GO2-22-076, Status of License Renewal Commitments

Status of License Renewal Commitments

ML22304A190
Person / Time
Site:	Columbia
Issue date:	10/31/2022
From:	Wolfgramm D Energy Northwest
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
GO2-22-076
Download: ML22304A190 (1)

Text




      

ENERGY Desiree M. Wolfgramm Columbia Generating Station NORTHWEST P.O. Box 968, PE20 Richland, WA 99352-0968 Ph. 509.377.4792 l F. 509.377.4674 dmwolfgramm@energy-northwest.com October 31, 2022 GO2-22-076 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 STATUS OF LICENSE RENEWAL COMMITMENTS Reference 1. NUREG-2123 "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station," dated May 2012 (ADAMS ML12139A300 and ML12139A302)

2. Letter GO2-21-112 "Columbia Generating Station, Docket NO. 50-397 Status of License Renewal Commitments," dated November 15, 2021 (ADAMS ML21319A27)

Dear Sir or Madam,

The purpose of this letter is to notify the U.S. Nuclear Regulatory Commission (NRC) of the completion of certain license renewal commitments (LRC) identified in Reference 1 and as required by Renewed License No. NPF-21 License Condition 2.C.(35) when implementation of these activities is complete.

The table provided in Attachment 1 identifies the LRCs that Energy Northwest is reporting as complete and includes the LRCs reported in Reference 2. The list of Reference 1 item numbers identified in Attachment 2 represent Columbia programs that existed prior to the license renewal application (LRA) and did not require enhancements to comply with the NRC's safety reviews in Reference 1. As such, no program or activity changes were made to these items. Program documentation for these items is available for inspection at the NRC's convenience. The remaining commitments are in the process of being completed.




      

GO2-22-076 Page 2 of 2 No new commitments are being made by this letter or the attachment. If you have any questions or require additional information, please contact Mr. R. M. Garcia, Licensing Supervisor, at (509) 377-8463.

Respectfully, r-;:: DocuSigned by:

L~6~~

Desiree M. Wolfgramm Regulatory Affairs Manager Attachments: As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH




      

GO2-22-076 Attachment 1 Page 1 of 3 Columbia's Completed License Renewal Commitment Table Commitment Summary/Description Status No.

The Fatigue Monitoring Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Columbia has analyzed the effects of the reactor coolant environment on fatigue for the six locations recommended by NUREG\CR-6260. These analyses are based on the projected cycles for 60 years of operation (plus some conservatism) rather than the original design cycles in FSAR Table 3.9-1. The Fatigue Monitoring Program will be enhanced to ensure that action will be taken when the lowest number of analyzed cycles is approached.

- For each location that may exceed a CUF of 1.0 (due to projected 24 Implemented cycles exceeding analyzed, or due to as-yet undiscovered industry issues), the Fatigue Monitoring Program will implement one or more of the following: (1) Refine the fatigue analyses to determine valid CUFs less than 1.0, (2) Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC, or (3)

Repair or replace the affected locations before exceeding a CUF of 1.0.

x Correlate information relative to fatigue monitoring and provide more definitive verification that the transients monitored and their limits are consistent with or bound the FSAR and the supporting fatigue analyses, including the environmentally-assisted fatigue analyses.

The High-Voltage Porcelain Insulators Aging Management Program is an existing program that will be continued for the period of extended operation, with the following enhancement:

31 Implemented For the in-scope station post insulators located at the Ashe substation, add testing for contamination, and cleaning if required, every 8 years.

The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is a new program. The Thermal Aging and Neutron Embrittlement of CASS Program will manage loss of fracture toughness due to thermal aging and neutron irradiation GO2-19-162 embrittlement of CASS reactor vessel internals. Subsumed in 52 The program includes: (a) identification of susceptible components Commitment 10 determined to be limiting from the standpoint of thermal aging or neutron BWR Vessel irradiation embrittlement (neutron fluence), (b) a component specific Internals Program evaluation to determine each identified components susceptibility to loss of fracture toughness, and (c) a supplemental examination of any component not eliminated by the component specific evaluation.

Reported Incorporate FSAR Supplement into the Columbia FSAR as required by 55 Completed in Letter 10 CFR 54.21(d).

GO2-21-112




      

GO2-22-076 Attachment 1 Page 2 of 3 Commitment Summary/Description Status No.

The elements of corrective actions, confirmation process, and administrative controls in the OQAPD (operational quality assurance Reported program description) will be applied to required aging management 56 Completed in Letter programs for both safety-related and non-safety related structures and GO2-21-112 components determined to require aging management during the period of extended operation.

Commitments identified in association with the Columbia license renewal Reported 57 will be tracked within the Columbia Regulatory Commitment Completed in Letter Management Program GO2-21-112 In accordance with the BWR Vessel Internals Program, Columbia will Reported 58 implement the additional inspection requirements of BWRVIP-42-A Completed in Letter once those requirements are approved by the NRC staff. GO2-21-112 Energy Northwest will submit a licensing basis change request to implement the BWRVIP ISP(E) at least two years prior to the period of Reported 59 extended operation. Columbia will implement the ISP(E) as amended by Completed in Letter the BWRVIP letter of January 11, 2005, including the new capsule test GO2-21-112 schedule in Table 1 of that letter.

BWRVIP-116 The Columbia site procedure was modified to require any capsules removed from the reactor vessel to be stored in a manner that Reported 60 would support future re-insertion of these capsules in the reactor vessel. Completed in Letter Columbia will notify the BWRVIP prior to any change in the storage of GO2-21-112 on-site materials.

