU-V-831.

" Added green highlight to the continuation of pipe 144" I.D.CW(2)-I up to Circulating Water Discharge Tunnel.

2.3.3.6 Containment Moniitorinq System (CMS)

RAI 2.3.3.6-01

Background:

The CMS system has intended functions that are safety-related and are within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are in scope as nonsafety-related affecting safety-related components for spatial interaction based on the criteria of 10 CFR 54.4(a)(2). Portions of the CMS system are in scope as per 10 CFR 54.4(a)(3) criteria as this system is relied upon to demonstrate compliance with the Fire Protection, Environmental Qualification, Anticipated Transients Without Scram, and station blackout regulated events.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 12 of 39 Issue:

The system description of the CMS system states that this system monitors Category 2 parameters like drywell and suppression pool atmosphere temperature and suppression pool water temperature. Drawing LR-M543-1 shows thermal elements CMS-TE-3 and CMS-TE-4, zone E-7, CMS-TE-1, zone E-1 3, CMS-TE-2, zone E-1 1 and others in the drywell as not within the scope of license renewal, while similar thermal elements CMS-TE-25, zone K-9 and CMS-TE-32, zone K-1 1 are included within the scope of license renewal.

Request:

Provide additional information explaining why some of the thermal elements are not included within scope of license renewal while similar components in the drywell are included within scope.

Energv Northwest Response:

Boundary drawings only provide the scoping boundary for mechanical systems and components. The CMS-TR-5 and 6 recorders are included in the scope of LR for the criterion of 10 CFR 54.4(a)(3), as they provide input required for the Columbia Station Blackout event. Therefore, the temperature elements (TE) connected to CMS-TR-5

and 6 are within scope. Except for CMS-TE-32 and 32, the TEs have only an electrical "function and screen out. These two components, CMS-TE-32 and 33, have a mechanical function to maintain pressure boundary or a structural integrity function since they are installed in ductwork. The other temperature elements associated with recorders CMS-TR-5 and CMS-TR-6 do have an electrical function as required by 10 CFR 54.4(a)(3) and they are within the scope of LR. With respect to the electrical LR evaluation, the CMS temperature elements are active components and, therefore, are not subject to AMR.

A revised drawing (LR-M543, Rev. 1) is provided in Enclosure 2 to show the proper highlighting for these components. No change to the LRA text is necessary because the CMS is correctly shown as within the LR scope in LRA Table 2.2-1.

In addition to the removal of the highlighting on LR-M543-1 for the temperature elements, the highlighting for level switches and radiation elements (in primary containment) was also removed for the same reason as stated above for the temperature elements (i.e., these components perform no mechanical function).

The complete listing of CMS components for which green highlighting was removed on LR-M543-1 is as follows:

1. CMS-LS-1, 2, 3, and 4,

2. CMS-RE-27E and CMS-RE-27F, and

3. CMS-TE-24, 25, 26, 41, 42, 43, 44, 51, 52, 53, 54, and 55.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 13 of 39 2.3.3.13 Demineralized Water (DW) System RAI 2.3.3.13-01

Background:

NUREG-1800 and NEI 95-10, Revision 6 contain guidance that nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Issue:

Anchors could not be found on the following nonsafety-related lines, in scope for 10 CFR 54.4(a)(2), which are connected to safety-related lines.

Non-Safety/Safety Pipe Number/Description Interface Location LR-M512-1, zone F-15 1 "DW(23)-1 S LR-M512-2, zones J-2,J-13 1 "DW(23)-1 S LR-M512-3, zones J-2,J-1 4 1 "DW(23)-1 S LR-M517, zones H-8,H-9 1-1/2"DW(19)-1S LR-M517, zone D-1 1/2"DW(55)-3S LR-M517, zone F-1 1/2"DW(55)-3S Request:

Provide additional information to locate the seismic anchors or anchored components between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

Energv Northwest Response:

The table provided in the issue description is duplicated with a column added to describe the location of seismic anchors or anchored components between the NSR/SR interface and the end of the scoping boundary. In each case the boundary was

.determined by on the guidance of the NEI 95-10, revision 6, Appendix F.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 14 of 39 Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M512-1, 1" DW(23)-1 S The evaluation boundary for NSR DW piping zone F-15 attached to the SR DCW piping includes portions of the subject NSR piping upstream and downstream of an equivalent anchor (as established by piping analysis) located inside the Radwaste building. The equivalent anchor is located on line 1 "DW(23)-1 S between valve DW-V-162 and DW-V-607(V) vent line.

The NSR components between the equivalent anchor and the Diesel Generator System Boundary, up to the SR Diesel Generator Boundary are also included in the scope of LR for NSAS.

LR-M512-2, 1" DW(23)-1 S The evaluation boundary for NSR DW piping zone J-2, J-13 attached to the SR DCW piping includes portions of the subject NSR piping upstream and downstream of an equivalent anchor (as established by piping analysis) located inside the Radwaste building. The equivalent anchor is located on line 1 "DW(23)-1 S between valve DW-V-1 62 and DW-V-607(V) vent line.

The NSR components between the equivalent anchor and the Diesel Generator System Boundary, up to the SR Diesel Generator Boundary, are also included in the scope of LR for NSAS.

LR-M512-3, 1" DW(23)-1 S The evaluation boundary for NSR DW piping zone J-2, J-14 attached to the SR DCW piping includes portions of the subject NSR piping upstream and downstream of an equivalent anchor (as established by piping analysis) located inside the Radwaste building. The equivalent anchor is located on line 1"DW(23)-1S between valve DW-V-162 and DW-V-607(V) vent line.

The NSR components between the equivalent anchor and the Diesel Generator System Boundary, up to the SR Diesel Generator Boundary, are also included in the scope of LR for NSAS.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 15 of 39 Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M517, 1-1/2" DW(19)-lS 4A. LR-M517 Zone H-8 zone (4A) H-8, (48) H-9 The evaluation boundary for NSR DW piping attached to the SR SW piping includes equivalent anchors that are located upstream of valve SW-V-175A. SW-V-175A is indicated on LR-M524-1 (E/15) and is included in the boundaries of the LR scope.

4B. LR-M517 Zone H-9 The evaluation boundary for NSR DW piping attached to the SR SW piping includes equivalent anchors that are located upstream of valve SW-V-1 75B within the boundaries of the DW boundary. SW-V-175B is indicated on LR-M524-2 (G/15) and is included in the LR boundaries.

LR-M517, 1/2" DW(55)-3S The evaluation boundary for NSR DW piping zone D-1 attached to the SR CRD piping includes two equivalent anchors. One equivalent anchor is located downstream of drain valve DW-V-267A and a second anchor located downstream of DW-V-268A and upstream of the branching tee.

