IR 05000397/2023011

License Renewal Phase 2 Report 05000397/2023011

ML23277A181
Person / Time
Site:	Columbia
Issue date:	10/04/2023
From:	Nick Taylor NRC/RGN-IV/DORS/EB2
To:	Schuetz R Energy Northwest
Smith W
References
IR 2023011
Download: ML23277A181 (61)

Text

October 04, 2023

SUBJECT:

COLUMBIA GENERATING STATION - LICENSE RENEWAL PHASE 2 REPORT 05000397/2023011

Dear Robert Schuetz:

On August 24, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station and discussed the results of this inspection with R.A. Prewett, Plant General Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Nicholas H. Taylor, Branch Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000397 License No. NPF-21

Enclosure:

As stated

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2023011

Enterprise Identifier:

I-2023-011-0002

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, WA

Inspection Dates:

August 06, 2023 to August 26, 2023

Inspectors:

J. Drake, Senior Reactor Inspector

S. Graves, Senior Reactor Inspector

J. Mejia, Reactor Inspector

G. Pick, Senior Reactor Inspector

C. Smith, Senior Reactor Inspector (Team Leader)

Approved By:

Nicholas H. Taylor, Branch Chief

Engineering Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a License Renewal Phase 2 inspection at Columbia Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

71003 - Post-Approval Site Inspection for License Renewal Post-Approval Site Inspection for License Renewal

(1) The inspectors conducted a Phase 2 license renewal inspection. The following aging management programs were evaluated by the inspectors:

A.2.1.1 Aboveground Steel Tanks Inspection and Commitment 1 This is a new aging management program to manage the effects of aging for the condensate storage tanks by direct observation of the bottom surfaces of the tanks.

The licensee committed to perform the inspections before entering the period of extended operation (PEO), and then on a recurring 10-year frequency.

Commitment 1 specified:

The Aboveground Steel Tanks Inspection detects and characterizes the conditions on the bottom surfaces of the condensate storage tanks. The program provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred in inaccessible areas.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, work orders, and inspection results. The inspectors interviewed plant and implementing personnel. The inspectors reviewed the internal inspection results for tanks COND-TK-1A and COND-TK-1B and found the tank bottom thickness measurements met the minimum wall acceptance criteria, and that the tanks internal coatings were acceptable.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 1 and its associated aging management program.

A.2.1.2 Compressed Air Monitoring Program and Commitments 2 and 16 The Compressed Air Monitoring Program is a new aging management program that replaces the Air Quality Sampling Program and the Diesel Starting Air Inspection in accordance with NUREG-1801, Rev. 2,Section XI.M24. The purpose of the compressed air monitoring program is to provide reasonable assurance of the integrity of the compressed air system. The program consists of monitoring moisture content, corrosion, and performance of the compressed air system. This includes (a)preventive monitoring of water (moisture) and other potential contaminants to keep within the specified limits; and

(b) inspection of components for indications of loss of material due to corrosion. The aging management program manages the loss of material for carbon steel, stainless steel, and copper alloy components in the Diesel Starting Air (DSA) system and the air quality in the DSA and Control Air System (CAS) systems that contain compressed air and are within the scope of license renewal.

The Compressed Air Monitoring Program is a prevention and condition monitoring program that manages loss of material due to corrosion for DSA components that contain compressed air through periodic sampling of the air for hydrocarbons, dewpoint, and particulates and periodic ultrasonic inspection of the DSA System air receivers. In addition, the Compressed Air Monitoring Program ensures that the CAS remains dry and free of contaminants, such that no aging effects require management.

The licensee implemented the Compressed Air Monitoring Program prior to entering the PEO, and committed to continue it after the PEO by conducting opportunistic inspections when components are opened for periodic maintenance, repair, or surveillance activities when surfaces are made available for inspection.

Commitment 2 specified:

This plant-specific, existing program was credited with managing loss of material due to corrosion in the diesel generator starting air system and ensuring the control air system remained dry and free of contaminants. The program periodically monitored the air quality through sampling for hydrocarbons, dew point, and particulates in both systems, and periodically performed ultrasonic inspections of diesel starting air system air receivers.

Commitment 16 specified:

The Diesel Starting Air Inspection is a new program, which detects and characterizes the condition of materials for the DSA system air dryers and downstream piping and components (excluding the DSA system air receivers). The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, work orders, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitments 2 and 16 and its associated aging management program.

A.2.1.3 Appendix J Program and Commitment 3 This is an existing program that manages leakage of the Primary Containment and all systems and components penetrating the Primary Containment, which are the containment shell and primary containment penetrations including (but not limited to)the personnel airlock, equipment hatch, control rod drive hatch, and drywell head.

Leakage tests are performed in accordance with procedures TSP-CONT-R801, TSP-CONT-B801, and TSP-CONT-C801. The Appendix J Program is an existing program that will be continued into the PEO.

Commitment 3 specified:

The program will manage leakage of the Primary Containment and all systems and components penetrating the Primary Containment, which are the containment shell and primary containment penetrations including (but not limited to) the personnel airlock, equipment hatch, control rod drive hatch, and drywell head. The program will monitor and detect aging effects of in-scope components and corrective actions, where necessary, will resolve any issues before loss of intended function.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 3, and its associated AMP.

A.2.1.4 Bolting Integrity Program and Commitment 4 This program is a combination of existing activities that address the management of aging for the bolting of mechanical components and structural connections. The program relies on manufacturer and vendor information and industry recommendations for the proper selection, assembly, and maintenance of bolting for pressure retaining closures and structural connections. The licensee performs periodic inspection of bolting for indications of degradation such as leakage, loss of material due to corrosion, loss of pre-load, and cracking due to stress corrosion cracking (SCC) and fatigue. This program will be continued for the PEO.

Commitment 4 specified:

The Bolting Integrity Program will be continued for the PEO and includes periodic inspection of pressure-retaining components, including bolting, for signs of leakage through the External Surfaces Monitoring Program.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 4, and its associated AMP.

A.2.1.5 Buried and Underground Piping and Tanks Inspection and Commitment The Buried Piping and Tanks Inspection Program is an existing program that manages the effects of loss of material due to corrosion on the external surfaces of metallic piping and tanks that are underground. It monitors protective coatings, cathodic protection, and backfill quality, as well as visual inspections of pipe or tank external surfaces, and non-destructive evaluation of pipe or tank wall thicknesses.

The program also manages the effects of cracking, loss of material (and loss of pre-load) for buried bolting and buried polymer piping. Additional inspections of buried and underground piping and buried tanks are performed within the 10 years of entering the PEO and in each 10-year period thereafter.

Per NUREG-2123, Vol. 1, a representative number of components were selected for inspection based on a material-environment-aging effect combination. There is a minimum of 12 inspections required within 6 sample groups prior to the PEO.

Integrity of coatings are 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 buried and underground piping and tanks for the purpose of inspection were performed before year 40. Additional inspections of buried and underground piping and buried tanks are performed in each 10-year period thereafter.

The AMP adopts relevant sections of, LR-ISG-2011-03 (Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program XI.M41, Buried and Underground Piping and Tanks), LR-ISG-2012-02 (Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation), and LR-ISG-2015-01 (Changes to Buried and Underground Piping and Tanks Recommendations)

Commitment 5 specified:

The Buried Piping and Tanks Inspection Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, work orders, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 5 and its associated AMP.

A.2.1.6 BWR Feedwater Nozzle Program and Commitment 6 The BWR Feedwater Nozzle Program is an existing program in accordance with American Society of Mechanical Engineers (ASME)Section XI and NRC augmented requirements. The program consists of

(a) enhanced in-service inspections, in accordance with the requirements of the ASME Code,Section XI, Subsection IWB, Table IWB 2500-1 (2007 edition including the 2008 Addenda), and the recommendations of General Electric (GE) NE-523-A71-0594-A, and

(b) system modifications to mitigate cracking. This program will be continued for the PEO.

Commitment 6 specified:

The BWR Feedwater Nozzle Program manages cracking due to stress corrosion cracking/intergranular attack (SCC/IGA) and flaw growth of the six

(6) feedwater nozzles (N04). This includes the safe end (nickel alloy), safe end extension and thermal sleeve. The program specifies periodic ultrasonic inspection of critical regions of the feedwater nozzles and complies with the requirements of 10CFR50.55a.

Mitigation of cracking in the Feedwater (FW) nozzles involved several elements, including material selection and processing, nozzle clad elimination, and thermal sleeve and sparger redesign. The sparger design includes a welded thermal sleeve such that there is no thermal sleeve bypass and no rapid thermal cycling of the blend radius for each FW nozzle. Stainless steel cladding of the FW nozzles was not included in the original design.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 6, and its associated AMP.

A.2.1.7 BWR Penetration Program and Commitment 7 Management of Reactor Vessel, Internals and Reactor Coolant System Piping Integrity, SWP-VIP-01 is the procedure is used to satisfy portions of the License Renewal Program requirements for the BWR Penetrations Program. This is an existing program that will be continued for the PEO.

Commitment 7 specified:

The BWR Penetration Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 7, and its associated AMP.

A.2.1.8 BWR Stress Corrosion Cracking and Commitment 8 The BWR Stress Corrosion Cracking (SCC) Program is an existing condition monitoring program that manages cracking due to SCC for and intergranular attack (IGA) on stainless steel and nickel alloy reactor coolant pressure boundary piping, nozzle safe ends, nozzle thermal sleeves, valve bodies, flow elements, and pump casings. This is an existing program that will be continued for the PEO.

Commitment 8 specified:

The BWR SCC Program consists of

(a) preventive measures to mitigate SCC/IGA, and

(b) inspection and flaw evaluation to monitor SCC/IGA and its effects. The BWR Water Chemistry Program monitors and controls reactor coolant water chemistry in accordance with BWR Vessel Internals Program (BWRVIP) guidelines to ensure the long-term mitigation of SCC/IGA. The program includes the scope of NUREG-0313 Revision 2, Generic Letter (GL) 88-01, and GL 88-01 Supplement 1, as modified by the staff-approved BWRVIP-75 report.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 8, and its associated AMP.

A.2.1.9 BWR Vessel ID Attachment Welds Program and Commitment 9 Management of Reactor Vessel, Internals and Reactor Coolant System Piping Integrity, SWP-VIP-01 is the program applicable to structural welds for BWR reactor vessel internal integral attachments, is a condition monitoring program and has no preventive actions. This program looks for surface discontinuities that may indicate the presence of a crack in the component in accordance with the guidelines of approved BWRVIP-48-A and the requirements of the ASME XI, Table IWB 2500-1 (2004 edition). This is an existing program that will be continued for the PEO.

Commitment 9 specified:

The BWR Vessel ID Attachment Welds Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 9, and its associated AMP.

A.2.1.10 BWR Vessel Internals Program and Commitment 10 and 52 Management of Reactor Vessel, Internals and Reactor Coolant System Piping Integrity, SWP-VIP-01 is the procedure is used to satisfy portions of the License Renewal Program requirements for the XI.M9 BWR Vessel Internals Program.

The Reactor Vessel and Internals Program follows the guidance of BWRVIP-94. This is an existing program that will be continued for the PEO.

Commitment 10 specified:

The BWR Vessel Internals Program is an existing program that will be continued for the PEO.

Commitment 52 specified:

The Thermal Aging and Neutron Embrittlement of CASS was a new program for Columbia that was to be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS). However, under NUREG-1801 Rev 2, XI.M13 was subsumed into the XI.M9, BWR Vessel Internals Program. Energy Northwest identified that XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel, can be incorporated into XI.M9, BWR Vessel Internals (see letter GO2-19-162).

As a result, Energy Northwest combined Columbia FSAR items A.1.2.52, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), with A.1.2.10, BWR Vessel Internals Program, to reflect the later guidance contained in NUREG-1801, Rev. 2 via LDCN-18-029. A stand-alone CASS XI.M13 Program is therefore not implemented.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 10 and 52, and its associated AMP.

A.2.1.11 BWR Water Chemistry Program and Commitment 11 The BWR Water Chemistry Program is an existing program with no enhancements or exceptions that uses established procedures and Preventative Maintenance tasks (PMRQs) to implement activities that mitigate degradation of components that are within the scope of license renewal and contain or are exposed to treated water, treated water in the steam phase, reactor coolant, or treated water in a sodium pentaborate solution. The program manages the relevant conditions that could lead to the onset and propagation of a loss of material due to corrosion or erosion, cracking due to stress corrosion cracking (SCC), or reduction in heat transfer due to fouling through proper monitoring and control of chemical concentrations consistent with BWR Vessel Internals Program (BWRVIP) water chemistry guidelines. The program was supplemented by one-time inspection programs Chemistry Program Effectiveness Inspections and the Heat Exchanger Inspections.

