ML102440342

Response to Request for Additional Information License Renewal Application

ML102440342
Person / Time
Site:	Columbia
Issue date:	08/19/2010
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-10-117
Download: ML102440342 (135)

Text

ENERGY NORTHWEST Sudesh K. Gambhir Vice President, Technical Services P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@energy-northwest.com August 19, 2010 G02-10-117 U.S. Nuclear ATTN: Docur Washington,

Reference:

Regulatory Commission ment Control Desk D.C. 20555-0001 COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITION\\AL INFORMATION LICENSE RENEWAL APPLICATION

1) Letter, G02-1 0-11, dated January 19, 2010 WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter dated June 21, 2010, NRC toWS Oxenford (Energy Northwest),

"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application" (ADAMS Accession No. ML101660665)

3) Letter dated June 24, 2010, NRC to WS Oxenford (Energy Northwest),

"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application 7 Scoping and Screening Methodology," (ADAMS Accession No. MIL1 01650276)

4) Letter dated June 24, 2010, NRC to WS Oxenford (Energy Northwest),

"Request for Additional Information for the Review of\\ the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML101660030)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested the renewal of the Colurmbia Generating Station (Columbia) operating license. Via References 2, 3 and 4, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal.

>4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 Transmitted herewith in Attachment 1 is the Energy Northwest response to Request for Additional Information (RAI) Reference 2. Attachment 2 is the response to RAI Reference 3. Attachment 3 provides the responses to RAI Reference 4. Enclosure 1 contains Amendment 2 to the License Renewal Application (LRA) that was submitted in Reference 1. Enclosure 2 contains informational copies of new and revised License Renewal boundary drawings. The NRC Project Manager, Ms. Evelyn Gettys, was informed of the schedule for the Energy Northwest response to the three RAIs and that we would be combining the three responses in one letter.

The new commitments included in this response are provided in Enclosure 1, LRA Amendment 2, Appendix A, Table A-1. In Table A-I, commitment 26 is revised and commitment 61 has been added.

If you have any questions or require additional informationr please contact Abbas Mostala at (509) 377-4197.

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

Rtaectfully, S

Pambhir Vice President, Technical Services Attachments:

Enclosures

1) Response to Request for Additional Information

2) Response to Request for Additional Information

3) Response to Request for Additional Information

4) Example Wear Rate Analyses, for RAI B.2.28-1

1) License Renewal Application, Amendment 2

2) New and Revised Boundary Drawings (3 copies for information only) cc:. NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EJ Leeds -NRC NRR EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn EH Gettys - NRC NRR (w/a)

BE Holian - NRC NRR RR Cowley - WDOH

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 11 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Letter dated June 21, 2010, NRC to WS Oxenford (Energy Northwest),

"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application" (ADAMS Accession No. ML101660665)

RAI 3.3.2.2.6-1

Background

The Generic Aging Lessons Learned (GALL) Report for neutron absorbing materials cites both loss of material and loss of neutron absorbing capacity as potential aging effects. In addition, the LR-ISG-2009-01, "Aging Management of Spent Fuel Pool Neutron-Absorbing Materials other than Boraflex," April 27, 2010, recommends that applicants implement an aging management program to address these effects on neutron absorber material other than Boraflex during the period of extended operation.

In the LRA, it was stated that boron carbide (B4C) is used as the neutron absorbing material, sealed in stainless steel racks, and is not exposed to treated water. As a result, it was stated that there are no aging effects requiring management for this neutron absorber material.

Issue The LRA does not address applicability of recent adverse industry operating experience with neutron absorber materials and staff guidance (i.e., NRC Information Notice 2009-26: Degradation Of Neutron-Absorbing Materials in the Spent Fuel Pool, and LR-ISG-2009-01).

Request

1) Describe how the Columbia plant plans to address the potential effects of loss of material and loss of neutron absorbing capacity of the boron carbide material. If it is determined that there are no aging affects requiring managing for the neutron absorber material, please provide and discuss the justification.

2) Describe the material specifications (i.e., dimensions, percentage B4C, etc) of the boron carbide material. Also, provide the age, manufacturer of the material and method of fabrication.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 11

3) If the applicant identifies aging effect requiring management for the boron carbide, describe the aging management program(s) that will be used. Specifically:

a) Provide the 10 elements of the aging management program for boron carbide (i.e., scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance, corrective actions, confirmation process, administrative controls, and operating experience).

b) Discuss the weight loss acceptance criteria for the boron carbide neutron absorber material such that the 5 percent subcriticality margin is maintained.

c) Indicate whether the boron carbide material in the spent fuel pool is vented or not.

d) Indicate the installation date of the boron carbide material in the Columbia spent fuel pool.

e) Describe the surveillance approach that will be used in the cited AMP, specifically the methods and techniques utilized (e.g., visual, weight, volumetric, surface inspection, neutron attenuation testing; frequency, sample size, data collection, timing and acceptance criteria).

f) Describe how the neutron attenuation of the material will be measured. Include a description of the testing, parameters measured, calculations, and acceptance criteria.

g) Discuss the corrective actions that would be implemented if test results are not acceptable.

