GO2-11-020, Response to Request for Additional Information License Renewal Application

Response to Request for Additional Information License Renewal Application

ML110310010
Person / Time
Site:	Columbia
Issue date:	01/27/2011
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-11-020
Download: ML110310010 (49)

Text

Sudesh K. Gambhir ENER Y-*.*/ *P.O. Vice 968, MailEngineering BoxPresident, Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@ energy-northwest.com January 27, 2011 G02-11-020 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, G02-10-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

3) Letter dated October 20, 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. ML102850735)

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 18 to the Columbia License Renewal Application. One new commitment and two revised commitments are reflected in the changes to Table A-1 in this amendment.

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

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, YK5 mb h ir Vice President, Engineering

Attachment:

Response to Request for Additional Information

Enclosure:

License Renewal Application Amendment 18 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1399 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 13 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"

(ADAMS Accession No. ML102850735)

Holston RAI 3.3.2.3.17-2

Background

LRA Tables 3.3.2-17 and 3.3.2-41 state that for stainless steel filter bodies, flexible connections, piping, strainer screens, tubing, and valve bodies exposed to air (internal),

there is no aging effect and no aging management program (AMP) is proposed. The aging management review (AMR) line items cite Generic Note G. License Renewal Application (LRA) Table 3.0-1 states that air can be, "process air in locations where condensation, water pooling, or accumulation of contaminants could occur (moisture content is enough to facilitate crevice and pitting corrosion in various metals, as well as general corrosion of steel)." The GALL Report states that for stainless steel components exposed to condensation a plant-specific AMP is to be evaluated to address pitting and crevice corrosion.

Issue The staff does not have sufficient information to evaluate the air environment in relation to the applicant's claim that there are no aging effects and no AMP is required.

Request Justify why the air environment for these components does not contain moisture, or specify an AMP to manage the aging effect.

Energy Northwest Response Columbia agrees that there are Diesel Starting Air (DSA) piping and components that contain moisture and require aging management. The components in LRA Table 3.3.2-17 upstream of the air relay valve have an internal environment of air that is compressed air taken from inside the Diesel Generator Building. Plant specific operational experience indicates that the DSA System is not reliably dry, and may contain some amount of moisture. This environment is evaluated as a wetted environment at the air receivers. The DSA System is configured such that any moisture in the air will collect in the air receivers, as supported by site operating experience. As the air receivers are the first section of the system that is cold relative to the air temperature coming from the compressor (the heat of compression raises the air temperature) and it is also where the air stagnates, it forms a water trap for the system.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 13 Moisture is removed from the air receivers once per shift (twice per day); the blow down air comes from the bottom of each receiver and will remove accumulated moisture from the air receivers. The environment has been identified as "Raw water (Internal)" and components exposed to the environment are managed by the plant-specific Air Quality Sampling Program. However, the subject stainless steel components are not exposed to condensation, water pooling, or an accumulation of contaminants. The air receivers receive a periodic UT examination to comply with Washington State commitments for ASME pressure vessels. These periodic examinations adequately manage aging of the air receivers.

Visual inspections of the air receiver internal surfaces have shown that there is only minor surface corrosion on the walls. These inspections also indicate that the water only pools in the bottom head where wall thinning has been identified. Since the air discharges to the air start motors from the upper wall region, the piping downstream is expected to be in the same condition as the upper walls. Therefore, no water pooling is expected downstream of the air receivers. The periodic UT examinations support the visual inspections as only very little wall loss has been noted to date.

The piping and components downstream of the air relay valve are exposed to compressed air only during DG start activities. As the air pressure drops across the air relay valve, the dew point also drops and the air is drier than when it was in the air receiver. After the start sequence, the piping and components downstream of the air relay valve are exposed to ambient air in the DG room.

License renewal application (LRA) Table 3.0-1 is revised in the attached amendment to clarify that air does not include "process air in compressed air systems with locations where condensation, water pooling, or accumulation of contaminants could occur (moisture content of the air is enough to facilitate general corrosion of steel)."

Compressed air system locations where condensation, water pooling, or accumulation of contaminants could occur, constitutes wetting that would facilitate crevice and pitting corrosion in various metals, and a "Raw water (internal)" environment was assigned.

The stainless steel components in LRA Table 3.3.2-41 have an internal environment of air that is compressed air from the Service Air (SA) System. The SA System internal environment is compressed air that is expected to be dry and free of contaminants.

However, due to operational considerations (e.g., occasional connection of portable compressors without dryers), the SA System is not considered to be reliably dry, and may contain some amount of moisture. The configuration of the Standby Liquid Control (SLC) System includes compressed air from the SA System to the storage tank (SLC-TK-1) for sparging as part of periodic sampling. This sampling occurs monthly via SLC-V-12, which is otherwise normally closed.

Therefore, neither of these environments is evaluated as a wetted environment since the moisture is not expected to condense or collect. Those areas where moisture may condense or collect are managed by other programs, as described above. Loss of material due to such aging effects as pitting and crevice corrosion are only applicable for stainless steel components subject to air if it is a wetted environment. Therefore,

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 13 there are no aging effects requiring management for the subject stainless steel components and no aging management program is required.

Holston RAI 3.3.2.3.33-1 Background LRA Table 3.3.2-33 states that stainless steel piping exposed to air-indoor uncontrolled (external) is being managed for loss of material by the Supplemental Piping/Tank Inspection Program. The AMR line item cites Generic Note G. The line item associated with piping in LRA Table 3.3.2-33 also cites plant specific Note 0303, which states that the Supplemental Piping/Tank Inspection Program will manage loss of material at the air-water interface. The staff notes that the GALL Report states that stainless steel exposed to air-indoor uncontrolled (external) is not subject to any aging effects; however, the plant-specific note states that this item is associated with an air-water interface. The GALL Report recommends that stainless steel exposed to (a) treated water should be managed by the XI.M2, "Water Chemistry" and the XI.M32, "One-Time Inspection" Programs, (b) raw water can be managed by the XI.M20, "Open-Cycle Cooling Water System" Program, and (c) condensation can be managed by a plant specific AMP.

Issue The staff lacks sufficient information to determine the type of water environment that exists at the air-water interface and thus cannot determine if the Supplemental Piping/Tank Inspection Program is sufficient to manage aging of the components.

Request

1. If the water environment at the air-water interface is treated water, justify why the XI.M2, "Water Chemistry" program is not utilized in managing the aging of this piping.

2. If the water environment at the air-water interface is raw water, justify why the Supplemental Piping/Tank Inspection Program, based on one time inspections, is sufficient to manage the aging of the piping whenthe XI.M20, "Open-Cycle Cooling Water System" Program includes periodic inspections to detect the associated aging effect.

3. If the water environment at the air-water interface is condensation justify why the Supplemental Piping/Tank Inspection Program, based on one time inspections is sufficient to manage the aging of the piping.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 13 Energy Northwest Response:

The one-time Supplemental Piping/Tank Inspection Program supplements other periodic programs credited for aging management of the subject components at the air-water interface zone, as described below.

The subject component that is described in LRA Table 3.3.2-33 is the Process Sampling Radioactive (PSR) System sample line from the suppression pool and is shown on license renewal boundary drawing LR-M896 at zone D/1 4. The portion of the subject stainless steel piping that is above the air-water interface is exposed to an air-indoor uncontrolled (external) environment; as indicated in LRA Table 3.3.2-33 Row #29, there are no aging effects requiring management for stainless steel piping above this air-water interface, and no aging management program is specified. The portion of the subject stainless steel piping that is below the air-water interface is submerged within the suppression pool and exposed to a treated water (external) environment; as indicated by LRA Table 3.3.2-33 Rows #30 and #31; loss of material is an aging effect requiring management for the subject stainless steel piping that is below the air-water interface and will be managed by the BWR Water Chemistry Program with the Chemistry Program Effectiveness Inspection providing confirmation of program effectiveness.

The portion of the subject stainless steel piping at the air-water interface is exposed to an air-indoor uncontrolled (external) environment; as indicated by LRA Table 3.3.2-33 Row 28; loss of material is an aging effect requiring management for the subject stainless steel piping that is at the air-water interface with the Supplemental Piping/Tanks Inspection credited for aging management. As described in the Mechanical Tools (EPRI 1010638), loss of material due to crevice and pitting corrosion is an applicable aging effect for the external surfaces of stainless steel components if the surface is subject to a concentration of contaminants. Prolonged or frequent wetting (e.g., from condensation, leakage, ponding/pooling) or alternate wetting. and drying can concentrate contaminants from the atmosphere and they can thereby become aggressive species for metals. Since the surfaces of the subject piping at the air-water interface is subject to alternate wetting and drying, this constitutes a potentially aggressive environment. The Supplemental Piping/Tank Inspection Program will detect and characterize the material condition of the piping at the air-water interface to ensure that the structural integrity of the nonsafety-related piping will be maintained such that spatial interactions will not result in the loss of any safety-related component intended functions during the period of extended operation. Plant operating experience has not indicated any aging effect related to air-water interfaces and the inspection will provide confirmation. Any identified aging effect will be managed by the corrective aging program.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 13 Electrical Rhow RAI B.2.40-1 Supplement 1

Background

In the applicant's response to RAI B.2.40-1, dated August 31, 2010, the applicant stated that an appropriate frequency for thermography checks will be established in conjunction with performing torque checks on the other non-segregated metal enclosed buses (MEB) during the next refueling outage to prevent recurrence of this type of event. The applicant also stated the content and controls for preventive maintenance (PM) activities will be strengthened to ensure proper completion of critical steps, that there are appropriate levels of review, and approval is applied to changes. In addition, the applicant stated that both the thermography inspection and the visual inspections will be performed at least once every 10 years, with the first inspections to be completed prior to the end of the current operating license.