LR-M517, 1/2" DW(55)-3S The evaluation boundary for NSR DW piping zone F-1 attached to the SR CRD piping includes two equivalent anchors. One equivalent anchor is located upstream of valve DW-V-266B and the downstream of tee leading to CRD-V-1 03A. The second equivalent anchor is located upstream of the tee to valve CRD-V-1 03A and downstream of the branch tee to valve CRD-V-91 D.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 16 of 39 2.3.3.16 Diesel (Engine) Exhaust (DE) System RAI 2.3.3.16-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

Table 2.3.3-16 lists the turbocharger pump casing and heat exchanger components (tube, cover and shell). Drawings LR-512-1, LR-512-2, and LR-512-3 do not show the turbochargers or aftercooler. LRA Section 2.3.3.16 and Final Safety Analysis Report (FSAR) Section 9.5.8 indicated that the turbocharger and aftercooler are components in the diesel engine intake and exhaust systems which would be expected to be shown on the subject drawings.

Request:

Provide additional information to confirm that all components in the line leading to the

'turbocharger are in scope. Identify any additional in scope components of the DE system that are not shown on the boundary drawings.

Energy Northwest Response:

LRA Table 2.3.3-16 lists the Diesel (Engine) Exhaust System components, including turbocharger pump casing and heat exchanger components (tube, cover, and shell),

that are in the scope of LR and subject to aging management review (AMR). The air intake and exhaust components are highlighted on LR boundary drawings LR-M512-1, LR-M512-2, and LR-M512-3. The turbochargers and aftercoolers do not have separate equipment piece numbers and are not explicitly shown on the LR boundary drawings but they are considered part of the diesel engine.

Per 10 CFR 54.21(a)(1)(i) diesel generators are excluded from AMR. For Columbia, the engines are considered active components with the diesel generators and are excluded from AMR. The diesel engine boundary includes the engine, intake and exhaust manifolds, lube oil pan (crankcase), and the fuel injectors.

However, the cited LR boundary drawings do identify lubricating oil going to turbocharger (bearings) and cooling water going to and from the engine (which includes the aftercooler). As described in LRA Section 2.3.3.16, "Each engine air intake system consists of prefilters, an oil bath type air cleaner for the HPCS engine and cartridge type for the engines associated with diesel generators 1 and 2, air turning box, the necessary piping, ductwork, and flexible connections to the inlet of the engine turbocharger and

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 17 of 39 aftercooler." As also described in LRA Section 2.3.3.16, "Each engine exhaust system consists of an exhaust manifold, turbocharger, exhaust silencer, and the necessary piping and ductwork." As stated above, the exhaust manifolds are excluded from AMR.

LR boundary drawing LR-M512-1 displays the air intake and exhaust train for the HPCS Diesel Generator skid. The components included in the drawing are the air intake prefilter/cleaner (DE-F-1), air intake silencer (DE-IS-2), exhaust silencer (DE-ES-1),

flexible connections (DE-FLX-3, DE-FLX-4), air turning box (which is evaluated as piping), necessary piping and ductwork (which is evaluated as piping as described in LRA Section 2.3.3.16).

LR boundary drawings LR-M512-2 and LR-M512-3 display the air intake and exhaust trains for the diesel generator sets 1 and 2. The components included in the drawing are the air intake prefilters (DE-F-1A1, DE-F-1A2, DE-F-1B1, DE-F-1 82), exhaust silencers (DE-ES-1Al, DE-ES-1A2, DE-ES-1B1, DE-ES-1B2), flexible connections (DE-FLX-1A1, DE-FLX-1A2, DE-FLX-1B1, DE-FLX-1 B2, DE-FLX-2A1, DE-FLX-2A2, DE-FLX-2B1, DE-FLX-2B2), air turning boxes (which are evaluated as piping), and necessary piping and ductwork (which is evaluated as piping as described in LRA Section 2.3.3.16).

In summary, components leading to the turbocharger, including the aftercooler, as described in FSAR Section 9.8.5.2, were included in the scope of LR. There are no additional components, other than the turbocharger and the aftercooler, in the Diesel (Engine) Exhaust System that are in the scope of LR, but are not shown on the LR boundary drawings.

2.3.3.17 Diesel Engine Starting Air (DSA) System RAI 2.3.3.17-01

Background:

License renewal rule 10 CFR 54.21 (a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing LR-M512-1, zone J/3 and J/4, shows 3/4" lines (3/4"DSA (6)-2) as within scope for license renewal for 10 CFR 54.4(a)(2). However, portions of an interconnecting line and a drain line connecting to components DSA-HX-2 and DSA-DY-2 are shown as not within scope.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 18 of 39 Request:

Provide additional information to clarify why the connection between DSA-HX-2 and DSA-DY-2 and the drain line are not in scope for spatial interaction (leakage or spray).

Enerav Northwest Response:

As described in LRA Section 2.3.3.17, the DSA System contains NSR components that are attached to or located near SR systems, structures, and components (SSCs) whose failure creates a potential for spatial interaction. For NSR SSCs directly connected to SR SSCs, the non-safety piping and supports up to and including the first equivalent anchor, or attachment to a major (base-mounted) component beyond the NSR/SR interface are within the scope of LR. The attachment to structure for the Division 3 diesel include air compressors DSA-C-1 C and 2C, the compressor aftercooler DSA-HX-2, and the air dryer DSA-DY-2.

Boundary drawing LR-M512-1 depicts LR NOTE H as applicable to DSA-C-1(C and 20, DSA-HX-2, and DSA-DY-2. LR NOTE H states, "Evaluation boundaries for NSR connected to SR end at base-mounted components."

The interconnecting line between the compressor aftercooler and the air dryer is not within the scope of LR for spatial interaction (leakage or spray), as it is not directly

,connected to SR components, the aftercooler and air dryer provide the attachment to structure, and the line does not contain a fluid (liquid or steam) that could leak or spray onto SR components.

The same is true for the interconnecting line between the compressor aftercoolers (DSA-HX-1 Al, 11B1) and air dryers (DSA-DY-1 A, 1 B) shown on LR-M512-2 and LR-M512-3. However, the drain lines, by definition, could contain water. Therefore, the following table defines the changes needed for boundary drawings LR-M512-1, LR-M512-2, and LR-M512-3.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 19 of 39 uryer UbA-UY-2 outlined (Magenta), drain/blowdown piping and valve body should also be highlighted.

Add magenta figfl1igflting to drain (blowdown) line and valve (DSA-V-78) for dryer DSA-DY-2 (Zone J3).

LR-M512-2 Dryer DSA-DY-1A outlined Add magenta highlighting (Magenta), drain/blowdown to drain (blowdown) line piping and valve body should and valve (DSA-V-77A) also be highlighted, for dryer DSA-DY-1A (Zone K9).

LR-M512-3 Dryer DSA-DY-1 B outlined Add magenta highlighting (Magenta), drain/blowdown to drain (blowdown) line piping and valve body should and valve (DSA-V-77B) also be highlighted, for dryer DSA-DY-1 B (Zone K9).

Updates to LRA Tables 3.3.1 and 3.3.2-17 are provided in Enclosure 1.

Revised boundary drawings LR-M512-1, LR-M512-2, and LR-M512-3 are provided in.