The BWR Water Chemistry Program is applicable to gray cast iron, nickel-based alloy, stainless steel (including cast austenitic stainless steel), and steel components in systems and structures in the scope of license renewal that contain or are exposed to treated water or steam during normal operation. This is an existing program that will be continued for the PEO.

Commitment 11 specified:

The program will detect aging effects of in-scope components and corrective actions, where necessary, will resolve any issues before loss of intended function.

Implementing documents have been annotated and recurring actions have been created to ensure sustainability of the program through the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 11, and its associated AMP.

A.2.1.12 Chemistry Program Effectiveness Inspection and Commitment 12 This one-time inspection evaluated and characterized the material conditions in representative low-flow and stagnant areas of plant systems influenced by the following mitigation programs: BWR Water Chemistry Program, the Fuel Oil Chemistry Program, and the Closed Cooling Water Chemistry Program. The licensee inspected to identify direct evidence whether, and to what extent, a loss of material caused by crevice, general, galvanic, or pitting corrosion (in treated water or fuel oil environments) had occurred. In addition, the licensee evaluated whether, and to what extent: and

(2) cracking due to stress corrosion cracking of susceptible materials (in treated water greater than 140 degrees Fahrenheit) in susceptible locations has occurred. This is a new one-time aging management program.

Commitment 12 specified:

The Chemistry Program Effectiveness Inspection detects and characterizes the condition of materials in representative low flow and stagnant areas of systems with water chemistry controlled by the BWR Water Chemistry Program or the Closed Cooling Water Chemistry Program, and with fuel oil chemistry controlled by the Fuel Oil Chemistry Program. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, plant drawings, work orders, inspection guidelines, and inspection results. The inspectors interviewed plant and implementing personnel.

The inspectors determined that the licensee had taken a representative sample of components that reflected the material-environment combinations at the plant.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 12 and its associated one-time AMP.

A.2.1.13 Closed Cooling Water Chemistry Program and Commitment 13 This program managed aging effects related to loss of material, cracking, and reduction in heat transfer of plant components that contain treated water in a closed cooling water system or components (e.g., heat exchanger) served by or connected to a closed cooling water system. The licensee monitored and controlled closed cooling water chemistry within acceptable limits using procedures and processes based upon Electric Power Research Institute (EPRI) water chemistry guidelines.

This program included the diesel cooling water system, reactor closed cooling water system, the radwaste building chilled water system and the components (e.g., heat exchangers) directly cooled by any of these systems (as described in the aging management program basis document). The reactor closed cooling water system had side stream ability to measure corrosion rates and biological contamination on corrosion coupons that reflected the materials contained in the system. This is an existing program that will be continued for the PEO.

Commitment 13 - Closed Cooling Water Chemistry Program specified:

The Closed Cooling Water Chemistry Program is an existing program that will be continued for the PEO, with the following enhancement:

Ensure that at least one additional reactor closed cooling water corrosion rate measurement is performed and evaluated prior to entering the PEO to provide direct information as to the effectiveness of the chemical treatments. If necessary, based on the results, establish a frequency for subsequent measurements.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, work orders, and inspection results. The inspectors interviewed plant and implementing personnel. The inspectors reviewed the measurements taken of the corrosion and biological coupons annually and noted no adverse trends. The annual measurements exceeded the requirements of commitment 13.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 13 and its associated AMP.

A.2.1.14 Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Program (ISMPD) and Commitment 14 The Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Program (ISMPD) is a new program, which subsumed existing Cooling Units Inspection, Diesel Systems Inspection, Diesel-Driven Fire Pump Inspection, Flexible Connection Inspection, Monitoring and Collection Systems Inspection, Potable Water Monitoring, Service Air System Inspection, and Supplemental Piping and Tanks Inspection license renewal aging management plant-specific programs (commitments 14, 17, 18, 27, 41, 43, 48 and 51, respectively) into a single program, in accordance with the GALL. In addition, the ISMPD also performs the inspections of augmented and non-safety related components from the Open-Cycle Cooling Water license renewal aging management program. The Inspection of ISMPD Program manages fouling, cracking, loss of material, and change in material properties using opportunistic visual inspections of the internal surfaces of piping and other components during periodic surveillances or maintenance activities when the surfaces are accessible for visual inspection during the PEO. This program was implemented prior to the PEO, and will be continued for the PEO.

Commitment 14 specified:

The Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program (ISMPD) manages fouling, cracking, loss of material, and change in material properties using opportunistic visual inspections of the internal surfaces of piping and other components during periodic surveillances or maintenance activities when the surfaces are accessible for visual inspection during the PEO. This opportunistic approach is supplemented as needed to ensure a representative sample is achieved in each 10-year interval of the PEO. At a minimum, in each 10-year interval during the PEO a representative sample of 20% of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population is inspected.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, work orders, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 14 and its associated AMP.

A.2.1.15 Control Rod Drive Return Line Nozzle Program and Commitment 15 The Control Rod Drive Return Line (CRDRL) Nozzle Program is an existing program in accordance with ASME Section XI and NRC augmented requirements. The program consists of

(a) enhanced ISI in accordance with the requirements of the ASME Code,Section XI, Subsection IWB, Table IWB 2500-1 (2007 edition including the 2008 Addenda) and the recommendations of GE NE-523-A71-0594-A, and (b)system modifications to mitigate cracking. This program is an existing program that will be continued for the PEO.

Commitment 15 specified:

The CRDRL Nozzle Program manages cracking due to flaw growth of the CRDRL nozzle and connecting welds. The nozzle to safe end and safe end to cap are category B-J welds and are covered by the risk-informed ISI Program. In part because of the low alloy steel construction that is not susceptible to SCC, these are low risk welds and are not scheduled for inspection in the third 10-year interval. The program specifies periodic ultrasonic inspection of critical regions of the nozzles. The CRDRL Nozzle Program at Columbia monitors cracking by detection and sizing of cracks using ISI in accordance with ASME Section XI, Subsection IWB and 10CFR50.55a.

The CRDRL Nozzle Program at Columbia includes augmented ISI examinations to monitor crack initiation and growth of the CRDRL nozzles. The schedule, examination techniques and personnel qualification recommendations of GE NE-523-A71-0594-A have also been incorporated into the ISI Program. Inspections are performed in accordance with ISI-4, the Inservice Inspection Program Plan - Interval 4.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 15, and its associated AMP.

A.2.1.19 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program and Commitment 19 This is a new aging management program, which after enhancements is consistent with the GALL Report. The program scope was enhanced to include all cables and connections (terminal blocks, fuse holders, and electrical penetration assemblies) not subject to the EQ requirements of 10 CFR 50.49. The program was also enhanced to include additional potential aging effects such as signs of reduced insulation resistance due to thermal/thermoxidative degradation of organics, radiolysis, and photolysis (UV sensitive materials only) of organics; radiation-induced oxidation, and moisture intrusion as indicated by signs of embrittlement, discoloration, cracking, melting, swelling or surface contamination.

The licensee committed to periodic visual inspection of accessible, non-environmentally qualified cables and connections in order to determine if age-related degradation is occurring, particularly in plant areas with adverse localized environments. The licensee used the guidance in Electric Power Research Institute (EPRI) report TR-109619, Guideline for the Management of Adverse Localized Equipment Environments to identify adverse localized environments and develop their methodology.

Prior to the PEO electrical cables and conduits were visually inspected for adverse environmental and/or radiological impacts. Environmental conditions included the environmental stressors of heat, radiation, chemicals, moisture, and any other physical influence that could have an adverse effect on the component. The inspection results were documented in a proprietary contractor report, FAI/17-0469. The licensee also developed and implemented a program for cable management activities, CCMP-01, Cable Condition Monitoring Program, which consists of monitoring electrical cables and connections against approved performance criteria to assess the adequacy of electrical cable and connection performance. Anomalies are entered into the site corrective action program. This new program was implemented prior to the PEO and will be continued for the PEO.

Commitment 19 specified:

The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program is an inspection program that detects degradation of electrical cables and connections that are not environmentally qualified and are within the scope of license renewal.

The program provides for the periodic visual inspection of accessible, non-environmentally qualified cables and connections in order to determine if age related degradation is occurring, particularly in plant areas with adverse localized environments.

The inspectors reviewed license renewal program basis documents, implementing procedures, corrective action program documents, completed work orders for the inspections performed to satisfy the LRA commitment, the licensees proprietary contractors report and conclusions, and held discussions with program staff.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 19 and its associated AMP.

A.2.1.20 Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits and Commitment 20 This is a new aging management program, consistent with the GALL Report, created with detection and identification of age-related degradation associated with non-environmental qualified (EQ), sensitive, high-voltage, low-current instrumentation cables and connections. At CGS, this program was originally developed for in-scope, non-EQ electrical cables and connections used in circuits with sensitive, high-voltage, low-current signals (such as radiation monitoring and nuclear instrumentation loops).

The licensee committed the program to provide for a review of calibration records for low-current instruments to detect and identify degradation of the cable system insulation resistance. The program retains the option to perform direct cable testing using a proven cable system test for detecting deterioration of the insulation system and will test at least once every 10 years. Any aging related anomalies will be evaluated by the site corrective action program. These instruments are also subject to required technical specification surveillance testing to ensure operability.

During initial scoping, a list of the cables and connections which met the criteria for this program was compiled, but after further review the licensee determined that all in-scope cables are part of the required 10 CFR 50.49 EQ program at CGS. The inspectors reviewed the original cable scoping population and compared the licensees EQ program inventory listing. The licensee chose to conservatively include all the in-scope license renewal cables within the 10 CFR 50.49 (Equipment Qualification) program. The Equipment Qualification program requires, by regulation, that cables be replaced or refurbished at the end of their qualified service life. The inspectors questioned the licensees decision to retain this aging management program and noted that CGS elected to retain a small population of the EQ cables and connections within this program for trending purposes, and to provide input to the EQ Program. The licensee retained the following instruments (cabling and connections) in the aging management program (also covered by the EQ regulation):

Main Steam Line Radiation Detectors

Reactor Building Exhaust Plenum Radiation Detectors

Standby Service Water Radiation Detectors This new program was implemented prior to the PEO and will be continued for the PEO.

Commitment 20 specified:

The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Program is a monitoring program that detects degradation of electrical cables and connections that are not environmentally qualified and used in circuits with sensitive, low-current applications. The program provides for a review of calibration records for low current instruments, in order to detect and identify degradation of the cable system insulation resistance. The program retains the option to perform direct cable testing.

The inspectors reviewed the license renewal program basis documents, completed work orders and surveillances for the inspections performed to satisfy the commitment, the licensee's 10 CFR 50.49 equipment tracking documents, cable routing and plant drawings, and corrective action documents. The inspectors discussed the licensees decision to retain the aging management program with the aging management program owner and identified no issues.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 20 and its associated AMP.

A.2.1.21 Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Inspection Program and Commitment 21 This was a new one-time inspection program, consistent with the GALL Report after exception, credited with managing the effects of aging for the metallic parts of in-scope non-environmentally qualified electrical cable connections.

The licensee has taken an exception to the periodic testing requirement in revision one of the GALL Report, noting that the one-time inspection is now consistent with the recommendations in LR-ISG-2007-02, Changes to Generic Aging Lessons Learned (GALL) Report Aging Management Program (AMP) XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements which was subsequently integrated into revision two of the GALL Report.

The licensee committed to use thermography (augmented by contact resistance testing) to detect loose or degraded connections that lead to increased resistance for a representative sample of metallic electrical connections in various plant locations.

This program provided a set of inspections, on a sampling basis (twenty percent of the population with a maximum sample of 25 constitutes a representative sample size), using the existing plant thermography program and augmented by contact resistance testing as necessary. The one-time inspections were performed to detect loose or degraded connections that could lead to increased resistance of metallic electrical connections in various plant locations. The licensee documented the inspection results in ENGNW-00461-REPT-019, XI.E6 Sampling and Inspection Plan.

This new one-time program was implemented prior to the PEO.

Commitment 21 specified:

The Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements Inspection detects and characterizes the material condition of metallic electrical connections within the scope of license renewal. The inspection uses thermography (augmented by contact resistance testing) to detect loose or degraded connections that lead to increased resistance for a representative sample of metallic electrical connections in various plant locations.

The inspectors reviewed the Sampling and Inspection Plan, license renewal documents, completed work orders for the inspections performed to satisfy the commitment, and corrective action documents. The inspectors discussed the results of the one-time inspections with the aging management program owner. This program is also covered by licensee procedure CCMP-01, Cable Condition Monitoring Program. The program inspections were performed prior to entering the PEO and no aging issues were identified.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 21 and its associated one-time inspection AMP.