4) Discuss how it is assured that spent fuel pool water does not leak into the sealed stainless steel weld.

5) Discuss the results of coupon testing at Columbia, other industry operating experience of boron carbide, and how that experience is applicable to Columbia and any potential safety concerns identified in the boron carbide operating experience.

Energy Northwest Response

1) As stated in the LRA, no aging effects that require management have been observed for the neutron absorbing material used at Columbia Generating Station (Columbia). However, Energy Northwest has decided to develop the current monitoring program into a plant specific Boron Carbide Monitoring Program. The 10 element program has been added to the License Renewal Application (LRA) in Amendment 2, provided in Enclosure 1.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 11

2) The neutron absorber plates are a boron carbide material (B4C) manufactured in West Germany by Electroschmelzwerk-Kempen (ESK). The absorber plates are composed of B4C granule (powder) material that is mixed with a phenolic resin and catalyst. The plates are then pressed into the approximate shape, baked in an oven to 10500C for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to pyrolyze the resin material, and then trimmed to the final size.,

The final size of the B4C plate material is:

a. Length 19.00

_+0.09 inches

b. Width 5.880

+0.040 inches

- 0.100 inches

c. Thickness 0.210

+0.035 inches

- 0.020 inches The B4C plate composition is as follows in percent by weight:

B 63%

(Approx.)

B+C 95%

(Min.)

B20 3 1.5%

(Max.)

Fe 0.5%

(Max.)

B4C 75%

(Min.)

The minimum B-10 loading of the plates and bare plate density is:

B-10 Loading 0.0959 gm/cm 2 Density 1.55 +/- 0.1 gm/cm 3 or 0.05 +/- 0.004 lb/in3 The length of the B4C plate material assembly is 152 inches.

The plates were fabricated and installed between 1979 and 1983.

3. a) Columbia's aging management program (AMP) for boron carbide (B4C) is provided in Enclosure 1, as Amendment 2 to the LRA b) The current criticality analysis for Columbia spent fuel racks assumes a 10%

degradation of the nominal B-10 loading of 0.0959 g/cm 2. The 10% degradation corresponds to a B-10 loading of 0.08631 g/cm 2. This assumption ensures that the 5% criticality margin is maintained.

c) To prevent distortion of the spent fuel pool rack cavities and binding of spent fuel pool assemblies due to pressure buildup, the Spent Fuel Rack enclosures are vented above storage pool water surface through an arrangement of tubing and sampling valves at the pool curb. Monitoring of gas pressure and venting to relieve pressure are provided for in the plant's work management system.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 11 d) Installation date for the boron carbide material in the Columbia spent fuel pool was in the period between 1979 and 1983.

e) A visual examination of the B4C sample coupons is made on a four-year frequency to evaluate surface appearance, size, shape and color. Neutron attenuation testing of B4C samples will be conducted on a periodic basis to determine if physical degradation is occurring in the plate material. In addition, chemical testing will take place on a periodic basis to determine if leaching of the boron content is occurring. The acceptance criteria are based on the ability to maintain the 5% subcriticality margin of the spent fuel racks for the period of extended operation.

f) Energy Northwest is not capable of performing the neutron attenuation testing and will contract an offsite testing lab vendor for the neutron attenuation testing of the B4C coupons. The contract will specify that the vendor have an approved Quality Assurance Program, in compliance with 10 CFR 50, Appendix B. The vendor will be required to perform the testing in accordance with the applicable ASTM standards.

g) Corrective actions are initiated if the test results find that the 5% subcriticality margin cannot be maintained because of the current or projected future degradation. The fuel rack loading pattern will be determined by Reactor Engineering and one or more samples will be analyzed for B-10 content. A criticality analysis from all three fuel vendors (AREVA, GNF and Westinghouse) would be needed for normal and accident conditions to determine the maximum B-10 degradation that could be allowed while still meeting the Tech Spec subcritical multiplication factor criteria of 0.95 under normal and accident conditions. If data continues to suggest less than 5% subcriticality, then blackness testing such as Boron-1 0 Areal Density Gage for Evaluating Racks (BADGER) testing may be performed on the racks as a result of corrective action process (CAP).

4. As stated in Final Safety Analysis Report (FSAR) Section 9.1.2.2.1, the plate has been shown by tests to have negligible corrosion in water and thermally stable over the range of pool water temperatures that can occur. The plates are seal welded in a stainless steel cavity to prevent water intrusion and are vented at the pool curb through sampling valves.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 11 The safety evaluation section for 8X8 fuel, FSAR Section 9.1.2.3.1.1, states that with the void space between the B4C plates and the box flooded with water the KENO calculation yielded a lower Keff than the Keff with the space voided. In this configuration the fuel is over moderated with respect to the amount of water surrounding it, thus causing the water to absorb more neutrons than it moderates back to the fuel. This would also be applicable to the 9X9 and 1OX10 fuel in the pool. In addition there is negligible corrosion in water. Isotopic measurements performed on plate samples exposed to the spent fuel water for approximately 10 years showed no measurable difference in isotopic abundance compared to a control sample.

