ML101730271

Letter Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application Concerning Electrical

ML101730271
Person / Time
Site:	Columbia
Issue date:	07/07/2010
From:	Gettys E License Renewal Projects Branch 1
To:	Oxenford W Energy Northwest
Gettys E, NRR/DLR, 415-4029
References
Download: ML101730271 (8)

Text

July 7, 2010 Mr. W.S. Oxenford, Vice President Nuclear Generation and Chief Nuclear Officer Columbia Generating Station Energy Northwest MD PE08 P.O. Box 968 Richland, WA 99352

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION CONCERNING ELECTRICAL

Dear Mr. Oxenford:

By letter dated January 19, 2010, Energy Northwest submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew Operating License NPF-21 for Columbia Generating Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Abbas Mostala and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or by e-mail at evelyn.gettys@nrc.gov.

Sincerely,

/RA/

Evelyn Gettys, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-397

Enclosure:

As stated cc w/encl: See next page

ML101730271 OFFICE PM:RPB1:DLR LA:DLR BC: RPB1:DLR PM:RPB1:DLR NAME EGettys SFigueroa BPham EGettys DATE 6/30/10 6/28/10 7/1/10 7/7/10

Letter to W. Oxenford from E. Gettys dated July 7, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION CONCERNING ELECTRICAL DISTRIBUTION:

HARD COPY:

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COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI B.2.19-1

Background:

The Generic Aging Lessons Learned (GALL) Report XI.E1 program, under the scope of program element, states that this inspection program applies to accessible electrical cables and connections within the scope of license renewal that are installed in an adverse localized environment.

Issue:

The applicant has not described the methodology to be used to identify an adverse localized environment.

Request:

Describe how an adverse localized environment will be identified including EQ records, environment surveys, plant walkdowns, and operating experiences.

RAI B.2.19-2 Background; The GALL Report XI.E1 program, under the parameters monitored or inspected element, states that a representative sample of accessible electrical cables and connections installed in adverse localized environment are to be visually inspected for cable and connection jacket surface anomalies. In addition, the technical basis for the sample selected is to be provided. In the basis document LRPD-05, under the same element, the applicant states that the program will provide for the visual inspection of accessible cables and connections located in adverse localized environments. LRPD-05 also states that the implementing document for the program will provide the technical basis for the sample selection with respect to both sample size and inspection locations.

Issue:

The applicant has not developed the technical basis for sample selection for accessible cables and connections installed in adverse localized environments.

Request:

Provide the technical basis for selecting samples of accessible cables and connections installed in adverse localized environments.

RAI B.2.21-1

Background:

The GALL Report XI.E6, under Element 3 (parameters monitored or inspected), states that the applicant is to document the technical basis for the samples selected. In the basis document LRPD-05, under the same program attribute, the applicant states that it will document the technical basis for the sample selected.

Issue:

The applicant has not developed the technical basis for selecting samples of bolted connections for one-time testing.

Request:

Provide the technical basis for selecting samples of bolted connections for one-time inspection.

RAI B.2.22-1

Background:

In Standard Review Plan (SRP) Table 4.4-2, Examples of FSAR Supplement for EQ of Electrical Equipment TLAA Evaluation, it states that reanalysis addresses attributes of analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, corrective actions if acceptance criteria are not met, and the period of time prior to the end of qualified life when the reanalysis will be completed. In license renewal application (LRA)

Appendix A, Final Safety Analysis Report (FSAR) Supplement A.1.2.22, the applicant did not address the reanalysis attributes.

Issue:

The LRA Appendix A, FSAR Supplement A.1.2.22 description is not consistent with SRP Table 4.4-2. The reanalysis attributes are important attributes to extend the qualified life of EQ electrical components and must be included in the summary description in LRA Appendix A.

Request:

Explain why reanalysis attributes are not included in the FSAR Supplement to be consistent with SRP Table 4.4-2.

RAI B.2.32-1

Background:

The GALL Report aging management program (AMP) XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provides definitions for significant moisture and significant voltage. In addition, the GALL Report AMP XI.E3 states that the specific type of test performed will be a proven test for detecting deterioration of the insulation system due to wetting. The GALL Report AMP XI.E3 also states that inspection for water collection is performed based on actual plant experience with a minimum inspection frequency at least once every two years. SRP-LR Table 3.6-2, FSAR Supplement for Aging Management of Electrical and Instrumentation and Control System also includes definitions for significant moisture and significant voltage, and discussions on the specific type of test, and inspection for water collection based on plant-specific experience.

Issue:

LRA FSAR Supplement Section A.1.2.32 does not include definitions of significant moisture or significant voltage consistent with SRP-LR Table 3.6-2 or GALL Report AMP XI.E3. LRA FSAR Supplement Section A.1.2.32 does not include a discussion of the specific type of test to be performed or specify that inspection of water collection will be based on plant-specific

experience. The missing LRA FSAR Supplement definitions and testing and inspection discussions results in inconsistency with the GALL Report AMP XI.E3 and SRP-LR Table 3.6-2.