Issue The staff is concerned that applicant's new AMP using thermography and visual inspections performed at least every 10 years is similar to previous maintenance activities (including procedure and schedules) and as such, the management of aging effects under the new program may not be adequate to allow in-scope MEBs to continue to perform their intended function consistent with the current licensing basis (CLB) for the period of extended operation.

Request Describe maintenance activities (including procedures and schedules) for the MEB preventive maintenance program applied to non-segregated MEB prior to the August 5, 2009 6.9 kV E-BUS-NONSEG/N2/X MEB event. Recognizing that there has been an MEB failure, discuss how the proposed inspection frequency of at least once every 10 years will be adequate and provide reasonable assurance that the aging effects will be managed such that in-scope MEBs will continue to perform their intended functions consistent with the CLB for the period of extended operation.

In addition, discuss how the-torque checks are consistent with the guidance provided in Electric Power Research Institute documentTR-1 04213, "Bolt Joint and Applications Guide," with regard to electrical bolted connection torque checks at CGS.

Energy Northwest Response The maintenance activities for the Metal Enclosed Bus (MEB) E-BUS-NONSEG/N2/X (not with-in the scope of License Renewal) prior to the August 5, 2009 event were:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 13 Thermography, Frequency - 24 weeks. There were locations which had infrared (IR) inspection windows which were installed in response to previous heating events, but most locations did not have them installed. The thermography inspection that occurred prior to the event was not done through an IR inspection window because the window had not yet been installed in the bus. This indicates that bus duct temperature measurements were not sensitive enough to detect problem with a high degree of confidence. Since duct temperature is not indicative of bus temperature, an action was initiated following the bus failure to install thermography windows at all link locations so that bus temperatures can be monitored.

" Inspect and clean bus support insulators per plant procedure.

• Perform High-Potential or Megger testing. A review of eleven Preventive Maintenance (PM) work orders for 6.9 kV and 4.16 kV non-segregated bus inspections for the period 2001 through 2009 found that, in each case, the work scope was revised to remove High Potential or Megger testing. However, these PM scope revisions were neither reviewed nor approved in accordance with direction in plant procedures.

" Inspect bus rigid and flexible connections for proper torque. A review of eleven Preventive Maintenance (PM) work orders for 6.9 kV and 4.16 kV non-segregated bus inspections for the period 2001 through 2009 found that, in each case, the work scope was revised to remove bus connection torque verifications.

However, these PM scope revisions were neither reviewed nor approved in accordance with direction in plant procedures. The root cause of the event was determined to be failure to perform the full scope of preventive maintenance on E-BUS-NONSEG/N/2X as directed by the PM Program.

• Inspect bus mounting bolts for proper torque if accessible.

Discussion of 10-year Inspection Frequency The proposed inspection frequency of at least once every 10 years will be adequate and provide reasonable assurance that the aging effects will be managed such that in-scope MEBs will continue to perform their intended functions consistent with the CLB for the period of extended operation. As stated above; MEB duct temperature measurements, as opposed to bus temperature, were not sensitive enough to detect problems with a high degree of confidence. Since duct temperature is not indicative of bus temperature, an action was initiated following the bus failure to install thermography windows at critical locations so that bus temperatures can be monitored, with the exception of 12 locations on the E-BUS-NONSEG/S/X and E-BUS-NONSEG/S/Y buses. These missing windows are to be utilized by the thermography monitoring program during the period of time when 12 R heating would be observable, namely between 10% and 20% reactor power. Current is not present in the SIX and SlY buses above 23% reactor power because house loads are transferred to the NI/X, NI/Y, and N2/X buses. Although the

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 13 SY bus may be periodically loaded during diesel generator monthly surveillances, it is only for a short period of time at a limited load. Currently there is not a thermography PM scheduled to coincide with this activity. Energy Northwest commits to install IR windows at all locations of bolted connections of the in-scope bus before the first inspections to be completed within the period prior to the end of the current operating license required by the Metal-Enclosed Bus Program. As part of the corrective actions associated with the event, the frequency of the thermography PM was increased to every 12 weeks until all of the bus connections are reworked in R-20. This frequency was recommended to allow the acquisition of a range of temperatures expected during a yearlong period of exposure to changing atmospheric conditions that will be encountered thus establishing a "normal" range of temperatures for these influences.

The frequency of the thermography inspection will be at least once every 10 years. It will be adjusted based on industry and plant specific operating experience, but the interval will not exceed 10 years.

Other relevant factors are:

The configuration for the link connections was revised after the event to use Belleville washers in place of the split lock washer and a heavy flat washer in place of the standard flat washer. This configuration change results in an improved torque at the links because it has less relaxation over time due to thermal cycles. The failed connection had not been upgraded to the new design prior to failure. The corrective action program is tracking the completion of work orders to replace the hardware for any connections.

" Since the event occurred at a flexible link connection, and the MEB manufacturer identified the flexible links as being marginally rated following the power up-rate for the Adjustable Speed Drive (ASD), all marginally sized flexible connections were replaced.

• The MEB manufacturer's analysis provided in 1994, as part of the ASD power up-rate, to establish a new rating of the 6.9 kV non-segregated phase bus duct (E-BUS-NONSEG/N2/X and E-BUS-NONSEG/S/X) from 2500 amps to 2806 amps (a 12.2% increase) appears to be non-conservative. The maximum calculated load of E-BUS-NONSEG/N2/X (the bus involved in the event) exceeds the original 2500 amp rating. The normal routine loading is about 2270/2500 =

90.8% of the original rating. The maximum calculated load for 6.9 kV bus E-BUS-NONSEG/S/X is 1794 amps or 1794/2500 = 71.8% of the design rating.

The TR-S 6.9 kV X winding and associated non-segregated buses are in standby during normal plant operation. The TR-S 6.9 kV X winding is limited by procedure to a maximum operating load of 2400 amps or 2400/2500 = 96% of the original design rating.

• There is currently a study being done that indicates it is possible that any rating over the original 2500 ampere rating is non-conservative. This issue could

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 13 indicate that the failure was the result of a design issue rather than an aging issue. The rating issue only applies to out of scope MEB.

E-BUS-NONSEG/S/X is part of the 6.9 kV AC Electrical Distribution system, which is shown in the License Renewal Application (LRA) Table 2.2-2 as being in scope. The 6.9 kV system is in scope because it contains two circuit breakers associated with the Reactor Recirculation System (RRC) pumps. These breakers are safety-related and are credited for Anticipated Transients Without Scram (ATWS) and End of Core Life Recirculation Pump Trip (EOC RPT). The breakers perform their License Renewal (LR) functions by interrupting the 6.9 kV power to the RRC pumps (Tripping). As the function of E-BUS-NONSEG/S/X is to supply 6.9 kV power, the failure of the bus does not adversely impact the LR functions of the circuit breakers to remove power to the pumps. Therefore, E-BUS-NONSEG/S/X is not within the scope of LR and the License Renewal Application is updated in amendment 18 to reflect the removal from scope. The table below shows the original and revised scoping results.

Bus EPN Originally Currently Note In-Scope In-Scope E-BUS- NONSEG/N1/X No No E-BUS- NONSEG/N1/Y No No E-BUS- NONSEG/N2/X No No Bus that Faulted E-BUS- NONSEG/N2/Y No No E-BUS- NONSEG/S/X Yes No E-BUS- NONSEG/S/Y Yes Yes Discussion of Torque Checks The torque checks that were identified in the response to RAI B.2.40-1, dated August 31, 2010 are consistent with the guidance provided in Electric Power Research Institute document TR-1 04213, "Bolt Joint and Applications Guide." The EPRI technical report states:

Inspect bolted joints for evidence of overheating, signs of burning or discoloration, and indications of loose bolts. The bolts should not be retorqued unless the joint requires service or the bolts are clearly loose.

Verifying the torque is not recommended. The torque required to turn the fastener in the tightening direction (restart torque) is not a good indicator of the preload once the fastener is in service.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 13 The response stated:

The torque checks identified in item 2 above are not part of the B.2.40 program. Thermography is the B.2.40 credited inspection.

In addition, the torque checks are better categorized as a looseness check and the joint is serviced after the "torque check." The revised Model Work Orders that implement the current Preventative Maintenance requirements state:

Using a torque wrench set 10 ft-lbs below the required torque; obtain As-Found torque for each link location. Iffastener turned, record "Loose" on the link inspection signoff sheet, "As found torque." If fastener did NOT turn, record "OK" on signoff sheet.

The work orders then go on to remove the bolting hardware and link then require a visual inspection of the disassembled connection and cleaning the contact area. The work orders require the inspection of the bolting hardware and replacement if needed then re-installation of the connection. The instructions require torquing of the bolting to defined requirements and re-insulating the connection. Therefore, the joint is serviced and the torque check is consistent with the EPRI guidance.

Small Bore Piping Program RAI B.2.49-2

Background

LRA Section B.2.49 states that the Small Bore Piping Program is a new plant-specific program that will detect and characterize cracking in small-bore piping components that are exposed to reactor coolant. In the "detection of aging effects" program element the applicant stated that in-scope components will be grouped into populations based on component type, material, and environment. The applicant also stated that the sample size will be 10% of each population (except for socket welds) with a minimum of one location and a maximum of 20 locations; the socket weld sample will include three locations. SRP-LR Section A.1.2.3.4 states that this program element should describe "when," "where," and "how" program data are collected (i.e., all aspects of activities to collect data as part of the program). It also states that when sampling is used to inspect a group of structures and components, a basis should be provided for the inspection population and sample size that is selected.