2.3.3.20 Diesel Lubricating Oil (DLO) System RAI 2.3.3.20-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

Drawings LR-M512-1, zone E/1 1, LR-M512-2, zones E/5 and E/1 1, and LR-M512-3, zones E/5 and E/1 1, show an overspeed trip housing component in scope for 10 CFR 54.4(a)(1) that was not included in LRA Table 2.3.3-20 as a component type subject to AMR.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 20 of 39 Request:

Provide additional information that explains why the overspeed trip housing component type within scope for criterion 10 CFR 54.4(a)(1) is not included in LRA Table 2.3.3 20.

Energy Northwest Response:

The overspeed trip housing should have been included in Tables 2.3.3-20 and 3.3.2-20.

Drawings LR-M512-1 (zone E/1 1), LR-M512-2 (zones E/5 and E/1 1) and LR-M512-3 (zones E/5 and E/1 1) show an overspeed trip housing connected to 1/2" oil cooler and filter vent tubing as well as to a 1/2" branch line off of the main lube oil header. This housing (including its intended function, material, and environment) is considered to be the same as the tubing to which it is attached and was included with the tubing in the AMR.

Plant drawings identify the oil cooler and vent line tubing as steel with the overspeed trip housing material considered to be the same. The function, material, internal environment, external environment, aging effects requiring management, and credited aging management programs are the same for the steel tubing and overspeed trip housing as for other steel components of the DLO system.

Updated LRA Tables 2.3.3-20 and 3.3.2-20 are provided in Enclosure 1.

2.3.3.21 Equipment Drains Radioactive (EDR) System RAI 2.3.3.21 -01

Background:

NUREG-1800 and NEI 95-10 Revision 6, contain guidance that nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Issue:

Drawing LR-M521-2, zone G-4, shows 10 CFR 54(a)(1) line 4"RHR(9)-2-6 connected to 10 CFR 54 (a)(2) line 4"EDR(20)-I. Line 4"FDR (43)-i is a branch from 4"EDR (20)-i and the anchor on this line could not be located.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 21 of 39 Request:

Provide additional information to locate the seismic anchors or anchored components between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

Energy Northwest Response:

LR boundary drawing LR-M521-2 (zone G-4) shows 10 CFR 54(a)(1) line 4"RHR(9)-2-6 connected to 10 CFR 54 (a)(2) line 4"EDR(20)-I. Line 4"FDR (43)-i is a branch from 4"EDR (20)-i. Line 4"FDR (43)-i continues on LR boundary drawing LR-M539 (zone C-11), as does the LR scoping boundary.

Consistent with the guidance of NEI 95-10, Revision 6, Appendix F the evaluation boundary for NSR piping attached to the SR RHR piping includes the portions of the subject NSR piping downstream of RHR-V-40 up to a seismic anchor. As depicted on plant isometric drawings, the location of the first seismic anchor is on line 4"EDR(20)-1 downstream of RHR-V-40 and upstream of tee where the 3" line from RHR-V-70 tees into 4" EDR(20)-I (at LR-M521-2 Zone B/2).

As shown on plant drawings and piping calculations, the evaluation boundary for the NSR piping attached to the SR RHR piping at RHR-V-70 consist of the following anchors:

1. A seismic anchor located on 4"EDR(20)-I, between RHR-V-40 and where the 3" line from RHR-V-70 tees into 4" EDR(20)-I;

2. A seismic anchor located in the radwaste building on 4"EDR(20)-I (as described by LR Note E on LR-M521-2 Zone B/8-9);

3. A seismic anchor on line 6" FDR(43)-i where the line is embedded in the concrete floor where the drain piping is routed to reactor building floor drain sump FDR-SUMP-R1 which is shown on LR-M539 Zone B/1 1; and,

4. An equivalent anchor determined by overlap criteria in the piping calculation on line 6" FDR(43)-i where the line penetrates the reactor building floor slab at elevation 606' 10-1/2", which is shown on LR-M539 Zone J/13. As shown on LR-M539, all of the intervening branch lines attached to 6" FDR(43)-i between this equivalent anchor and the seismic anchor identified in item 3 above is already included in the scope of LR for non-safety affecting safety (NSAS) since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 22 of 39 2.3.3.23 Floor Drain (FD) System RAI 2.3.3.23-01

Background:

LRA Section 2.3.3.23 "Floor Drain (FD) System," states in part, "The FD System consists of non-radioactive floor drain subsystems in the Service Building and Turbine Building."

Issue:

Drawing LR-540, zone H/12 shows 6"FD (10)-i within scope for 10 CFR 54.4(a)(2).

This line appears to be located in the Radwaste Building.

Request:

Provide additional information to clarify that the system description of LRA Section 2.3.3.23 is correct and the Floor Drain System is not also located in the Radwaste Building.

Energy Northwest Response:

The FD system description presented in LRA Section 2.3.3.23 was taken from FSAR Section 9.3.3.2.3 and the system description is incomplete. As shown in drawing LR-M540, there are FD System components within the scope of LR. There are also FD system components located outside of the Service Building and Turbine Building, as shown in LRA Section 2.3.3.23 under LR drawings LR-M539 (Reactor Building), LR-M788-1 (Diesel Generator Building), LR-M852 (Diesel Generator Building), and LR-216-01,3682 (Reactor Building). A condition report (CR) has been entered into the corrective action program to investigate the adequacy of the Non-radioactive Water Drainage System description.

Energy Northwest amends the LRA to add further clarification based on this RAI. The system description presented in LRA Section 2.3.3.23, "Floor Drain (FD) System," is amended to include, in addition to the Service Building and Turbine Building, the Radwaste Control Building, Diesel Generator Building, and Reactor Building.

Updated LRA Section 2.3.3.23 is provided in Enclosure 1.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 23 of 39 2.3.3.25 Fuel Pool Cooling System RAI 2.3.3.25-01

Background:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

Drawing LR-M526-1, zone H/1 0 shows the diffuser assembly component as within scope for criterion 10 CFR 54.4(a)(1). The diffuser assembly is not listed as a component type in Table 2.3.3-25.

Request:

Provide additional information to explain why the diffuser is not listed as a component type in Table 2.3.3-25.

Enerqv Northwest Response:

The diffuser is not listed as a component type in LRA Table 2.3.3-25 because it is considered a pipe fitting and is evaluated as piping which is listed in LRA Table 2.3.3-

25. The diffuser is made of steel. As shown in LRA Table 3.3.2-25, rows 38, 39, 42 and 43, the subject diffusers are subject to aging management review and are evaluated as piping exposed to an internal and external treated water environment. The diffuser is shown on LR-M526-1 as a welded cap consistent with License Renewal Boundary Drawing Flow Diagram Legend, Symbols, and Abbreviations, LR-M501-1.