Request:

Explain why LRA FSAR supplement A.1.2.32 for LRA AMP B.2.32 does not include the definitions of significant voltage, significant moisture, or discussions on specific testing and inspection for water collection based on operating experience consistent with the GALL Report AMP XI.E3 and SRP LR Table 3.6-2.

RAI B.2.32-2

Background:

The GALL Report AMP XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements states that the specific type of test performed will be a proven test for detecting deterioration of the insulation system due to wetting and tested at least once every ten years. The GALL Report AMP XI.E3 also states that inspection for water collection is performed based on actual plant experience with a minimum inspection frequency at least once every two years. The GALL Report AMP XI.E3 states that the first test and inspections are to be completed before the period of extended operation.

Issue:

In element 4, detection of aging effects, of the LRA AMP, it states that cable testing and inspection for water collection will be performed, with the first test and inspection to occur during the 10-year period prior to the end of the current operating license. However, LRA Appendix A, Section A.1.2.32 states that the first test and inspection are to be implemented prior to the period of extended operation. The GALL Report AMP also states that the first tests and inspections for license renewal are to be completed before the period of extended operation.

The staff is concerned that the inaccessible medium-voltage cable inspection and test may exceed the interval specified by the GALL Report AMP XI.E3. In addition, the staff is concerned that if cable inspection or tests are performed up to 10 years prior to the period of extended operation and credited as the initial test, the test or inspection results may not be representative of inaccessible medium-voltage cable data taken prior to the period of extended operation.

Request:

Explain how LRA AMP B.2.32, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements Program, is consistent with the GALL Report AMP XI.E3 and SRP LR Table 3.6-2 with respect to performing the inspection and test prior to the period of extended operation such that the inspection and test frequency wont exceed the intervals specified by the GALL Report AMP XI.E3.

RAI B.2.32-3

Background:

The GALL Report AMP XI.E3, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provides definitions for significant moisture and significant voltage. In addition, the GALL Report AMP XI.E3 states that the specific type of

test performed will be a proven test for detecting deterioration of the insulation system due to wetting. The GALL Report AMP XI.E3 also states that inspection for water collection is performed based on actual plant experience with a minimum inspection frequency of at least once every two years.

Issue:

LRA AMP B.2.32 and associated basis document specify that inspections for water collection will be based on actual plant operating experience with a minimum frequency of at least once every two years. However, event driven water collection is not discussed. Periodic inspection may not mitigate event driven water collection and may allow inaccessible medium-voltage cables to be exposed to significant moisture.

Request:

Explain why event based inspection is not included in LRA AMP B.2.32 to prevent inaccessible medium voltage cable exposure to significant moisture.

RAI B.2.40-1

Background:

In element 10 of the LRA AMP, the applicant states that the Metal-Enclosed Bus (MEB)

Program is a new program for which there is no direct site-specific operating experience. In the GALL Report AMP XI.E4, it states that operating experience has shown that bus connections in MEBs exposed to appreciable ohmic heating during operation may experience loosening due to repeated cycling of the connected load.

During the staff walkdown on May 25, 2010, the staff noticed possible smoke residue on the 6.9kV E-BUS -NONSEG/N2/X MEB and the surrounding conduits and cable trays. In Action Request (AR) 202384, the applicant states that the bus failed catastrophically on August 5, 2009. The applicant determined that the failure of the bus was caused by loosening of the bolted connections on the central phase flexible link due to repeated thermal cycles over time.

Issue:

Even though these MEBs are not in-scope of license renewal, the staff is concerned that a similar failure mode may occur in the in-scope MEBs during the extended period of operation.

Columbia Generating Station operating experience may not support the applicants conclusion that LRA AMPB.2.40 will provide reasonable assurance that the aging effects will be managed such that the in-scope MEBs will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Request:

Describe the corrective actions taken or planned to prevent recurrence of similar failures of MEBs in the scope of license renewal.

Columbia Generating Station cc:

Mr. J.V. Parrish, Chief Executive Officer EFSEC Manager Energy Northwest Energy Facility Site Evaluation Council MD 1023 P.O. Box 43172 P.O. Box 968 Olympia, WA 98504-3172 Richland, WA 99352-0968 Mr. Abbas Mostala Mr. S. K. Gambhir Energy Northwest Energy Northwest P.O. Box 968 MD PE04 MD PE 29 P.O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Douglas W. Coleman, Manager, Regulatory Programs Energy Northwest P.O. Box 968 MD PE20 Richland, WA 99352-0968 Mr. William A. Horin, Esq.

Winston and Strawn 1700 K Street, NW Washington, DC 20006-3817 Chairman, Benton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190 Mr. Richard Cowley Washington State Department of Health 111 Israel Road, SE Tumwater, WA 98504-7827 Mr. Ron Cohen U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352 Regional Administrator U.S. NRC Region IV Texas Health Resources Tower 612 E. Lamar Boulevard, Suite 400 Arlington, TX 76011-4125