Issue The applicant stated the number of socket welds to be examined as a part of the Small Bore Piping Program; however, it does not state the total number of such welds in the plant (i.e., the sample population). The staff is unable to determine the sample size for socket welds as a percentage of the total number of such welds present to assess

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 13 whether the sample size is sufficient to be representative of the total socket weld sample population.

Request Provide and justify the sampling information that is selected, in terms of number of welds and percent of welds to be inspected, for the volumetric examinations of socket welds for both nondestructive and/or destructive examinations.

Energy Northwest Response The sample population criteria will use the guidance given in NUREG-1801, Revision 2,Section XI.M35. The Small Bore Piping Program will inspect a sample of ASME Code Class 1 piping less than NPS 4 and greater than or equal to NPS 1. The inspection will include 10% of the weld population or a maximum of 25 welds of each weld type (e.g.,

full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, Columbia may take credit for each weld destructively examined equivalent to having volumetrically examined two welds.

Columbia has 1,851 ASME Code Class 1 socket welds less than NPS 4 and greater than or equal to NPS 1. Therefore, 25 socket welds will be inspected each 10 year interval.

Columbia will prepare and submit the ISI Program Plan for the fourth 10-year interval no later than 2015. (The third 10-year ISI interval extends from December 2005 until December, 2015). The Small Bore Piping Program will be included in the fourth 10-year interval ISI program plan as an augmented inspection. The locations to be inspected, the sample size, the inspection methodology will be included in the program plan.

Kichline RAI 3.4.2.3.3-1

Background

In LRA Tables 3.4.2-3, 3.4.2-4 and 3.4.2-6, the applicant stated that the steel main condenser heat exchanger (shell), tanks, piping, piping components, piping elements, strainers, traps and valve bodies exposed to moist air (internal) are being managed for loss of material by the Supplemental Piping/Tank Inspection Program. The AMR line items cite Generic Note G, indicating that for the line items the environment is not in the GALL Report for these components and material.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 13 GALL Report Item VII.G-23 in the Fire Protection Table and VII.H2-21 in the Emergency Diesel Generator Table apply for steel piping, piping components, and piping elements exposed to moist air or condensation (internal). Both entries recommend GALL AMP XI.M38 "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," to manage loss of material for steel components exposed to moist air or condensation (internal) via the performance of visual inspections.

In LRA Section B.2.51, the applicant stated that its Supplemental Piping/Tank Inspection Program is a new program that will manage the aging of steel, gray cast iron, and stainless steel components that are exposed to moist air environments, particularly the aggressive alternate wet and dry environment that exists at air water interfaces or air spaces of susceptible piping and tanks, using a combination of volumetric and visual one-time inspections of the internal and external surfaces of components to identify evidence of a loss of material.

Issue It is unclear to the staff how the one-time inspections performed by the Supplemental Piping/Tank Inspection Program are adequate to manage aging for components exposed to moist air or condensation, given that the GALL Report recommends periodic inspections.

Request Justify how the one time inspections performed by the Supplemental Piping/Tank Inspection Program are adequate to manage aging for components exposed to moist air or condensation.

Energy Northwest Response The inspections performed by the Supplemental Piping/Tank Inspection are adequate to manage loss of material of steel, stainless steel, and gray cast iron components exposed to moist air, primarily at air-water interfaces. The inspections provide additional verification of the effectiveness of existing programs credited with managing aging above and below the air-water interface and also serve to verify the effectiveness of the existing External Surfaces Monitoring Program for material above an air-water interface, as clarified below.

Table 3.4.2-3 Row 53 is for the steel condensate storage tanks (COND-TK-1A, 1B) components at and above the water line. Also, in response to RAI 3.3.2.3.16-1, Amendment 17 to the License Renewal Application was made to add the moist air environment for the stainless steel level sensing tubing for the condensate storage tanks. The condensate storage tanks are vented to the outdoor air. Therefore, the upper portion of the tanks is an air-outdoor environment and the lower portion is treated water with an air-water interface between the two environments. The air-outdoor environment is managed by the External Surfaces Monitoring Program and the treated water environment is managed by the BWR Water Chemistry Program, with verification

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 12 of 13 of effectiveness provided by the Chemistry Program Effectiveness Inspection. The Supplemental Piping/Tank Inspection manages the air-water interface. A one-time inspection is adequate for this item since it, in effect, provides additional verification of the effectiveness of the ongoing BWR Water Chemistry Program and External Surfaces Monitoring Program where they intersect.

Table 3.4.2-4 Rows 29 and 36 is the steel piping that is the main steam relief valve (MSRV) discharge line to the suppression pool. There is an air-water interface between the indoor air environment and the treated water environment of the suppression pool.

The air-indoor environment is managed by the External Surfaces Monitoring Program and the treated water environment is managed by the BWR Water Chemistry Program with verification provided by the Chemistry Program Effectiveness Inspection. The Supplemental Piping/Tank Inspection manages the air-water interface. A one-time inspection is adequate for this item since it, in effect, provides additional verification of the effectiveness of the on-going BWR Water Chemistry Program and External Surfaces Monitoring Program where they intersect.

In Amendment 1 to the License Renewal Application (LRA) the steel auxiliary condensate pressure equalization tank (CO-TK-4) was added to LRA Table 3.4.2-2.

This tank also has an air-water interface between the indoor air environment and the treated water of the condensate. The air-indoor environment is managed by the External Surfaces Monitoring Program and the treated water environment is managed by the BWR Water Chemistry Program with verification provided by the Chemistry Program Effectiveness Inspection. The Supplemental Piping/Tank Inspection manages the air-water interface. A one-time inspection is adequate for this item since it, in effect, provides additional verification of the effectiveness of the on-going BWR Water Chemistry Program and External Surfaces Monitoring Program where they intersect.

Originally, the environment for the upper portion of the main condenser (COND-HX-9) and connected systems and components was evaluated as a moist air environment.

After further review, this evaluation was overly conservative and should have been evaluated as a steam environment. Therefore, the main condenser only has the two environments of steam and treated water. Both of these environments are managed by the BWR Water Chemistry Program, with credited verification provided by the Chemistry Program Effectiveness Inspection, and by the Flow-Accelerated Corrosion Program, as appropriate. Those systems and components that are connected to the main condenser are only subject to the internal environment of steam. This realignment of environments is applicable to Table 3.4.2-3 Row 14, Table 3.4.2-4 Rows 16, 39, 44, 58, 64, and 100, and Table 3.4.2-6 Rows 10, 25, 31, and 37. The LRA is amended as shown on the attached markup to reflect these changes.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 13 of 13 TLAA-Parks RAI 4.2.1-2

Background

10 CFR 54.3 defines time-limited aging analyses (TLAA) as those licensee calculations and analyses that:

(1) Involve systems, structures and components within the scope of license renewal, as delineated in 10 CFR 50.54(a)

(2) Consider the effects of aging (3) Involve time-limited assumptions defined by the current operating term (4) Were determined to be relevant by the licensee in making a safety determination (5) Involve conclusions or provide the basis for conclusions related to the capability of the system, structure, and component to perform its intended functions, and (6) Are contained or incorporated by reference in the CLB Reactor vessel neutron fluence meets all six of these criteria. It is relevant in making a safety determination because its value affects the reference temperature for nil-ductility transition and the reactor coolant system pressure-temperature limits.

Issue The Columbia Generating Station License Renewal Application states that neutron fluence is not a TLAA.

Request Please revise LRA Section 4.2.1 to indicate the correct categorization of neutron fluence and provide the appropriate disposition in accordance with 10 CFR 54.21(c).

Energy Northwest Response Columbia did not identify neutron fluence as a TLAA because there are no limits on fluence itself; rather the limits are on fluence-dependent parameters like upper shelf energy (USE), adjusted reference temperature (ART), pressure-temperature (P-T) limits, etc. As explained in Section 4.2 of the Columbia LRA, fluence was projected through the period of extended operation in order that TLAA associated with USE, ART, P-T limits, etc. could be evaluated.

