GO2-11-011, Generation Station - Response to Request for Additional Information Dated November 1, 2010 Regarding License Renewal Application

Generation Station - Response to Request for Additional Information Dated November 1, 2010 Regarding License Renewal Application

ML110180457
Person / Time
Site:	Columbia
Issue date:	01/14/2011
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-11-011
Download: ML110180457 (21)

Text

Sudesh K.Garbhir N N ERGY Vice President, Engineering P.O. Box 968, Mail Drop PE04 NRichland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@ energy-northwest.com January 14, 2011 G02-11-011 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 0-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter dated November 1, 2010, NRC to SK Gambhir (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML102930593)

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 1 is the Energy Northwest response to the Request for Additional Information (RAI) contained in Reference 2.

As a result of a walkdown in May 2010, the License Renewal Team determined that the material specified for the oil fog lubricators in the Diesel Engine Starting Air System, as documented in Table 3.3.2-17 of Reference 1, was incorrect. Rather than a copper alloy, as stated in rows 24, 25, 26, and 27, the material is steel. The discussion of this issue is provided in Attachment 2.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 Changes to the LRA as a result of the RAI responses and the oil fog lubricator material discrepancy are contained in Amendment 20, provided in the enclosure. No new commitments are included in this response. The LRA Table A-i, Commitment 61 is revised to reflect the changes in the Boron Carbide Monitoring Program.

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.

Jeaectfully S ambhir Vice President, Engineering

Attachment:

1. Response to Request for Additional Information

2. Oil Fog Lubricator Material

Enclosure:

License Renewal Application Amendment 20 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1 399 WA Horin - Winston & Strawn EH Gettys - NRC NRR (w/a)

AD Cunanan - NRC NRR (w/a)

BE Holian - NRC NRR RR Cowley - WDOH

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 11 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"

(ADAMS Accession No. ML102930593)

Holston OTI vs periodic program RAI 3.2.2.1.Y-1

Background

License Renewal Application (LRA) Table 3.3.1, Item 3.3.1-58 addresses external steel piping and pump surfaces exposed to air-indoor uncontrolled, which are being managed for loss of material due to general corrosion. The LRA credits the External Surfaces Monitoring Program to manage the aging effects for the air-indoor uncontrolled environment. In LRA Tables 3.3.2-9, Containment Vacuum Breaker System, 3.3.2-21, Equipment Drains Radioactive Systems, and 3.3.2-24, Floor Drain Radioactive System, for piping, and LRA Tables 3.3.2-22, Fire Protection System, 3.3.2-42, Standby Service Water System, and 3.3.2-43, Tower Makeup Water System, for pump casings, the applicant cites plant-specific Note 303 which states, "The Supplemental Piping/Tank Inspection will manage loss of material at the air-water interface." The Generic Aging Lessons Learned (GALL) Report recommends GALL aging management program (AMP) XI.M36 "External Surfaces Monitoring" program to ensure that these aging effects are adequately managed. The associated aging management review (AMR) line items cite generic Note E.

Issue The staff noted that the applicant's plant-specific Note 303 is not clear on whether only the Supplemental Piping and Tank Inspection Program will be utilized or if it will be utilized in conjunction with the External Surfaces Monitoring Program for external surfaces at the air-water interface zone. The staff also noted that the Supplemental Piping and Tank Inspection Program is a one-time inspection program, where the GALL AMP XI.M36 is based on periodic inspections.

Request

1. State whether the external surfaces within the air-water interface will be inspected by both the Supplemental Piping and Tank Inspection and External Surfaces Monitoring Programs.

2. If only the Supplemental Piping and Tank Inspection Program will be utilized, justify why a one-time inspection program is acceptable when the GALL Report recommends a periodic inspection program.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 11 Enerav Northwest Reswonse

1. The External Surfaces Monitoring Program manages the effects of surfaces exposed to an air-indoor uncontrolled environment. Other programs (depending on the system) will address the surfaces below the water line. The table below provides a summary of the systems and environments with the credited programs. Therefore, the combination of the External Surfaces Monitoring Program and the other appropriate water environment programs will manage the aging effects. The Supplemental Piping/Tank Inspection will address the air-water interface that has a potentially aggressive environment due to wetting and drying on a one-time confirmatory basis to demonstrate that other programs adequately manage the aging effects. The one-time inspection basis for the Supplemental Piping/Tank Inspection is acceptable because it verifies the effectiveness of other programs.