The diffusers at the bottom of the fuel pool are sections of capped pipe with drilled holes.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 24 of 39 2.3.3.29 Plant Service Water (TSW) System RAI 2.3.3.29-01

Background:

NUREG-1800 and NEI 95-10, Revision 6 contain guidancethat nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Issue:

An anchor could not be found on the following nonsafety-related line, in scope for 10 CFR 54.4(a)(2), which is connected to a safety-related line.

Non-Safety/Safety Pipe Number/Description Interface Location LR-M548-2, zone G/5, 8, 10, 14 TSW supply to WMA-CC-53B2, 52B2, 52A2, and 53A2 Request:

Provide additional information to locate the seismic anchor or anchored component between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

Enerav Northwest Response:

Drawing LR-548-2 shows that the Cable Spreading Room Cooling Coils WMA-CC-52A2 and WMA-CC-52B2 are supplied by the Radwaste Building Chilled Water'(WCH) system not the TSW system. The SR/NSR interface is at the cooling coils. The attached NSR piping is in scope as NSAS until just before it exits the Control Structure.

The equivalent anchor locations are determined by calculation. The piping that extends from the equivalent anchors through the wall into the radwaste building is in scope for (a)(2) spatial only. The highlighting on LR-M550-2 stops at WCH-V-64 and WCH-V-65 which are in the radwaste building. LR note C is revised to indicate that the valves are outside of the control structure and that the boundary ends where the piping leaves the control building. Revised LR-M550-2 is provided in Enclosure 2.

Cooling Coils-WMA-CC-53A2 and WMA-CC-53B2 are supplied by the TSW system.

The SRINSR interface is at the cooling coils for both the supply and return piping. The supply piping to the cooling coils is considered NSAS from the cooling coils to a seismic anchor located on the control building wall where the pipe exits to the radwaste building.

The piping that extends from the seismic anchor through the wall into the radwaste building is in scope for (a)(2) spatial only. The return piping from the cooling coil to the

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 25 of 39 TSW return header is in scope as a SR/NSR interface. The non safety affecting safety pipe extends to a seismic anchor located on the control building wall as the pipe exits to the radwaste building. The piping that extends from the seismic anchor through the wall into the radwaste building is in scope for (a)(2) spatial only. This is indicated by LR Note D on drawing LR-M508-1.

Cooling Coils WMA-CC-53A2 and WMA-CC-53B2 have an alternate water supply from the WCH system as shown on LR-M548-2 detail C (zone G/l). This cross connection between the TSW and WCH system is within the control building. The cross connections are located on the NSAS section of the WCH system as described above for Cooling Coils WMA-CC-52A2 and WMA-CC-52B2. Therefore, the discussion of the location of the equivalent anchors for cooling coils WMA-CC-52A2 and WMA-CC-52B2 above and the revision to the LR note on LR-M550-2 apply to the cross connect feature because they are the WCH same boundary locations.

2.3.3.34 Process Sampling Radioactive (PSR) System RAI 2.3.3.34-01

Background:

NUREG-1800 and NEI 95-10, Revision 6 contain guidance that nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Issue:

Anchors could not be found on the following nonsafety-related lines, in scope for 10 CFR 54.4(a)(2), which are connected to safety-related lines.

Non-Safety/Safety Pipe Number/Description Interface Location LR-M607-1, zone H/13 3/8"PSR(1)-4S LR-M607-3, zone J/H/4 Pipe connecting Sample Point (SP-69) to the Radwaste Building LR-M896, zone B/1 1 3/8"PSR(1)-4S to Reactor Building wall LR-M896,zone D/1 1-12 3/8"PSR(106)-4S to Reactor Building wall LR-M896,zone E/F/12 3/8"PSR(103)-4S to Reactor Building wall

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 26 of 39 Request:

Provide additional information to locate the seismic anchors or anchored components between the safety/non-safety interface and the end of the 1 OCFR 54.4(a)(2) scoping boundary.

Energy Northwest Response:

Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M607-1, 3/8"PSR(1)-4S Consistent with the guidance of Appendix F of zone H/13 NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR RRC piping includes the portions of the subject NSR piping downstream of RRC-V-20 up to and including the equivalent anchor located at a base-mounted component, heat exchanger PSR-CC-1. The NSR components between the equivalent anchor and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor Building wall in the Radwaste Building is not within the scope of LR.

LR-M607-3, Pipe connecting Consistent with the guidance of Appendix F of zone J/H/4 Sample Point (SP-NEI 95-10, Rev. 6, the evaluation boundary for NSR

69) to the radwaste piping attached to the SR FPC piping includes the building portions of the subject NSR piping downstream of FPC-V-730 up to a seismic (tubing) anchor. As depicted on plant isometric drawings, the location of the seismic anchor is downstream of FPC-V-730 and before the tubing run exits the Reactor Building. The NSR piping and components between the seismic anchor and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor

,Building wall in the Radwaste Building is not within the scope of LR.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 27 of 39 Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M896, 3/8"PSR(1)-4S to Consistent with the guidance of Appendix F of zone B/1 1 reactor building wall NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR PSR piping includes the portions of the subject NSR piping upstream of PSR-V-X82/2 up to the first anchor. Piping between the anchor and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor Building wall in the Radwaste Building is not within the scope of LR.

LR-M896,zone 3/8"PSR(106)-4S to Consistent with the guidance of Appendix F of D/1 1-12 reactor building NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR PSR piping includes the portions of the subject NSR piping downstream of PSR-V-003/A and PSR-V-003/B up to and including the first anchor located within the reactor building.

The NSR piping and components between the anchors and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor Building wall in the Radwaste Building is not within the scope of LR.

LR-M896,zone 1"PI(1)-4S-X88 to During the review to respond to this RAI a location D/1 1-12 reactor building, similar to zone B131 LR-M896 was noted as not being questioned. This location was added to the RAI response. Consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR PSR piping includes the portions of the subject NSR piping downstream of PSR-V-X88/2 up to and including the first anchor located within the reactor building. The NSR piping and components between the anchor and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor Building wall in the Radwaste Building is not within the scope of LR.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 28 of 39 Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M896,zone 3/8"PSR(103)-4S to Consistent with the guidance of Appendix F of E/F/12 reactor building wall NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR PSR piping includes the portions of the subject NSR piping downstream of PSR-V-X77A/2 and PSR-V-X77A/4 up to and including the first anchor. The NSR piping and components between the equivalent anchor and the Reactor Building wall are also included in the scope of LR for NSAS since it contains a fluid and has the potential for spatial interaction with SR components located within the Reactor Building. Subject piping beyond the Reactor Building wall in the Radwaste Building is not within the scope of LR.

RAI 2.3.3.34-02

Background:

Portions of the process sampling radioactive system have spatial interaction as non-safety affecting safety-related components in the reactor building and are within the scope of license renewal as non-safety affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).

Issue:

License renewal drawing LR-M896, zone G/7 shows lines 1/2"PSR(1)-4S and 3/8"PSR(1)-4S downstream of pumps PSR-P-702 and PSR-P-701 in the reactor building as not in scope for license renewal. The staff questions if these lines have the potential for spatial interaction as non-safety affecting safety-related components in the Reactor Building.