In response to this RAI, Columbia revises Section 4.2.1 (as well as Table 4.1-1 and Section A.1.3.1.1) of the Columbia License Renewal Application to say that neutron fluence is a TLAA that has been successfully projected for the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure I Page 1 of 2 License Renewal Application Amendment 18 Section No. Page No. RAI Response 2.5.5.2 2.5-5 B.2.40-1 Table 3.0-1 3.0-7 3.3.2.3.17-2 3.4.2.1.3 3.4-4 3.4.2.3.3-1 3.4.2.1.6 3.4-7 3.4.2.3.3-1 3.4.2.1.6 3.4-8 3.4.2.3.3-1 Table 3.4.2-3 3.4-45 3.4.2.3.3-1 Row 14 Table 3.4.2-3 3.4-53 3.4.2.3.3-1 89, 90 Row Tbe3423 3.4-53c 3.4.2.3.3-1 Row 89, Table 90 3.4.2-3 Ro9 0 3.4-53c 3.4.2.3.3-1 Table 3.4.2-4 3.4-55 3.4.2.3.3-1 Row 16 Table 3.4.2-4 3.4-58 3.4.2.3.3-1 Row 44 Table 3.4.2-4 3.4-60 3.4.2.3.3-1 Row 58 Table 3.4.2-4 3.4-61 3.4.2.3.3-1 Row 64 Table 3.4.2-4 Row 105-1 3.4-65 3.4.2.3.3-1 Row 105-110 Table 3.4.2-4 Rw1510 3.4-65a 3.4.2.3.3-1 Table 3.4.2-6 3.4-70 3.4.2.3.3-1 Row 10 Table 3.4.2-6 3.4-71 3.4.2.3.3-1 Row 25 Table 3.4.2-6 3.4-72 3.4.2.3.3-1 Row 31

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 License Renewal Application Amendment 18 Section No. Page No. RAI Response TableTbe3426 3.4.2-6 3.4-73 3.4.2.3.3-1 Row 37, 39-45 Table 3.4.2-6 3.4-73a 3.4.2.3.3-1 Row 39-45 Table Sabe 4.1-1 4.21- 4.1-3 4.2.1-2 Section 4.2.1 4.2.1 4.2-3 4.2.1-2 A.1.3.1.1 A-28 4.2.1-2 Table A-i A-57 B.2.40-1 Line 40 Table A-i A-61 a B.2.49-2 Line 49 Table A-i A-68b B.2.49-2 New line Table A-i A-68c B.2.49-2 Line 65 B.2.40 B-155 B.2.40-1 B.2.40 B-156 B.2.40-1 B.2.49 B-1 87a B.2.49-2 B.2.49 B-1 87b B.2.49-2 B.2.49 B-1 89a B.2.49-2 B.2.49 B-189b B.2.49-2

Columbia Generating Station License Renewal Application Technical Information 2.5.5.2 Metal-Enclosed Bus Metal-enclosed bus connects two or more elements of an electric power circuit and is used to connect active electrical components such as switchgear, transformers, and switches.

The metal-enclosed bus within the Columbia license renewal scope is the non-segregated phase bus associated with startup transformer E-TR-S, found in thI I .- kv,

.l.etri..l *,yte... (E BUS N.NSEG.S.X) and..al.. in the 4.16 kV electrical system (E-BUS-NONSEG/SY). The in-scope metal-enclosed bus is of a rigid metallic construction, with flexible link attachmentsat the bus-to-switchgear connections. The license renewal evaluation of the non-segregated metal-enclosed bus includes only the bus sections between active electrical components. The distribution bus and the connections inside the enclosures of active components are inspected and maintained as pas of the active components, and are therefore excluded from AMR.

I, the 6.9 kV non-segregated bus associated with the start-up transformers, and I The 6.9 kV and 4.1QIkV non-segregated phase bus associated with the unit normal auxiliary transformers and the 25 kV iso-phase bus are not within the scope of license renewal. These metal-enclosed buses are excluded from the license renewal review because back-feed through the main transformers is not credited for station blackout recovery at Columbia, and these components do not perform any other license renewal function. There is no segregated metal-enclosed bus at Columbia.

The non-segregated phase metal-enclosed bus is enclosed within its own passive enclosure and is not part of an active component, such as switchgear, a load center, or a motor control center. Non-segregated phase bus (evaluated as metal-enclosed bus for license renewal) is electrical bus constructed with all phase conductors in a common metal enclosure without barriers (i.e., with only an air space) between the phases. The bus assembly is comprised of two parts: the portion associated with the electrical conductor (the bus bar and its connections) and the portion associated with the bus enclosure and supports. The bus enclosure and support assembly is evaluated as a structural commodity (see Section 2.4.13). The gaskets (elastomers) in the enclosure assembly (at the enclosure joints) are also listed as a structural commodity.

The function of a non-segregated metal-enclosed bus is to provide electrical connection to specified portions of an electrical circuit to deliver voltage and current. The internal bus supports also provide insulation. Non-segregated metal-enclosed bus is a passive, long-lived component. Therefore, non-segregated metal-enclosed bus meets the criteria of 10 CFR 54.21(a)(1) and is subject to AMR.

2.5.5.3 Switchyard Bus and Connections Switchyard bus is uninsulated, unenclosed, rigid electrical conductor used in plant switchyards and switching stations to connect two or more elements of an electrical power circuit. The switchyard bus which connects backup transformer E-TR-B to circuit breaker E-CB-TRB, and the switchyard bus between the 230 kV overhead line and Scoping and Screening Results Page 2.5-5 Jauay2010 '

[Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.0-1 Internal Environments Columbia Description Environment

• Air Air and moist air are defined to be air environments that contain some amount of

• Moist Air moisture or contaminants. This includes:

1) air for use in plant components before it has been dried (moisture content is enough to facilitate general corrosion of steel); or

2) prcGess air in OcRtions whore condens.ation, water, pooling*, or accumul~ation of contaminantc could occurF (moEisturo GEntcnt is enou1gh to 2 ~~~facilitate creViOe and pitting corsinin vaiuU eals, as Well G16 general4 corroSion Of Steel), or

) air-water interfaces where alternate wetting and drying can concentrate contaminants and become aggressive species for metal, or

4) air contained in the space above the air-water interface inside a component 00" that contains water.

These environments encompass the following NUREG-1 801 terminology:

• Moist Air

• Dried Air Dried air is compressed air that has been filtered, compressed and dried for use in

• Gas plant equipment. Compressed air that has not been dried is evaluated as Air.

Gas is a compressed gas such as carbon dioxide, Halon, hydrogen, nitrogen, Freon or other refrigeration gases. Such gases are received in bulk and are dry and free of contaminants, except when used in a manner that allows contact with water or condensation, in which case the gas becomes moist.

These environments encompass the following NUREG-1 801 terminology:

• Dried Air

• Gas

• Closed Cycle Includes treated water, as defined below, which is from and returns to a closed Cooling Water source (e.g., a tank) that is not open to the elements, and is used for cooling of

• Closed Cycle plant components. That is, demineralized water that may contain additives in a:

Cooling Water 1) closed cooling water system such as control room chilled water, fuel pool

>60 'C (140 *F) cooling, reactor closed cooling water, or residual heat removal; or

2) heat exchanger, cooler or other component in another system that is served by cooling water from a closed system.

These environments encompass the following NUREG-1801 terminology:

• Closed cycle cooling water

• Closed cycle cooling water >60 'C (>140 *F)

Aging Management Review Results Page 3.0-7 Janua.'20410 IAmendment 18EI

Columbia Generating Station License Renewal Application Technical Information 3.4.2.1.3 Condensate (Nuclear) System Materials The materials of construction for the subject mechanical components of the Condensate (Nuclear) System are:

• Cast austenitic stainless steel (CASS)

• Stainless steel

• Steel Environments The subject mechanical components of the Condensate (Nuclear) System are exposed to the following normal operating plant environments:

• Air-indoor uncontrolled

• Air-outdoor

• Condensation

• Moist air Soil

" Treated water Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Condensate (Nuclear) System:

• Cracking

• Loss of material

• Loss of pre-load Aging Management Programs The following aging management programs manage the aging effects for the subject mechanical components of the Condensate (Nuclear) System:

• Aboveground Steel Tanks Inspection 0 Bolting Integrity Program

• Buried Piping and Tanks Inspection Program

• BWR Water Chemistry Program Aging Management Review Results Page 3.4-4w,...,41,

[Amendment 18

Columbia Generating Station License Renewal Application Technical Information Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the Main Steam Leakage Control System:

• Bolting Integrity Program

• BWR Water Chemistry Program

• Chemistry Program Effectiveness Inspection

" External Surfaces Monitoring Program 3.4.2.1.6 Miscellaneous Drain System Materials The materials of construction for subject mechanical components of the Miscellaneous Drain System are:

• Stainless steel

• Steel Environments Subject mechanical components of the Miscellaneous Drain System are exposed to the following normal operating environments:

• Air-indoor uncontrolled

, Moit air

• Steam Aging Effects Requiring. Management The following aging effects require management for the subject mechanical components of the Miscellaneous Drain System:

• Cracking

• Loss of material

• Loss of pre-load Aging Management Review Results Page 3.4-7 Ja~wa.y204Q

[Amendment 18

Columbia Generating Station License Renewal Application Technical Information Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the Miscellaneous Drain System:

• Bolting Integrity Program

• BWR Water Chemistry Program

" Chemistry Program Effectiveness Inspection

• External Surfaces Monitoring Program

• Flow-Accelerated Corrosion (FAC) Program Supplemental PipinggTank lncpection 3.4.2.1.7 Reactor Feedwater System Materials The materials of construction for the subject mechanical components of the Reactor Feedwater System are:

• Stainless steel

• Steel Environments The subject mechanical components of the Reactor Feedwater System are exposed to the following normal plant operating environments:

• Air-indoor uncontrolled

• Treated water> 60 0C (140 0F)

Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Reactor Feedwater System:

• Cracking

• Loss of material

• Loss of pre-load Aging Management Review Results Page 3.4-8 JaR*u*.2G10

[Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-3 Aging Management Review Results - Condensate (Nuclear) System Aging Effect NUREG-RowMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 1 Item 2 Item Air-indoor Structural Stelincor Loss of 3.4.1-10 Bolting integrity Steel uncontrolled (External) pre-load pr-od2 Bolting Integrity VIII.H-5 3. B 11 Bolting Structural Steel Condensation Cracking Bolting Integrity N/A N/A H integrity (External) 12 Bolting Structural Steel Condensation Loss of Bolting Integrity VIII.H-10 3.4.1-integrity (External) material 28 13 Bolting Structural Steel Condensation Loss of Bolting Integrity N/A N/A H Hatn integrity (External) pre-load Boltin 3.4.1-4 C Heat St a _m.

Exchanger iresur L.