2. As discussed above, the Supplemental Piping/Tank Inspection will be used as a confirmatory inspection of other programs and will not be used alone.

A summary table and detailed discussion are provided below.

System LRA Program Environment Table Containment 3.3.2-9 External Surfaces Air-indoor, uncontrolled Vacuum Breaker BWR Water Chemistry Treated water System Chemistry Program Treated water Effectiveness Equipment 3.3.2-21 External Surfaces Air-indoor, uncontrolled Drains Radioactive BWR Water Chemistry Treated water Systems Chemistry Program Treated water Effectiveness Floor Drain 3.3.2-24 External Surfaces Air-indoor, uncontrolled Radioactive System BWR Water Chemistry Treated water Chemistry Program Treated water Effectiveness Fire Protection 3.3.2-22 External Surfaces Air-indoor, uncontrolled System Fire Water Raw water

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 11 System LRA Program Environment Table Standby 3.3.2-42 External Surfaces Air-indoor, uncontrolled Service Water System Open-Cycle Cooling Raw water Water Tower Makeup 3.3.2-43 External Surfaces Air-indoor, uncontrolled Water System Open-Cycle Cooling Treated water Water Open-Cycle Cooling Raw water Water As discussed in license renewal application (LRA) Table 3.3.1 Item 58, the Supplemental Piping/Tank Inspection is credited for the external surfaces of steel components at the air-water interface with-a Generic Note E. The air-water interface has the potential to be an aggressive environment where contaminants may concentrate due to alternate wetting and drying. Above the air-water interface the subject components are exposed to an air-indoor uncontrolled environment. The Supplemental Piping/Tank Inspection addresses the potential for a unique environment at the air-water interface and supplements other periodic programs credited for aging management. The External Surfaces Monitoring Program will manage the effects of aging for subject components above the air-water interface. Below the water line, the BWR Water Chemistry Program, with verification by the Chemistry Program Effectiveness Inspection, will manage the treated water environment or the Open-Cycle Cooling Water Program will manage the raw water environment, as applicable. The following paragraphs provide additional information regarding the external surfaces of steel piping and pump casings.

The downcomers in the Containment Vacuum Breaker System have an air-water interface where the components enter the suppression pool. Above the water line, the environment is the indoor air and below the water line the components are subject to a treated water environment. As indicated by LRA Table 3.3.2-9 rows 11, 13, and 14, the "Air-indoor uncontrolled" environment is managed by the External Surfaces Monitoring Program and the "Treated water" environment is managed by the BWR Water Chemistry Program, with verification by the Chemistry Program Effectiveness Inspection.

Piping in the EDR and FDR systems has an air-water interface where it enters the suppression pool. Above the water line, the environment is the indoor air and below the water line the components are subject to a treated water environment. The "Air-indoor uncontrolled" environment is managed by the External Surfaces Monitoring Program and the "Treated water" environment is managed by the BWR Water Chemistry Program, with verification by the Chemistry Program Effectiveness Inspection, as indicated by LRA Table 3.2.2-21 Rows 18, 20, and 21 and Table 3.2.2-24 Rows 14, 17, and 18.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 11 The Fire Protection System pumps (FP-P-1, 2A, and 2B) have an air-water interface where the pump columns enter the circulating water basin. Above the water line, the environment is the indoor air and below the water line the components are subject to a raw water environment. As indicated by LRA Table 3.2.2-22 Rows 101 and 103, the "Air-indoor uncontrolled" environment is managed by the External Surfaces Monitoring Program and the "Raw water" environment is managed by the Fire Water Program.

The Standby Service Water System pumps (HPCS-P-2, SW-P-1A, and SW-P-1B) have an air-water interface where the pump columns enter the spray pond. Above the water line, the environment is the indoor air and below the water line the components are subject to a raw water environment. As indicated by LRA Table 3.2.2-42 Rows 73, 74, 78, and 79, the "Air-indoor uncontrolled" environment is managed by the External Surfaces Monitoring Program and the "Raw water" environment is managed by the Open-Cycle Cooling Water Program.

The Tower Makeup System pumps (TMU-P-1A, 1B, and 1C) have an air-water interface where the components enter the water in the Make-up Water Pump House well. Above the water line, the environment is the indoor air and below the water line the components are subject to a raw water environment. The "Air-indoor uncontrolled" environment is managed by the External Surfaces Monitoring Program and the "Raw water" environment is managed by the Open-Cycle Cooling Water Program, as indicated by LRA Table 3.2.2-43 Rows 24 and 26.

