GO2-12-026, License Renewal Application Third Annual Update

License Renewal Application Third Annual Update

ML12052A005
Person / Time
Site:	Columbia
Issue date:	02/16/2012
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-12-026
Download: ML12052A005 (10)

Text

NTEAlex L. Javorik ENERGY Columbia Generating Station NORTHW EST P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-2354 aljavorik@ energy-northwest.com February 16, 2012 G02-12-026 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE RENEWAL APPLICATION THIRD ANNUAL UPDATE

References:

1) Letter, G02-10-011, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter, G02-10-094, dated July 16, 2010, SK Gambhir (Energy Northwest), "License Renewal Application First Annual Update"

3) Letter, G02-11-074, dated April 5, 2011, SK Gambhir (Energy Northwest), "License Renewal Application Second Annual Update"

Dear Sir or Madam:

By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. The first and second annual updates were provided to the Nuclear Regulatory Commission (NRC) in References 2 and 3. The License Renewal Rule, 10 CFR 54.21 (b), requires that each year following submittal of a license renewal application (LRA), and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA.

In accordance with this requirement, Energy Northwest performed a review of CLB changes after the LRA Second Annual Update reference freeze date of November 1, 2010. The reference freeze date for the third annual update was November 1, 2011.

This update also includes a review of applicable industry and plant specific operating experience for the same time frame. No changes in the CLB were found that materially affected the content of the LRA.

41(715

LICENSE RENEWAL APPLICATION THIRD ANNUAL UPDATE Page 2 of 2 One plant modification added a stainless steel platform and ladder in the primary containment at Columbia. This material-environment combination of stainless steel in air-indoor has been addressed in the LRA, but not for this specific component type.

Therefore, two line items were added for the applicable component type with this material-environment combination in Amendment 52 which is provided as the enclosure to this letter. No change in the aging management review resulted from this change.

Another modification removed the automatic closure due to smoke or combustible vapors for the remote air intakes. No change in scoping / screening resulted due to this modification.

Additionally, during the reviews for this update, Energy Northwest also incorporated administrative or editorial changes in Amendment 52. The attachment provides a brief explanation of the changes made.

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.

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

Respectfully, AL Javorik Vice President, Engineering

Attachment:

Summary of LRA Changes

Enclosure:

License Renewal Application Amendment 52 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a)

MA Galloway - NRC NRR RR Cowley - WDOH

LICENSE RENEWAL APPLICATION THIRD ANNUAL UPDATE Attachment Page 1 of 1 AMENDMENT 52 Summary of LRA Changes LRA Section LRA Page Summary Type 2.4.6 2.4-25 Removed auto-close signal Plant modification on smoke.

Editorial change in the FSAR. Analyzer rooms do 2.3.3.38 2.3-137 not requir not oost de require aea post-accident Editorial change cooling capability.

Table 3.5.2-13 3.5-1123 Installed new stainless steel Table 3.5.2-13 3.5-124 platform and ladder in Plant modification Table 3.5.2-13 3.5-124a Primary Containment.

Identified that the High-Voltage Porcelain Insulator Aging Management Program requires Table B-2 B-22 enhancement to be Consistency consistent with LRA A.1.2.31, Table A-1 Item Number 31, and B.2.31 as revised by Amendment 42.

Changed description from B.2.5 B-39b "Specification" to the more Consistency accurate "Standard" for AWWA Standard C203.

Columbia Generating Station License Renewal Application Technical Information 2.4.6 Fresh Air Intake Structure No. 1 and 2 - Seismic Category I Structure Description Two Seismic Category I remote Fresh Air Intake Structures are provided as part of the plant control room ventilation system design. In the event of a LOCA, operating personnel within the control room are protected from airborne radioactivity by means of pressurizing the control room with filtered air drawn from either of two separate remote fresh air intakes. Both intakes are physically remote from all plant structures. The fresh air intake structures are predominantly buried structures with above grade access grating to the air intake plenum. The structures are designed to withstand the effects of Seismic Category I disturbances, design basis wind velocity, and design basis tornado and tornado-generated missiles. The bottom of the Fresh Air Intake Structures are at elevation 431 ft. msl and the top of the structures are at elevation 441 ft. 9.5 in. msl.