14 (shell), Main Pressure Steel (int-al Loss ofpiA9-.nk Condenser boundary (Internal) material COND-HX-9 BWR Water Heat Chemistry Exchanger Pressure Treated water Loss of Flow-Accelerated 3.4.1-15 (shell), Main Steel marI CorrosionVIII.E-35 C Condenser boundary (Internal) material Corrosion (FAC) 29 -

COND-HX-9 Heat Exchanger Pressure Treated water Loss of BWR Water 3.4.1-16 Condenserll)

Main boundary Steel (Internal) material Chemistry VIII.E-7 05 A COND-HX-9 J~a~:y4Q40 Aging Management Review Results Page 3.4-45 Page 3.4-45 Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-3 Aging Management Review Results - Condensate (Nuclear) System Aging Effect NUREG-RowMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 1 Item 2 Item Structural Stainless Air-indoor3.41-78 Valve Body uncontrolled None None VIII.I-10 41 A integrity 78 alveody Steel (External) 41 Structural Stainless Condensation Loss of External Surfaces 79 Valve Body integrity Steel (External) material Monitoring N/A NIA G Structural Treated water Loss of BWR Water . 3 .4.1-80 Valve Body integrity Steel (Internal) - material Chemistry VII0E-33 04 A Structural Treatedwater Loss of Chemistry Program 3.4.1-81 Valve Body integrity Steel (Internal) material Effectiveness VIII.E-33 04 A Inspection Structural Air-indoor Loss of External Surfaces 3.4.1-82 Valve Body Steel uncontrolled VIII.H-7 A integrity (External) material Monitoring 28 Structural Condensation Loss of External Surfaces 3.4.1-83 Valve Body integrity Steel (External) material Monitoring VIII.H-10 28,A Insert new rows 84 Insert new row Insert new rows 89 through 87 to Table 88 to Table and 90 to Table 3.4.2-3 as shown 3.4.2-3 as shown 3.4.2-3 as shown on page 3.4-53a on page 3.4-53b on page 3.4-53c Aging Management Review Results Page 3.4-53 -JWMZTy-201'0-

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-3 Aging Management Review Results - Condensate (Nuclear) System Aging Effect NUREG-RowMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 1 Item 2 Item Heat Exchanger Pressure Steam Loss of Chemistry Program 3.4.1-89 (shell), Main Effectiveness - VIII.B2-3 Condenser boundary (Internal) material Inspection COND-HX-9 Heat Exchanger Pressure Steam Loss of Flow-Accelerated 3.4.1-90 (shell), Main boundary Steel (Internal) material Corrosion (FAC) VIII.B2-4 29 C Condenser COND-HX-9 Aging Management Review Results Page 3.4-53c Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-4 Aging Management Review Results - Main Steam System Aging Effect NUREG-Row Component Intended Material Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 1 Item 2 Item 10 Manifold Pressure Aluminum Dried air None None VIII.1-1 3.4.1- A boundary (Internal) 44 0402 d

Pressure Air-indoor S Manifold boundary Aluminum uncontrolled None None N/A N/A G (External) 12 Moisture Pressure Steel Steam Loss of BWR Water VIII.B2-3 3.4.1- C Separator boundary (Internal) material Chemistry 37 Moisture Pressure Steam Loss of Chemistry Program 3.4.1-13 Separator boundary Steel (Internal) material Effectiveness VIII.2- 37

___________Inspection 14 Moisture Pressure Steel Steam Loss of Flow-Accelerated VIII.1B2-4 3.4.1-Separator boundary (Internal) mate*rial ý*rr 'ion (FAC) 29 Air-indoor BWR Wa 15 Moisture Separator Pressure Seaao boundary budrSteel uncontrolled m

RaterIa Lrno mtra MniString MonitoringI 2 cx[.Hn S V1III. B2-2 IVIIH- 3.4.1-8 A (External)A Structural Stainless MeiSt ai Loss of 9L " I/reN-A.

16 Orifice integrity Steel (Internal) material 3""

Structural 37 41 17 Orifice integrity integriy Stainless Steel Steel(External)

Air-indoor uncontrolled None None V4II.1-17 4 41 A

18 Piping Pressure Stainless Steam BWR Water VIII B21 3.4.1- A boundary Steel (internal) Cracking Chemistry 13 Aging Management Review Results Page 3.4-55 Jamendye 218 jAmendment 8

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-4 Aging Management Review Results - Main Steam System A AgingANUREG-Ro opnnneddAging Effect Management 1801 TableNoe Row Component Intended Material Environment Requiring A gi am 1801 Table Notes No. Type Function(s) Management Program Volume 2 Item I __ ____ 2 Item 36 Piping Pressure boundary Steel Air-indoor uncontrolled Loss of material Supplemental Piping/Tank VIII.H-7 3.4.1-28 E 0401 (External) Inspection Pressure Treated Loss of BWR Water 3.4.1-37 Piping boundary Steel water material Chemistry 04 (External) 38 Piping Pressure boundary Steel Treated water Loss of Chemistry Program Effectiveness VIII.B2-6 3.4.1-04 A (External) material Inspection S t r'-ct 'Jr l Up s ; L - 6e S pp-m e ta R4oIteamk S WA NA G 40 Piping Structural SteelSteam Loss of BWR Water VIII.2-3 3.4.1-integrity (Internal) material Chemistry 37 Structural Steam Loss of Chemistry Program 3.4.1-41 Piping integrity Steel (Internal) material Effectiveness VIII.B2-3 37 E Inspection 42 Piping Structural Steel Steam Loss of Flow-Accelerated VIII B24 3.4.1- A integrity (Internal) material Corrosion (FAC) 29 Structural Air-indoor Loss of External Surfaces 3.4.1-43 Piping integrity Steel uncontrolled material Monitoring 28 (External) materialMonitoring_ 28 44 Piping Structural Stainless M 9i6t-aam Loss of PipgN integrity Steel (Internal) materia NN Steam [BWR Water Chemistry VIII.B2-2 3.4 1-37 1 Aging Management Review Results Page 3.4-58 AmendenY1 A,ýmendment 181

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-4 Aging Management Review Results - Main Steam System Aging Effect NUREG-Row Component Intended Material Environment Requiring1801 Table No. Type Function(s) Management Program Volume 1 Item 2 Item Pressure Steam Loss of Chemistry Program 3.4.1-54 Strainer Body boundary Steel (Internal) material Effectiveness VIII.B2-3 37 E Inspection 55 Pressure Steel Steam Loss of Flow-Accelerated VIII 824 3.4.1- A Strainer Body boundary (Internal) material Corrosion (FAC) 29 Pressure Air-indoor Loss of External Surfaces 3.4.1-56 Strainer Body boundary Steel uncontrolled material Monitoring 28 (External)

Gray Loss of Selective Inspection Leaching N/A N/A G 57 Trap Body Structural integrity Iron Cast Moist air (Internal) material G~a G StFUt~a e~staii 1=96 9Suppleme~ta4 g T,8 vap i (!ReMal) Faater' Ppi.Pi" a4 NIA WA..

59 Structural Gray Cast Steam Loss of BWR Water VIII.B2-3 3.4.1- A Trap Body integrity Iron (Internal) material Chemistry 37 Structural 60 Tray BodyGray Cast Steam SEffectiveness Loss of Chemistry Program VIII.B2-3 3.4.1-37 E 60 Trap Body integrity Iron (Internal) material Inspection 61 Trap Body Structural Gray Cast Steam Loss of Flow-Accelerated VIII.824 3.4.1- A integrity Iron (Internal) material Corrosion (FAC) 29 Gray Loss of Selective Leaching N/A N/A G Iron Cast 62 Trap Body Structural Steam material Inspection integrity (Internal)

Aging Management Review Results Page 3.4-60

[Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-4 Aging Management Review Results - Main Steam System Aging Effect NUREG-Row Component Intended Material Environment Requiring1801 Table No. Type Function(s) Management Program Volume I Item 2 Item Air-indoor Structural Gray Cast uncontrolr Loss Los of ofa External Extrna Surfaces Surfacesle VIII.H-7 3.4.1-28 63 Trap Body integrity Iron (External) material Monitoring 28 Strutral Moist4i L-ess-p4ppnemegt-a 44 Ta, B,,, Steel ( NA NA G

1. • Peetýe 65 Trap Body Structural Steel Steam Loss of BWR Water VIII.B2-3 3.4.1- A integrity (Internal) material Chemistry 37 66 Trap Body Structural integrity Steel Steam (Internal) Loss of material Chemistry Program Effectiveness VIII.B2-3 3.4.1-37 Inspection 67 Trap Body Structural Steel Steam Loss of Flow-Accelerated VIII B24 3.4.1- A integrity (Internal) material Corrosion (FAC) 29 Structural Air-indoor Loss of External Surfaces 3.4.1-68 Trap Body integrity Steel uncontrolled material Monitoring VIII.H-7 28 A (External) mea Ming Pressure Stainless Air-indoor3.4.1- A 69 Tubing uncontrolled None None VIiI.l-10 41 A boundary 69 Tubing Steel (Internal) 41 0410 70 Tb Pressure Stainless Dried air None None V1I1.1-12 3.4.1- A uing boundary Steel (Internal) 44 0402 71 Tbubing Pressure boundary Stainless Steel Steam (Internal) Cracking BWR Water Chemistry Vll:B2l 3.4.1-13 A Aging Management Review Results Page 3.4-61 4aRmenFy20n1 jAmendment 18]

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-4 Aging Management Review Results - Main Steam System Aging Effect NUREG-Row Component Intended Material Environment Requiring1801 Table No. Type Function(s) Management Program Volume 1 Item 2 Item Pressure Steam Loss of Chemistry Program 3.4.1-97 Valve Body boundary Steel (Internal) material Effectiveness VIII.B2-3 37 E.