A.2.1.23 External Surfaces Monitoring Program and Commitment 23 This is an existing condition monitoring program, consistent with the GALL Report after taking an exception for the Corrosion Under Insulation (CUI) Inspections requirements. The external surfaces monitoring program accomplishes the same objectives as the CUI program. Although the licensee did not commit to LR-ISG-2012-02 for CUI inspections, the licensee plans to perform a total of 15 CUI inspections over a 10-year period, in addition to the external surfaces monitoring aging management program.

The external surfaces monitoring program is credited with managing:

loss of material for external surfaces of steel, stainless steel, aluminum, copper, copper alloy (greater than15 percent zinc (Zn)), and gray cast iron exposed to condensation, air-indoor uncontrolled and air-outdoor;

cracking of aluminum exposed to condensation environments;

hardening and loss of strength for elastomer mechanical sealants and flexible connections in the HVAC systems; This existing program was enhanced, as described below, implemented prior to the PEO, and will be continued for the PEO.

Commitment 23 specified:

The licensee committed to enhancing the program resulting in the addition of several material types to the program scope, additional aging effects for review, and additional inspection techniques:

Aluminum, copper alloy, copper alloy > 15 % Zn, gray cast iron, stainless steel (including CASS), and elastomers added to the program scope;

Cracking as an aging effect for aluminum components was added;

Visual (VT-1 or equivalent) or volumetric examination techniques are used to detect cracking;

Hardening and loss of strength as an aging effect for elastomer based mechanical sealants in HVAC systems was added; and

Physical examination (i.e. manual manipulation) techniques used in addition to visual inspection to detect hardening and loss of strength for elastomer-based mechanical sealants in HVAC systems was added.

This program uses periodic plant system inspections and walkdowns to monitor for material degradation and leakage. Visual inspections are conducted for component surfaces at least once per refueling cycle. The program inspects piping, piping components, ducting, polymeric components, insulation jacketing, and other components. For metallic components, coatings deterioration is an indicator of possible underlying degradation. The aging effects for flexible polymeric components are monitored through a combination of visual inspection and manual or physical manipulation of the material. Visual inspection of flexible polymers for hardening and loss of strength and observed surface cracking, discoloration, and, for elastomers with internal reinforcement, the exposure of reinforcing fibers, mesh, or underlying metal. The program is also credited with managing loss of material from internal surfaces of metallic piping and components in the fire water (FW) systems that are normally empty and dry, such as pre-action and deluge systems.

The program is implemented, and inspections are controlled by engineering program procedure ENG-PRG-08, License Renewal External Surfaces Monitoring and Aging Management Plant Walkdown Procedure. Inspections were conducted prior to the start of the PEO and will be performed every two

(2) years in the PEO for all plant rooms or areas.

The inspectors reviewed license renewal program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program prior to the PEO. The inspectors held discussions with the program owner, and reviewed licensee staff training provided as part of the program. In addition to the program owner, the site uses system engineers to aid and support the inspections.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 23 and its associated AMP.

A.2.1.24 Fatigue Monitoring Program and Commitment 24

The Fatigue Monitoring Program (FMP) manages fatigue of the reactor pressure vessel by tracking thermal cycles as required by Technical Specification 5.5.5, Component Cyclic or Transient Limit. The FMP also manages fatigue of other components (including the American Society of Mechanical Engineers (ASME) Class 1 reactor coolant pressure boundary, high energy line break locations, and Primary Containment) by tracking transient cycles. The FMP is a combination of time-limited aging analyses (cumulative usage factor calculations) and transient counting procedures. The FMP uses the systematic counting of plant transient cycles to ensure that the numbers of analyzed cycles are not exceeded, thereby ensuring that component fatigue usage limits are not exceeded. The BWR Vessel Internals Program contributes to managing fatigue of the jet pumps by checking the jet pump set screw gaps each outage. If any out of specification gaps are found, Columbia would calculate the additional fatigue accumulated by the jet pumps due to those gaps. The FMP acceptance criteria are to maintain the number of counted transient cycles below the analyzed number of cycles for each transient. The Columbia program periodically updates the cycle counts. When the accumulated cycles approach the analyzed design cycles, corrective action is required to ensure the analyzed number of cycles is not exceeded. Corrective action may include update of the fatigue usage calculation. Any re-analysis would use an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case) to determine a valid Cumulative Usage Factor (CUF). This program is an existing program that will be enhanced, as described below, before the PEO, and continued for the PEO.

Commitment 24 specified:

The Fatigue Monitoring Program Section 2.1.b will be consistent with NUREG-1801 Revision 2: In accordance with 10 CFR54.21(c)(1)(iii), the Fatigue Monitoring Program will be used to manage the effects of aging due to fatigue on the intended functions of the components associated with fatigue TLAAs for the PEO.

The Fatigue Monitoring Program is an existing program that will be continued for the PEO, with the following enhancements:

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 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.

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 inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 24, and its associated AMP.

A.1.2.25 Fire Protection Program and Commitment 25 This is an existing program, revised to reflect selected changes introduced in revision 2 of the GALL Report, credited with managing aging effects related to loss of material, cracking, increased hardness, shrinkage, loss of strength and change in material properties for susceptible components in the scope of license renewal that have a fire barrier function. Halon, carbon dioxide, and dry chemical fire suppression systems are also included to ensure that functionality and operability are maintained.

CGS added additional fire-resistant materials (e.g., flamastic, 3M fire wrapping, spray-on fire proofing material, intumescent coating, etc.) to be managed under this program. CGS also revised the program to remove the diesel-driven fire pumps and associated fuel oil supply lines, meeting the revised guidelines in the GALL Report.

These components are now managed by the Fuel Oil Chemistry Program and the Internal Surfaces of Miscellaneous Piping and Ducting Program. This program is an existing program that will be continued for the PEO.

The licensee currently performs periodic visual inspections of fire barrier penetration seals, structural fire barriers (walls, ceilings, floors), fire wrapping, fire proofing, and intumescent coatings that serve a fire barrier function. Additionally, the licensee visually inspects 10 percent of each type of fire-rated penetration seal every 18 months, with the entire population inspected on a 15-year cycle; visually inspected the exposed external surfaces of fire barriers, fire wraps, raceway fire barriers and fire proofing for abnormal degradations/changes in appearance that could affect the barrier function every 18 months; performed visual examinations and functional tests of fire dampers every 8 years and inspected fire-rated doors on a monthly (abnormal wear and ensure latching as required) basis and an additional more intrusive fire door operability inspection on an annual basis, which included lockset and bolt mechanism functionality, closing speed checks and clearance checks.

This is an existing program that will be continued for the PEO.

Commitment 25 specified:

The Fire Protection Program is an existing program that will be continued for the PEO.

The inspectors reviewed the implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program prior to the PEO, plant operating experience, and corrective action documents. The inspectors interviewed fire protection personnel.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 25 and its associated AMP.

A.1.2.26 Fire Water Program and Commitment 26 This is an existing program consistent after enhancements with GALL Report credited with managing aging of the water-based fire suppression components in the scope of license renewal. This program is part of the site NRC approved fire protection program described in Appendix F of the Final Safety Analysis Report (FSAR), and the licensee has committed to continue the program throughout the PEO.

The program is structured to manage loss in a variety of materials including carbon steel, gray cast iron, copper alloy, copper alloy > 15% Zn and stainless steel, for piping and piping components such as valve bodies, tubing, strainer bodies, standpipes, sprinklers (spray nozzles), pump casings, orifices, and hydrants.

The program manages corrosion on the internal surfaces of the buried fire water piping, cracking due to stress corrosion cracking/intergranular attack of copper alloy >

15% zinc components exposed to raw water, and manages loss of material due to selective leaching for the copper alloy > 15% zinc spray nozzles that are part of a wet-pipe sprinkler configuration exposed.

The licensee also credits other aging management programs to manage aging in the fire water system. The Selective Leaching Inspection program is credited with managing loss of material in susceptible components other than the wet-pipe spray nozzles, including components constructed of gray cast iron; the External Surfaces Monitoring Program is credited with managing loss in normally empty (dry) sprinkler piping; the Buried Piping and Tank Inspection program manages external surfaces of buried fire water suppression piping; the Flow-Accelerated Corrosion program is credited with managing loss of material in susceptible fire protection system components other than locations identified to have cavitation erosion in the past. The licensee enhanced the program to credit scheduled ultrasonic examinations in cavitation susceptible locations not covered by the Flow-Accelerated Corrosion program. This program is an existing program that will be enhanced, as described below, before the PEO, and continued for the PEO.

Commitment 26 specified:

The licensee committed to enhancing the program, prior to the PEO, to include:

Performing either ultrasonic testing or internal visual inspection of representative portions of above ground fire protection piping exposed to water but do not normally experience flow (stagnant areas) at reasonable intervals based on engineering review of the results. The inspectors confirmed the licensee had implemented this enhancement.

Performing ultrasonic testing of representative portions of above ground fire protection piping that is exposed to flowing water during periodic tests, and susceptible to a loss of material due to erosion (wall thinning). Perform engineering review of the results and trends to determine future inspection intervals and expansion of representative portions. The inspectors confirmed the licensee had implemented this enhancement.

Either replace sprinkler heads that have been in place for 50 years or submit representative samples to a recognized laboratory for field service testing in accordance with NFPA 25 recommendations. Perform subsequent replacement or field service testing of representative samples at 10-year intervals thereafter or until there are no sprinkler heads installed that reach 50 years of service life during the PEO. Perform hardness testing (or equivalent)of the sprinkler heads as part of their NFPA sampling, to determine whether loss of material due to selective leaching is occurring. The inspectors confirmed the licensee has implemented this enhancement and is meeting this commitment.

Perform visual inspection of a representative sample of copper alloy > 15% Zn components exposed to water (with presence of ammonia) for evidence of cracking within the 10-year period prior to entering the PEO, and within 10 years after entering the PEO. The inspectors confirmed the licensee had implemented this enhancement.

The licensee continues to implement periodic inspection and testing activities as required by the existing fire protection program requirements including hydrant and hose station inspections, flushing, flow tests, and spray and sprinkler system inspections. The operability requirements, compensatory actions, and testing requirements for the essential fire protection systems are contained in the Licensee Controlled Specification, section 1.10, Fire Protection.

The inspectors reviewed license renewal documents, aging management program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program prior to the PEO, plant operating experience, and corrective action documents. The inspectors interviewed plant personnel and walked down fire water system equipment, including the fire pumps and jockey pumps, fire water short-lived bladder tank, and associated piping and valves.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 26 and its associated AMP.

A.2.1.28 Flow Accelerated Corrosion Program and Commitment 28 The Flow-Accelerated Corrosion (FAC) FAC Aging Management Program (AMP) is an existing CGS program that, with enhancements, manages loss of material for all components located in the treated water environment of systems that are susceptible to FAC. The licensee uses the computer program CHECKWORKS to model susceptible piping for predictive analysis, performs inspections and non-destructive exams (to baseline and monitor wall-thinning), evaluates industry experience, and uses engineering judgment to monitor and predict FAC wear rates. This program is an existing program that was enhanced, as described below, and continued for the PEO.

Commitment 28 specified:

The Flow-Accelerated Corrosion (FAC) Program is an existing program that will be continued for the PEO, with the following enhancements:

Add the containment nitrogen system components supplied with steam from the auxiliary steam system to the scope of the program.

Add gray cast iron as a material identified as susceptible to FAC.

The inspectors reviewed license renewal documents, aging management program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program prior to the PEO, plant operating experience, and corrective action documents.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 28 and its associated AMP.

A.2.1.29 Fuel Oil Chemistry Program and Commitment 29 This program managed aging effects related to loss of material and cracking on the internal surfaces of fuel oil system components by verifying and maintaining the quality of the fuel oil. The licensee performed maintenance tasks to monitor fuel oil quality and the levels of water and microbiological organisms to prevent plugging of filters, fouling of injectors, and corrosion of fuel systems. The licensee uses a polisher skid to process new fuel before adding it to the bulk fuel oil storage tank; before transferring fuel oil to the emergency diesel generator storage tanks, and any time sampling reveals that the fuel oil is out of specification. In addition, the licensee has a mobile polisher skid that they use to process fuel oil before adding to the diesel driver fire pump tanks. The systems and components in this program included the bulk fuel oil tank, emergency diesel tanks, emergency diesel day tanks, and the diesel fire pump tanks. This program is an existing program that will be continued for the PEO.