For consistency and completeness, LRA Amendment 20, adding plant-specific note 0303 to Row 102 of Table 3.2.2-22, is provided in the enclosure.

RAI B.2.17-1

Background

GALL AMP XI.M32 states that use of a one-time inspection is appropriate when: (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period. GALL AMP XI.M32 also states that for these cases, the one-time inspection should provide confirmation that either the aging effect is indeed not occurring, or the aging effect is occurring very slowly so as not to affect the component or structure's intended function during the period of extended operation.

The GALL Report Table VII.H2, Item VII.H2-2 states that steel piping, piping components, and piping elements exposed to diesel exhaust can undergo loss of material and recommends a plant-specific AMP.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 11 Issue The LRA Table 3.3.2-16, Row Numbers 14, 27, 32 and 38, refers to the above item and cites generic Note E and plant-specific Note 0322, which states that the environment is predominantly outdoor air with infrequent, and for short duration, exposure to diesel exhaust. The applicant credited the Diesel Systems Inspection Program as the AMP to manage this aging effect. However, it is not clear to the staff how the Diesel System Inspection Program, which is a one-time inspection program, will appropriately manage aging of this component, because the recommended GALL AMP would include periodic inspections to detect the associated aging effect.

Request Justify how the one-time inspections proposed by the Diesel Systems Inspection Program are adequate to manage loss of material for steel components exposed internally to outdoor air by explaining how, for each component managed by the program, one of the following criteria for use of a one-time inspection is satisfied: (a) the aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) the aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period.

Energy-Northwest Response Based on a teleconference with NRC staff on October 26, 2010, Energy Northwest is re-evaluating the use of one-time inspections described in the License Renewal Application. A comprehensive response to this issue will be provided under separate cover letter. The information related to this request for additional information will be provided at that time.

RAI B.2.18-1

Background

GALL AMP XI.M32 states that use of a one-time inspection is appropriate when: (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period. GALL AMP XI.M32 also states that for these cases, the one-time inspection should provide confirmation that either the aging effect is indeed not occurring, or the aging effect is occurring very slowly so as not to affect the component or structure's intended function during the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 11 In LRA Section B.2.18, the applicant stated that its Diesel-Driven Fire Pump Inspection Program will be used to identify loss of material in the interior of the fire protection system diesel engine steel exhaust piping exposed to outdoor air and the copper alloy, gray cast iron (steel), and stainless steel heat exchangers exposed to raw water (antifreeze). The applicant also stated that the inspection checks for reduction in heat transfer and cracking due to stress corrosion cracking of susceptible materials.

GALL Report Item VIII.B1-6 recommends GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" to manage loss of material for steel piping exposed internally to outdoor air. GALL AMP XI.M38 includes periodic inspections of the internal surfaces of components to manage loss of material. GALL Report Items VII.C1-3, VII.C1-5, and V.A-8 recommend GALL AMP XI.M20, "Open Cycle Cooling Water" to manage loss of material for copper alloy, steel, and stainless steel heat exchanger. components, respectively. GALL AMP XI.M20 includes periodic inspections, surveillance testing, and water chemistry controls to manage loss of material and reduction of heat transfer. The GALL Report for copper alloy, steel, and stainless steel components exposed to raw water recommend GALL AMP XI.M27, "Fire Water System" to manage loss of material. GALL AMP XI.M27 also recommends periodic inspections and surveillance testing to manage loss of material and fouling.

Issue It is not clear to the staff how a one-time inspection program is appropriate to manage loss of material and reduction of heat transfer for these material and environment combinations given that: (a) loss of material is expected to occur for steel piping exposed to outdoor air; (b) loss of material and reduction in heat transfer is expected to occur for copper alloy, steel, and stainless steel heat exchanger components exposed to raw water; (c) the GALL Report recommends periodic inspection programs to manage aging for these material and environment combinations; and (d) a one-time inspection program is only to be used when an aging effect is not expected or is expected to progress very slowly.

Request Justify how the one-time inspections proposed by the Diesel-Driven Fire Pump Inspection Program are adequate to manage loss of material and reduction of heat transfer for copper alloy, steel, and stainless steel components exposed internally to outdoor air or raw water by explaining how, for each component managed by the program, one of the following criteria for use of a one-time inspection is satisfied: (a) the aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) the aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 11 Energy-Northwest Response Based on a teleconference-with NRC staff on October 26, 2010, Energy Northwest is re-evaluating the use of one-time inspections described in the License Renewal Application. A comprehensive response to this- issue will be provided under separate cover letter. The information related to this request for additional information will be provided at that time.