To ensure the integrity of the spent fuel storage racks in the event that water has leaked into the racks, specially designed Control samples, consisting of B4C plates in vented (to pool water) canisters, are placed in a readily accessible position in the spent fuel pool. These samples are subjected to periodic examinations to check for possible deterioration and they are also analyzed to ensure that the boron has not leached from the plates.

5. The results of the coupon testing at Columbia and other operating experience are contained in the Operating Experience section of the Boron Carbide Monitoring Program (B.2.54) added in Amendment 2 to the LRA and provided in Enclosure 1 to this letter.

RAI B.2.28-1

Background

In LRA Section B.2.28, the applicant states that the Flow-Accelerated Corrosion (FAC)

Program includes procedures to assure that the structural integrity of all steel and gray cast iron lines containing high energy fluids is maintained. The applicant further states that to ensure that all aging effects caused by FAC are properly managed following Nuclear Safety Analysis Center-202L Rev. 3, the program includes the use of a predictive code such as CHECWORKS model predictions, trending, inspections and plant and industry operating experience events.

Issue The LRA does not contain information regarding the accuracy of the FAC Program in predicting FAC degradation in components.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 11 Request Please provide a sample list of components, from the systems most affected by FAG, for which wall thinning is predicted and measured in order to assess the accuracy of the FAG predictions from CHECWORKS. This list should also include the initial wall thickness (nominal), current (measured) wall thickness, and a comparison of the measured wall thickness to the thickness predicted by the CHECWORKS FAG model.

Energy Northwest Response A table of sample locations with measure data is provided. The example locations examined were selected based on recommendations from CHECWORKS. A location is examined with no less than two years before reaching the predicted design minimum thickness (T-Crit). Additional locations are selected based on highest wear rate predicted by the CHECWORKS Pass 1. Pass 1 within CHECWORKS is an evaluation that does not include inspection data while a Pass 2 includes inspection data.

CHECWORKS Pass 1 analyses are used to indicate the relative susceptibility of the components within the lines. An example of selected wear rated analyses is included in.

Trended Measured Wear Rate Out Nominal Thickness (at last Location Component System age (inches)

(inches) exam) 368-7 Tee HD R18 0.375 0.126 0.014 in./yr 323-4 Elbow HD R18 0.375 0.357 0.002 in./yr 329-11 Elbow HD R19 0.375 0.356 0.002 in./yr 338-4 Elbow COND R18 0.812 0.763 0.008 in./yr 424-5 Expander COND R16 0.344 0.256 0.006 in./yr 340-11 Elbow COND R19 0.812 0.656 0.006 in./yr 652-2 Nozzle/Pipe HV R17 0.237 0.179 0.004 in./yr 378-1 Nozzle HV R17 0.600 0.516 0.006 in./yr

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 11 RAI B.2.29-1

Background

After the issuance of Revision 1 of the GALL Report, the NRC has issued Information Notice (IN) 2009-02, "Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance." This Information Notice discusses potential issues that mayoccur with the use of B5 blend fuel oil, such as: suspended water particles, biodegradation of B5, material incompatibility, etc.

Issue The LRA does not provide information discussing the concerns of IN 2009-02 and the acceptable or unacceptable use of biodiesel at Columbia.

Request

1. Provide a summary of the actions that were taken to determine the impact of IN 2009-02 and the use of biodiesel fuel oil at Columbia, particularly, whether issues of suspended water particles and biodegradation introduces a new aging environment to be considered.

2. If biodiesel is currently being used at Columbia, please describe any problems that Columbia encountered with the use of bio-diesel and the associated corrective actions to prevent reoccurrence in the future.

3. If biodiesel has been determined to not be acceptable for use at Columbia, please describe the actions taken and/or will be taken to prevent its addition into fuel oil supply. Please also describe actions that will be taken if it is determined that biodiesel has been added into the fuel oil supply.

Energy Northwest Response NRC IN 2009-02 is summarized as follows.

On June 19, 2008, the American Society forTesting and Materials (ASTM)

International D02 Main Committee approved a revision to the conventional petrodiesel standard specification. The revised standard, ASTM D975-08a, "Standard Specification for Diesel Fuel Oils," now permits No. 2 diesel fuel to contain up to a B5 blend and still be considered the same without labeling the blend. The changes to this standard will take effect within 3 to 5 months after the October 13, 2008, publication date of the final standard. The introduction of biodiesel blends into the No. 2 diesel fuel supply raises potential generic applicability and common-cause failure concerns because of the possibly adverse physical properties associated with biodiesel use in diesel engines including the safety-related emergency diesel generators (EDGs).

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 11

1. Energy Northwest performed an evaluation of IN 2009-02 to determine the impact of biodiesel fuel use oil at Columbia. The evaluation determined that biodiesel is not acceptable for use at Columbia due to the limited stability for long term storage and the adverse effect on components in the emergency diesel generator system.

Actions taken as a result of this evaluation include revision in the blanket purchase order for procurement of No. 2 diesel fuel for the emergency diesel generators to state, "Straight biodiesel is not acceptable. Any blended biodiesel is not acceptable." The facilities contract was also revised to prohibit vendor deliveries of B5 blended biodiesel for use in non-emergency equipment, such as the diesel fire pumps and diesel generators for emergency preparedness and response function.