Commitment 29 specified:

The Fuel Oil Chemistry Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, and monitored parameter trends for the last 10 years. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents, parameter trends, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 29 and its associated AMP.

A.2.1.30 Heat Exchangers Inspection and Commitment 30 The Heat Exchangers Inspection is a new one-time inspection of heat transfer surfaces of in-scope heat exchangers and coolers exposed to treated water, closed cooling water, or indoor air environments using a variety of non-destructive examination methods, including visual and volumetric techniques. It detects reduction in heat transfer due to fouling on in-scope components. This is a new, one-time aging management program, which was completed within the 10-year period prior to the PEO.

Commitment 30 specified:

The Heat Exchangers Inspection is a new one-time activity. The Heat Exchangers Inspection detects and characterizes the surface conditions with respect to fouling of heat exchangers and coolers that are in the scope of the inspection and exposed to treated water, closed cooling water, or indoor air. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 30 and its associated AMP.

A.2.1.31 High-Voltage Porcelain Insulators Aging Management Program (Plant Specific)

The High-Voltage Porcelain Insulators program is an existing plant-specific program credited with managing buildup of hard water residue and other contaminants on the surfaces of the post insulators between the 115-kV backup transformer and circuit breaker E-CB-TRB located in the station transformer yard. This program is an existing program that was enhanced, as described below, and continued for the PEO.

Commitment 31 specified:

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

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

This preventive maintenance program includes inspecting and cleaning of uncoated post insulators located in the transformer yard every two years. Coated post insulators located in the transformer yard are visually inspected for damage every two years and re-coated every ten years. The licensee developed repetitive preventive maintenance activities to clean and remove mineral deposits from 115-kV insulators, perform Equivalent Salt Deposit Density (ESDD) testing or other industry recognized test for detecting contamination every eight years on the 230-kV Ashe substation insulators. Coated 230-kV line insulators in the transformer yard (installed R24) are recoated every 10 years.

The inspectors reviewed license renewal aging management program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program prior to the PEO, plant operating experience, and corrective action documents.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 31 and its associated AMP.

A.2.1.32 Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program and Commitment 32 This is a new aging management program, consistent with GALL Report with exception and after enhancement, credited with managing aging related to normally energized inaccessible power cables (greater than or equal to 400V) that could be exposed to significant moisture.

The licensee committed to, and the program was enhanced to include:

scope broadened to include inaccessible power cables (400V to 2kV), in response to industry and plant-specific operating experience;

frequency of the manhole inspections will be at least annually, with the first inspections to be performed prior to the PEO.

verify operation of dewatering devices and manhole water level alarms prior to heavy rain or flooding events;

details regarding the potential testing methodologies (additional types of acceptable tests) for the cable testing;

frequency of the cable testing portion of the program will be once every 6 years, with the first test to be performed prior to the PEO; Commitment 32 specified:

The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program manages the aging of inaccessible medium-voltage and lower service voltage cables that are not environmentally qualified and are within the scope of license renewal. The program provides for testing to identify the conditions of the conductor insulation, and also provides for periodic inspection and drainage (if necessary) of electrical manholes. The frequency of the cable testing portion of the program will be once every 6 years, with the first test to be performed prior to the PEO. The frequency of the manhole inspections will be at least annually, with the first inspections to be performed prior to the PEO.

The scope of the AMP will be enhanced to include inaccessible power cables (400V to 2kV), in response to industry and plant-specific operating experience.

The licensee implemented the commitments. The inspections include direct observation that cables are not wetted or submerged, and that cables / splices and cable support structures are intact. Tan-delta cable testing is used for the medium-voltage cables to determine overall condition of the cable insulation. Very Low Frequency (VLF) Withstand testing (a form of insulation resistance testing) is performed simultaneously with a Tan-Delta test or a second Tan-Delta test is performed after the Withstand test to identify any severe localized degradation. The lower-voltage power cables are tested with a megger test. Anomalies are addressed in the site corrective action program.

During work to broaden the scope and identify inaccessible cables that operate at greater than or equal to 400V, the licensee identified another manhole (E-MH-B105)that is subject to the requirements of the program. This manhole contains one in-scope low voltage cable associated with the fire protection system and is located inside the Circulating Water Pumphouse (CWPH) underneath (below ground level)the motor control centers. The sump access hatch lies at an elevation higher than the probable maximum precipitation flood level, so this location is not subject to water intrusion from environmental conditions; however, this manhole is subject to site-specific water intrusion due to circulating water pump proximity and a backflow condition when the circulating water pumps are stopped. The vault has an installed sump pump. Steps to address the water intrusion are in operating procedures SOP-CW-OPS and SOP-CW-SHUTDOWN.

The licensee took an exception to the GALL requirements and will not verify the operation of the sump pump located in CWPH cable vault B-105 prior to any known or predicted heavy rain or flooding event. The inspectors had no concerns with this exception for the following reasons:

the manhole is elevated inside the CWPH, and not subject to water intrusion from rainfall.

the manhole historical trends over decades of operation showed water intrusion did not reach the higher elevations of the cables; and

the manhole is periodically inspected to ensure the sump pump is functional.

The original program description from FSAR Appendix A was revised by LDCN 22-022 to clarify that the sump pump in E-MH-B105 has no water level alarm, and as a result, CWPH cable vault B-105 will not have a water level alarm operation verified.

The inspectors verified this exception during a walkdown inspection of manhole B105 and had no concerns.

The inspectors reviewed licensee procedure CCMP-01, Cable Condition Monitoring Program, and supporting documents, completed work orders satisfying the testing and examination requirements for the program prior to the PEO, the license renewal program basis document, completed a walkdown of MH-B105 (added to program)with program personnel, and reviewed plant operating experience.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 32 and its associated AMP.

A.2.1.34 Inservice Inspection (ISI) Program - IWE and Commitment 34 & 64 This is an existing program that establishes responsibilities and requirements for conducting IWE inspections as required by 10 CFR 50.55a. The program employs visual examination of all accessible surface areas of the steel containment and its integral attachments, and containment pressure-retaining bolting in accordance with the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE. This is an existing program that will be continued for the PEO.

Commitment 34 specified:

The Inservice Inspection (ISI) Program - IWE is an existing program that will be continued for the PEO.

The inspectors reviewed procedures, work orders, examination data, drawings, and corrective actions related to the ISI - IWE program. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance with commitment 34, and its associated AMP.

Commitment 64 specified:

Verify leakage is not entering the annular space between the containment vessel and the concrete shield wall from the outer refueling bellows seal. Inspection of the portions of the outer containment vessel shell made accessible by opening four of the eight inspection ports in the containment vessel at 570-foot elevation will be performed to check for evidence of leakage.

The inspectors reviewed procedures, work orders, examination data, drawings, and corrective actions related to the one-time inspection. The inspectors interviewed plant and implementing personnel. The inspectors had concerns with the quality and scope of the inspections performed and discussed these issues with the licensee.

Specifically, the work order documentation did not contain the expected, objective evidence that the inspection was completed satisfactorily, and lacked photos of the subject components. The licensee generated CR 449744 in response to these issues and plans to reperform the inspections during a future refueling outage. This aging management program and associated commitments remains open and will be reinspected at a future date.

A.2.1.35 Inservice Inspection (ISI) Program - IWF and Commitment 35 This is an existing program that establishes responsibilities and requirements for conducting IWF Inspections for ASME Class 1, 2, and 3 component supports as required by 10 CFR 50.55a. The program employs visual examination of supports based on sampling of the total support population for degradation that potentially compromises support function or load capacity is identified for evaluation. This is an existing program that will be continued for the PEO.

Commitment 35 specified:

The Inservice Inspection (ISI) Program - IWF is an existing program that will be continued for the PEO.

The inspectors reviewed procedures, work orders, examination data, drawings, and corrective actions related to the ISI - IWF program. The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 35, and its associated AMP.

A.2.1.36 Lubricating Oil Analysis Program and Commitment 36 This program managed aging effects related to the onset and propagation of loss of material resulting from crevice, galvanic, general, or pitting corrosion or selective leaching or reduction in heat transfer. The licensee maintained the oil environment in the mechanical systems to the required quality by monitoring parameters such as particulate and water content, viscosity, neutralization number, and flash point.

Periodically, the licensee sampled lubricating oil from plant components subject to aging management review. This is an existing program that will be continued for the PEO.

Commitment 36 - Lubricating Oil Analysis Program specified:

The Lubricating Oil Analysis Program is an existing program that will be continued for the PEO, with enhancements to include the following fire protection system components that are exposed to lubricating oil within the scope of the program: (1)fire protection diesel engine heat exchangers (lube oil coolers),

(2) fire protection diesel engine lube oil piping, and

(3) fire protection diesel engine lube oil pump casings.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, procedures, and monitored parameter trends for the last 10 years. The inspectors interviewed plant and implementing personnel. The inspectors determined that the licensee had performed inspections of a diesel engine lubricating oil heat exchanger but did not select any components in the piping nor a lubricating oil pump casing. The inspectors determined that the licensee had plans to replace both fire pumps and their associated diesel engines in 2025 because of reliability and obsolescence issues. The licensee was in the planning stages of Design Engineering Change 19770, MASTER EC - Replacement of Diesel Driven Fire Pumps, Revision 0 at the time of this inspection.

Because the licensee had not inspected each of the components added as an enhancement and because the components had not been replaced, the inspectors determined that this commitment had not been met. Consequently, this aging management program and commitment 36 remains open and will be reinspected at a future date.

A.2.1.37 Lubricating Oil Inspection and Commitment 37 This one-time inspection evaluated and characterized the material conditions in systems and components for which the licensee credited the lubricating oil analysis program with aging management. The inspection provides direct evidence as to whether, and to what extent, a loss of material caused by corrosion, a reduction of heat transfer, or selective leaching had occurred. This is a new, one-time, program that was be completed prior to the PEO.

Commitment 37 specified:

The Lubricating Oil Inspection is a new activity. The Lubricating Oil Inspection detects and characterizes the condition of materials in systems and components for which the Lubricating Oil Analysis Program is credited with aging management. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, plant drawings, work orders, inspection guidelines, and inspection results. The inspectors interviewed plant and implementing personnel.

The inspectors determined that the licensee had taken a representative sample of components that reflected the lubricating oil material-environments at the plant.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 37 and its associated one-time AMP.

A.2.1.38 Masonry Wall Inspection and Commitment 38 This program managed aging effects through visual inspection of external surfaces prior to the loss of the structures or components intended function(s) by monitoring for cracking in joints and blocks that could affect wall qualification. The licensee had no Category 1 masonry block walls but included walls that performed a fire barrier function, which are also managed by the fire protection program. The licensee included the masonry wall inspections as part of their Structures Monitoring Program. This is an existing program that will be continued for the PEO.

Commitment 38 - Masonry Wall Inspection specified:

The Masonry Wall Inspection is an existing program that will be continued for the PEO, with enhancements that specify that for each masonry wall, the extent of observed masonry cracking or degradation of steel edge supports, and bracing are evaluated to ensure that the current evaluation basis is still valid. Corrective action is required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e., acceptance by further evaluation).

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, plant drawings, work orders, inspection guidelines, and inspection results. The inspectors interviewed plant and implementing personnel.

The inspectors determined that the licensee had specific requirements and acceptance criteria in Procedure ENG-PRG-09, License Renewal Structures Monitoring Program Inspections, Revision 1 related to masonry wall inspections.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 38 and its associated aging management program.

A.2.1.39 Material Handling System Inspection and Commitment 39 This program manages loss of material for cranes (including bridge, trolley, rails, and girders), monorails, and hoists within the scope of license renewal. This includes all cranes/hoists specified in the response to NUREG-0612, Control of Heavy Loads, as well as other monorail/hoist system and miscellaneous cranes. This is an existing program, which is based on American Society of Mechanical Engineers (ASME)

B30.2 for overhead and gantry cranes, ASME B30.11 for monorail systems and underhung cranes, and ASME B30.16 for overhead hoists. This existing program will be continued for the PEO.

Commitment 39 specified:

The Material Handling System Inspection Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, non-destructive examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 39, and its associated AMP.

A.2.1.40 Metal-Enclosed Bus Program and Commitment 40 This is a new aging management program consistent with the GALL Report after exception and enhancement. The program is credited with detecting degradation of the metal enclosed bus in scope of license renewal. The metal-enclosed bus addressed by this program includes the 4.16-kV non-segregated bus (E-BUS-NONSEG/S/Y) associated with transformer E-TR-S (the 230-kV startup auxiliary power transformer to the SM-1 and SM-3 switchgear).