These elevations are sufficient to protect the structures from the effects of the design basis groundwater elevation 420 ft msl and the design basis flood elevation 433.3 ft msl.

The intake structures are designed to handle, with adequate drainage, the instantaneous or local intense probable maximum precipitation (PMP).

Fire external to the plant and any resulting ingress of smoke or combustion vapors is detected by smoke detectors in the control room fresh air intake ducting, which will automatically "lozc the firc ratcd dam4"cr" downstrEam of tho.mokc dcte4to". and

\plccthccotrol rooEm in Ean unfiltercd rocirculatio) nemdc-.

Reason for Scope Determination The Fresh Air Intake Structure is within the scope of license renewal as a safety-related structure, which meets the criteria of 10 CFR 54.4(a)(1). The function of the Fresh Air Intake Structure, part of the main control room habitability system, is to ensure habitability inside the main control room during all normal and abnormal station operating conditions.

The function of the Fresh Air Intake Structure is to provide protection from airborne radioactivity by means of pressurizing the control room with filtered air drawn from either of two separate remote fresh air intakes in the event of a LOCA.

Fire external to the plant and any resulting ingress of smoke or combustion vapors is detected by smoke detectors in the control room fresh air intake ducting, which will

• automatically clozc the firc Fated dampers do)Wn tFcamn of the smekc dctectors.

Therefore, the Fresh Air Intake Structure provides support and protection for equipment used for coping with and recovery from a Fire Protection (10 CFR 50.48) regulated event and meets the 10 CFR 54.4(a)(3) scoping criteria.

Scoping and Screening Results Page 2.4-25 JaRHAPAP2O!0 jAmendment 52

Columbia Generating Station ISection 2.3.3.38 License Renewal Application Technical Information The critical motor control center7-, ,,lyeF,_ and fuel pool cooling (FPC) pump room emergency cooling fans auto start and the rooms are isolated from the Reactor Building HVAC system on an emergency signal. Although the FPC pump room is isolated from the Reactor Building HVAC system, the room temperature can be maintained below equipment operability limits with the Reactor Building HVAC dampers open. The ECCS and RCIC pump rooms emergency cooling fans auto start when their respective pump starts.

Each of the rooms housing critical equipment is provided with an individual air-handling unit (two units in the FPC pump room), which is fully enclosed within the room. Each air-handling unit is comprised of a fan and a water cooling coil in a sheet metal housing.

Water is supplied to the cooling coils by the Standby Service Water System. During normal operation, these air-handling units are in standby. All units recirculate the air within the room they serve, removing the heat generated in the room via the cooling coil, to maintain temperatures below design limits.

Reason for Scope Determination The Reactor Building HVAC systems provide:

" Secondary containment isolation and integrity [REA, ROA]

• Cooling to critical switchgear, ECCS pump rooms, and other vital rooms in the Reactor Building during emergency conditions [RRA]

These system-intended functions are safety-related. Therefore, the Reactor Building HVAC systems meet the scoping criteria of 10 CFR 54.4(a)(1).

The Reactor Building HVAC systems do not contain any NSR components that perform a 10 CFR 54.4(a)(1) function. The Reactor Building HVAC systems do, however, contain NSR components that are attached to or located near safety-related SSCs, whose failure creates a potential for spatial interaction that could prevent the satisfactory accomplishment of one or more of the functions identified in 10 CFR 54.4(a)(1). Therefore, the Reactor Building HVAC systems meet the scoping criteria of 10 CFR 54.4(a)(2). [REA, ROA, RRA]

The Reactor Building HVAC systems are relied upon to demonstrate compliance with, and meet the 10 CFR 54.4(a)(3) scoping criteria for, the following regulated events:

• Fire Protection (10 CFR 50.48) [REA, ROA, RRA]

• Environmental Qualification (10 CFR 50.49) [REA, ROA, RRA]

" Station Blackout (10 CFR 50.63) [RRA]

Scoping and Screening Results Page 2.3-137 janiwF

. -2910 jAmendment 52 7

Columbia Generating Station License Renewal Application Technical Information Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging Effect Aging Management NUREG-1801 Table 1 Commodity Function1 Material Environment Requiring Program Volume 2 Item Notes No.