2. Energy Northwest does not accept biodiesel and therefore it is not in use at Columbia.

3. A screening test is performed for biodiesel prior to receiving fuel oil for emergency diesel generators. If the test is positive for biodiesel, the shipment is rejected. For non-emergency diesel generator fuel oil, no receipt tests are performed, however a water and sediment test is performed on the storage tank on a quarterly basis. B5 biodiesel blends contain suspended particles of water from the manufacturing process which will, in time, fall out of suspension and form "dirty water" in the fuel oil storage tank. If the water and sediment test results are above the limit of 0.05%,

then a condition report would be entered in the CAP to document the unsatisfactory results and notification made to the system engineer. Corrective action would be taken, if necessary, to clean the storage tank to remove the water and sediment.

RAI B.2.29-2

Background

The GALL Report AMP XI.M30 states that degradation of the diesel fuel oil tank cannot occur without exposure of the tanks internal surfaces to contaminants in the fuel oil, such as water and microbiological organisms. It is further stated that periodic multilevel sampling provides assurance that fuel oil contaminants are below unacceptable levels.

Issue The LRA states that multilevel sampling of the fuel oil storage tanks is not performed; rather, a representative fuel stream sample is drawn from the flushing line during recirculation and transfer.

Request Discuss how the sampling method utilized for the fuel oil storage tanks is consistent with the recommendations of the GALL Report (i.e., multilevel sampling).

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 11 Energy Northwest Response As stated in the LRA Section B.2.29, Energy Northwest described the exception for the detection of aging effects. Energy Northwest will obtain the representative sample drawn from the flushing line during tank recirculation, rather than using the multilevel sampling technique discussed in the GALL Report. The objective of multilevel sampling is to provide a representative sample of a fuel oil storage tank. Fuel oil storage tanks for the emergency diesel generators are sampled for particulate analysis on a monthly basis by drawing a line sample from the Diesel Fuel Oil Filter/Polisher System. The filter/polisher system is designed to recirculate and filter the applicable tank. By drawing the particulate sample from this recirculation system a representative sample is ensured as required by ASTM D4057, Standard Practice for Manual Sampling of Petroleum and Petroleum Products. Line sampling for particulate contamination is allowed by ASTM D2276. However, ASTM D2276 is specified for the use of online particulate testing via a field monitor. Since the current design of the filter/polisher system does not allow the installation of an online field monitor, the representative sample is drawn from the recirculation line of the filter/polisher system and analyzed in the laboratory per ASTM D5452.

Based on the ability of the system to recirculate the tank contents and allow a sample of the recirculated fuel oil, this representative sample is consistent with multilevel sampling which takes small samples at different levels in the storage tank.

RAI XI.$8-1

Background

The GALL Report states that proper maintenance of protective coatings inside containment (defined as Service Level I in Nuclear Regulatory Commission Regulatory Guide [RG] 1.54, Rev. 1) is essential to ensure operability of post-accident safety systems that rely on water recycled through the containment sump/drain system. Degradation of coatings can lead to clogging of strainers, which reduces flow through the sump/drain system.

Issue The Columbia LRA does not credit the protective coating monitoring and maintenance program for aging management. Although the licensee does not credit the program for aging management, there needs to be adequate assurance that there is proper management and maintenance of the protective coatings in containment, such that they will not degrade and become a debris source that may challenge the Emergency Core Cooling Systems performance.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 11 Request

1. Discuss why XI.S8, "Protective Coating Monitoring and Maintenance Program," is not credited for aging management.

2. Discuss in detail whether Columbia has a coatings monitoring and maintenance program. Describe the program if one is used.

3. Describe how Columbia will ensure that there will be proper maintenance of the protective coatings inside containment such that they will not become a debris source that could impact the operability of post-accident safety systems that rely on water recycled through the containment sump or drain system in the extended period of operation.

4. If a program is used, describe the frequency and scope of the inspections, acceptance criteria, standards used, and the qualification of personnel who perform containment coatings inspections.

Energy Northwest Response

1. As stated in Table B-1 of the LRA, protective coatings are not credited for aging management at Columbia. Coatings inside containment are not credited for managing the aging effects for structures and components or to ensure that the intended functions of coated structures and components are maintained. Also, as stated in LRA Table line item 3.5.1-25, the effect of coating debris on ECCS pump suction strainers has been evaluated to have no safety impact on strainer operation (see FSAR Section 6.1.2). Containment coatings are subject to ongoing oversight that addresses their current status and will continue to address their status over the period of license renewal. Therefore, these coatings do not have an intended function as described in 10 CFR 54.4 and do not require aging management for license renewal.

2. Columbia has a Service Level 1 Protective Coatings Program. The program directs, performs, and evaluates Service Level 1 Coating evaluations and inspections. The program ensures that Columbia does not exceed the licensing limit of 5000 square feet of unqualified coatings in the drywell and 4000 square feet of unqualified coatings in the wetwell. The Energy Northwest response to Generic Letter (GL) 98-04 identified that Columbia will manage the containment work control process so that the amount of unqualified or degraded coatings do not exceed licensing-basis limits as specified in the FSAR.

