ML102300229
| ML102300229 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/26/2010 |
| From: | Gettys E License Renewal Projects Branch 1 |
| To: | Gambhir S Energy Northwest |
| Gettys E, NRR/DLR, 415-4029 | |
| References | |
| TAC 3058 | |
| Download: ML102300229 (11) | |
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UNITED STATES
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Mr. S.K. Gambhir Vice President Technical Services Columbia Generating Station Energy Northwest MD PE04 P.O. Box 968 Richland, WA 99352-0968
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. 3058)
Dear Mr. Gambhir:
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 bye-mail at evelyn.gettys@nrc.gov.
Sincerely,
'&r Evelyn G ys, 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
COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI8.2.32-4 Inaccessible Cables
Background:
NUREG-1801, Rev. 1, "Generic Aging Lessons Learned" (the GALL Report), addresses inaccessible medium voltage cables in Aging Management Program (AMP) XI.E3, "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." The purpose of this program is to provide reasonable assurance that the intended functions of inaccessible medium voltage cables (2 kV to 35 kV), that are not subject to environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by moisture while energized, will be maintained consistent with the current licensing basis. The scope of the program applies to inaccessible (in conduits, cable trenches, cable troughs, duct banks, underground vaults or direct buried installations) medium voltage cables within the scope of license renewal that are exposed to significant moisture simultaneously with significant voltage.
The application of AMP XI.E3 to medium voltage cables was based on the operating experience available at the time Revision 1 of the GALL Report was developed. However, recently identified industry operating experience indicates that the presence of water or moisture can be a contributing factor in inaccessible power cables failures at lower service voltages (480V to 2kV). Applicable operating experience was identified in licensee responses to Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," which included failures of power cable operating at service voltages of less than 2kV where water was considered a contributing factor. The staff has proposed changes to be included in the next revision of the GALL Report AMP XI.E3 to address recently identified operating experience concerning the failure of inaccessible low voltage power cables, which includes general water intrusion as a failure mechanism and increases the scope of program to include power cables greater than or equal to 480V.
Issue:
The staff has concluded, based on recently identified industry operating experience concerning the failure of inaccessible low voltage power cables (480v to 2kV) in the presence of significant moisture, that these cables should be included in an AMP. The staff notes that your AMP does not address these low voltage cables.
Request:
- 1. Provide a summary of the evaluation of recently identified industry operating experience and any plant specific operating experience concerning inaccessible low voltage power cable failures within the scope of license renewal (not subject to 10 CFR 50.49 environmental qualification requirements), and how this operating experience applies to the need for additional aging management activities at your plant for such cables.
ENCLOSURE
-2
- 2. Provide a discussion of how your AMP will address aging management of inaccessible low voltage power cables within the scope of license renewal(not subject to 10 CFR 50.49 environmental qualification requirements); with consideration of recently identified industry operating experience and any plant specific operating experience. The discussion should include an assessment of your AMP description, program elements (i.e., scope of program, parameters monitored/inspected, detection of aging effects, and corrective actions), and Final Safety Analysis Report summary description to demonstrate reasonable assurance that the intended functions of inaccessible low voltage power cable (not subject to environmental qualification requirements of 10 CFR 50.49) exposed to adverse localized environments will be maintained consistent with the current licensing basis through the period of extended operation.
RAI 3.3.1-53.1
Background:
The GALL Report Table 3, line items 53 and 54 indicate that steel or stainless steel piping, piping components, and piping elements exposed to condensation should be managed by the Compressed Air Monitoring Program. The GALL AMP XI,M24, "Compressed Air Monitoring Program" includes recommendations for the management of aging effects through visual inspection and for preventive maintenance including air quality checks and performance monitoring. Specifically, the "Monitoring and Trending" element of the GALL Report Compressed Air Monitoring Program recommends testing to verify proper operation of the compressed air system by comparing measured system performance values with specified performance limits as part of the AMP.