RAI B.2.48-1

Background

The GALL AMP XI.M32 states that use of a one-time inspection is appropriate when: (a) an aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period. GALL AMP XI.M32 also states that for these cases, the one-time inspection should provide confirmation that either the aging effect is indeed not occurring, or the aging effect is occurring very slowly so as not to affect the component or structure's intended function during the period of extended operation.

In LRA Section B.2.48, the applicant stated that its Service Air System Inspection Program will be used to identify the material condition of piping and valve bodies exposed to an internal air environment. The applicant also stated that the inspection checks for loss of material due to general corrosion.

The GALL Report recommends GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" Program to manage loss of material for steel piping exposed internally to air. GALL AMP XI.M38 includes periodic inspections of the internal surfaces of components.to manage loss of material.

Issue It is not clear to the staff how a one-time inspection program is appropriate to manage loss of material for these material and environment combinations given that: (a) loss of material is expected to occur for steel piping exposed internally to air; (b) the GALL Report recommends periodic inspection programs to manage aging for these material and environment combinations; and (c) a one-time inspection program is only to be used when an aging effect is not expected or is expected to progress very slowly.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 11 Request Justify how the one-time inspections proposed by the Service Air System Inspection Program are adequate to manage loss of material for steel components exposed internally to air by explaining how, for each component managed by the program, one of the following criteria for use of a one-time inspection is satisfied: (a) the aging effect is not expected to occur but the data is insufficient to rule it out with reasonable confidence; (b) the aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteristics of the aging effect include a long incubation period.

Energy-Northwest Response Based on a teleconference with NRC staff on October 26, 2010, Energy Northwest is re-evaluating the use of one-time inspections described in the License Renewal Application. A comprehensive response to this issue will be provided under separate cover letter. The information related to this request for additional information will be provided at that time.

Spent Fuel Pool RAI B.2.54-1

Background

Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Section A. 1.2.3.1, states that the scope of the program should include the specific structures and components of which the program manages the aging.

In addition, SRP-LR Section A. 1.2.3.4, states that detection of aging effects should occur before there is a loss of the structure and component intended functions. The parameters to be monitored or inspected should be appropriate to ensure that the structure and component intended functions will be adequately maintained for license renewal under all current licensing basis design conditions. This includes aspects such as method or technique (e.g., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new or one-time inspections to ensure timely detection of aging effects.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 11 In its response dated August 19, 2010, the applicant states that the Boron Carbide Monitoring Program detects degradation of boron carbide (B4C) neutron absorbers in the spent fuel storage racks by B4 C coupon inspection. The applicant further stated that boron loss is determined through measurement of the boron areal density (i.e., neutron attenuation testing) in the coupons. In addition, per the corrective action program, the applicant also indicated that in situ areal measurement density techniques such as Boron-10 Areal Density Gauge for Evaluating Racks (BADGER) testing may be performed to determine boron loss.

Issue LRA Section B.2.54 does not indicate the location and number of B4 C coupons used in the Boron Carbide Monitoring Program and whether or not coupon inspection will be performed in the period of extended operation. Furthermore, the applicant indicated that neutron attenuation testing will be performed, but the frequency of testing was not stated.

Request

1. Indicate the number of B4C coupons available for use for the Boron Carbide Monitoring Program.

a. Discuss the number of coupons inspected during each inspection and whether coupon inspection will be performed throughout the period of extended operation.

b. Provide past inspection test results for the coupons, including boron areal density measurements.

2. Provide the frequency for which neutron attenuation testing, either in situ or coupons, will be performed during the period of extended operation.

3. Discuss the location, neutron flux, and mounting of the sample coupons relative to the fuel assemblies.

a. If the coupons are at a location of low neutron flux they will not be representative or bounding of the higher flux racks in the pool. As such, discuss how the loss of material and reduction of neutron absorbing capacity in the racks will be monitored or inspected.

b. Guidance on an acceptable program is available in License Renewal Interim Staff Guidance (LR-ISG) 2009-01, "Aging Management of Spent Fuel Pool Neutron-Absorbing Materials other than Boraflex." Describe how your program is consistent with LR-ISG-2009-01.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 11

4. Provide the associated license renewal final safety analysis report supplement and commitment to perform this program in the period of extended operation.