3. The Protective Coatings Program requires coating inspections to assess Service Level 1 Coatings. Coatings found to be deficient, degraded, or failing are included in the unqualified coatings log and planned for repair either immediately or the following outage. Coatings will continue to be repaired, as needed, to ensure Columbia does not violate the 5000/4000 unqualified coatings limit. A total failure of the unqualified coatings will not impact the operability of the Emergency Core Cooling System suction strainers.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 11

4. The program requires inspections for the drywell and wetweli to be performed during refueling outages, scheduled every 2 years. Acceptance criteria for blistering, cracking, flaking/peeling/delamination, and rusting are outlined in the program. The program was developed based on standards used for the inspections, consistent with the guidance of ASTM and ANSI (ANSI N45.2.6, ANSI N101.2, ANSI N101.4, ASTM D714, ASTM D3843, ASTM D5163, and ASTM D5962). Inspection personnel are qualified in accordance with ANSI N45.2.6.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 9 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Letter dated June 24, 2010, NRC to WS Oxenford (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application - Scoping and Screening Methodology,"

(ADAMS Accession No. ML101650276)

RAI 2.3.3.22-1 License renewal application (LRA) drawing LR-M515-1, shows that several yard fire hydrants and post indicator valves are out of scope (i.e., not colored in green). The staff believes that yard fire hydrants and post indicator valves have the fire protection intended functions required to be compliant with 10 CFR 50.48 as stated in 10 CFR 54.4. The fire hydrants also serve as the pressure boundary for the fire protection water supply system. Further, NUREG-0892, "Safety Evaluation Report related to the operation of WPPSS Nuclear Project No. 2," dated March 1982, Section 9.5.1.6, "Fire Detection and Suppression," on page 9-33, states that "fire hydrants are provided on the yard main at 300-foot intervals. A hydrant hose house is provided at each hydrant with 200 feet of 2 1/ in. hose and other equipment. A valve is provided in each hydrant lateral to facilitate hydrant maintenance and repair without interrupting flow in the underground pipe loop...." The staff requests that the applicant verify whether the yard hydrants and valves are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an aging management review (AMR) in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response The initial scoping for the yard hydrants did not include all yard fire hydrants and post indicating valves that have fire protection functions compliant with 10 CFR 50.48, as stated in 10 CFR 54.4. Additional yard hydrants and post indicating valves have been added to the scope of license renewal based on the Final Safety Analysis Report (FSAR) Appendix F, as shown in revised License Renewal (LR) boundary drawings provided in Enclosure 2. These hydrants and post indicating valves are credited in the Fire Hazards Analysis section of FSAR Appendix F for the diesel building, reactor building, radwaste building, service water pumphouses, turbine building, and ASD building. The additional hydrants and valve bodies are subject to aging management review (AMR) as listed in LRA Tables 2.3.3-22 and 3.3.2-22, rows 57-61.

RAI 2.3.3.22-2 The fire protection components including jockey pump (FP-P-3), valves, piping, and fittings are not highlighted in the LRA drawing LR-M515-1 as components within the scope of license renewal and subject to an AMR. Further, NUREG-0892, "Safety Evaluation Report related to the operation of WPPSS Nuclear Project No. 2," dated March 1982, Section 9.5.1.6, "Fire Detection and Suppression," on page 9-33, states

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 9 that "a separate jockey pump, rated at 50 gpm at 100 psig, maintain[s] the yard fire main pressure at 100 to 125 psig....." The staff believes that these fire protection components perform a pressure boundary intended function consistent with rest of the fire protection system in scope. The staff requests that the applicant verify whether the fire protection components listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response The primary water supply jockey pump (FP-P-3) is provided to maintain system pressure and to prevent cycling of the main fire pumps (FP-P-1, 2A, 2B), as described in LRA Section 2.3.3.22 and FSAR Section F.2.4.1. The jockey pump (FP-P-3) and associated components, shown on LR-M515-1, do not have a fire protection intended function required for compliance with 10 CFR 50.48. That is, the main (electric and diesel) fire pumps have fire protection intended functions for compliance with 10 CFR 50.48, whereas the jockey pump is a support feature to reduce unnecessary cycling of the main fire pumps. However, Energy Northwest has included the primary water supply jockey pump (FP-P-3) and associated components, as well as the secondary water supply jockey pump (FP-P-1 11) and associated components that support diesel fire pump (FP-P-1 10) within the scope of license renewal and subject to AMR. The boundary drawings are provided in Enclosure 2 and a revision to LRA Table 3.3.2-22, Aging Management Review - Fire Protection to include the jockey pumps and associated components is provided in Enclosure 1.