Issue:
License renewal application (LRA) Table 3.3.1 indicates that the GALL Report Table 3, line items 53 and 54 are not applicable to Columbia Generating Station (CGS) for compressed air system steel and stainless steel piping, piping components and piping elements exposed to internal condensation. As a result, the applicant has not developed a Compressed Air Monitoring Program consistent with the GALL guidance to manage steel or stainless steel piping, piping components, and piping elements exposed to condensation. However, it is not clear to the staff how internal condensation can be quantitatively ruled out as an environment for all compressed air system steel and stainless steel piping, piping components, and piping elements.
Request:
Identify the Compressed Air System components and their corresponding environments within the scope of license renewal and provide justification for how those environments are kept free of all moisture.
- 3 RAI3.1.1.57-01
Background:
In LRA Table 3.1.1, Item 3.1.1-57, the applicant stated that it is not applicable to the CGS LRA.
The applicant stated that loss of fracture toughness due to thermal aging does not need to be identified and managed for the cast austenitic stainless steel (CASS) main steam flow restrictors because they are not part of the reactor coolant system (RCS) pressure boundary and there is no significant pressure drop across these components and thus no driving force for the propagation of cracks.
The GALL Report Item IV.C1-2 recommends GALL AMP XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)" to manage loss of fracture toughness/thermal aging in CASS bOilingwater reactor (BWR) piping, piping components, and piping elements (including main steam line flow elements or restrictors) that are exposed to reactor coolant/steam greater than 250°C (482°F) environment.
Issue:
The staff noted, that Item 3.1.1-57 states that there is no significant pressure drop across the flow restrictors and thus no driving force for the propagation of cracks. The applicant further stated that unpropagated cracking does not affect the throttling function of the main steam flow restrictors. In addition the applicant stated that, cracking (due to any mechanism) of the main steam flow restrictors is not an aging effect requiring management. The staff noted that loss of fracture toughness due to thermal aging embrittlement is an aging effect which may have an adverse effect on the material properties of a component and it is dependent on time and temperature.
Request:
Clarify if these CASS main steam flow restrictors have been screened for susceptibility to loss of fracture toughness due to thermal aging embrittlement consistent with GALL AMP XI.M12. If yes, please provide the results and the applicable AMP to manage this aging effect during the period of extended operation, if needed. If not, justify how loss of fracture toughness due to thermal aging embrittlement for these CASS main steam flow restrictors exposed to reactor coolant/steam greater than 250°C (482°F) will not occur during the extended period of operation for CGS.
RAI3.3.2.1-Y1 Open Cycle
Background:
The GALL Report Table VII.C1, item VII.C1-1 states that elastomer components exposed to raw water can undergo hardening and loss of strength due to elastomer degradation, and loss of material due to erosion. The GALL Report further states that Chapter XI.M20, "Open-Cycle Cooling Water System" AMP was found acceptable to properly manage these aging effects with no further evaluation.
Issue:
The LRA Table 3.3.2-22, Row Number 15, refers to the above item and cites generic note "I,"
indicating that the aging effect in the GALL Report for this component, material, environment are not applicable. The LRA stated that there were no aging effects requiring managing and no
-4 AMP was credited for this component. It is not clear to the staff, why the aging effects are not applicable.
Request:
Provide technical justification substantiating the claim that the flexible connections exposed to raw water are not susceptible to the above aging effects and that no AMP is needed for these components during the period of extended operation.
RAI 3.3.2.1-Y2
Background:
The GALL Report Table VII.H2, item VII.H2-22 states that steel piping, piping components, and piping elements exposed to raw water can undergo loss of material. The GALL Report further states that Chapter XI.M20, "Open-Cycle Cooling Water System" AMP was found acceptable to properly manage this aging effect with no further evaluation.
Issue:
The LRA Table 3.3.2-16, Row Number 28, refers to the above item and cites note "E," indicating that the component is consistent with the GALL Report for material, environment, and aging effect, but that a different AMP is credited. The applicant credited the Diesel Systems Inspection Program as the AMP to manage this aging effect. However, it is not clear to the staff how the Diesel System Inspection Program, which is a one-time inspection program, will appropriately manage aging of this component, because the GALL-accepted AMP includes periodic inspections to detect the associated aging effect.