Reported 61 Boron Carbide Monitoring Program Completed in Letter GO2-21-112 Reported ISI Program: Prepare and submit the ISI Program Plan for the fourth 10-65 Completed in Letter year interval no later than 2015.

GO2-21-112 Perform a one-time internal inspection of the spent fuel pool telltale drain lines prior to the period of extended operation to confirm the drain lines are free of obstructions. Unexpected inspection results of clogged lines 66 Completed will require a condition report be documented and further engineering evaluation of adverse impacts to the spent fuel pool structure and to identify the periodicity of drain cleaning and maintenance process.

Structures Monitoring Program: Perform borescope inspection of Reported 67 containment sand pocket drain lines to confirm the absence of clogged Completed in Letter drain lines and that a flow path exists GO2-21-112 Reported FAC Program: Ensure that the condensate and feedwater systems are 68 Completed in Letter screened and evaluated for cavitation prior to entering the PEO.

GO2-21-112 Re-evaluate the portions of the reactor pressure vessel beltline welds BG and BM for the period of extended operation (54 EFPY), in Reported 69 accordance with the requirements of the ASME Code,Section XI, Completed in Letter IWB- 3600 based on the results of 2015 inservice inspection. GO2-21-112 Perform a 54 EFPY equivalent margin analysis for the embrittlement Reported 70 (upper shelf energy) of the reactor vessel N12 (instrumentation) Completed in Letter nozzle forgings. GO2-21-112




      

GO2-22-076 Attachment 1 Page 3 of 3 Commitment Summary/Description Status No.

At least two years prior to the period of extended operation, Columbia will install core plate wedges unless:

1) A site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or

2) An NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC. Reported 71 Completed in Letter LC 2.C.(56) GO2-21-112 To prevent lateral motion of the core plate, the licensee shall install core plate wedges around the periphery of the core plate within the shroud on or before December 20, 2021. Upon completion of the core plate wedge installation, the licensee shall submit a written report to the NRC staff summarizing the results of the installation. The licensee shall also submit a written report regarding any corrective action taken related to core plate rim hold-down bolts or core plate wedges and the results of extent of condition reviews on or before December 20, 2021.




      

GO2-22-076 Attachment 2 Page 1 of 1 Existing Columbia Programs Not Requiring Enhancements SER Item Number/Title Commitment Statement from NUREG-2123 Table A-1 SECTION The Appendix J Program is an existing program that will be continued for

3. Appendix J Program 3.0.3.1.1 the period of extended operation.

4. Bolting Integrity The Bolting Integrity Program is an existing program that will be continued 3.0.3.2.2 Program for the period of extended operation.

6. BWR Feedwater Nozzle The BWR Feedwater Nozzle Program is an existing program that will be 3.0.3.1.2 Program continued for the period of extended operation.

7. BWR Penetrations The BWR Penetrations Program is an existing program that will be 3.0.3.1.3 Program continued for the period of extended operation.

8. BWR Stress Corrosion The BWR Stress Corrosion Cracking Program is an existing program that 3.0.3.1.4 Cracking Program will be continued for the period of extended operation.

9. BWR Vessel ID The BWR Vessel ID Attachment Welds Program is an existing program Attachment Welds 3.0.3.1.5 that will be continued for the period of extended operation.

Program

10. BWR Vessel Internals The BWR Vessel Internals Program is an existing program that will be 3.0.3.1.6 Program continued for the period of extended operation.

11. BWR Water Chemistry The BWR Water Chemistry Program is an existing program that will be 3.0.3.1.7 Program continued for the period of extended operation.

The CRDRL Nozzle Program is an existing program that will be continued

15. CRDRL Nozzle Program 3.0.3.1.10 for the period of extended operation.

The EQ Program is an existing program that will be continued for the

22. EQ Program 3.0.3.1.16 period of extended operation.

The Fire Protection Program is an existing program that will be continued

25. Fire Protection Program 3.0.3.2.8 for the period of extended operation.

29. Fuel Oil Chemistry The Fuel Oil Chemistry Program is an existing program that will be 3.0.3.2.12 Program continued for the period of extended operation.

33. Inservice Inspection The Inservice Inspection (ISI) Program is an existing program that will be 3.0.3.1.19 (ISI) Program continued for the period of extended operation.

34. Inservice Inspection The Inservice Inspection (ISI) Program - IWE is an existing program that 3.0.3.1.20 (ISI) Program - IWE will be continued for the period of extended operation

35. Inservice Inspection The Inservice Inspection (ISI) Program - IWF is an existing program that 3.0.3.1.21 (ISI) Program - IWF will be continued for the period of extended operation.

39. Material Handling The Material Handling System Inspection Program is an existing program System Inspection 3.0.3.2.15 that will be continued for the period of extended operation.

Program

44. Preventive Maintenance The Preventive Maintenance - RCIC Turbine Casing is an existing 3.0.3.3.10

- RCIC Turbine Casing program that will be continued for the period of extended operation.

45. Reactor Head Closure The Reactor Head Closure Studs Program is an existing program that will 3.0.3.1.24 Studs Program be continued for the period of extended operation.

46. Reactor Vessel The Reactor Vessel Surveillance Program is an existing program that will 3.0.3.1.25 Surveillance Program be continued for the period of extended operation

62. Service Level 1 The Service Level 1 Protective Coatings Program is an existing program Protective Coatings 3.0.3.3.12 that will be continued for the period of extended operation.

Program