RAI 2.3.3.22-3 LRA drawing LR-M515-1 shows that several fire suppression systems (Building 5, Building 6, and Building 8) are out of scope (i.e., not colored in green). The staff requests that the applicant verify whether these fire water suppression systems installed in various buildings of the plant are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response The fire suppression systems in the cited buildings are not in the scope of license renewal. They are not required for protection of safety-related equipment and are not required for post-fire safe shutdown, since there are no safety-related components in the buildings and other systems (not located in these buildings) are credited for protecting safety-related equipment and for post-fire safe shutdown of the plant, as described in the Fire Hazards Analysis Report, FSAR Section F.4. As such, the

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 9 suppression systems in the following buildings, as well as the buildings themselves, do not perform intended functions compliant with 10 CFR 50.48.

Building 5 (Alternate Health Physics Access Point), Building 6 (Technical Support Center), and Building 8 (Adjustable Speed Drive) are not within the scope of license renewal. LRA Table 2.2-3, License Renewal Scoping Results for Structures, provides the justification for the exclusion of Building 5, Building 6, and Building 8 from the scope of license renewal. These buildings do not contain any safety-related or safe shutdown equipment. Specific justification for each building is stated below:

Adjustable Speed Drive Building (Building 8) - As stated in LRA Table 2.2-3, the ASD building provides shelter and support for electrical components and cables. The ASD building contains no safe shutdown equipment, or cables, or associated circuits, therefore an ASD fire will not prevent safe shutdown. This is supported by FSAR section 'F.4.4.4, Fire Area ASD, Item 8.a (page F.4-190), "Potential consequences of a design basis fire." Item 8.b also states that the adjacent Turbine building 3-hr fire rated wall will prevent fire spread into other plant areas Health Physics Access Point (Building 5) - As stated in LRA Table 2.2-3, the alternate health physics access point (Building 5), houses health physics equipment required for ingress and egress from the power block. The building is located within the protected area and attached to the north wall of the Technical Support Center. FSAR section F.2.2.16 refers to this building as the Alternate Health Physics Building and states that the alternate health physics building is separated from the radwaste building and turbine building by 3-hr rated barriers. FSAR Table T.3-1, section F.14 states that the radwaste building is separated from other areas of the plant by fire barrier walls and door assemblies which have fire ratings adequate for the fire loadings.

Technical Support Center (Building 6) - As stated in LRA Table 2.2-3, the technical support center (Building 6) provides shelter and facilities for personnel in support of emergency response organization. The building is located within the protected area on west side of Radwaste Control Building. FSAR section F.2.2.15 states that the technical support center is separated from the radwaste building by 3-hr rated barriers."

RAI 2.3.3.22-4 LRA drawing LR-M515-4 shows that the fire suppression systems installed in the Turbine Building are out of scope (i.e., not colored in green). The staff requests that the applicant verify whether the Turbine Building fire water suppression systems are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21 (a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 9 Energy Northwest Response The fire suppression systems identified on LRA drawing LR-M515-4 for the turbine building are required for compliance with 10 CFR 50.48. This was incorrectly omitted in the LRA. Therefore, the piping and components in the turbine building as identified on drawings-LR-M515-1 and LR-M515-4 have been included in scope of license renewal as shown on revised boundary drawing provided in Enclosure 2.

RAI 2.3.3.22-5 LRA drawing LR-M573-2 show that the following fire protection components - pumps, tank, piping, valves, drains, and test connections - are out of scope (i.e., not colored in green). The staff requests that the applicant verify whether these fire protection components are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21 (a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response The 400,000 gallon fire protection water storage tank (FP-TK-1 10) is filled from the potable water tank PWC-TK-1 00, as shown on boundary drawing LR-M573-2 (Coordinates C-G/8-1 1). The primary water supply (circulating water basin) and the secondary water supply (FP-TK-1 10) can provide the necessary water demand for compliance with 10 CFR 50.48, as described in LRA Section 2.3.3.22 and in FSAR Section F.2.4.1. The FP-TK-110 fill pump (FP-P-113) and associated components are not required for compliance with 10 CFR 50.48. Therefore, PWC-TK-1 00, FP-P-1 13, and associated piping, valves, drains, and test connections do not perform a function that satisfies the license renewal scoping criteria of 10 CFR 54.4(a)(3) and are not included within the scope of license renewal.

The secondary water supply jockey pump (FP-P-1 11) is provided to maintain system pressure and to prevent cycling of the main fire pump, as described in LRA Section 2.3.3.22. The jockey pump (FP-P-111) and associated components, shown on LR-M573-2, do not have a fire protection intended function required for compliance with 10 CFR 50.48, as it is the diesel fire pump (FP-P-1 10) which the secondary water supply jockey pump supports, that has a fire protection function that complies with 10 CFR 50.48. While not required to comply with 10 CFR50.48, Energy Northwest has included the secondary water supply jockey pump (FP-P-1 11) and associated components to the scope of license renewal subject to AMR. Refer to the response to RAI 2.3.3.22-2. In addition, fire protection pump FP-P-1 12 (recirculation pump) keeps the bladder tank FP-TK-1 10 from freezing in the winter and therefore, performs a 10 CFR 50.48 function. The revised pages are shown in Amendment 2 to the LRA, provided in Enclosure 1. The revised boundary drawing LR-M573-2 including FP-P-1 11 (jockey pump), FP-P-112 and associated components within the scope of license renewal is provided in Enclosure 2.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 9 RAI 2.3.3.22-6 LRA Section 2.3.3.22, on page 2.3-93, states that "the low pressure carbon dioxide system automatically provides fire protection for turbine generator exciter housing. A manual carbon dioxide hose station, with reel and hose, is also provided for exciter housing protection on the turbine generator floor...." The automatic carbon dioxide (C02) fire suppression system and manual C02 hose station, with reel and hose, do not appear in LRA drawings as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether these C02 fire suppression features are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response The automatic carbon dioxide system was not originally within the scope of license renewal because Energy Northwest had determined that it did not perform a license renewal intended function. After further review, Energy Northwest established that the carbon dioxide system is relied upon to demonstrate compliance with, and meet the 10 CFR 54.4(a)(3) scoping criteria, for the fire protection (10 CFR 50.48) regulated event. Therefore, the automatic carbon dioxide system is included in the LRA Amendment 2 in Enclosure 1 and the boundary drawing is provided in Enclosure 2.