Request:

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

Enerav Northwest Response:

As shown on LR-M896, pumps PSR-P-701 and PSR-P-702 take suction from the drywell, suppression pool, or secondary containment atmosphere with the return lines downstream of the pumps to either the secondary containment or suppression pool.

Since these are atmospheric sample lines that normally contain ambient air, they do not

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 29 of 39 contain a fluid (liquid or steam). As described in Section 2.1.1.2.2 of the LR application, failure of NSR mechanical components that are not directly connected to SR components and do not contain a fluid (liquid or steam) will not result in spatial interaction as there is no fluid to leak, spray or impinge on SR SSCs. Therefore, these lines do not have the potential for spatial interaction with SR components within the Reactor Building other than those portions that are in the scope of LR for NSR piping that is directly attached to SR piping. As shown on LR-M896, the evaluation boundary for NSR piping attached to the SR PSR piping includes the portions of the subject NSR piping upstream of PSR-V-X82/8 up to the point of decoupling as indicated by LR Note D.

2.3.3.39 Reactor Closed Coolinq Water (RCC) System RAI 2.3.3.39-01

Background:

NUREG-1800 and NEI 95-10, Revision 6 contain guidance that nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Issue:

Anchors could not be found on the following nonsafety-related lines, in scope for 10 CFR 54.4(a)(2), which are connected to safety-related lines.

Non-Safety/Safety Pipe Number/Description Interface Location LR-M525-1, zone C-4 10"RCC(36)-1-3 LR-M525-1, zone, D-5 10"RCC (3)-1-1 Request:

Provide additional information to locate the seismic anchors or anchored components between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 30 of 39 Energy Northwest Response:

Non-Pipe

Response

Safety/Safety Number/Description I nterf ace Location Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M525-1, zone C-4 1 0"RCC(36)-1-3 Consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR RCC piping includes the portions of the subject NSR piping upstream of RCC-V-40 up to seismic anchors on the branch lines. As depicted on plant isometric drawings, these include: 1) two seismic anchors located immediately upstream of RCC-TCV-71A; 2) one seismic anchor located downstream of an 8" x 8" x 4" tee (on the RCC return header from RCC-TCV-71 B and 71C); 3) two seismic anchors located just upstream of RCC-TCV-72A; and, 4) one seismic anchor located between RCC-TCV-72B and an 8" x 8" x 4" tee. The NSR piping and components between the seismic anchors and the upstream base-mounted components are also included in the scope of LR for NSAS since they contain a fluid and have the potential for spatial interaction with SR components located within the Reactor Building.

The 10"RCC(36)-1-3 line extends through containment penetration X46 to RCC-V-21. The 10" RCC line continues on LR-M525-2 (D/1 4) as 1 0"RCC(36)-1. As depicted on plant isometric drawings there is an anchor located downstream of RCC-V-21 between RCC-TE-19 and RCC-FE-28 on the 1 0"RCC(36)-1 line.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 31 of 39 Non-Pipe

Response

Safety/Safety Number/Description Location__

LR-M525-1, zone D-5 10"RCC(3)-1 -1 Consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, the evaluation boundary for NSR piping attached to the SR RCC piping includes the portions of the subject NSR piping downstream of RCC-V-26 up to various seismic anchors via branch lines. As depicted on plant isometric drawings, these include: 1) two seismic anchors located immediately downstream of RCC-V-71A; 2) one seismic anchor located upstream of an 8" tee (on the RCC supply header to RCC-V-71 B); 3) one seismic anchor located adjacent to an 8" x 8" x 4" tee (near RCC-V-72A); and, 4) one seismic anchor located immediately upstream of an 8" x 4" eccentric reducer (on the RCC supply header to RCC-V-72B). The NSR piping and components between the seismic anchors and the downstream base-mounted components are also included in the scope of LR for NSAS since they contain a fluid and have the potential for spatial interaction with SR components located within the Reactor Building.

The 10" RCC line extends from RCC-V-104 (LR-M525-1 E/4) to LR-M525-2 E/1 4. As depicted on plant isometric drawings there is an anchor between RCC-FT-4 and RCC-V604.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 32 of 39 2.3.3.41 Reactor Water Cleanup (RWCU) System RAI 2.3.3.41-01

Background:

NUREG-1800 and NEI 95-10, Revision 6 contain guidance that nonsafety-related piping attached to safety-related piping should be included in scope for license renewal up to the first seismic anchor past the safety/non-safety interface. The licensee states that their scoping results comply with this guidance in LRA Section 2.1.

Anchors could not be found on the following nonsafety-related lines, in scope for 10 CFR 54.4(a)(2), which are connected to safety-related lines.

Non-Safety/Safety Pipe Number/Description Interface Location LR-M523-1, zone C/5 1/2"RCWU(60)-3-26 and 1/2"RCWU(60)-3-27 to 6"-RCWU(5)-3-1 LR-M523-1, zone H/10 3/4"RCWU(60)-4-9 and 3/4"RCWU(60)-4-10 to 6"-RCWU(2)-4-1 Request:

Provide additional information to locate the seismic anchors or anchored components between the safety/non-safety interface and the end of the 10 CFR 54.4(a)(2) scoping boundary.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 33 of 39 Energy Northwest Response:

The table provided in the issue description is duplicated with a column added to describe the location of seismic anchors or anchored components between the NSR/SR interface and the end of the scoping boundary.

Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M523-1, 1/2"RWCU(60)-3-26 Consistent with the guidance of Appendix F of NEI 95-zone 0/5 and 1/2"RWCU(60)-

10, Rev. 6, the evaluation boundary for NSR RWCU 3-27 to 6"-

piping attached to the SR RWCU flow instrumentation RWWCU(5)-3-1 includes the following:

" Portions of the subject NSR piping upstream of RWCU-FE-1 1 up to and including the seismic anchor located just inside the Radwaste building.

See Note F on LR-M523-1 at Zones G/4 and J/4.

• Portions of the subject NSR piping upstream of RWCU-FE-1 1 up to and including equivalent anchors located at base-mounted components, heat exchangers RWCU-HX-2B and RWCU-HX-1C.

" Downstream of RWCU-FE-1 1, there is a seismic anchor located between RWCU-FCV-33 and RWCU-RO-1 on the 4"RWCU(5)-3-1 (Drawing LR-M523-1 B/7).

The NSR components between the anchors/equivalent anchors and the Reactor Building wall are also included in the scope of LR for NSAS since they contain a fluid and have the potential for spatial interaction with SR components located within the Reactor Building.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 34 of 39 Non-Pipe

Response

Safety/Safety Number/Description Interface Location LR-M523-1, 3/4"RWCU(60)-4-9 Consistent with the guidance of Appendix F of NEI 95-zone H/10 and 3/4"RWCU(60)-

10, Rev. 6, the evaluation boundary for NSR RCWU 4-10 to 6"-RWCU(2)-

piping attached to the SR RCWU flow instrumentation 4-1 includes the following:

Portions of the subject NSR piping upstream of RCWU-FE-40 up to and including the seismic anchor located on 6" RWCU(2)-4-1 between branch lines 3/4" RWCU(55)-4-3 (LR-M523-1 Zone G/1 0) and 3/4" RWCU(53)-4 (LR-523-1 Zone E/1 0).