Inspection 98 Valve Body Pressure Steam Loss of Flow-Accelerated VIII.B2-4 3.4.1- A 9 Vav boundary (Internal) material Corrosion (FAC) 29 Pressure Air-indoor Loss of External Surfaces 3.4.1-99 Valve Body boundary Steel uncontrolled material Monitoring 28 (External) 440 .... ... Mest- L- 0 P9e-e NA WAG 101 Valve Body Structural Steel Steam Loss of BWR Water VIII B2-3 3.4.1- A integrity (Internal) material Chemistry 37 102 Valve Body Structural integrity Steel Steam (Internal) Loss of material Chemistry Program Effectiveness VIII.B2-3 3.4.1-102 interityInspection alveBody 103 Valve Body Structural Steel Steam Loss of Flow-Accelerated VIII B24 3.4.1-integrity (Internal) material Corrosion (FAC) 29 Structural Air-indoor Loss of External Surfaces 3.4.1-104 Valve Body integrity Steel uncontrolled material Monitoring 28 (External) matriaMnitrin_2

"--]insert new rows 105-110 from Page 3.4-65a Aging Management Review Results Page 3.4-65 FAmendment 18

Columbia Generating Station License Renewal Application Technical Information Insert A for Paae 3.4-65 Aging Management Review Results Page 3.4-65a Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-6 Aging Management Review Results - Miscellaneous Drain System Row Component Intended Aging Effect NUREG-oMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 2 Item 1 Item Structural Stainless ... 06 a Loss of d rNrn4a 10 Orifice integrity Stee (Internal) material ./ J A SteamVI .B2-2 3 .4.1-37 11 Orifice Structural Stainless Air-indoor uncontrolled None None VII.1-10

. 1 A integrity Steel (External) BWR Water Ch1 4 Stainless Steam C BWR Water 3.4.1-12 Orifice Throttling Steel (Internal) Cracking Chemistry 13 13 Orifice Throttling Stainless Steel Steam Chemistry Program 3.4.1-(internal) Cracking Effectiveness VIII.B2-1 3 A Inspection 13 14 Orifice Throttling Stainless Steam Loss of BWR Water VIII B22 3.4.1- A Steel (Internal) material Chemistry 37 Stainless Steam Loss of Chemistry Program 341-15 Orifice Throttling Effectiveness VIII.1B2-2 341 E Steel (Internal) material Inspection 37 16 Piping Pressure Steel Steam Loss of BWR Water VlllC3 3.4.1- A boundary (Internal) material Chemistry 02 Pressure Steel Steam (internal) Loss of material Chemistry Program Effectiveness VIII.C-3 3.4.1-02 17 Piping boundary SInspection 18 Piping Pressure Steel Steam Loss of Flow-Accelerated VlllCS 3.4.1- A boundary (Internal) material Corrosion (FAC) 29 Aging Management Review Results Page 3.4-70 jAmendment 18

Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-6 Aging Management Review Results - Miscellaneous Drain System Aging Effect NUREG-Row ComponentMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 1 Item 2 Item Pressure Air-indoor Loss of External Surfaces 3.4.1-19 Piping boundary Steel uncontrolled material Monitoring 28 (External) 20 P.i Pressure Stainless Steam BWR Water VIII 82-1 3.4.1- A iping boundary Steel (Internal) Cracking Chemistry 13 21 Piping Pressure Stainless Steam Cracking Chemistry Program Effectiveness VIII.B2-1 3.4.1-13 A 21 P gboundary Steel (Internal) Inspection 22 Piping Pressure Stainless Steam Loss of BWR Water VIII 822 3.4.1-37 A boundary Steel (Internal) material Chemistry Pressure Stainless Steam Loss of Chemistry Program 3.4.1-boundary Steel (Internal) material Effectiveness VIII.B2-2 37 2 Piiguncontrolle'-

Pressure Stainless uncont°°r W ,oe I "140T- VIII.1-10 3.4.1-* A boundary Steel ( Ext r nal1) -- ['- 4 L -111 Strctra of &Wfpleme~tal 25 Piping Structura ........ a;,*rF Los.s of PipngA I,,,,,A, integrity (Internal) material o ""

Air-idoor3.4.1-021 Structural Air-indoor Loss of External Surfaces 6 -4.1-integrity Steel uncontrolled materialVIII.H-7M28A (External) 27 Strainer Bd2 r Pressure boundary Stel e Steam (Internal) Loss of material BWR Water Chemistry VIlC3 3.4.1-02 A Aging Management Review Results Page 3.4-71 FAmendment 181

Columbia Generating Station.

License Renewal Application Technical Information Table 3.4.2-6 Aging Management Review Results - Miscellaneous Drain System Aging Effect NUREG-RowMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) me n age meng Program Volume I Item Management 2 Item Pressure Steam Loss of Effectiveness Chemistry Program VIII.C-3 02 3.4.1-28 Strainer Body boundary Steel (Internal) material Inspection _____0 _

29 Strainer Body Pressure Steel Steam Loss of Flow-Accelerated VIII.C-5 34.1- A boundary (Internal) =n (FAC) 29 Air-indoor BWR Water Chemistry 30 Strainer Pressure uncontrolled O ernal Surfaces VIII.H-7 3.4.1- A boundary SE lt material Monitoring VIII.C-3 28 31 Strainer Body integrity Structural Steel StelMes4ai (Internal) material LssofNL, /

3.4.1-02 32 Strainer Bd Structural Airl indor Loss of External Surfaces 3.4.1- A oy integrity Steel uncontrolled material Monitoring VIII.H-7 28 (External) 1_____

33 Valve Body Pressure Steel Steam Loss of BWR Water VIII.C-3 3.4.1- A boundary (Internal) material Chemistry 02 Pressure Steam Loss of Chemistry Program 3.4.1-34 Valve Body Peure Steel Steam Lossrofl Effectiveness VIII.C-3 02A boundary .(internal) material Inpcto Inspection 35 Valve Pressure Steel Steam Loss of Flow-Accelerated VIIICS 3.4.1- A dy boundary (Internal) material Corrosion (FAC) 29 Pressure Air-indoor Loss of External Surfaces 3.4.1-36 Valve Body boundary Steel uncontrolled material Monitoring 28 I (External) I I I Aging Management Review Results Page 3.4-72 JenmeFyn 148 jAmendment 18]

Columbia Generating Station License Renewal Application Technical Information Aging Management Review Results Page 3.4-73 Jamnday 2t1 jAmendmen18

Columbia Generating Station License Renewal Application Technical Information Insert A for Page 3.4-73 Table 3.4.2-6 Aging Management Review Results - Miscellaneous Drain System Aging Effect NUREG-RowMaterial Environment Requiring Aging Management 1801 Table Notes No. Type Function(s) Management Program Volume 2 Item I Item 39 Orifice Structural Stainless Steam Loss of Chemistry Program Effectiveness VIII.B2-1 3.4.1- A integrity Steel (Internal) material Inspection 13 40 Orifice Structural Stainless Steam BWR Water VIII.822 3.4.1- A integrity Steel (Internal) Cracking Chemistry' 37 41 Orifice Structural integrity Stainless Steel Steam (internal) Cracking Chemistry Program Effectiveness VIII.B2-2 3.4.1-Inspection 42 Piping Structural integrity Steel Steam (Internal) Loss of Material Chemistry Program Effectiveness VIII.C-3 3.4.1-02 42 PpinginterityInspection 43 Piping Structural Steel Steam Loss of Flow-Accelerated VlllC5 3.4.1- A integrity (Internal) Material Corrosion (FAC) 29 Structural Steam Loss of Chemistry Program 3.4.1-44 Strainer Body integrity Steel (Internal) Material Effectiveness VIII.C-3 02 Inspection 45 Strainer 4B Structural Steam Loss of Flow-Accelerated 3.4.1-integrity Steel (Internal) Material Corrosion (FAC) VIII.C-5 29 A Aging Management Review Results Page 3.4-73a Amendment 18

Columbia Generating Station License Renewal Application Technical Information Table 4.1-1 replace with (ii)

Time-Limited Aging Analyses Results of TLAA Evaluation by Category 1CF54.21(c)(1) 10 CFR1542(c() R LRA Pa agraph Section Reactor Vessel Neutron Embrittlement 1 4.2 Neutron Fluence .4 ; TL1A A 4.2.1 Upper Shelf Energy (USE) (ii) 4.2.2 Adjusted Reference Temperature (ART) (ii) 4.2.3 Pressure-Temperature (P-T) Limits (iii) 4.2.4 Reactor Vessel Circumferential Weld Examination (ii) 4.2.5 Relief Reactor Vessel Axial Weld Failure Probability (ii) 4.2.6 Metal Fatigue 4.3 Reactor Pressure Vessel Fatigue Analyses (iii) 4.3.1 Reactor Vessel Internals Fatigue Analyses (iii) 4.3.2 Reactor Coolant Pressure Boundary Piping and (iii) 4.3.3 Component Fatigue Analyses Non-Class 1 Component Fatigue Analyses (i) 4.3.4 Effects of Reactor Coolant Environment on Fatigue (iii) 4.3.5 Life of Components and Piping Environmental Qualification of Electrical Equipment (iii) 4.4 Concrete Containment Tendon Prestress Not a TLAA 4.5 Containment Liner Plate, Metal Containments, and Penetrations Fatigue 4.6 Analyses ASME Class MC Components (i) 4.6.1 Downcomers (i) 4.6.2 Safety Relief Valve Discharge Piping (i) 4.6.3 Diaphragm Floor Seal (i) 4.6.4 ECCS Suction Strainers (i) 4.6.5 Other Plant-Specific Time-Limited Aging Analyses 4.7 Reactor Vessel Shell Indications (iii) 4.7.1 Sacrificial Shield Wall (ii) 4.7.2 Main Steam Line Flow Restrictor Erosion Analysis (ii) 4.7.3 Time-Limited Aging Analyses Page 4.1-3 j~enment 18

14.2.1 Neutron Fluence~ I Columbia Generating Station License Renewal Application Technical Information As such, the beltline definition for the period of extended operation includes the lower shell, lower-intermediate shell, associated vertical (longitudinal) welds, the girth (circumferential) weld that connects the lower and lower-intermediate shells, and nozzle-"--J N6ý --- and ýN 2ý.I Disposition: Neutron fluence n.t...

