GO2-11-187, Response to Request for Additional Information License Renewal Application

Response to Request for Additional Information License Renewal Application

ML11325A067
Person / Time
Site:	Columbia
Issue date:	11/17/2011
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-11-187
Download: ML11325A067 (5)

Text

Alex L. Javorik ENERGY Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-2354 aljavorik@ energy-northwest.com November 17, 2011 G02-11-187 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"

3) Letter dated November 8, 2011, NRC to BJ Sawatzke (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application Regarding Fire Water and Open Cycle Cooling Aging Management Programs (TAC NO. ME 3058)," (ADAMS Accession No. ML11305A157)

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. No new or revised commitments are included in this response.

If you have any questions or require additional information, please contact John Twomey at (509) 377-4678.

3ý(L~k

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, AL Javvo k Vice President, Engineering

Attachment:

Response to Request for Additional Information 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 AD Cunanan - NRC NRR (w/a)

D Doyle - NRC NRR (w/a)

MA Galloway - NRC NRR RR Cowley - WDOH

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"

(ADAMS Accession No. ML11305A157)

RAI (Follow-up) SAMA FL-06R-1

Background:

The response to the request for additional information (RAI) severe accident mitigation alternative (SAMA) FL-06R, dated September 29, 2011, states that the piping segments that are under the scope of SAMA FL-06R include fire protection system piping which is age managed by the Fire Water aging management program (AMP), and plant service water and standby service water piping which are age managed by the Open Cycle Cooling Water AMP. The RAI response also states that the SAMA candidate uses risk importance measures to provide insights to identify in-scope piping sections in these three systems that are. more important to reducing the core damage frequency (CDF) contribution. The RAI response further states that both aging management programs include non-destructive examination methods to monitor for loss of material which, when performed, will reduce the frequency of pipe-break initiating events for these systems and thus reduce the CDF. The response states that, "Final determination of the AMP testing and inspection locations will use plant experience and engineering evaluations to identify the most susceptible piping sections, as well as risk importance for selection of the testing frequency and locations."

Issue:

The staff reviewed LRA Section B.2.26 and SER Section 3.0.3.2.9 for the Fire Water program; and license renewal application (LRA) Section B.2.42 and safety evaluation report Section 3.0.3.2.17 for the Open Cycle Cooling Water program and found no evidence that risk insights will be utilized in addition to plant experience and engineering evaluations to identify the most susceptible piping sections for inspections.

Request:

Revise LRA Sections B.2.26 and B.2.42 to state that risk insights will be utilized in addition to plant experience and engineering evaluations to identify the most susceptible piping sections for inspections, or state the basis for how the staff can conclude that the programs, when implemented, will utilize risk insights as an input to selecting inspection locations, or state how (e.g., specific program(s) and dates of implementation) this SAMA has been implemented independently of reliance on either the Fire Water AMP or the Open Cycle Cooling Water AMP.

If full implementation has not occurred, state a commitment to implement this change prior to the period of extended operations.

State whether this potential SAMA would have been screened out in Phase I as

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 3 already implemented if it had been discovered with the current state of program implementation.

Energy Northwest Response:

Prior to submittal of the license renewal application, moderate and large piping breaks in certain sections of the Service Water (SW), Plant Service Water (TSW), and Fire Protection (FP) systems piping were identified as significant contributors to the core damage frequency (CDF) in the Energy Northwest (EN) Probabilistic Safety Assessment (PSA) during upgrade to meet Regulatory Guide 1.200 Revision 2 requirements for internal events and flooding. As such, in accordance with EN procedures, this issue was entered into the corrective action program. The corrective action program evaluated whether periodic non-destructive examination (NDE) and inspection activities currently existed for the piping sections that significantly contributed to flooding risk, and whether the scope and frequency were sufficient to credit in the PSA. Corrective actions were initiated to make required changes. Subsequent to this, severe accident mitigation alternative (SAMA) candidate FL-06R was established during the SAMA sensitivity study, since the importance values of the initiating events in these lines were significantly high enough to warrant consideration of a SAMA candidate.

During the timeframe when SAMA FL-06R was being evaluated and eventually determined to be cost effective, the corrective action plan to address flooding risks was completed. Periodic NDE measurements and inspections are being performed on the sections of piping that pose significant risk for flooding in the PSA. This is being accomplished under the Preventive Maintenance Optimization Living Program. The table below includes specific preventive maintenance activities and dates of implementation. SAMA FL-06R has been implemented independently of reliance on either the Fire Water aging management program or the Open Cycle Cooling Water aging management program.

Based on the current state of the Preventive Maintenance Optimization Living Program with respect to the scope and frequency of NDE and inspections for the SW, TSW, and FP systems, SAMA FL-06R would now screen out in Phase 1 as already implemented at Columbia Generating Station.

PMID Description Implementation 08/19/97 23134-01 Division 1 Service Water Wall Thickness Measurement (Note 1) 16786-01 Division 2 Service Water Wall Thickness Measurement 08/19/97 Service Water Loop A Leakage Inspection 05/10/10 16954-02 05/10/10 (OSP-SW/IST-0701, Revision 20)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 3 PMID Description Implementation Service Water Loop B Leakage Inspection 16949-02 03/08/10 (OSP-SW/IST-Q702, Revision 21) 20251-01 TSW NDE/UT Corrosion Monitoring 05/01/02 24219-01 TSW System Piping Leakage Inspection 10/14/10 24178-01 Fire Protection NDE/UT Scan RW 484' 05/18/10 24178-02 Fire Protection NDE/UT Scan RW 467' 05/18/10 16297-02 Fire Protection Cable Spreading Room Leakage 04/18/10 Inspection (PPM 15.1.1, Revision 17)

Fire Protection RW 467' Leakage Inspection 04/17/10 16322-02 0/71 (PPM 15.1.8, Revision 10)

Note 1:

Division 1 and Division 2 scope was initially performed under PMID 16786-01.

Subsequently, a new activity was created for Division 1 to divide the scope on a divisional basis.