Energy Northwest Response:

1. There are 14 coupons in the coupon canister within the Spent Fuel Pool (SFP).

a. One coupon is removed from the spent fuel pool for inspection every four years. This inspection interval will be continued through the period of extended operation (PEO). There is a sufficient number of coupons to continue the inspection through the PEO at the same frequency.

Each coupon in the SFP has a matching controlled coupon in storage.

Both coupons, the irradiated coupon from the SFP and the controlled coupon, are inspected and the results are compared.

b. Energy Northwest has performed visual exams on coupons every four years beginning in 1999 and no signs of degradation have been seen.

Results from the 1995 isotopic abundance analyses are provided below.

The laboratory results showed no degradation of the boron carbide material. The table below shows the atom percent of the boron 10 and boron 11 isotopes. The first three sample ID rows are from coupon #4 which had been in the spent fuel pool. The first three lines correspond to three separate locations that were tested on coupon #4. Lines 4, 5, and 6 are the results from three separate locations on the corresponding control coupon #4.

Row Sample ID Isotope Atom Percent 1 B4 C R4 - #1 Blu 20.00 B" 80.00 B10 20.00 2 B4 C R4 - #2 B11 80.00 B' 0 20.03 3 B4 C R4 - #3 B10 79.97 B1° 20.04 4 4-1 B11 79.96 Blu 20.04 5 4-2 B11 79.96 Bl 0 20.05 6 4-3 B11 79.95

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 11

2. Initial in situ testing of the Spent Fuel Rack neutron absorbing material will be performed prior to the PEO to determine the current state of the racks.

Additional in situ testing will be based on the results of this initial testing, but at an interval not to exceed ten years. The SFP coupons will continue to be tested on a 4 year frequency unless the frequency of the in situ testing is set at a frequency less than or equal to six years. In situ testing at such a frequency would render the coupon testing meaningless.

3. The coupons are mounted on the outside of the racks at roughly the middle height of the bundles. This is in a low flux region of the SFP.

a. The coupon testing program will be compared with the in situ testing results and the comparison will determine the future of the coupon testing program. Additional periodic in situ testing will be performed based on the results of the initial in situ testing at a frequency not to exceed ten years.

b. Columbia's plant specific Boron Carbide Monitoring Program was submitted under letter G02-10-117, dated August 19, 2010, SK Gambhir (Energy Northwest) to NRC, "Response to Request for Additional Information, License Renewal Application." As a plant specific program an element to element comparison was not provided. However, the elements of Columbia's plant specific program as previously submitted and as amended to the response to this RAI is consistent with and meets the intent of the program to the guidance provided in LR-ISG-2009-01.

4. The FSAR supplement associated with the Boron Carbide Monitoring Program is found in Appendix A (section A.1.2.54) of the LRA and the corresponding commitment to continue with this program for the PEO is contained in Table A-1 (item 61). Both of these items were provided per Amendment 2 to the LRA as previously submitted under letter G02-10-117. Amendment 20 to the LRA to address the change to the commitment is provided in the enclosure.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 Oil Fog Lubricator Material There is no request for additional information associated with this issue.

Based on approved plant documents, the material for the oil fog lubricator was identified as copper alloy and aluminum. This fact was questioned after a system walkdown found some of the oil fog lubricator bowls were made of steel and others were made of aluminum. The License Renewal Team researched the issue and found a discrepancy between documents. The qualification information document (QID) incorrectly stated the material for the bowl was copper alloy. The vendor information in plant files shows that the bowl is made of steel. A substitution evaluation performed for the component approved aluminum as an acceptable substitute for steel. The issue was entered into the corrective action program (CAP) and the QID file has been corrected.