RAI 2.3.3.22-7 LRA Section 2.3.3.22, on page 2.3-93, states that "Halon 1301 suppression systems are installed in normally occupied areas where the application of water would be inappropriate. Halon 1301 provides automatic fire protection for the main control room Power Generation Control Cabinet (PGCC) under the floor. Eighteen Halon 1301 system[s] are installed in various main control room PGCC sub-floor duct sections to discharge on activation of their associated thermal detector units...." The eighteen main control room PGCC Halon 1301 fire suppression systems do not appear in LRA drawings as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether these Halon 1301 fire suppression systems are in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 9 Energy Northwest Response.

The Halon 1301 suppression system and associated components are included within the scope of license renewal; however, this distinction is not clear within the LRA. The revised boundary drawings provided in Enclosure 2 clarify that the Halon 1301 system is within the scope of license renewal.

Also, LRA section 2.3.3.22 states the following: "Halon cylinders are within the scope of license renewal. The principal design criterion for these bottles is Department of Transportation Standards (DOT). The Halon cylinders comply with the requirements of the DOT standards. The Halon cylinders are consumables, replaced periodically in accordance with DOT standards, and are not subject to AMR." The Halon cylinders are not replaced periodically and therefore, are subject to AMR. The LRA Amendment 2, provided in Enclosure 1 specifies that the Halon cylinders are subject to AMR.

RAI 2.3.3.22-8 LRA Section 2.3.3.22, on page 2.3-94, states that "A dry chemical system is installed in approved portable hazardous material storage buildings within the plant. The system automatically actuates by melting of the fusible links or manually by a local pull

.station...." The dry chemical fire suppression system does not appear in LRA drawings as being in the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the above dry chemical fire suppression system is in the scope of license. renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If the system is excluded from the scope of license renewaland not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response.

There is one dry chemical fire protection system in the plant. A portable hazardous material storage building is located in the Turbine Building on the 441' elevation. The Dry Chemical Fire Suppression System is associated with the portable storage building.

The automatic dry chemical system was not originally within the scope of license renewal because it was believed that it did not perform a license renewal intended function. After further review, Energy Northwest established that the dry chemical system is relied upon to demonstrate compliance with, and meet the 10 CFR 54.4(a)(3) scoping criteria for the fire protection (10 CFR 50.48) regulated event.

Therefore, the dry chemical system is included within the scope of license renewal as shown in LRA Amendment 2 in Enclosure 1.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 9 RAI 2.3.3.22-9 Tables 2.3.3-22 and 3.3.2-22 of the LRA do not include the following fire protection components:

" fire hose stations, fire hose connections, and hose racks pipe fittings, pipe supports, hangers, and couplings

• flow elements

" flow indicators strainers

" filter housings

• test connections

" sprinklers

• floor drains for fire water dikes and curbs for oil spill confinement The staff requests that the applicant verify whether the fire protection components listed above are in the scope of license renewal in accordance with 10 CFR 54.4(a) and whether they are subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

'Energy Northwest Response Each bulleted item listed in the RAI will be discussed in order.

Fire hose stations, fire hose connections, and hose racks: Fire hose stations consist of an angle hose valve, a wye gate valve, a hose cabinet, and fire hose.

Fire hoses connect directly to the wye gate and there is no separate connection fitting. All hose stations in the plant have a wye gate to convert the 2 Y2" outlet of the angle hose valve to two 1 Y2" hoses. The angle hose and wye gate valves are in the scope of license renewal and subject to AMR for those hose stations that are in scope. There is no separate equipment part number for the wye gate valve as it is included as part of the angle hose valve on the boundary drawings.

See boundary drawing LR-M515-5 detail C. The wye gate is considered a valve for the purposes of Tables 2.3.3-22 and 3.3.2-22. The hose cabinet is considered an equipment component support which is in the scope of license renewal and subject to AMR under bulk commodities in LRA table 2.4-13.

Therefore, the listed components are included in Tables 2.3.3-22, 3.3.2-22 rows 159-167, and 2.4-13. The fire hoses are in scope, but are not subject to AMR because they are not long-lived.