In a letter dated July 29, 2011, the applicant informed the NRC that the original bolted connections (described in the GALL revision one MEB Program) had been replaced with welded aluminum flexible transition connections during refueling outage 20 under Engineering Change 9008. The welded aluminum flexible connections are expected to significantly reduce the potential for a main turbine trip as a result of failure of bolted connections in the MEB.

The licensee revised their FSAR Appendix A, Section A.2.1.40 to reflect the removal of thermographic inspections for the previous bolted bus connections (removed by Engineering Change 9008) and added phase-to-phase bus resistance testing for the new welded flex connectors. This revision also updated the License Renewal Commitment (FSAR Table A-1, Commitment 40) for the MEB program. The inspectors reviewed these changes and identified no concerns. The change did not affect the bolted connections on the MEB termination ends to the switchgear or the transformer.

The licensee has implemented the following exceptions:

The MEB program has replaced the bus conductor bolted connections with welded aluminum flex connectors (laminated) which creates an exception to the aging effects identified in the GALL, which is concerned with loosening of bolted connectors. The replacement of bolted connections with welded flex connectors introduced a new postulated aging effect of increased resistance from cracking due to thermal cycling of the flexible connector laminations and the connector-to-bus welds.

The MEB 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. The inspection of the bus assembly external surfaces and the bus assembly structural supports will continue to be performed by the Structures Monitoring Program.

The licensee committed to conduct periodic visual inspections of the interior sections of the bus for signs of cracking or fatigue on the flex connector, and the elastomer seals at the joints of the duct sections. The bus enclosure internals are inspected for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. The internal bus supports are inspected for structural integrity and any sign of cracks. The program also inspects bus insulation and removable flex connector boots (weld coverings) for anomalies such as embrittlement, cracking, melting, swelling, or discoloration, or any other signs of degraded insulation which may indicate overheating or aging degradation.

The licensee also committed to conduct phase-to-phase bus contact electrical resistance testing to ensure all in-scope connectors (inaccessible flex connector laminations and the connector-to-bus welds) have not experienced increased resistance from cracking and conduct visual inspection of the welded flex connections to ensure that the flex connections do not have any breaks or cracks in the welds.

This is a new program that was implemented prior to the PEO, then continued for the PEO.

Commitment 40 specified:

The Metal-Enclosed Bus program is a new program that detects degradation of the metal enclosed bus in scope of license renewal. The program includes periodic inspection of the interior sections of the bus, and the elastomer seals at the joints of the duct sections. The program also conducts periodic connection resistance tests to ensure all welded flex connections are not experiencing any aging effects. These program aging management activities will be performed once every 10 years, with the first conducted prior to the PEO.

These aging management program activities will continue to be performed at least once every 10 years in the PEO.

The program requires that in-scope bolted connections (if it is ever reinstalled) will be subject to inspection by thermography through the existing infra-red windows in the bus duct.

The inspectors reviewed license renewal program basis documents, program implementing procedures, completed work orders satisfying the testing and examination requirements for the program prior to the PEO, the controlled MEB vendor manual, completed preventive maintenance tasks, and plant operating experience. The licensee had an existing MEB maintenance program to which the aging management program requirements have been integrated. The inspectors also inspected a sample of the aluminum flexible transition connections, and a sample of the existing insulator supports. The inspectors interviewed the MEB program owner and discussed aging management and maintenance aspects of the site MEB.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 40 and its associated AMP.

A.2.1.42 Open Cycle Cooling Water Program and Commitment 42 This program manages loss of material due to crevice, galvanic, general, pitting, and microbiologically influenced corrosion (MIC), and erosion for components located in the Service Water (SW) system and components connected to or serviced by that system. The program also manages fouling due to particulates (e.g., corrosion products) and biological material (micro-and/or macro-organisms) resulting in reduction in heat transfer for heat exchangers within the scope of the program.

The program consists of inspections, surveillances, and testing to detect the presence, and assess the extent, of fouling and loss of material, combined with chemical treatments and cleaning activities to minimize fouling and loss of material.

The existing program is a combination condition monitoring and mitigation program that implements the recommendations of NRC Generic Letter (GL) 89-13, Service Water System Problems Affecting Safety-Related Equipment. This is an existing program, which was enhanced as described below, and will continue for the PEO.

Commitment 42 specified:

The Open Cycle Cooling Water Program is an existing program that will be continued for the PEO, with the following enhancements:

Address loss of material due to cavitation erosion (for the standby service water (SW), circulating water (CW), plant service water (TSW), and tower make-up (TMU) systems) with activities such as opportunistic inspections of portions of the systems that have had indications of cavitation erosion in the past.

Non-safety related components within the license renewal scope in the SW, CW, TSW, and TMU systems, and the non-safety related components served by or connected to the TSW system that are in the process sampling, process sampling radioactive, radwaste building mixed air, radwaste building return air, reactor building return air, and reactor closed cooling water systems, are included within the Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, plant drawings, work orders, inspection guidelines, thermal performance results, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 42 and its associated AMP.

A.2.1.44 Preventative Maintenance - RCIC Turbine Casing and Commitment 44 Preventive Maintenance - Reactor Core Isolation Cooling (PM-RCIC) Turbine Casing aging management program (AMP) is an existing, plant specific program comprised of periodic inspection and surveillance activities to detect aging and age-related degradation on RCIC-DT-1 and associated component to ensure the components continue to perform their intended functions. The Preventative Maintenance - RCIC Program is credited for managing loss of material due to corrosion on the internal steel surfaces in the RCIC pump turbine casing and the in-scope piping and piping components in steam lines downstream from the steam admission valve.

This program is accomplished through inspection, repair, and overhaul of the RCIC turbine upper and lower halves of the turbine casing itself, as well as on gland seal housings and reversing chambers internal to the casing. The licensee also inspects the steam admission valve, governor valve, and upstream piping on ten year intervals. This is an existing program that will be continued for the PEO.

Commitment 44 specified:

The Preventive Maintenance - RCIC Turbine Casing is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, plant drawings, work orders, inspection guidelines, surveillance testing performance results, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 44 and its associated AMP.

A.2.1.45 Reactor Head Closure Studs Program and Commitment 45 This is an existing program that manages cracking due to SCC and loss of material due to corrosion for the reactor head closure stud assemblies (studs, nuts, washers, and bushings). The program examines reactor vessel stud assemblies in accordance with the examination and inspection requirements specified in the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWB. This is an existing program that will be continued for the PEO.

Commitment 45 specified:

The Reactor Head Closure Studs Program is an existing program that will be continued for the PEO.

The inspectors reviewed procedures, work orders, examination data, drawings, and corrective actions related to the reactor head closure studs program.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

During a field walkdown of fastener inventory storage, specifically high-strength bolts, the inspectors identified rust and corrosion on multiple samples. The licensees site procedure for storage of components, SWP-MMP-02, did not include the storage requirements of NUREG-1801 Rev. 2, XI.M18 Bolting Integrity, EPRI TR-104213 - Bolted Joint Maintenance & Applications Guide, Section 16.6 Segregation and Storage Requirements, specifically Section 16.6.3 the storage area must ensure the cleanliness of the bolting material and prevent corrosion. The licensee generated condition report CR 00449816 to add the requirement into their warehouse storage procedure.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 45, and its associated AMP.

A.2.1.46 Reactor Vessel Surveillance Program and Commitments 46, 54, 60 and This program managed aging effects related to reduction of fracture toughness caused by radiation embrittlement for the low alloy steel reactor vessel shell and welds in the beltline region. This program incorporates the Boiling Water Reactor Vessel and Internals Project (BWRVIP) Integrated Surveillance Program (ISP), as described in reports BWRVIP-86-A and BWRVIP-116.

The provisions of 10 CFR 50 Appendix G require Columbia to operate within the currently licensed pressure-temperature (P-T) limit curves, and to update these curves as necessary. The reactor vessel P-T limit curves, as contained in plant technical specifications, will be updated as necessary through the PEO. This is an existing program that will be continued for the PEO.

Commitment 46 - Reactor Vessel Surveillance Program specified:

The Reactor Vessel Surveillance Program is an existing program that will be continued for the PEO.

The inspectors determined that the licensee implemented this program using Procedure SWP-VIP-02, Columbia's RPV Surveillance Program and Implementation of the BWRVIP Integrated Surveillance Program (ISP), Revision 8 and Procedure WPPS-ENT-089, Columbia Generating Station Reactor Pressure Vessel Surveillance Program, Revision 6. NRC had approved the participation of the licensee in the BWRVIP ISP in 2005. The licensee was not a host plant but relied on generic data and surveillance coupon data from host plants that had matching material and weld heat numbers. As prescribed by the BWRVIP ISP, the licensee updated their analyses as required and submitted them to the NRC for approval of the technical specifications P-T limit curves, as well as the adjusted reference temperature and upper shelf energy calculations.

Commitment 54 - Pressure-Temperature Limits specified:

The Columbia P-T limit curves were revised in 2005 to include the effects of power uprate to 3486 MWth. The P-T limits are valid for 33.1 EFPY (effective full power years) through the end of the currently licensed period. P-T limits for the PEO will be calculated using the most accurate fluence projections available at the time of the recalculation. The projections may be adjusted if there are changes in core design or if additional surveillance capsule results show the need for an adjustment. The projected adjusted reference temperature (ART) for the PEO gives confidence that future P-T curves will provide adequate operating margin. License amendment requests to revise the P-T limits will be submitted to the NRC for approval, when necessary to comply with 10 CFR 50 Appendix G, as part of the Reactor Vessel Surveillance Program.

The inspectors determined that the licensee submitted a license amendment to operate for 54 effective full power years. NRC Letter Columbia Generating Station - Issuance of Amendment No. 268 to Revise Technical Specification 3.4.11, RCS Pressure and Temperature (P/T) Limits (EPID L-2021-LLA-0191), dated November 23, 2002, revised the P-T limit curves in technical specifications and satisfied commitment 54. The amendment provided valid P-T limit curves for 54 effective full power years that covered operation through the end of the PEO.

Commitment 60 - BWRVIP-116 specified:

Implementation of the BWRVIP ISP(E) for Columbia will include the following details in support of the contingency plan:

(1) Energy Northwest will include the requirement to keep all tested material (irradiated or unirradiated) for possible future reconstitution and testing;

(2) The Columbia site procedure, as modified, will continue to require any capsules removed from the reactor vessel to be stored in a manner that would support future re-insertion of these capsules in the reactor vessel; and

(3) Energy Northwest will notify the BWRVIP prior to any change in the storage of on-site materials. NRC approval will be obtained prior to any change in the storage of surveillance materials that would affect the potential use of the materials under the contingency plan.

The inspectors determined that the requirements of BWRVIP-116, BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Implementation for License Renewal, Revision 0 had been incorporated into BWRVIP-86A, BWR Vessel and Internals Project Updated BWR Integrated Surveillance Program (ISP)

Implementation Plan, Revision 1. The inspectors determined that the licensee had incorporated the following requirements in Procedure SWP-VIP-02:

(1) keep tested material for future reconstitution and testing,

(2) retain capsules in a manner that supports re-insertion into the reactor vessel, and

(3) notify BWRVIP prior to any change in onsite storage of materials.

Commitment 70 - TLAA - Embrittlement of Reactor Vessel specified:

Perform a 54 EFPY equivalent margin analysis for the embrittlement (upper shelf energy) of the reactor vessel N12 (pre-instrumentation) nozzle forgings.

The inspectors determined that the licensee had met this commitment as documented in Engineering Evaluation GEH Report 006N3818, Columbia Generating Station - Upper Shelf Energy and Equivalent Margin Analysis, Revision

0. The inspectors reviewed the aging management program basis document, gap

analysis, operating experience, plant drawings, procedures, engineering evaluations, and industry guidelines. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 46, commitment 54, commitment 60, commitment 70 and their associated aging management program or plant procedures.

A.2.1.47 Selective Leaching Inspection and Commitment 47 The Selective Leaching Inspection is a new one-time inspection of internal and external surfaces of vulnerable components (i.e. gray cast iron, un-inhibited copper alloy with > 15% zinc, or copper alloy with > 8% aluminum) exposed to raw water (including moist air and condensation), fuel oil, and treated water (including closed cooling water and steam) environments through a combination of visual examination and hardness testing, or NRC approved alternative, within the 5-year period prior to the PEO to detect loss of material due to selective leaching. Inhibited brass alloys, such as admiralty brass and naval brass, are more resistant to selective leaching.

The licensee uses a combination of visual examinations and mechanical examination techniques such as scraping, tapping and destructive testing when the opportunity arises.