The License Renewal Application (LRA) Table 3.3.2.17, rows 24, 25, 26 and 27 are changed and new row 74 is added in Amendment 20 to reflect steel instead of copper alloy. This introduces a new material and environment combination for the oil fog lubricator. However, the material and environment combination, the aging mechanism, and aging management program (AMP) were addressed in the aging management review for other system components. Therefore, the new material and environment combination does not require the review of a new aging mechanism or the development of a new AMP. No change of the applicable AMPs, Air Quality Sampling, Lubricating Oil Analysis, Lubricating Oil Inspection, External Surfaces Monitoring, and Diesel Starting Air Inspection, is necessary because of the change in material. Therefore, the identification of the new material and environment combination for the oil fog lubricators does not introduce a new aging mechanism or new program to control aging in the Diesel Engine Starting Air System.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 License Renewal Application Amendment 20 Section No. Page No. RAI Response Table 3.3.2-1 7, 3.3-201 No RAI, See Attachment 2 Rows 24, 25, 26, & 27 Table 3.3.2-17, Table 3.3.2-17, Insert A for new row 74 3.3-206b 3.3-206 Attachment 22 No RAI, See Attachment INsrAfonew Table row 74 3.3.2-17 Ne 43.3-206b o No RAI, See Attachment 2 Table 3.3.2-22 3.3-246 3.2.2.1.Y-1 Row 102 Table A-1 A-68a B.2.54-1 Item 61 A-68aB.2.54-1 B.2.54 208b B.2.54-1

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 Management___ P rItem Heat Air-indoor 19 Exchanger Structural Copper uncontrolled None None N/A N/A G (tubes) (DSA- integrity Alloy (External)

__ _ HX-2) 20 Oil Fog Pressure Aluminum Air (Internal) None None N/A N/A G Lubricator boundary Alloy 21 Oil Fog Pressure Aluminum Lubricating Loss of Lubricating Oil N/A N/A G Lubricator boundary Alloy oil (Internal) material Analysis 22 Oil Fog Pressure Aluminum Lubricating Loss of Lubricating Oil N/A N/A G 23 O Aluminum Air-indoor Oil iFog cato r Pressure boundar y Al loy uncontrolled None None N/A N/A G Lubricator boundary Alloy (External) Loss of material matppj QAi Sampling Air Quality 24 Oil Fog Pressure AGAir (Internal) None N/A N/A G Lubricator boundary 25 Oil Fog Pressure Lubricating Loss of Lubricating Oil VII.H2- 3.3.1- A Lubricator boundary oil (Internal) material Analysis 40 7 246 14 Oil Fog Pressure Ge Lubricating Loss of Lubricating Oil VII.H2- 3.3.1-26 Lubricator boundary - \ oil (Internal) material Inspection

• 14 A1-0 27 Fog Oil Pressure GAir-indoor OLubricator boundary Areo uncontrolled NOReA N/A N/A 27 Lubricator5_ boundary (External) n St.=eel ILoss of material External Surfaces 3.3.1-58 2 Monitoring Aging Management Review Results Page 3.3-201

[Amendet 20

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-17 Aging Management Review Results - Diesel Engine Starting Air System Row -Aging Effect Aging NUREG-Component Intended Material Environment Requiring Management 1801 Table Notes No. Type Function(s) Management Program Volume 2 1 Item

_Management_ Program_ Item Pressure Stainless Air-indoor 3.31-64 Valve Body uncontrolled None None VII.J-15 A boundary Steel (External) 94 65 Valve Body Pressure Steel Air (Internal) Loss of Air Quality boundary material Sampling 66 Valve Body Pressure Steel Air (Internal) Loss of boundary material Diesel Air Starting Inspection N/A N/A G

" Air-indoor oss o External 3..

67 Valve Body Pressure Steel uncontrolled loSurfaces V.-8 3.3.1- A 6boundary Valve y (External) material Monitoring 58 68 Valve Body Structural Stainless Air (internal) None None N/A N/A G integrity Steel 69 Valve Body Structural Stainless Air-indoor 331-integrity uncontrolled None None VII.J-15 A Steel (External) 94 Structural Steel Air (Internal) Loss of Air Quality AG integrity material Sampling 0314 71 Valve Body Structural integrity Air-indoor Loss of External 3.3.1-Steel uncontrolled material Surfaces VII.I-8 A (External) material Monitoring 58 3.3.2-17 IInsert newas rows shown72 on andpage 3.3-206a.

73 for Table Insert A from jPage 3.3-206b]-

Aging Management Review Results Page 3.3-206 Amendment.