The entire run of the NSR piping downstream of RCWU-FE-40 up to and including SR valve RWCU-V-40. Per the NEI 95-10, Appendix F criteria: For NS piping runs that are connected at both ends to SR piping include the entire run of NS piping.

The NSR components between the anchors/equivalent anchors and the Reactor Building wall are also included in the scope of LR for NSAS since they contains a fluid and have the potential for spatial interaction with SR components located within the Reactor Building.

RAI 2.3.3.41-02

Background:

License renewal rule 10 CFR 54.21 (a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing LR-M-523-1, zones G/4 and J/4, show 4" lines (4"RCWU(2)-3-1 and 4"RCWU(1)-3-1) as in scope for license renewal for 10CFR54.4(a)(2) which are connected to 10CFR54.4(a)(1) lines. Note F on drawing

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 35 of 39 LR-M-523-1 states that the "evaluation boundary for NSR connected to SR ends at a seismic anchor located just inside the radwaste building." The extent of the piping beyond this point is not shown in the drawings or described in the application.

Request:

Provide additional information to confirm there are no additional component types between the continuation and the seismic anchor.

Energy Northwest Response:

As indicated on Note F, of LR-M-523-1, seismic anchors are located just inside the Radwaste Building. Plant isometric drawings show the two subject seismic anchors are located at Radwaste Building wall where the piping enters the building. No additional components types are installed between the continuation point and the location of the anchors in Radwaste Building.

2.3.3.44 Standby Service Water (SW) System RAI 2.3.3.44-01 Backgqround:

License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Issue:

License renewal drawing LR-M524-1, zone B-1 0, shows 1" lines (1 "SW (7)-2-1 and 1 "SW (27)-2-1) in and out of LPCS pump as in scope for license renewal for 10 CFR 54.4(a)(1). However, the (LPCS) pump itself is shown as not within scope for license renewal Request:

Provide additional information explaining why the pump is not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4 (a).

Energy Northwest Response:

As shown in Table 2.3.2-4 and Table 3.2.2-4, rows 43 through 47, of the LRA, the Low-Pressure Core Spray (LPCS) pump LPCS-P-1 is within the scope of LR and is subject to aging management review.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 36 of 39 LR-M524-1 is a boundary drawing for the Standby Service Water System and shows the applicable boundary locations for that system. On that drawing, pump LPCS-P-1 is not highlighted because the pump is not within the evaluation boundaries of the Standby Service Water System. Per General License Renewal Note A9 (see LR-M501-2), major components that appear on more than one drawing are highlighted only on the parent drawing for the system to which the component is assigned. Pump LPCS-P-1 is evaluated in the Low-Pressure Core Spray System and is, therefore, highlighted on LR-M520 (Zone B-12) which is the boundary drawing for the Low Pressure Core Spray System.

2.3.3.46 Tower Makeup Water System RAI 2.3.3.46-01

Background:

LRA Section 2.3.3.46 tower makeup water 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:

Drawing LR-507-1, zones B/2 & C/2 shows sluice gate valves TMU-V-7A and TMU-V-7B as not within scope. However, drawings LR-225-02.21 and LR-225-02.22 show these valves as in scope for license renewal.

Request:

Provide additional information to clarify the scoping classification for these two valves.

Energy Northwest Response:

The sluice gate valves, TMU-V-7A and TMU-V-7B, are in scope for LR as shown on boundary drawings LR-225-02,21 and LR-225-02,22, respectively. Boundary drawing LR-M507-1 includes LR note (Note E) that gives instruction to refer to drawings LR-225-02, 21 and LR-225-02,22 for continuation. In this instance, the continuation includes the sluice gate valves connection to 14" TMU(3)-1 and 36" TMU(7)-1. Valves TMU-V-1 9A and TMU-V-1 9B are shown on LR-M507-1, but not on LR-225-02,21 or LR-225-02,22 as in-scope components are shown on only one drawing.

As described in LRA Section 2.3.3.46, the TMU System is designed to supply Columbia River water to the spray ponds to replace pond water during a tornado and is designed to withstand a design basis tornado coincident with a loss of offsite power.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 37 of 39 As described in LRA 2.3.3.46, the TMU System does contain NSR components that perform a 10 CFR 54.4(a)(1) function to support the once-through cooling mode of the Standby Service Water System to mitigate the consequences of a design basis tornado, which meets the scoping criterion of 10 CFR 54.4(a)(2). This includes the piping and components (e.g., sluice gate valves) that provide Columbia River water to the intake of the TMU pumps.

2.3.4 Steam and Power Conversion Systems 2.3.4.3 Condensate (Nuclear) (COND) System RAI 2.3.4.3-01

Background:

License renewal rule 10 CFR 54.21(a) 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:

Drawing LR-527-1, zones E-1 1 & E-1 4, show condensate storage tanks COND-TK-1 A

& COND-TK-1B (Code Group C) as within scope for 10 CFR 50.54(a)(1). However, the attached piping off of penetrations E, F & H for both tanks is not within scope.

Request:

Provide additional information to clarify why the piping attached to a 10 CFR 50.54 (a)(1) component is not in scope.

Energy Northwest Response:

Drawing LR-M527-1, zones E-1 1 & E-1 4, shows condensate storage tanks (CSTs)

COND-TK-1 A & COND-TK-1 B as within the scope of LR. The CSTs are NSR; they are classified as augmented quality and satisfy the requirements for the Station Blackout regulated event. The CSTs are within the scope of LR for 10 CFR 54.4(a)(3) with an intended function of "pressure boundary". The attached piping off CST penetrations E, F and H are addressed individually below:

Drawing LR-M527-1 indicates that the CSTs are vented to the atmosphere at the penetrations labeled "E". This penetration is located above the air-water interface line and does not support the function of maintaining a pressure boundary for coping with a Station Blackout. Therefore, attached piping off of penetrations "E" is not included in the scope of LR for 10 CFR 50.54(a)(3).

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 38 of 39 Drawing LR-M527-1 indicates that the CSTs have overflow piping that discharges to the "yard" at the penetrations labeled "F". This penetration is located above the air-water interface line and does not support the function of maintaining a pressure boundary for coping with a Station Blackout. Therefore, attached piping off of penetrations "F" is not included in the scope of LR for 10 CFR 50.54(a)(3).

Drawing LR-M527-1 indicates that the CSTs have a common header used for filling attached at the penetrations labeled "H". This penetration is located above the air-water interface line and does not support the function of maintaining a pressure boundary for coping with a Station Blackout. Therefore, attached piping off of penetrations "H" is not included in the scope of LR for 10 CFR 50.54(a)(3).