Request Provide technical justification for how the Diesel Systems Inspection Program will adequately manage loss of material for the steel piping exposed to raw water.
RAI 3.3.2.1-Y3
Background:
The GALL Report Table VII.H2, item VII.H2-22 states that steel piping, piping components, and piping elements exposed to raw water can undergo loss of material. The GALL Report Table VII.H2, item VII.H2-18 states that stainless steel piping, piping components. and piping elements exposed to raw water can undergo loss of material. The GALL Report further states that the Chapter XI.M20, "Open-Cycle Cooling Water System" AMP was found acceptable to properly manage these aging effects with no further evaluation.
Issue:
The LRA Table 3.3.2-17, Row Numbers 34,39, and 54, indicates that steel and stainless steel components exposed to raw water can undergo loss of material, and will be managed by the Diesel Starting Air Inspection Program. The LRA further states that these items are covered by note "E," which means the component is consistent with the GALL Report for material, environment, and aging effect, but that a different AMP is credited. The applicant has credited the Diesel Starting Air Inspection Program, as the AMP to manage these aging effects for the above items. It is not clear to the staff how the Diesel Starting Air Inspection Program, which is a one-time inspection program, will appropriately manage this aging effect for these
- 5 components, because the GALL-accepted AMP includes periodic inspections to detect the associated aging effects.
Request:
Provide technical justification for how the Diesel Starting Air Inspection Program will adequately manage loss of material for steel and stainless steel components exposed to raw water for the components discussed above during the period of extended operation.
RAI 3.3.2.1-Y 4
Background:
The GALL Report Table VILC1, item VILC1-19 states that steel piping, piping components, and piping elements exposed to raw water can undergo loss of material. The GALL Report Table VII.C1, item VILC 1-5 states that steel heat exchanger components exposed to raw water can undergo loss of material. The GALL Report Table VILC1, item VII.C1-15 indicates that stainless steel piping, piping components, and piping elements exposed to raw water can undergo loss of material. The GALL Report further states that the Chapter XI.M20, "Open-Cycle Cooling Water System" AMP was found acceptable to properly manage these aging effects for these components with no further evaluation.
Issue:
The LRA Table 3.3.2-21, Row Numbers 5,11,14,17,23,28,39,42,45,48, and 51; Table 3.3.2-23, Row Numbers 6, 11, and 15; Table 3.3.2-24, Row Numbers 6, 9, 13, 20, 24, 28, 31, 34, 37, and 40; Table 3.3.2-25, Row Number 77; Table 3.3.2-26, Row Numbers 8, 12, and 15; Table 3.3.2-33, Row Numbers 6,18,22,34,36,42, and 46; and Table 3.3.2-38, Row Number 15 all refer to the above items and cite generic note "E," indicating that the component is consistent with the GALL Report for material, environment, and aging effect, but that a different AMP is credited. The applicant credited the Monitoring and Collection Systems Inspection Program as the AMP to manage these aging effects. However, it is not clear to the staff how the Monitoring and Collection Systems Inspection Program, which is a one-time inspection program, will appropriately, manage the aging effects for these components, because the GALL-accepted AMP includes period inspections to detect the associated aging effects.
Request:
Provide technical justification for how the one-time inspection of the Monitoring and Collection Systems Inspection Program will adequately manage the aging effects for the components discussed above during the period of extended operation.
RAI3.3.2.1-Y5
Background:
The GALL Report Table VII.H2, item VII.H2-18 indicates that stainless steel piping, piping components, and piping elements exposed to raw water can undergo loss of material. The GALL Report Table VII. C 1, item VII. C 1-3 indicates that copper alloy heat exchanger components exposed to raw water can undergo loss of material. The GALL Report Table VII.C1, item VII.C1-6 indicates that copper alloy heat exchanger components exposed to raw water can undergo reduction of heat transfer due to fouling. The GALL Report Table VILG, item VII.G-7 indicates that stainless steel heat exchanger tubes exposed to raw water can undergo
- 6 reduction of heat transfer due to fouling. The GALL Report further states that the Chapter XI.M20, "Open-Cycle Cooling Water System" AMP was found acceptable to properly manage these aging effects with no further evaluation.