Columbia Generating Station License Renewal Application Technical Information Insert A for Page 3.3-206 Aging Management Review Results Page 3.3-206b Amendment 20

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results -Fire Protection System Row Component Intended Agn fet Aging Effect Aging Aig1801 NUREG- Table No. Type Function(s) Material Environment Requiring Management Vlm1 Te Notes Management Program Volume 1 Item 2 Item 97 Pump Casing Pressure Gray Cast Raw water Loss of Fire Water VII.G-24 3.3.1- A (FP-P-1,2A,2B) boundary Iron (External) material 68 Pump Casing Pressure Gray Cast Raw water Loss of Selective 3.3.1-98 (FP-P-1,2A,2B) boundary Iron (External) material Inspection 85 A (F PP-i,2A2B)boudar Stel Mistair Los ofSupplemental 99 Pump Casing (FP-P-1,2A,2B) Pressure boundary Steel Moist air (Internal) Loss of material Piping/Tank PinpeciongTn VIIG-23 LG 3.3.1-71 E 0303 Inspection71 03 100 Pump Casing Pressure Steel Raw water Loss of Fire Water VII.G-24 3.3.1- A (FP-P-1,2A,2B) boundary (Internal) material 68 Pump Casing Pressure Air-indoor Loss of External.

101 Pump ,2A,2B)

(FP-P-1 boury boundary Steel uncontrolled (External) material Surfaces Monitoring VII.1-8 3.3.1- A 58 103031 Pressure Air-indoor Loss of Supplemental 1102 Pup Casing Pump Casing (FP-P-1,2A,2B) boury boundary Steel uncontrolled (External) material Piping/Tank Inspection VII.I-8 3.3.1-58 E 103 Pump Casing Pressure Steel Raw water Loss of Fire Water VII.G-24 3.3.1- A (FP-P-1,2A,2B) boundary (External) material 68 104 Pump Casing Pressure Gray Cast Raw water Loss of Fire Water VII.G-24 3.3.1- A (FP-P-110) boundary Iron (Internal) material 68 Amendment 20 Aging Management Review Results Page 3.3-246 Janua=y 2010

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-68 Table A-1 Columbia License Renewal Commitments FSAR Enhancement Item- Number Commitment Supplement or Location Implementation (LRA App. A) Schedule

61) Boron Carbide The Boron Carbide Monitoring Program is an existing program that A.1.2.54 r-gu,,

Monitoring will be continued for the period of extended operation.

Program _-__ r__

< Insert A from pa Sge A-68b Initial in situ testing of the Spent Fuel Rack neutron absorbing Initial in situ testing material will be performed prior to the period of extended prior to the period operation to determine the current state of the racks. Additional of extended in situ testing will be based on the results of this initial testing, but operation, then at an interval not to exceed ten years. onging. I Amendment 1-4 04--

Final Safety Analysis Report Supplement Page A-68a -A Amendment2

Columbia Generating Station License Renewal Application Technical Information operating experience. A visual examination of the B4C sample coupons is made to evaluate surface appearance, size, shape and color. Mechanical testing of B4C samples is done on a periodic, basis to determine if physical degradation is occurring in the plate material. In addition, chemical testing will take place on a periodic basis to determine if leaching of the boron content is occurring.

Detection of Aging Effects:

The amount of boron loss from the B4C panels is determined through measurement of the boron areal density in the coupons. Visual inspections and measurements, as appropriate, are used to determine and assess the extent of degradation in the Boron Carbide before there is a loss of intended function. This can be supplemented with verification of boron loss in the spent fuel racks through areal density measurement techniques such as the (Boron-1 0 Areal Density Gage for Evaluating Racks) BADGER device.

onitoring and Trending:

The periodic inspection mea isurements and analysis are to be compared to values of previous measureiments and analysis to provide a continuing level of data for trend analysis. Also studies by other utilities using similar B4C material for high density spent fuel raicks will be monitored for information.

Acceptance. Criteria:

The 5% subcriticality margin I of the spent fuel racks is to be maintained for the period of extended operatioin. Corrective actions are initiated if the test results find that the 5% subcriticalit y margin cannot be maintained because of the current or projected future d egradation. The fuel rack loading pattern will be determined by Reactor Engineering and one or more samples will be analyzed for B-i10 content. If data con tinues to suggest less than 5% subcriticality, then blackness testing such as BADGER testing may be performed on the racks as+a result of corrective action pe rformed.

Corrective Actions:

This element is common to 4Columbia programs and activities that are credited with aging management dur ing the period of extended operation and is discussed in LRA Section B.1.3.

Initial in situ testing of the Spent Fuel Rack neutron absorbing material will be performed prior to the period of extended operation to determine the

~.+r m +,Io+'a II LL f +kn r' uL L,c Additional in situ testing will be based on the results of this initial testing , but at an interval not to exceed ten years.

Aging Management Programs Page 208b Amfend*mepA 2 J~mndm2 n 20