2.3.4.4 Main Steam (MS) System RAI 2.3.4.4-01

Background:

License renewal rule 10 CFR 54.21(a) 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:

The "Trap Station Component Numbers" table on Drawing 502-2 shows portions of various steam traps as within scope. Portions of steam traps 6, 7, 8, 9A, 9B, 13, 14, 15, and 24 are shown in scope for (a)(2) functional, while the entirety of traps 1, 2, 3, and 4 are shown in scope for (a)(2) for spatial interaction. The highlighting of detail A, corresponding to these steam traps, does not appear to accurately portray either set. It is also unclear why only traps 1 through 4 are in scope for spatial interaction.

Request:

Provide additional information to explain the scoping of the steam traps identified on Drawing 502-2.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 39 of 39 Energy Northwest Response:

The "Trap Station Component Numbers" table on LR boundary drawing LR-M502-2 shows which traps and trap station components are in the scope of LR, via magenta and green highlight. The second column, "Trap Location on DWG," of the "Trap Station Component Numbering" table of LR-M-502-2 identifies the drawing and zone for each trap listed.

The NSR steam trap stations 1 through 4 (MS-T-1A, 1B, 1C, & 1D) are attached to SR piping downstream of RPS/MSIV instrumentation branches. Therefore, the traps and associated components are within the scope of LR to the free end, consistent with the guidance of Appendix F of NEI 95-10, Rev. 6, and satisfy the 10 CFR 54.4(a)(2) scoping criteria. As such, these NSR traps and associated components (that comprise the station) are highlighted magenta as shown.

As described in LR Note C on LR-M502-2, except for trap stations 1 through 4, components are in scope for (a)(2) Functional considerations and components in the main flowpaths and branch lines to the first isolation valve have a pressure boundary component function in support of the system function. The main flow paths and branch lines, up to the first isolation valve, are part of the Main Steam System function of "providing holdup in the low-pressure turbines of the activity released from damaged fuel resulting from a postulated control rod drop accident (CRDA)" and are therefore highlighted green.

The NSR trap stations (6, 7, 8, 9A, 9B, 13, 14, 15, 24, and 34) highlighted green on Details A and C of LR-M502-2 are in the main flowpath or branch lines. As shown in Detail A and Detail C of LR-M502-2, the traps themselves are downstream of isolation valves from the branch lines, and as such are not part of the isolation of the main flow path or branch lines for providing holdup. Therefore, the traps for trap stations (6, 7, 8, 9A, 9B, 13, 14, 15, 24 and 34) are not within the scope of LR. Up to the isolation valves for these trap stations is within scope and highlighted green.

A duplicate of LR-M502-2 Detail A showing green highlighting up to the isolation valves only was not provided. Rather, the isolation valves were highlighted in the Trap Station Component Numbers table.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 License Renewal Application Amendment 6 Section no.

Page no.

RAI response Table 2.2-2 2.2-10 RAI 2.2-01 Table 2.3.3-20 2.3.88 RAI 2.3.3.20-01 Table 2.3.3-20 2.3.88a RAI 2.3.3.20-01 2.3.3.23 2.3-98 RAI 2.3.3.23-01 2.3.3.23 2.3-98a RAI 2.3.3.23-01 Table 3.3.1 3.3-108 RAI 2.3.3.17-01 Table 3.3.2-17 3.3-206 RAI 2.3.3.17-01 Table 3.3.2-17 3.3-206a RAI 2.3.3.17-01 Rows 72 and 73 Table 3.3.2-20 3.3-225 RAI 2.3.3.20-01 Table 3.3.2-20 3.3-225a RAI 2.3.3.20-01 Rows 65 through 70 1

1

12.2 Columbia Generating Station License Renewal Application Technical Information n=

Table 2.2-2 License Renewal Scoping Results for Electrical and I&C Systems (continued)

System Name In Scope?

Screening Results Section Obstruction Lighting No Plant Data Information System No_.....

Plant Process Computer No Plant Security No Plant Vibration Monitoring System No Process Radiation Monitoring Yes 2.5 Rad. Control Board No Reactor Protection System Yes 2.5 Rod Block Monitor No Rod Position Indication System No Rod Worth Minimizer No Seismic Monitoring No Source Range Monitoring No Supervisory Control Yes 2.5 Transient Data Acquisition System No Uninterruptible Power Yes 2.5 Wide Range Monitoring No Add New Row:

Normal Lighting I

No I //III///I //I/I///I/

Plant-Level Scoping Results Page 2.2-10 ny20 iAmendment 6

Columbia Generating Station License Renewal Application Technical Information Table 2.3.3-20 Diesel Lubricating Oil System Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)

Bolting Pressure Boundary Filter body Pressure Boundary Flexible connection Pressure Boundary Heat exchanger (channel and shell)

Pressure Boundary Heat exchanger (tubes)

Heat Transfer Pressure Boundary Orifice Pressure Boundary

_Throttling Piping Pressure Boundary Pump casing Pressure Boundary Sight glass Pressure Boundary Strainer (body and screen)

Filtration Pressure Boundary Tubing Pressure Boundary Valve body Pressure Boundary Insert new line item for "Overspeed Trip Housing" component type as shown on Page 2.3-88a between line items for "Orifice" and "Piping."

Scoping and Screening Results Page 2.3-88 JaR'a-J20!0

[Amendment 6

Columbia Generating Station License Renewal Application Technical Information Table 2.3.3-20 Diesel Lubricating Oil System Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)

Overspeed Trip Housing Pressure Boundary Scoping and Screening Results Page 2.3-88a Amendment 6 Scoping and Screening Results Page 2.3-88a Amendment 6

Columbia Generating Station License Renewal Application Technical Information 2.3.3.23 Floor Drain (FD) System

System Description

Insert A from Page 2.3-98a The FD System consists of non-radioactive floor drain subsystems in the Se IQ,,;I~jR q,- -aR, d T,,~ri-M, IHlA;nrl Floor drains from normally uncontaminated areas of the Turbine Building are collected in three sumps. All three sumps are routed to the Radwaste System for processing.

Floor drains in the Service Building are collected in a single sump containing two sump pumps. Water collected in the Service Building floor drain sump is pumped to the storm water drainage system.

Water collected by the storm water drainage system is conveyed by a concrete pipe to a point approximately 1,500 feet northeast of the plant.

The pipe discharges to an earthen channel that carries the water to a small unlined evaporation and percolation pond. Roof drains, which are evaluated as part of the FD System, are drained by gravity or pumped to the storm drain system.

Reason for Scope Determination The FD System contains components designated as safety-related by Columbia choice.

Therefore, the FD System meets the scoping criteria of 10 CFR 54.4(a)(1).

The FD System does not contain any NSR components that perform a

10 CFR 54.4(a)(1) function. The FD System does, however, contain NSR components that are attached to or located near safety-related SSCs, whose failure creates a potential for spatial interaction that could prevent the satisfactory accomplishment of one or more of the functions identified in 10 CFR 54.4(a)(1). Therefore, the FD System meets the scoping criteria of 10 CFR 54.4(a)(2).