Management Item Structures Monitoring Program 87 Pipe Supports SNS, SRE, Carbon Steel Treated water Loss of material III.B1.1-11 3.5.1-49 E SSR BWR Water Chemistry Program Structures Monitoring Program 88 Pipe Supports SNS, SRE, Stainless Steel Treated water Loss of material a11.B1.1-11 3.5.1-49 E SSR BWR Water Chemistry Program Stair, Ladder, Structures Monitoring 89 Platform, and SNS, SRE Carbon Steel Air-indoor Loss of material Program III.B5-7 3.5.1-39 A Grating Supports Stair, Ladder, Galvanized 90 Platform, and SNS, SRE Steel Air-indoor None None I1.B5-3 3.5.1-58 A Grating Supports Stair, Ladder, Structures Monitoring 91 Platform, and SNS, SRE Carbon Steel Air-outdoor Loss of material Program 111.B5-7 3.5.1-39 A Grating Supports 92 S ta ir , La d dand Platform, e r, SNS, Gl a i e Galvanized Air-outdoor Loss of material Structures t u t r sMonitoring M nt r n III.B2-7 3.5.1-50 A 9 Pltoman SNRE Steel Program Grating Supports Stairs, Ladders, 93 Platforms, and SNS, SRE Aluminum Air-indoor None None II1.B5-2 3.5.1-58 C Gratings Insert A from page 3.5-124a Aging Management Review Results Page 3.5-123 JnuaFy- 2010 FAmendment 52 57

Columbia Generating Station License Renewal Application Technical Information Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging Effect NUREG-1801 Row Component Intended Material Environment Requiring Aging Management Volume 2 Table 1m No. Commodity Function' Management Program Item Item Stairs, Ladders, 94 Platforms, and SNS, SRE Carbon Steel Air-indoor Loss of material Structures Monitoring 111.B5-7 3.5.1-39 C Gratings Program Stairs, Ladders, Galvanized 95 Platforms, and SNS, SRE Gal Air-indoor None None III.B5-3 3.5.1-58 C Gratings Steel Stairs, Ladders, S 96 Platforms, and SNS, SRE Aluminum Air-outdoor None Structures Monitoring 111.B4-7 3.5.1-50 0525 Gratings Program Stairs, Ladders, 97 Platforms, and SNS, SRE Carbon Steel Air-outdoor Loss of material Structures Monitoring 111.B5-7 3.5.1-39 C Gratings Program Stairs, Ladders, 98 Platforms, and SNS, SRE Galvanized Air-outdoor Loss of material Structures Monitoring 111.B2-7 3.5.1-50 C Steel Program Gratings Tube Track SNS, SRE, Loss of material Structures Monitoring 99 Carbon Steel Air-indoor 111.B2-10 3.5.1-39 A Supports SSR Program 100 Tube Track SNS, SRE, Galvanized Air-indoor None None 111.B2-5 3.5.1-58 A Supports SSR Steel 101 Tube Track SNS, SRE, Carbon Steel Air-outdoor Loss of material Structures Monitoring 111.B2-10 3.5.1-39 A Supports SSR Program 102 Tube Track SNS, SRE, Galvanized Air-outdoor Loss of material Structures Monitoring 111.B2-7 3.5.1-50 A Supports SSR Steel Program 103 Tube Tracks SNS, SRE, Carbon Steel Air-indoor Loss of material Structures Monitoring II1.B2-10 3.5.1-39 C SSR Program linsert B from page 3.5-124a I Aging Management Review Results Page 3.5-124 jaRwaFy 2919 jAmendment 52

Columbia Generating Station License Renewal Application Technical Information Insert A:

Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging Effect Aging Management NUREG-101 Table Notes Row Component / Intended.. AgnTal1 Volume 2 Item No. Commodity Function 1 Material Environment Requiring Program Management Item Stairs, Ladders, Stainless 92a Platforms, and SNS, SRE Air-Indoor None None II1.B5-5 3.5.1-59 A Grating Supports Steel Insert B:

Page 3.5-124a Amendment 52 Results Aging Management Review Results Page 3.5-124a Amendment 52

Columbia Generating Station License Renewal Application Technical Information Table B-2 Consistency of Columbia Aging Management Programs with NUREG-1801 (continued)

Consistent Consistent with New Cosset wt Plant- Enhancement Program Name ne with NUREG- NUREG- plant- enhneen Existing 1801 1801 with Specific Required Exceptions Fire Water Program Existing Yes Yes Section B.2.26 Flexible Connection Inspection *, New -- Yes

[Program ]

Section B.2.27 Flow-Accelerated Corrosion (FAC) Existing Yes Yes Program Section B.2.28 Fuel Oil Chemistry Program Existing Yes Section B.2.29 Heat Exchangers Inspection New Yes Section B.2.30 High-Voltage Porcelain Insulators Aging Management Existing Yes ,"

JPower Program

\11 Section B.2.31 Inaccessible MAi im Y.oltogc Cables Not Subject to 10 CFR 50.49 New Yes EQ Requirements Program Section B.2.32 Inservice Inspection (ISI) Program Existing Yes Section B.2.33 Inservice Inspection (ISI) Program - IWE Existing Yes Section B.2.34 Aging Management Programs Page B-22 Ja eRUTIC11 Rden_t5_2__

Columbia Generating Station ISection B.2.5 License Renewal Application Technical Information Insert E to LRA Section B.2.5 on page B-39 The Buried Piping and Tanks Inspection Program will manage the effects of loss of material due to corrosion on the external surfaces of metallic piping and tanks that are buried or underground. The program also manages cracking, loss of material and loss of pre-load for buried bolting. Additionally, the program will verify that aging degradation is not occurring for buried concrete and polymer piping.

Buried piping and tanks are those whose external surface is in direct contact with soil, or concrete of a wall penetration below grade. Underground piping and piping components are also located below grade, but are exposed to air and are contained within outdoor vaults, valve pits, or guard pipes where access for inspection is restricted. The Buried Piping and Tanks Inspection Program supplements the External Surfaces Monitoring Program in such instances.

The Buried Piping and Tanks Inspection Program is a combination of a mitigation program (consisting of protective coatings, cathodic protection, and backfill quality) and a condition monitoring program (consisting of electrochemical verification of cathodic protection, confirmation of backfill quality, visual inspections of pipe or tank external surfaces, and non-destructive evaluation of pipe or tank wall thicknesses as needed).

Integrity of coatings will be inspected when components are excavated for maintenance or other reasons. If opportunistic inspections have not occurred between year 30 and year 38, directed excavation of the requisite sections of buried piping and tanks for the purpose of inspection will be performed before the end of year 40. Additional inspections of buried and underground piping and buried tanks will be performed within 10 years of entering the period of extended operation, and in each 10 year period thereafter.

Insert F to LRA Section B.2.5, page B-39 Program Elements Affected:

• Preventive Actions Cathodic _protection (in accordance with NACE SP0169-2007 or NACE RP0285-2002) is not, and will not be, provided for Diesel Fuel Oil System piping and tanks in the scope of license renewal. As described in FSAR Section 9.5.4.3, regarding Diesel Generator fuel oil piping and tanks, "The overflow lines from the day tank to the storage tank run underground south of the diesel generator building.

Diesel fuel oil pipe lines extending under the diesel generator building do not receive full protection from the exterior rectifier-anode system because of the electrical shielding effect of the ground grid and foundation reinforcing and structural steel.

Since the earth area under the diesel generator building is sheltered and hence relatively much drier than the earth exterior to this building, no additional cathodic protection system is provided or required." FSAR Section 9.5.4.3 further indicates that the "exterior surfaces of the buried piping and components in the diesel oil supply system are coated with coal tar enamel. Application of coatings is in strict accordance with AWWA Spe'i"i"atieR C203."

iTS-tandard Aging Management Programs Page B-39b Amcndmcnt 25 jAmendment 52--