Replace with "has been projected to the end of the period of extended operation".

Table 4.2-1 '

RPV Beltline Fluence Values at 54 EFPY

- PLATES: Identification OT fluence 1/4T fluence

__(I.D.) No. (n/cm 2) (n/cm 2)

Lower Shell Mk 21-1-1, 4.78E+17 2.71 E+1 7 Mk 21-1-2, Mk 21-1-3, Mk 21-1-4 Lower-I ntermediate Shell Mk 22-1-1, 1.17E+18 8.10E+17 Mk 22-1-2, Mk 22-1-3, Mk 22-1-4 NOZZLES:

N6 (RHR / LPCI) Mk 64-1 6.49E+17 4.48E+17 (3 nozzles)

WELDS:

Lower Vertical BA, BB, 4.78E+17 2.71E+17 (Axial / Longitudinal) BC, BD Lower-Intermediate Vertical BE, BF, 1.17E+18 8.10E+17 (Axial / Longitudinal) BG, BH Lower to Lower-Intermediate Girth AB 4.78E+17 3.3E+17 (Circumferential)

Insert row for Nozzles N12 from Insert A on Page 4.2-3a Time-Limited Aging Analyses Page 4.2-3 Jamendment ji F~mndment 18 18

1A.1.3.1.1 Neutron Fluence Columbia Generating Station License Renewal Application Technical Information Beltline Evaluation For the extended operating period, ferritic materials for vessel beltline shells, welds, and assembly components are required to be evaluated for neutron irradiation embrittlement if high energy neutron, fluence is greater than a threshold value of 1E+17 n/cm 2 (E >1 MeV) at the end of the 60 years. The only vessel assembly items, other than the shells and welds of the beltline region that would experience neutron fluence greater than 1E+17 n/cm 2 during the period of extended operation are instrumentation nozzle N12 and residual heat removal/low pressure coolant injection (RHR/LPCI) nozzle N6.

-IRstrumeRtatien-Rez-le-N-1-2-has-a-thiGkRess-less-than-2-:§-inehes-aRd-theSefeFe-dees8-et

.FequiFe-a-ffaeture-teughness-evaluatien-per-fASME-6ode-Appendix-sTSection-62223-

-Nozzle-N6-is-evaluated-for-A-RT-below.--T-he-ART-ff-tfh is-n8zle-is-less-thaR-that-feF-the-hiighest-weld-and-plate.--eonsequentlynozzle-N 6-is--not-the-limiting-material-for-the

-ves~seland-4hus-is-not-a-beltline-eemponent.--However ,as-noz-zle-NS-was-evaluated-fer AR-T-it-meets-the-definition-of-a-beltline-component-per- GFR-5TAppendix-G- /

The beltline definition for the period of extended operation includes the lower shell (Course #1 / Ring #21), lower-intermediate shell (Course #2 / Ring #22), associated vertical (longitudinal) welds, the girth (circumferential) weld that connects the lower and lower-intermediate shells, and nozzle Disposition 2 Neutron fluence n T , it iG s timo-Ilmitod t u " arneus ,nenutr-n

. . UReplace with Insert A from page A-28a.

/ .1.3.1.2 Upper Shelf Energy Evaluation 10 CFR 50 Appendix G requires the upper shelf energy (USE) of the vessel beltline materials to remain above 50 ft-lb at all times during plant operation, including the effects of neutron radiation. If USE cannot be shown to remain above this limit, then an equivalent margin analysis (EMA) must be performed to show that the margins of safety against fracture are equivalent to those required by Appendix G of Section XI of the ASME Code.

The initial (unirradiated) USE is not known for all the Columbia vessel plates and welds.

For those plates and welds for which the initial USE is known, USE was projected using Regulatory Guide 1.99, Revision 2 methods. For the vessel plates and welds for which the initial USE is not known, USE equivalent margin analyses were performed using the Boiling Water Reactor Owners Group (BWROG) equivalent margin analysis (EMA) methodology. Results from the testing and analysis of surveillance materials were used in the EMA analyses.

Replace with "has been projected to the end of the period of extended operation".

Final Safety Analysis Report Supplement Page A-28 L~e ment W 18

Infra-red window installation at bolted connections of the in-scope bus will be completed prior to the initial thermography inspection, discussed Columbia Generating. Station above. License Renewal Application Technical Information Table A-I Columbia License Renewal Commitments FSAR Supplement Enhancement o

Commitment Splecet or Item Number Location Implementation

\(LRA App. A) . Zchedble

40) Metal-Enclosed The Metal-Enclosed Bus Program is a new program. A.1.2.40 Implementation Bus Program The Metal-Enclosed Bus Program is an inspection program that prior to the period detects degradation of metal-enclosed bus within the scope of of extended license renewal. The program provides for the visual inspection of operation.

interior sections of bus, and an inspection of the elastomeric seals at Then ongoing.

the joints of the duct sections. The program also makes provision for thermographic inspection of bus bolted connections.

The thermography portion of the program will be performed once every 10 years, with the initial inspections to be performed prior to the period of extended operation. The visual inspection portion of the program will also be performed once every 10 years, with the first inspections to be performed prior to the period of extended operation.

41) Monitoring and The Monitoring and Collection Systems Inspection is a new activity. A.1.2.41 Within the 10-Collection The Monitoring and Collection Systems Inspection detects and year period prior

• Systems characterizes the condition of materials at the internal surfaces of to the period of Inspection subject mechanical components that are exposed to equipment or extended area drainage waterand other potential contaminants and fluids. operation.

The inspection provides direct evidence as to whether, and to what extent, the relevant effects Of aging have occurred.

Final Safety Analysis Report Supplement Page A-57 J~ment1mV-

Columbia Generating Station Iicense Renewal Application Technical Information Insert A to Page A-61 Tha Q Ianrn l Cli

('1 1 Dmninn Drrnrm ic a nals an nnmnanmnn nrnnram The Small Rore Class 1 DPing Program will detfecnt c-harar-terize cracking Of small hbore Class 1 piping components that are exposed to rear-tr coolant. his *eriodi program will prnovide physical evide*nr-e as to whether, and- to wA.4haft extent, cracking due to SCC or to therml o r mechanical loading has occuwrred insmall bore Class 1 piping GQMPOM~nts. It will1 also Iverify, by isetosfor cracking, that reduction of fracture toughness due tQ o thermal ermbrittlement requires no dditional aging management for small Class 1 cast austenitic stainless steel valve bodies. The Small Bore Class 1 PiingA Program Will be a conditn monitoring program" With no actions to prevent Or mitogate aging effects. The prgram ill incr-lude visual and volume-tric inspection of a re~resentative sam£le of small bore ClassR IiDinQ. includin bu-tt Welds and socket Insert B to Page A-61 Implemented prior to the period of extended operation. Inspection activities will start during the fourth 10-y ear inservice inspection interval, then ongoing.

The Small Bore Piping Program will inspect a sample of ASME Code Class 1 piping LT NPS 4 to GE to NPS 1. The inspection will include 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, Columbia may take credit for each weld destructively examined equivalent to having volumetrically examined two welds.

Page A-61a Safety Analysis Final Safety Final Report Supplement Analysis Report Supplement Page A-61 a ---- I Amendment _7 jAmendment 18 -ý7

Columbia Generating Station License Renewal Application Technical Information Insert A into page A-68a Enhancement FSAR Supplement Commitment Location or Item Number (LRA App. A) Implementation Schedule

62) Service Level 1 The Service Level 1 Protective Coatings A.1.2.55 Ongoing Protective Coatings Program is an existing program that will be Program continued for the period of extended operation.

63) Inservice Inspection Ultrasonic Testing (UT) examination of A.1.2.33 When demonstrated (ISI) Program creviced shroud support plate access hole acceptable UT cover weld, top hat configuration, will be technique is available.

performed once a demonstrated acceptable UT technique becomes available. Then ongoing.

64) Inservice Inspection Verify leakage is not entering the annular N/A During the fourth (ISI) Program - IWE space between the containment vessel and Inservice Inspection the concrete shield wall from the outer (ISI) interval prior to the refueling bellows seal. Inspection of the period of extended portions of the outer containment vessel operation (PEO) and shell made accessible by opening all eight again in the fifth ISI inspection ports in the containment vessel at interval after entering 570 foot elevation will be performed to check the PEO.

for evidence of leakage. These inspections will be performed during a refueling outage while the reactor cavity is flooded.