Issue:
The LRA Table 3.3.2-22, Row Numbers 20, 26, 27, 28, 29, 36, 40, 44, 45, 47, 51, and 54 refer to the above items and cite generic note "E," indicating that the component is consistent with the GALL Report for material, environment, and aging effect, but that a different AMP is credited.
The applicant credited the Diesel Driven Fire Pumps Inspection Program as the AMP to manag~
these aging effects. However, it is not clear to the staff how the Diesel Driven Fire Pumps Inspection Program, which is a one-time inspection program, will appropriately manage these aging effects for these components, because the GALL-accepted AMP includes period inspections to detect the associated aging effects.
Request:
Provide technical justification for how the one-time inspection of the Diesel Driven Fire Pumps Inspection Program will adequately manage these aging effects for the stainless steel and copper components exposed to raw water, during the period of extended operation.
RAI 3.3.2.2.7.2-1 Backqround The SRP-LR Section 3.3.2.2.7, item 2, refers to Table 3.3-1, item 17 and states that steel piping in reactor water cleanup and shutdown cooling systems exposed to treated water should be managed for loss of material due to corrosion by monitoring and controlling reactor water chemistry. It continues by stating that the effectiveness of the water chemistry control program should be verified to ensure corrosion is not occurring and that a one-time inspection of select components at susceptible locations is an acceptable method to verify the effectiveness of the water chemistry program.
Issue:
The LRA Section 3.3.2.2.7 item 2 reflects the above recommendation, but notes an exception for steel piping and piping components in the equipment drains radioactive system that are exposed to treated water will be managed for loss of material by the Monitoring and Collection Systems Inspection Program, which is a new one-time inspection program. It is not clear to the staff why a water chemistry program maintaining control of the water chemistry is not implemented to manage aging of these components that are exposed to treated water.
Request:
Provide addition information on why the Monitoring and Collection Systems Inspection Program by itself will adequately manage loss of material for steel piping during the period of extended operation.
RAI 3.3.2.2.10.2 - 1
Background:
-7 The SRP-LR Section 3.3.2.2.10, item 2 refers to Table 3.3-1, item 22 and states that stainless steel and aluminum components exposed to treated water should be managed for loss of material due to corrosion by monitoring and controlling reactor water chemistry. It continues by stating that high concentration of impurities at crevices and locations of stagnant flow could cause pitting and crevice corrosion, and that the effectiveness of the chemistry control program should be verified to ensure that corrosion is not occurring. The SRP-LR states that a one-time inspection of select components at susceptible locations is an acceptable method to verify the effectiveness of the water chemistry program.
Issue:
The LRA Section 3.3.2.2.10 item 2 reflects the above recommendation, but states that loss of material for components in the process sampling radioactive and equipment drains radioactive systems that are not submerged with the suppression pool will only be managed by the Monitoring and Collection Systems Inspection Program, which is a new one-time inspection program. It is not clear to the staff why a water chemistry program maintaining control of the water chemistry is not implemented to manage aging of these components that are exposed to treated water.
Request:
Provide addition information on why the Monitoring and Collection Systems Inspection Program by itself will adequately manage loss of material for the associated components during the period of extended operation.