The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water, treated water, fuel oil, soil, lube oil and moist air (including condensation) environments. The inspection provides direct evidence through a combination of visual examination and hardness testing, or NRC approved alternative, as to whether, and to what extent, the relevant effects of aging have occurred.

Commitment 47 specified:

The Selective Leaching Inspection is a new activity. The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water, treated water, fuel oil, soil, and moist air (including condensation) environments. The inspection provides direct evidence through a combination of visual examination and hardness testing, or NRC-approved alternative, as to whether, and to what extent, the relevant effects of aging have occurred.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 47, and its associated AMP.

Because the licensee had not completed inspections of all the components, and selective leaching corrective action program CRs remain open awaiting resolution, the licensee listed this commitment as open during the inspection. The inspectors agreed and determined that this commitment had not been met. Consequently, this aging management program and commitment 47 remains open and will be reinspected at a future date.

A.2.1.49 Small Bore Class 1 Piping Program and Commitment 49 The Small Bore Class 1 Piping Program is plant-specific program. The program detects and characterizes cracking of small bore (NPS equal to or greater than 1.0-inch and less than 4-inches) ASME Class 1 piping components and piping welds that are exposed to reactor coolant and provides inspections of selected small bore piping butt and socket welds using visual and volumetric examinations for cracking. The inspection techniques used demonstrate the capability to detect cracking in piping weld and base metal. The Columbia risk-informed ISI Program added the ISI program to manage cracking due to SCC and IGA, in addition to the BWR Water Chemistry Program and Small-Bore Class 1 Piping Inspection Program. Cracking due to flaw growth refers to cracking due to thermal and mechanical loading. The program was originally a continuing plant-specific inspection program, but Licensing Document Change Notice (LDCN) LDCN-22-023 was used to change the commitment to a one-time inspection.

Commitment 49 specified:

The Small-Bore Piping Program will inspect a sample of ASME Code Class 1 piping less than NPS 4 to 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.

The inspectors reviewed the aging management program basis document, gap analysis, inspection procedures, work orders, examination data, and corrective action program documents. The inspectors interviewed plant and implementing personnel.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance associated with commitment 49, and its associated AMP.

A.2.1.50 Structures Monitoring Program and Commitments 50 and 66 This program managed aging effects related to loss of material for plant structures and structural components. The Structures Monitoring Program encompasses and implements the Water Control Structures Inspection and the Masonry Wall Inspection.

This program implements provisions of the Maintenance Rule, 10 CFR 50.65, that relate to structures, masonry walls, and water control structures. Concrete and masonry walls that perform a fire barrier intended function are also managed by the fire protection program.

Commitment 50 specified:

The Structures Monitoring Program is an existing program that will be continued for the PEO, with the following enhancements:

Include and list the structures within the scope of license renewal that credit the Structures Monitoring Program for aging management.

Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation prior to backfilling.

Identify that the term structural component for inspection includes component types that credit the Structures Monitoring Program for aging management.

Include the potential degradation mechanism checklist in the procedural documents. The checklist also requires enhancement to include aging effect terminology (e.g., loss of material, cracking, change in material properties, and loss of form).

Specify that the responsible engineer shall review site groundwater and raw water testing results for pH, chlorides, and sulfates prior to inspection to validate that the below-grade or raw water environments remain non-aggressive during the PEO. Chemistry data shall be obtained from Columbias chemistry and environmental departments. Groundwater chemistry data shall be collected at least once every four years. The time of data collection shall be staggered from year to year (summer-winter-summer) to account for seasonal variations in the environment.

Specify additional direction for quantifying, monitoring, and trending of inspection results.

Provide better alignment with referenced Industry codes, standards, and guidelines regarding terminology and evaluation.

Revise to add sufficient acceptance criteria and critical parameters to trigger level of inspection and initiation of corrective action. ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structural elements, steel liners, joint, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R-96, will be developed, and added to the inspection procedure.

Conduct a base line inspection of the structures within the scope of license renewal plus a minimum of one additional inspection prior to entering the PEO.

The inspectors reviewed Procedure ENG-PRG-09, License Renewal Structures Monitoring Program Inspections, Revision 1, and determined that the licensee had included the each of the enhancements described above as guidance in the procedure. The inspectors confirmed that the licensee had conducted one additional inspection prior to entering the PEO.

Commitment 66 specified:

Perform a one-time internal inspection of the spent fuel pool telltale drain lines prior to the PEO to confirm the drain lines are free of obstructions. Unexpected inspection results of clogged lines 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.

The inspectors reviewed the actions taken by the licensee to confirm the lines remained free of any obstructions. The inspectors expected a borescope of the lines like that performed on the sandbox tell-tale drains. Instead, the licensee had taken a two-pronged approach. First, the licensee used a fish tape to confirm there were no obstructions in the final 12-foot vertical section and used an ultrasonic test of the first 3-feet from the spent fuel pool. This section had a 6-inch vertical drop to a 90-degree elbow, traveled for 7 inches then turned at a 90-degree elbow horizontally for 24 inches before becoming inaccessible. The licensee had not identified any water in the top section of the spent fuel pool drain line from their ultrasonic test. The inspectors confirmed that the licensee had demonstrated the accessible portions of the line remained clear of obstructions.

Second, the licensee provided information that described: the spent fuel pool contains demineralized water that would not result in boric acid clogging the lines as described by industry experience, the line is open to atmosphere with no valves, and no water has ever been seen leaking from the line.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, work orders, procedures, and inspection results. The inspectors interviewed plant and implementing personnel.

Because the inspectors had not seen any review of the reactor building exterior, the inspectors reviewed actions taken by the licensee to evaluate sealant placed on grout located on the reactor building exterior to prevent water intrusion potentially reaching reinforcing bars. The licensee had sealed the grout in January 2009. During a previous inspection, the licensee demonstrated that the crack did not affect the structure. Because sealants have limited lifetime, the inspectors questioned whether the grout remained protected since the sealant had been in place for 14 years.

General information identified that the sealant would last for 15 years. The licensee initiated Condition Report 449815 to evaluate the life of the sealant and implement appropriate corrective measures.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 50, commitment 66, and their associated aging management program or plant procedures.

A.2.1.53 Water Control Structures Inspection and Commitment 53 This program managed aging effects related to loss of material for water control structures and structural components. The program, implemented as part of the Structures Monitoring Program, consists of inspection activities to detect aging and age-related degradation. The program ensures the structural integrity and operational adequacy of the spray ponds, standby service water pump houses, circulating water pump house (including circulating water basin), makeup water pump house, cooling tower basins, and those structural components within the structures.

Commitment 53 specified:

The Water Control Structures Inspection is an existing program that will be continued for the PEO, with the following enhancements:

Include and list the water control structures within the scope of license renewal. Include the RG 1.127, "Inspection of Water Control Structures Associated with Nuclear Power Plants," Revision 1 inspection elements for the water control structures, including submerged surfaces. Ensure descriptions of concrete conditions conform with the appendix to the American Concrete Institute (ACI) publication, ACI 201, "Guide for Making a Condition Survey of Concrete in Service." Add a recommendation to use photographs for comparison of previous and present conditions. Add a requirement for the documentation of new or progressive problems as a part of the inspection program;

Specify additional direction for quantifying, monitoring, and trending of inspection results;

Provide better alignment with referenced Industry codes, standards, and guidelines regarding terminology and evaluation;

Revise to add sufficient acceptance criteria and critical parameters to trigger level of inspection and initiation of corrective action. ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R-96, will be developed and added to the inspection procedure; and

Energy Northwest will conduct a baseline inspection of the spray ponds (including submerged portions) plus a minimum of one additional inspection prior to entering the PEO. Inspection will use quantitative acceptance criteria in accordance with ACI 349.3R.

The inspectors reviewed the aging management program basis document, gap analysis, operating experience, work orders, procedures, and inspection results. The inspectors interviewed plant and implementing personnel.

The inspectors determined that Procedure ENG-PRG-09, Revision 1, included the water control structures and structural components within the program scope. The inspectors did not identify specific additional direction for

(1) aligning with industry standards, monitoring,

(2) monitoring water control structures,

(3) demonstrating acceptable and unacceptable criteria during inspections, and

(4) reviewing structures as described in Regulatory Guide 1.127, Revision 1. In addition, the licensee had scheduled the additional baseline inspections planned for service water spray ponds A and B by work orders 02168052 and 02168053, respectively.

The licensee initiated corrective action program record CR 449773 to document needed changes to Procedure ENG-PRG-09 to address the failure to include the first four enhancement bullets and to implement appropriate corrective actions.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 53 and the associated aging management program.

Because all actions had not been implemented, this commitment and aging management program will be evaluated during a future inspection and this commitment remains open.

A.2.1.55 Service Level 1 Protective Coatings Program and Commitment 62 This program monitors the performance of Service Level 1 coatings inside containment through periodic coating examinations, condition assessments, and remedial actions including repair or testing. This program also ensures the design basis accident analysis limits regarding coatings would not be exceeded for the suction strainers.

Commitment 62 specified:

The Service Level 1 Protective Coatings Program is an existing program that will be continued for the PEO.

The inspectors reviewed the aging management program basis document, operating experience, plant drawings, work orders, and inspection results. The inspectors interviewed plant and implementing personnel.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 62 and its associated AMP.

A.2.2.7.1 Rx Vessel Shell Indications and Commitment 69

The Columbia Generating Station (CGS) Inservice Inspection (ISI) Program is a part of Columbia Generating Stations overall strategy for maintaining plant material condition into the PEO. Commitment 69 was generated from RAI 4.7.1-9(b). This commitment is plant-specific and relies on the existing ISI program to perform a re-inspection of the reactor vessel (RV) axial welds in 2015, to include including portions of beltline welds BG and BM, which contained previously reported flaws. Based on the results of the 2015 inspection CGS will re-evaluate the subject flaws for the PEO (54 Effective Full Power Years (EFPY)) in accordance with ASME Boiler and Pressure Vessel Code (ASME Code),Section XI, IWB-3600 flaw evaluation requirements, and continue augmented inspections as required by the ASME Code,Section XI.

The previously planned and scheduled 2015 inspection and re-evaluation would have been conducted for the existing program 10-year lSI interval and would not necessarily have included the evaluation for the full 60 years (54 EFPY) of the PEO.

In 2015 (R22) the BM weld was re-examined using ASME approved UT techniques and, as documented in GEH Examination Report R-R22-091, dated May 30, 2015, the previously unacceptable flaw was re-characterized as an acceptable laminar reflector and not a planar flaw. With the absence of planar flaw indicators, the BM weld was classified as acceptable per the requirements of ASME XI IWB-3000 in the UT report. Therefore, it was not evaluated in subsequent revisions to ME-02-05-07.

Thus, the flaw is no longer a TLAA (component) issue.

In 2015 (R22) the BG weld was re-examined using ASME approved UT techniques.

The indication still did not meet the acceptance standards of ASME Code,Section XI, IWB-3500. Therefore, a flaw evaluation was required per the guidelines of ASME Code,Section XI, IWB-3600, which included acceptance criteria based on the applied conservative stress intensity factors and conservative assumptions in the applied stresses. The BG flaw evaluation documented in CGS Calculation ME-02-05-07, Revision 3 Evaluation of RPV Shell Indications Identified During R17 [BG weld],

concluded that the flaw met the requirements of ASME Code,Section XI, IWB-3610.

The calculation revision also updated fluence projections and cycle projections to confirm the extended evaluation to 60 years, corresponding to 54 effective full-power years (EFPY) for CGS.

Commitment 69 specified:

Re-evaluate the portions of the reactor pressure vessel beltline welds BG and BM for the PEO (54 EFPY), in accordance with the requirements of the ASME Code,Section XI, IWB-3600 based on the results of 2015 in-service inspection.

The UT examination of the BM weld in 2015 concluded that the flaw was acceptable per ASME Code,Section XI IWB-3600 requirements and no further re-evaluation was required. The BG weld flaw evaluation documented in CGS Calculation ME-02-05-07 (R3) Evaluation of RPV Shell Indications Identified During R17 [BG weld],

concluded the indication met the requirements of ASME Code,Section XI, IWB-3610.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with commitment 69 and planned licensee actions.

Review of Specific Administrative Commitments The inspectors confirmed that the licensee implemented the following administrative commitment since the last inspection. This commitment did not apply to any specific aging management program.

Commitment 57, License Renewal Commitment List specified:

The commitments identified in association with Columbia license renewal will be tracked within the Columbia Regulatory Commitment Management Program.