FinAlnsert y Aay65 from A-68c for Page Amendment 18 Final Safety Analysis Report Supplement Page A-68b Amendment F1 8 ýý 4-7 45

7ý"

Columbia Generating Station License Renewal Application Technical Information Insert A into Paae A-68b FSAR Enhancement Commitment Supplement or Item Number Location Implementation (LRA App. A) Schedule

65) ISI Columbia will prepare and submit the ISI Program Plan for the LRA Appendix Upon submittal fourth 10-year interval no later than 2015. (The third 10-year B of the ISI ISI interval extends from December 2005 until December, Program Plan 2015.) The small bore piping program will be included in the for the fourth fourth 10-year interval ISI program plan as an augmented 10-year interval inspection. The locations to be inspected, the sample size, the inspection methodology will be included in the program plan.

Final Safety Analysis Report Supplement Page A-68c Amendment 18

Columbia Generating Station License Renewal Application Technical Information B.2.40 Metal-Enclosed Bus Program Program Description The Metal-Enclosed Bus Program will manage the aging of metal-enclosed bus within the scope of license renewal. The program provides for the periodic visual inspection of metalenclosed bus, along,'with the use of thermography, in order to determine if,age-related degradation is occurring. The program will provide reasonable assurance that the electrical components will perform their intended functions for the period of extended operation.

The Metal-Enclosed Bus Program is a new aging management program that will be implemented prior to the period of extended operation, with the first inspection to be completed prior to the end of the current operating license, and with both the thermography portion and the visual inspection portion to be performed every 10 years thereafter. 4.16 kV The metal-enclosed bus addressed by this program includes the non-segregated bus associated with transformer E-TR-S (the 230-kV startup auxiliary power transformer).

NUREG-1801 Consistency The Metal-Enclosed Bus Program is a new Columbia program that will be consistent with the 10 elements of an effective aging management program, as described in NUREG-1801,Section XI.E4, "Metal-Enclosed Bus," with an exception.

Exceptions to NUREG-1801 Program Elements Affected:

• Parameters Monitored or Inspected The Metal-Enclosed Bus Program will perform the inspection of the various bus joints, seals, and gaskets when the bus assembly covers are removed for inspection of the internal components, rather than the Structures Monitoring Program (as listed in NUREG-1801 item VI.A-12). The Structures Monitoring Program will perform the inspection of the bus assembly external surfaces and the bus assembly structural supports.

Aging Management Program Elements The results of an evaluation of each program element are provided below.

• Scope of Program Aging Management Programs Page B-155 2 FAZm'endment 1-8

Columbia Generating Station License Renewal Application IB'2"40 Technical Information The Metal-Enclosed Bus Program is credited with detecting aging effects for in-scope metal-enclosed bus. The in-scope bus is limited to non-segregated metal-enclosed bus in the-6.9-W.Vand 4.16-kV electrical systems associated with the off-site power supply (via transformer E-TR-S).

• Preventive Actions The Metal-Enclosed Bus Program is an inspection program; no actions are taken to prevent or mitigate aging degradation.

• Parameters Monitored or Inspected The Metal-Enclosed Bus Program will inspect bus insulation for anomalies, such as embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. The internal bus enclosure will be inspected for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. The internal bus supports (i.e., internal to the enclosure) will be inspected for structural integrity and any sign of.cracks.

The Metal-Enclosed Bus Program will inspect a sample of bus bolted connections via thermography for signs of loose connections. The in-scope bus will be checked from the exterior with the bus energized to provide gross detection of circuit hot spoti.

The Metal-Enclosed Bus Program will inspect the bus joints, seals, and gaskets when the assembly covers are removed for inspection of the internal components.

• Detection of Aging Effects The Metal-Enclosed Bus Program will utilize thermography to check the bolted connections in the non-segregated metal-enclosed bus that is within the license renewal scope. The thermography inspection will be performed for representative portions of the in-scope non-segregated metal-enclosed bus.

The Metal-Enclosed Bus Program also includes visual inspection of the internal bus enclosure, bus insulation, and internal bus supports. The bus enclosure will be inspected for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. The bus insulation will be inspected for anomalies, such as signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation. The internal bus supports (internal to the enclosure) will be inspected for structural integrity and signs of cracking. The elastomers used to seal the bus enclosure assembly will be inspected for embrittlement, cracking, loosening, flaking, peeling, and other indications of aging degradation.

Both the thermography inspection and the visual inspections will be performed at least once every 10 years, with the first inspections to be completed withi, the 10 ye.--peiied.prior to the end of the current operating license.

Aging Management Programs Page 8-156 -- January-2Ol 0-IAmendment

1B.2.49 Small Bore Piping Program I

Columbia Generating Station License Renewal Application Technical Information Insert A to Paae B-187 The Small Bore Class 1 Piping Program will detect and characterize cracking of small bore, less that 4 inches nominal pipe size, Class 1 piping components (piping, fittings, branch connections, and valve bodies) that are exposed to reactor coolant. This periodic program will provide physical evidence as to whether, and to what extent, cracking due to SCC or to thermal or mechanical loading has occurred in small bore Class 1 piping components. It will also verify, by inspections for cracking, that reduction of fracture toughness due to thermal embrittlement requires no additional aging management for small bore Class 1 cast austenitic stainless steel valve bodies. The Small Bore Class 1 Piping Program will be a condition monitoring program with no actions to prevent or mitigate aging effects.

While the ASME Code does not require volumetric examination of Class I small bore piping, the Small Bore Class 1 Piping Program includes visual and volumetric inspection of a representative sample of small bore Class 1 piping components; the sample will include butt welds and socket welds, and will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Actual inspection locations will be based on physical accessibility, exposure levels, NDE techniques, and locations identified in NRC Information Notice 97-46. Volumetric examinations (including destructive and/or nondestructive techniques) will be performed by qualified personnel following procedures that are consistent with Section XI of the ASME Code and 10 CFR 50, Appendix B. R with Insert A from Page B-187b In scope components will be grouped ,ito populations based on component type, material and environment. Sa..le..,... o- 6.. 0%of each popl..o

. , -.

welds) with a mini mum of one location and a maximum of twent; locations; the socket weld sample will in.lud. thrcc locations. 100% of each sample will be inspected each 10-year ISI interval, with the breakdown of inspections between outages within the interval per ASME Section XI, Subsection IWB, Program B.

If a qualified non-destructive volumetric examination technique does not become available for socket welds, destructive examination will be conducted. Opportunistic destructive examination will be performed when socket welds are removed from service for other considerations, such as plant modifications. If socket welds do not become available on opportunistic bases prior to the scheduled inspections within the 10-year interval, then socket welds will be selected for planned destructive examinations.

Unacceptable inspection findings will be evaluated by the Columbia corrective action process. The evaluation of indications will include determining the extent of condition by the expansion of the sample size.

Aging Management Programs Page B-187a Ame*...ent 7 4 mndet 8

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-1 87a The sample population criteria will use the guidance given in NUREG-1801, Revision 2,Section XI.M35. The Small bore Piping Program will inspect a sample of ASME Code Class 1 piping less than NPS 4 and greater than or equal to NPS 1. The inspection will include 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, Columbia may take credit for each weld destructively examined equivalent to having volumetrically examined two welds.

Amendment 18 Management Programs Aging Management Programs Page B-1 87b Page B-i 87b Amendment 18

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-189 The Small Bore Class 1 Piping Program will perform visual and volumetric inspection of a representative sample of small bore Class 1 piping components, including butt welds and socket welds, and will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin. Actual inspection locations will be based on physical accessibility, exposure levels, NDE techniques, and locations identified in NRC Information Notice 97-46.

Replace with Insert A from Pa.qe B-189b In scope components will be grouped into populations based on component type, material and environment. Sample iz-,Awil; be 10% of each p.pulation (ex-ept,,ock.t w..da) ...-ith mnu" of o-n loction and a maximum of twenty loctin; . thsGsOCk

... d smp.... will in.lud. th'c" locations. 100% of each sample will be inspected each 10-year ISI interval, with a breakdown of inspections between outages within the interval per ASME Section XI, Subsection IWB, Program B. Inspections will start during the fourth 10-year interval, which begins prior to the period of extended operation.

Volumetric examinations (including destructive and nondestructive techniques) will be performed by qualified personnel following procedures that are consistent with Section XI of the ASME Code and 10 CFR 50, Appendix B. If a qualified non-destructive volumetric examination technique does not become available for socket welds, destructive examination will be conducted. Opportunistic destructive examination will be performed when socket welds are removed from service for other considerations, such as plant modifications. If socket welds do not become available on opportunistic bases prior to the scheduled inspections within the 10-year interval, then socket welds will be selected for planned destructive examinations.

Insert B to Page B-189 Unacceptable program findings will be evaluated, tracked, and trended by the Columbia corrective action program. Extent of condition will be determined by the expansion of the sample size as called for by the ASME Code,Section XI, Subsection IWB-2400.

Insert C to Paae B-189 Acceptance criteria will be in accordance with the ASME Code, Section Xl, Subsection IWB-3100. The evaluation of indications will include determining the extent of condition by the expansion of the sample size as called for by the ASME Code,Section XI, Subsection IWB-2400.

Aging Management Programs Page B-189a LfA-mendment 18

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B.189a The sample population criteria will use the guidance given in NUREG-1801, Revision 2,Section XI.M35. The Small bore Piping Program will inspect a sample of ASME Code Class 1 piping less than NPS 4 and greater than or equal to NPS 1. The inspection will'include 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, Columbia may take credit for each weld destructively examined equivalent to having volumetrically examined two welds.

Amendment 18 Aging Management Programs Aging Management Programs Page B-189b Page B- 1 89b Amendment 18