RAI 4.2.1-a Reactor Vessel (RV) Neutron Embrittlement The staff has found that additional information is required from the applicant concerning the time-limited aging analyses (TLAAs) for neutron embrittlement of the reactor vessel (RV) beltline nozzles, addressed in Section 4.2 of the CGS LRA:
- 1. Section 4.2.1 of the CGS LRA states that RV N12 instrumentation nozzle has a thickness less than 2.5 inches and therefore requires no fracture toughness evaluation per the ASME Code,Section XI, Appendix G, Paragraph G-2223. Therefore this nozzle is not included in the analyses for the neutron fluence in LRA Section 4.2.1, the adjusted reference temperature (ART) in LRA Section 4.2.3, and the Charpy Upper Shelf Energy (USE) in LRA Section 4.2.2, despite the fact that this is a beltline nozzle that would be exposed to a projected neutron fluence greater that 1 x 1017 n/cm 2 (E > 1.0 MeV) at the end of the period of extended operation.
Subparagraph G-2223(c) of the ASME Code,Section XI, Appendix G states that, U[flracture toughness analysis of demonstrate protection against nonductile failure is not required for portions of nozzles and appurtenances have a thickness of 2.5 in. (63 mm) or less, provided the lowest service temperature is not lower than RT NOT plus 60 OF (33 Qq." [emphasis added] Since the RV N 12 instrumentation nozzle will be exposed to a projected neutron fluence greater that 1 x 10 17 n/cm 2 (E > 1.0 MeV) at the end of the period of extended operation, the effects of radiation on the material properties of the nozzle must be considered. Therefore, an ART value (Le., RTNOT adjusted to account for the effects of radiation) must be determined for the N12 instrumentation nozzle to determine if the criteria stated above will continue to be met through the end of the extended operating period. If not, the N 12 instrumentation nozzle must be considered when the licensee develops pressure-temperature limits for CGS in accordance with
-8 Title 10 of the Code of Federal Regulations Part 50, Appendix G (10 CFR Part 50, Appendix G) and ASME Code,Section XI, Appendix G.
10 CFR Part 50, Appendix G, Paragraph IV.A.1.a. states that, "[r]eactor vessel beltline materials must have Charpy upper-shelf energy in the transverse direction for the base material of no less than 75 ft-Ib (102 J) initially and must maintain Charpy upper-shelf energy throughout the life of the vessel of no less than 50 ft-Ib (68 J)" 10 CFR Part 50, Appendix G, Paragraph II F, defines beltline materials to include those "that are predicted to experience sufficient radiation damage to be considered in the selection of the most limiting material with regard to radiation damage.
Without additional evaluation of the effects of radiation on the USE of the N 12 instrumentation nozzle, it cannot be determined whether this material is, or is not, limiting with respect to USE for the CGS RV.
Therefore, please supplement Sections 4.2.1,4.2.2, and 4.2.3; including Table 4.2-1; Table 4.2 2,4.2-3, or 4.2-4 (as applicable); and Table 4.2-5; of the CGS LRA to include data for the analysis of the neutron fluence, ART, and USE for the CGS RV N 12 instrumentation nozzle.
- 2. Similarly to the request in Question 1, please supplement Section 4.2.2, including Table 4.2 2, 4.2-3, or 4.2-4 (as applicable), of the CGS LRA to include data for the analysis of the USE for the RV N6 RHR/LPCI nozzles, as these are beltline nozzles, and as such, the USE for these nozzles must be projected to the end of the period of extended operation to determine whether the nozzles will remain in compliance with 10 CFR Part 50, Appendix G requirements.
August 26, 2010 Mr. S.K. Gambhir Vice President Technical Services Columbia Generatillg Station Energy Northwest MD PE04 P.O. Box 968 Richland, WA 99352-0968
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. 3058)
Dear Mr. Gambhir:
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 bye-mail at evelyn.gettys@nrc.gov.
Sincerely, IRA!
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 DISTRIBUTION:
See next page ADAMS Accession No'.. ML102300229 I~~E LA:DLR IKing PM:RPB1 :DLR EGettys w/edits BC: RPB1:DLR BPham PM:RPB1 :DLR EGettys DATE 8/16110 8/27/10 8/25/10 8/26/10 OFFICIAL RECORD COpy
Letter to S.K. Gambhir from E. Gettys Last dated August 26,2010
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATI NG STATION, LICENSE RENEWAL APPLICATION (TAC NO. 3058)
DISTRIBUTION:
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