The inspectors determined that Amendment 266 to Operating License NPF-21

[ADAMS ML No. ML21293A164] removed License Condition 2.C.34. The license condition no longer applied because the Columbia Final Safety Analysis Report had been updated to include the license renewal commitments. Further, the amendment described that future changes to license renewal commitment would be made under the provisions of 10 CFR 50.59. The inspectors determined that the licensee had deleted this commitment on April 23, 2020, after placing the commitments into the final safety analysis report supplement as described in Licensing Document Change Notice 19-035. The inspectors identified no concerns with the licensee administratively controlling their license renewal commitments in accordance with 10 CFR 50.59 and consider commitment 57 closed.

(2) NRC closed commitments: 55, 56, 59, 61 and 67 in Inspection Report 05000397/2021013 During this inspection, the inspectors closed the following commitments listed in the updated safety evaluation report: 1, 2, 3, 4, 5, 7, 8, 9,10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 37, 38, 39,40, 41, 42, 43, 44, 45, 46, 48, 49, 50, 51, 52, 54, 57, 58, 59, 60, 62, 63, 65, 66, 68, 69, 70, and As described in the report, the inspectors did not close the following commitments:

36,47, 53, and 64. The aforementioned commitments will be closed in a future NRC license renewal inspection report, after the PEO begins.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On August 24, 2023, the inspectors presented the License Renewal Phase 2 results to Mr. R.A. Prewett, Plant General Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Calculations

CVI 1012-00,23

Pressure-Temperature Curves Report for Energy Northwest

Columbia Generating Station 60-Year License Extension

Calibration

Records

Hygrometer

0063283:1467706632, 0063283:1436975670,

0066069:1649851201, 0066069:1675087650

71003

Corrective Action

Documents

2727, 240269,

241301, 311556,

27367, 333558,

366255, 366440,

378192, 382110,

401649, 410318,

413329, 414057,

416030, 419297,

21505, 423540,

437004, 444724,

447161, 444597,

449400, 449812,

00020018,

00036737,

00048043,

00057688,

210391,

241740,

249685,

262446,

268896,

273200,

00302779,

00327666,

00356400,

00356979,

00368492,

00379518,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

00389689,

00400369,

00403253,

00406620,

00412806,

00414605,

00415708,

00416198,

00439964

Corrective Action

Documents

Resulting from

Inspection

449267 449287

449329 449331

449333 449334

449335 449341

449343 449344

449345 449346

449400 449572

449816

2B13-04, Sheet

170

Nozzle-CRD Hyd Sys Return

2B13-06, Sheet

115

Bushing for Stud

2B13-06, Sheet

Shell Flange Details

105D4719

Reactor Assembly - Surveillance Program Standard Plan

197R611

Reactor Assembly Reactor Vessel

26985

Spent Fuel Pool Material Inventory

6911R03002

Diesel Lube Oil Pumps DLO-P-2B1, DLO-P-3B1 and DLO-P-

11B1 Discharge for DG-ENG-1B1

DG BLDG EL 441'-0"

6911R03002,

sheet 2

Diesel Lube Oil Pumps DLO-P-2B2, DLO-P-3B2 and DLO-P-

11B2 Discharge for DG-ENG-1B2

DG BLDG EL 441'-0"

Drawings

6911R03002,

sheet 2

Diesel Lube Oil Pumps DLO-P-2A1, DLO-P-3A1 and DLO-P-

11A1 Discharge for DG-ENG-1A1

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

DG BLDG EL 441'-0"

6911R03002,

sheet 2

Diesel Lube Oil Pumps DLO-P-2A2, DLO-P-3A2 and DLO-P-

11A2 Discharge for DG-ENG-1A2

DG BLDG EL 441'-0"

D-DOTK-046

Ultrasonic Sensor Mount for DO-TK-1A, DO-TK-1B, and DO-

TK-2

DO-2524-3

1" DO-2524 from DO-TK-3A to Diesel Engine DG-ENG-1A2

FM892-3

Fire Barrier and Fire Boundary Plan Operating Floors at EL

501'-0", 507'-0" and 525' -0" (Modified to show cable routing)

FPC-4219-1

Fuel Pool Liner Drain to 3" EDR

FSAR Fig. 5.3-7

Feed Water Spargers

11/1998

M512-4

Flow Diagram - Diesel Oil & Miscellaneous Systems Diesel

Generator Building

RPV-113

Control Rod Drive N10-Nozzle at 180 Deg

S740

Structural Reactor Building Method of Conc. Placement at

Containment Vessel-Ellipsoidal Head

S741

Structural Reactor Building Biological Shield Wall Sh. 1

S794

Structural Containment Vessel Sheet 1

S799

Structural Containment Vessel Sheet 6

Engineering

Changes

16688

Accept-As-Is SSH-300 Removal

Engineering

Evaluations

GEH Report

006N3818

Columbia Generating Station - Upper Shelf Energy and

Equivalent Margin Analysis

X-1D Inspect External side of Primary Containment Vessel

05/20/2019

X-1E Inspect External side of Primary Containment Vessel

05/20/2019

X-1H Inspect External side of Primary Containment Vessel

05/20/2019

Site Specific Demonstration for Encoded Phased Array

Ultrasonic Inspection of Small Bore

Socket Welds using GE Hitachi Procedure GEH-UT-255 V.O

5/13/2021

Small Bore Piping Database

DO/DLO Low-point inspections in support of position paper

Presentation - Columbia Generating Station License

Renewal Implementation

Miscellaneous

Corrosion Coupon Report: Open Cooling Systems TSW,

05/18/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CW, SW 90-day

Photographs of Spent Fuel Pool Drain Line and Obstructions

RWP Tracking Revised Dose WO 2115128 R24 DW Minor

Maintenance and Surveillances

X-1B Inspect External side of Primary Containment Vessel

05/20/2019

206-03 Sheet 5

Joint Sealer

ACI 349.3R-96

Evaluation of Existing Nuclear Safety-Related Concrete

Structures

AMPBD - CPEI

Aging Management Program Basis Document - Chemistry

Program Effectiveness Inspection

AMPBD - FOC

Aging Management Program Basis Document - Fuel Oil

Chemistry Program

AMPBD - LOI

Aging Management Program Basis Document - Lubricating

Oil Inspection

AMPBD - MWI

Aging Management Program Basis Document - Masonry

Wall Inspection

AMPBD - RVSP

Aging Management Program Basis Document - Reactor

Vessel Surveillance Program

AMPBD - SMP

Aging Management Program Basis Document - Structures

Monitoring Program

AMPBD - WCSI

Aging Management Program Basis Document - Water

Control Structures Inspection

AMPBD-CCW

Aging Management Program Basis Document - Closed

Cooling Water Chemistry Program

AMPBD-COAT

Aging Management Program Basis Document - Service

Level 1 Protective Coatings Program

AMPBD-E1

Aging Management Program Basis Document - Electrical

Cables and Connections Not Subject to 10 CFR 50.49 EQ

Requirements Program

AMPBD-E2

Aging Management Program Basis Document - Electrical

Cables and Connections Not Subject to

CFR 50.49 EQ Requirements Used in Instrumentation

Circuits Program

AMPBD-E2

Aging Management Program Basis Document - Electrical

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Cables and Connections Not Subject to 10 CFR 50.49 EQ

Requirements Used In Instrumentation Circuits Program

AMPBD-E3

Aging Management Program Basis Document - Inaccessible

Power Cables Not Subject to 10 CFR 50.49 EQ

Requirements Program

AMPBD-E6

Aging Management Program Basis Document - Electrical

Cable Connections Not Subject to 10 CFR 50.49 EQ

Requirements Inspection

AMPBD-ESMP

Aging Management Program Basis Document - External

Surfaces Monitoring Program

AMPBD-FMP

Fatigue Monitoring Program

AMPBD-FW

Aging Management Program Basis Document - Fire Water

Program

AMPBD-ISMPD

Inspection of Internal Surfaces of Miscellaneous Piping and

Ducting Components Program

AMPBD-LOA

Aging Management Program Basis Document - Lubricating

Oil Analysis Program

AMPBD-MEB

Aging Management Program Basis Document - Metal-

Enclosed Bus Program

AMPBD-SBP

Small Bore Class 1 Piping Program

AVR-R24-06 N4B

Nondestructive Examination report

AVR-R24-07 N4B IR Nondestructive Examination report

AVR-R24-08 N4B Bore Nondestructive Examination report

AVR-R24-09 N4C-V Nondestructive Examination report

AVR-R24-10 N4C IR Nondestructive Examination report

AVR-R24-11 N4C Bore Nondestructive Examination report

AVR-R24-07 N4B

IR

Nondestructive Examination report

AVR-R24-08 N4B

Bore

Nondestructive Examination report

AVR-R24-09

N4C-V

Nondestructive Examination report

AVR-R24-10 N4C

IR

Nondestructive Examination report

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AVR-R24-11 N4C

Bore

Nondestructive Examination report

BWRVIP-86A

Updated BWR Integrated Surveillance Program (ISP)

Implementation Plan

1-A

CDR CGS R26

IVVI 23-01

Jet Pump 11 AS-1-SS

Commitment #12

Commitment

Notebook

Chemistry Program Effectiveness Inspection

Commitment #13

Commitment

Notebook

Closed Cooling Water Chemistry Program

Commitment #19

Commitment

Notebook

Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program, XI.E1

0a

Commitment #20

Commitment

Notebook

Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits

Program, XI.E2

0a

Commitment #21

Commitment

Notebook

Electrical Cable Connections Not Subject to 10 CFR 50.49

EQ Requirements Inspection, XI.E6

0a

Commitment #23

Commitment

Notebook

External Surfaces Monitoring Program

0a

Commitment #25

Commitment

Notebook

Fire Protection Program

0a

Commitment #26

Commitment

Notebook

Fire Water Program

0a

Commitment #29

Fuel Oil Chemistry Program

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Commitment

Notebook

Commitment #31

Commitment

Notebook

High-Voltage Porcelain Insulators

0a

Commitment #32

Commitment

Notebook

Inaccessible Power Cables Not Subject to 10 CFR 50.49

Environmental Qualification Requirements Program, XI.E3

0a

Commitment #36

Commitment

Notebook

Lubricating Oil Analysis Program

Commitment #37

Commitment

Notebook

Lubricating Oil Inspection

Commitment #38

Commitment

Notebook

Masonry Wall Inspection

Commitment #40

Commitment

Notebook

Metal-Enclosed Bus, XI.E4

0a

Commitment #46

Commitment

Notebook

Reactor Vessel Surveillance Program

Commitment #50

Commitment

Notebook

Structures Monitoring Program

Commitment #53

Commitment

Notebook

Water Control Structures Inspection (WCSI), XI.S7

Commitment #60

Commitment

Notebook

BWRVIP-116 Integrated Surveillance Program (ISP)

Commitment #64

Inservice Inspection (ISI) Program (Annulus)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Commitment

Notebook

Commitment #66

Commitment

Notebook

Structures Monitoring Program Spent Fuel Pool Tell Tale

Drain Lines

Commitment #70

Commitment

Notebook

TLAA - Embrittlement of Reactor Vessel

Commitments #4,

1. 6, #8, #15, #34,

1. 35, #45, and #52

Commitment

Notebook

1. 4 Bolting Integrity Program, #6 BWR Feedwater Nozzle

Program, #8 BWR Stress Corrosion Cracking Program, #15

CRDRL Nozzle Program, #34 Inservice Inspection (ISI)

Program - IWE, #35 Inservice Inspection (ISI) Program -

IWF, #45 Reactor Head Closure Studs Program, and #52

Thermal Aging and Neutron Embrittlement of Cast Austenitic

Stainless Steel (CASS)

ENGNW00461-

REPT-002

License Renewal Sampling Plan - Chemistry Program

Effectiveness Inspection

ENGNW00461-

REPT-007

License Renewal GAP Analysis - Bolting Integrity Program

ENGNW00461-

REPT-008

License Renewal GAP Analysis - Fuel Oil Chemistry

Program

ENGNW00461-

REPT-009

License Renewal GAP Analysis - ASME Section XI,

Subsection IWF Program

ENGNW00461-

REPT-010

License Renewal GAP Analysis - Structures Monitoring

Program

ENGNW00461-

REPT-011

License Renewal Gap Analysis - Metal Enclosed Bus

Program

ENGNW00461-

REPT-012

License Renewal GAP Analysis - ASME Section XI,

Subsection IWE Program

ENGNW00461-

REPT-013

License Renewal Gap Analysis - Fire Protection Program

ENGNW00461-

REPT-014

License Renewal GAP Analysis - Reactor Head Closure Stud

Program

ENGNW00461-

License Renewal Sampling & Inspection Plan - Electrical

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

REPT-019

Cable Connections Not Subject To 10 CFR 50.49 EQ

Requirements

ENGNW00461-

REPT-023

License Renewal Gap Analysis Fire Water Program

ENGNW00461-

REPT-024

License Renewal Gap Analysis - Inaccessible Power Cables

Not Subject To 10CFR50.49 Environmental Qualification

Requirements Program

ENGNW00461-

REPT-025

License Renewal Gap Analysis - Electrical Cable

Connections Not Subject To 10CFR50.49 Environmental

Qualification Requirements

ENGNW00461-

REPT-027

License Renewal Sampling and Inspection Plan - Lubricating

Oil Inspection

ENGNW00461-

REPT-039

License Renewal Inspection Plan - Chemistry Program

Effectiveness Inspection (CPEI)