The FD System is not relied upon to demonstrate compliance with any regulated event and does not meet the 10 CFR 54.4(a)(3) scoping criteria.

FSAR References Section 9.3.3.2.3 of the FSAR describes the Nonradioactive Water Drainage System, and the Roof Drain System, evaluated collectively for license renewal as the Floor Drain System.

License Renewal Drawinqs The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:

LR-M539, LR-M540, LR-M788-1, LR-M852, LR-216-01,3682

_1 Insert:fLR-M531" Scoping and Screening Results Page 2.3-98

.R LO...2n.,

jAmendment416

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 2.3-98 Service Building, Turbine Building, Radwaste Control Building, Diesel Generator Building, and Reactor Building.

Scoping and Screening Results Page 2.3-98a Amendment 6 Scoping and Screening Results Page 2.3-98a Amendment 6

Columbia Generating Station License Renewal Application Technical Information Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1 801 Further Item Aging Aging Management Evaluation Discussion Number Component/Commodity Effect/Mechanism Programs Recommended Discussio 3.3.1-80 Stainless ste'el and copper alloy Loss of material Open-Cycle Cooling No Consistent with NUREG-1801, piping, piping components, and due to pitting, Water System with exceptions.

piping elements exposed to raw crevice, and water microbiologically Except as noted below, the influenced Open-Cycle Cooling Water corrosion Program is credited to manage loss of material for stainless steel and copper alloy heat exchanger components in the auxiliary systems that are exposed to raw

-water.

A Note D is applied.

Add:

Ng, "and piping For stainless steel pipin copnt exposed to raw (drainage) water Scomponents in the Diesel Starting Air System, Sthat are" the Diesel Starting Air Inspection is credited. A Note E is applied.

For stainless steel heat exchanger tubes that are exposed to raw water in the Fire Protection System, the Diesel-Driven Fire Pumps Inspection is credited. A Note E is applied.

Aging Management Review Results Page 3.3-108

.JIdanaos.t. 29119

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-17 Aging Management Review Results - Diesel Engine Starting Air System NUREG-Aging Effect Aging Notesl Row Component Intended Material Environment Requiring Management 1801 Table Notes No.

Type Function(s) qangemn Prgra Volume 21 Item SManagement Program Item Pressure Stainless Air-indoor3.3.1-64 Valve Body uncontrolled None None VII.J-15

3.

A y boundary Steel (External) 65 Valve Body Pressure Steel Air (Internal)

Loss of Air Quality N/A N/A G

boundary material Sampling 66 Valve Body Pressure Steel Air (Internal)

Loss of Diesel Starting N/A N/A G

boundary material Air Inspection Air-indoor Loss of External SurfaceseVII.s1-8 3.3.1 -

67 Valve Bodyur Steel uncontrolled Surfaces VII.m-8 5A boundary (External) material Monitoring 68 ValveBody Structural Stainless Air (Internal)

None None N/A N/A G

integrity Steel Structural Stainless Air-indoor3.3.1-69 Valve Body integrity Steel uncontrolled None None VII.J-15

3.

A 6 VavBoy itgiy Sel(External) 70 Valve Body Structural Steel Air (Internal)

Loss of Air Quality N/A N/A G

70 Vle oy integrity material Sampling 0314 Structural Air-indoor Loss of External 71 Valve Body integrity Steel uncontrolled Surfaces VII.1-8 58 A

integrity (External) material Monitoring I

Insert new rows 72 and 73 for Table 3.3.2-17 as shown on page 3.3-206a.

h Aging Management Review Results Page 3.3-206 Aging Management Review Results Page 3.3-206 jAmendment 6 20..

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-17 Aging Management Review Results - Diesel Engine Starting Air System Aging Effect Aging NUREG.

Row Component Intended Material Environment Requiring Management 1801 Table Notes No.

Type Function(s)

Management Program Volume 2 1 Item

___Item 72 Piping Structural Stainless Raw water Loss of Diesel Starting VII.H2-331-E integrity Steel (internal) material Air Inspection 18 80 73 Valve Body Structural Stainless Raw water Loss of Diesel Starting VIIH2-3.3.1-E integrity Steel (internal) material Air Inspection 18 80 Aging Management Review Results Page 3.3-206a Amendment 6 Aging Management Review Results Page 3.3-206a Amendment 6

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-20 Aging Management Review Results - Diesel Lubricating Oil System 1c Aging NUREG-Row Component Intended Aging Effect agint 1801 Table No.

Type Function(s)

Material Environment Requiring Management Volume 2 1 Item Notes dManagement Program Item 57 Valve Body Pressure Copper Alloy Lubricating None None VII.H2-3.3.1-boundary oil (Internal) 10 26 0311 Pressure Air-indoor 58 Valve Body Copper Alloy uncontrolled None None N/A N/A G

58 Valve Body boundary (External) 59 Pressure Stainless Lubricating Loss of Lubricating Oil VII.H2-3.3.1-A Valve Body boundary Steel oil (Internal) material Analysis 17 33 60 Valve Body Pressure Stainless Lubricating Loss of Lubricating Oil VII.H2-3.3.1-A boundary Steel oil (Internal) material Inspection 17 33 Pressure Stainless Air-indoor 3.3.1-61 Valve Body boundary Steel uncontrolled None None VII.J-15 A

(External) 94 62 Valve Bd Pressure Steel Lubricating Loss of Lubricating Oil VII.H2-3.3.1-A oy boundary oil (Internal) material Analysis 20 14 63 Valve Body Pressure Steel Lubricating Loss of Lubricating Oil VII.H2-3.3.1-A boundary oil (Internal) material Inspection 20 14 Air-indoor Loss of External SurfaceseVII.s1o8 3.3.1-64 Valve Body boundary Steel uncontrolled maeilSurfaces VII.I-8 58 A

(Extroll material Monitoring Insert new rows 65 through 70 for Table 3.3.2-20 as shown on page 3.3-225a.

Aging Management Review Results Page 3.3-225 j~mendmet 6 291

Columbia Generating Station License Renewal Application Technical Information Aging Management Review Results Page 3~3-225a Amendment 6 Aging Management Review Results Page 3.3-225a Amendment 6

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 Revised Boundary Drawings Drawing Number Reason RAI Number LR-M507-1, Rev 0 Revised RAI 2.3.3.1-01 LR-M512-1, Rev 0 Revised RAI 2.3.3.17-01 LR-M512-2, Rev 0 Revised RAI 2.3.3.17-01 LR-M512-3, Rev 0 Revised RAI 2.3.3.17-01 LR-M530-1, Rev 0 Revised RAI 2.3.3-01 LR-M531, Rev-01 Revised RAI 2.3.3-01 LR-M550-2, Rev 0 Revised RAI 2.3.3.29-01 LR-M556-1, Rev 0 Revised RAI 2.3.3-01

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