ENGNW00461-

REPT-052

GAP Analysis - Remaining Programs

FAI/17-0469

Columbia Generating Station: Cable Health and Aging

Management Program (CHAMP) Walkdown Report

FSAR 3.9.5.1.8

Feedwater Sparger Amendment 58

2/xx/2005

Indication

Notification

Report CGS R23

IVVI 17-09

Surveillance Specimen Holder 300

5/23/2017

INR CGS R26

IVVI 23-05

Jet Pumps 11-20 Aux Wedges and Set Screws

INR CGS R26

IVVI 23-07

Jet Pumps 1-10 Aux Wedges and Set Screws

LDCN -22-020

Revise Metal-Enclosed Bus Program Description in FSAR

Appendix A

11/03/2022

LDCN -22-022

Change FSAR A.2.1.32 to clarify Manhole B105 actions

related to heavy rain or floods

11/22/2022

LDCN-18-012

Final Safety Analysis Report Update to Reflect Removal of

SSH-300 from Reactor Pressure Vessel

LDCN-21-038

Revise Inspection for Annulus License Renewal Commitment 07/26/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

in FSAR Appendix A

LDCN-22-037

Revise Open Cycle Cooling Water Program Description

05/10/2023

Letter

Columbia Generating Station - Issuance of Amendment No.

268 to Revise Technical Specification 3.4.11, "RCS Pressure

and Temperature (P/T) Limits" (EPID L-2021-LLA-0191)

11/23/2022

Letter 2022-018

Notification of New BWRVIP Integrated Surveillance

Program (ISP) Data Applicable to Columbia

3/31/2022

LRAMR-S06

Structures Screening and Aging Management Review of Bulk

Commodities

LRPD-06

General Aging Considerations

NUC2021101-L-

FER-001

Suppression Pool Coating Assessment / Suppression Pool

Cleanliness Inspection / Foreign Material Inspection R25

NUC2021104-L-

FER-001

Drywell, Under Reactor Vessel and Wetwell Safety Related

Coating Inspection Report for R25

NUC2300002-L-

FER-001

23 R26 - Service Level I Coatings Drywell, Under Reactor

Vessel and Wetwell (Above Water)

NUC2300018-L-

FER-001

Suppression Pool Coating Assessment / Suppression Pool

Cleanliness Inspection / Foreign Material Inspection/Coating

Repairs R26

OER-AR 431644-

BWRVIP 2022-018, Notification of New BWRVIP Integrated

Surveillance Program (ISP) Data Applicable to Columbia

R-R19-048

UT Reports R19 N4B and N4C

5/20/2009

R25 FAC Report

INSPECTION OF COMPONENT 051-3 and 51-4, Reactor

Vessel Welds

Technical Report

EP-2015-0039-

TR-02

Energy Northwest - Columbia Generating Station Erosion

Susceptibility Evaluation (ESE)

10/16/2019

Technical Report

EP-2015-0039-

TR-02

Energy Northwest - Columbia Generating Station Erosion

Susceptibility Evaluation (ESE)

WPPS-ENT-089

Columbia Generating Station Reactor Pressure Vessel

Surveillance Program

4RPV-002

Visual Examination - 22 RPV Nuts

05/24/2019

NDE Reports

4RPV-003

Visual Examination - RPV Washers

05/24/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

4RPV-004

Visual Examination - RPV Nuts

05/16/2021

4RPV-005

Visual Examination - RPV Washers

05/16/2021

R-R22-039

Ultrasonic Examination - N10-180 CRD NZ-V@180

05/23/2015

R-R22-040

Ultrasonic Examination - N10-180-IR CRD NZ-IR@180

05/23/2015

R-R22-064

Ultrasonic Examination - RPV Threads

Threads RPV Flange

05/11/2015

R-R24-009

Ultrasonic Examination - RPV Studs

05/18/19

R-R25-007

Ultrasonic Examination - RPV Studs

05/09/2021

R-R25-045

Ultrasonic Examination - N10-180-IR Nozzle Inner Radius

05/25/2021

R-R25-046

Ultrasonic Examination - N10-180 Nozzle to Vessel

05/25/2021

R17-041

Ultrasonic Examination - N10-180 CRD NZ-V@180

05/15/2005

RPV Inservice

Examination

Seventh

Refueling and

Inspection Outage

Report of

Examination

Results

Ultrasonic Examination - CRD NZ-V@180 and CRD NZ-IR

@180

06/30/1992

1.19.3C

Lubrication Analysis

1.3.1

Operating Policies, Programs, and Practices

140

1.3.30

Repair, Replacement, and Alteration of ASME Items

1.3.56

Conduct of Maintenance

1.3.58

Conduct of Chemistry

1.3.9

Temporary Modifications

1.5.5

Primary Containment Leakage Rate Testing

10.1.13

Foreign Materials Controls for Systems and Components

10.2.10

Fastener Torque and Tensioning

10.2.13

Approved Lubricants

10.2.29

Installation, Modification and Inspection of Pipe Supports

10.2.32

Soil Excavation, Backfill and Compaction

Procedures

10.20.12

Division 1 and 2 Diesel Generator 2, 4, & 6 Year

Preventative Maintenance

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

10.20.17

Division 3 Diesel Generator Engine 2 Year Preventive

Maintenance

10.20.18

Division 3 Diesel Generator Engine 2/4/6/12/18 Year

Preventative Maintenance

10.20.19

Diesel Generator Alternative Refuel Cycle (2 Year & 4 Year)

Preventative Maintenance (Division 1 And 2)

10.24.206

Containment Annulus Sand Pocket Humidity Measurement

10.25.179

Flexible and Rigid Link Removal, Inspection, and Installation

10.25.202

Non-Segregated Bus Inspection and Maintenance

10.25.215

High Potential Testing of 4.16KV and 6.9KV Non-Segregated

Buses

10.27.90A

DSA System Instrument Air Sampling - DG-1

10.3.22

Reactor Pressure Vessel Reassembly

10.3.22

Reactor Pressure Vessel Reassembly

10.4.1

Pendant Controlled Crane Inspection, Maintenance, and

Testing

10.4.10

JIB Cranes and Electrically Operated Hoists Inspection,

Maintenance and Testing

10.4.5

Reactor (MT-CRA-2) and Turbine Building (MT-CRA-1)

Overhead Traveling Crane Inspection, Maintenance and

Testing

2.14.12

Reactor Closed Cooling Water

15.1.2

Fire Door Operability Surveillance

15.3.17

Fire Door Operability Inspections

15.3.5

Fire Damper Operational Inspection

15.4.9

Fire Rated Thermo-Lag Structural Steel Fireproofing

Operability Inspection

15.6.1

Diesel Fire Pump Fuel Test

15.6.1

Diesel Fire Pump Fuel Test

16.8.4

CC/RC - Standby Service Water System Effluent Monitor -

CH B

8.3.3

Suppression Chamber Protective Coatings Inspection

8.3.384

Suppression Pool Cleanliness Determination

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

8.3.4

Non-Destructive Testing and Examination Program

8.3.63

Procedure for Monitoring Pipe Wall Thinning

8.3.63

Procedure for Monitoring Pipe Wall Thinning

CCMP-01-02

Manhole Inspections

DES-2-16

Temporary Engineering Change Process

ENG-DES-50

Interface Procedure for IP-ENG-001 Standard Design

Process

ENG-PRG-08

License Renewal External Surfaces Monitoring and Aging

Management Plant Walkdown Procedure

ENG-PRG-09

License Renewal Structures Monitoring Program Inspections

GEH-UT-255

Procedure For Encoded Phased Array Ultrasonic Inspection

of Small Bore Socket Welds With The TOPAZ

ICP-MS/PRM-

X301

MSL High Radiation Channel A - CC

IP-ENG-001

Standard Design Process

ISI-4

Inservice Inspection Program Plan - Interval 4

LLRT-01

Primary Containment Leakage Rate Testing Program

MI-1.8

Conduct of Maintenance

MMP-DO-E001

Diesel Fuel Oil Storage Tank Cleaning

PWTP-01

Flow Accelerated Corrosion Pipe Wall Thinning Monitoring

Program Plan

PWTP-05

Erosion Pipe Wall Thinning Monitoring Program Plan

PWTP-07

Pipe Wall Thinning Program Erosion Susceptibility

Evaluation

SPES-1.7.18

Storage Maintenance

SPS-12-8

NDE Data Evaluation

SPS-7-3

Visual Examination - Component Supports

SPS-7-4

Visual Examination of Containment

SPS-7-4

Visual Examination of Containment

SWP-CHE-01

Groundwater Protection Program

SWP-CHE-02

Chemical Process Management and Control

SWP-CHE-04

Diesel Fuel Oil Testing Program

SWP-CM-02

Temporary Configuration Changes

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SWP-FPP-01

Nuclear Fire Protection Program

SWP-IS-02

Temporary WAP Installations in The Power Block

SWP-ISI-01

ASME Section XI Inservice Inspection

SWP-MMP-02

Warehousing

SWP-PRO-02

Preparation, Review, Approval and Distribution of

Procedures

SWP-SPS-03

Service Level 1 Protective Coatings Program

SWP-VIP-02

Columbia's RPV Surveillance Program and Implementation

of the BWRVIP Integrated Surveillance Program (ISP)

SYS-2-1

Conduct of System Engineering Manual (COSEM)

TSP-CONT-C801

Primary Containment Integrated Leak Rate Test

TSP-CONT-R801

Containment Isolation Valve and Penetration Leak Test

Program

WPPS-ENT-089

Columbia Generating Station Reactor Pressure Vessel

Surveillance Program

Work Orders

200341,

2005990,

2006766,

2011860,

2059215,

2066675,

2066676,

2066677,

2066678,

2078839,

2084364,

2087401,

2092266,

2100971,

2111294,

2111924,

2112116,

2112372,

2116384,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2116545,

2117315,

2135820,

2138169,

2139209,

2140168,

2140249,

2142683,

2144296,

2144981,

2149741,

2150931,

2151126,

2153657,

2153811,

2162936,

2167190,

2167598,

2168234,

2177542,

2181327,

2181331,

2181332,

2183445,

2183564,

2184611,

2185108,

2185555,

2185602,

2190340,

2190847,

204096,

204097,

211496,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20465151,

21509315,

0104964301,

20128513,

20128603,

20128916,

20129014,

200339101,

200986301,

202121801,

202637501,

204459701,

205007101,

205251301,

205336401,

205336501,

205336601,

205442001,

205929001,

206653701,

207705501,

208141201,

208437601,

208485701,

208488701,

208513101,

208518501,

208560501,

208990401,

210491101,

210491301,

210615120,

210754818,

210899601,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

211146801,

211146901,

211192401,

211192416,

211289603,

211512811,

211512821,

211512822,

211512824,

211711201,

211711301,

211714201,

211805301,

211914001,

211914002,

212074208,

212087001,

212608701,

2642801,

2642803,

212810106,

212810206,

212902601,

212902602,

213060501,

213475001,

213551801,

213915901,

214020801,

214053001,

214053002,

214053003,

214053004,

214053005,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

214053006,

214053007,

214053008,

214264901,

214409501,

214477501,

214587801,

214613601,

214705901,

214747601,

214747611,

214874108,

214974401,

214976601,

214976902,

215008403,

215008404,

215008406,

215008407,

215008418,

215008708,

215024201,

215031311,

215031317,

215031319,

215092503,

215092526,

215221101,

215384401,

215384402,

215615613,

215839501,

216035101,

216035601,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

216303403,

216744001,

216911501,

217087601,

217138901,

217138902,

217138903,

217138904,

217138905,

217138906,

217174901,

217291601,

217291604,

217326401,

217544001,

217544006,

217675301,

217863301,

218002001,

218128501,

218134101,

218333501,

218395501,

219011901,

219541201,

219962301,

20142901,

20142904,

20142906,

2115128,

2151071,

2189624,

2144506,

2179618,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2148101,

2187024