Pipe fittings, pipe supports, hangers, and couplings: Pipe fittings such as elbows, reducers, couplings, flanges are included as piping in Tables 2.3.3-22 and 3.3.2-22. Pipe supports and hangers are included in bulk commodities in Table 2.4-13. Therefore, the listed components are included in Tables 2.3.3-22, 3.3.2-22, and 2.4-13

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 9

" Flow elements: There are no flow elements within the scope of license renewal because the piping sections that contain flow elements do not meet the 10 CFR 54.4(a)(3) criteria.

" Flow indicators: There are no flow indicators within the scope of license renewal because the piping sections that contain flow indicators do not meet the 10 CFR 54.4(a)(3) criteria.

" Strainers: There are strainers (body and screen) within the scope of license renewal and subject to AMR. The component type "Strainer (body and screen)"

is listed on Table 2.3.3-22 and Table 3.3.2-22 of the LRA.

" Filter housings: There are no filter housings within the scope of license renewal because the piping sections that contain filter housings do not meet the 10 CFR 54.4(a)(3) criteria.

" Test connections: Scoping of mechanical systems that have an 10 CFR 54.4(a)(3) fire protection function was performed as follows:

For components that are in scope only for 10 CFR 54.4(a)(2)-

functional, and for 10 CFR 54.4(a)(3), highlight the main flow paths required to perform the functions, and branch lines up to and including the first valve capable of isolating the branch line. Also, highlight (outline) major components, such as tanks, that support these (a)(2) and (a)(3) functions. However, do not highlight attached piping (e.g., vents, drains, fill and overflow lines) that is not part of the main flow path, and does not support the functions, unless its failure could result in a loss of inventory; then, highlight up to and including the first valve.

Test connections do not perform a 10 CFR 54.4(a)(3) function and would be downstream of an isolation valve. Therefore, no test connections are within the scope of license renewal.

Sprinklers: Sprinklers are called "Spray Nozzles" which are in scope and listed in Table 2.3.3-22 and Table 3.3.2-22.

" Floor drains for fire water: Columbia does not have floor drains specifically for fire water. Columbia does have floor drain systems that are in the scope of license renewal and are the method of removing fire protection water from building areas. The Floor Drain (FD) system is discussed in LRA section 2.3.3.23 and the Floor Drain Radioactive (FDR) system is in LRA section 2.3.3.24.

Dikes and curbs for oil spill confinement:. Curbs for oil spill confinement are considered structural commodities and are listed as Flood Curbs on Table 3.5.2-13.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 9 RAI 2.4.13-1 LRA Section 2.1.2.2, "Screening of Structures," provides the methodology for determining the structures and components including fire barriers within the scope of license renewal. LRA Section 2.4.13, "Bulk Commodities," and Table 2.4-13 provide the results of scoping and screening of structures including fire barriers. However, scoping and screening results do not provide the type of fire barriers present in various fire areas of the plant. The staff requests that the applicant provide details of fire barrier type and material in each plant fire area within scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). For any fire barrier type or material that is excluded from the scope of license renewal and is not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

Energy Northwest Response All plant fire barrier types and materials are within the scope of license renewal to support 10 CFR 54.4(a)(3) criteria. There are no fire barriers or materials (in plant fire areas in scope) that were excluded from the scope of license renewal. Energy Northwest performed the fire barriers AMR and determined that all fire doors, fire stops, fire proofing and fire wraps are subject to AMR. The fire barriers material, environment, aging effect requiring management, and aging management program are addressed in LRA table 3.5.2-13. Therefore, no fire barrier types or materials (in plant fire areas in scope) were excluded from the scope of license renewal regardless of location in the plant.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 50 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Letter dated June 24, 2010, NRC to WS Oxenford (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application" (ADAMS Accession No. ML101660030)

RAI B2.4-1

Background

The "monitoring and trending" program element of the GALL XI.M18 states that if bolting connections for pressure retaining components (not covered by American Society of Mechanical Engineer (ASME)Section XI) is reported to be leaking, then it may be inspected daily. If the leak rate does not increase, the inspection frequency may be decreased to biweekly or weekly.

Issue The applicant has taken an exception to the Generic Aging Lessons Learned (GALL)

Report for the "monitoring and trending" program element of the GALL XI.M18.

Specifically, the frequency of follow-up inspections in the license renewal application (LRA) Section B.2.4 is established by engineering evaluation of the identified problem.

Request Provide the technical basis and justification for adequacy of the event and plant-specific determination of the monitoring frequency, and state reasons for the alternative method to be as effective as the GALL prescription method to manage the bolting integrity over the extended period of operation.

Energy Northwest Response Prior to the monitoring and trending stage is the identification of a leak. Identified leaks of any medium (steam, water, air or oil) are documented in the corrective action process (CAP). Documentation of leaks in the CAP is a specific expectation in plant procedures.

The CAP then assigns a responsible organization and individual to perform an evaluation and determine immediate actions including monitoring.

In conjunction with the CAP, Columbia Generating Station (Columbia) has a Leak Reduction Program that specifies monitoring and trending of identified leaks that do not require immediate repair to ensure they are managed and corrected in a timely manner.

The program, based on guidance from "Establishing an Effective Fluid Leak Management Program, EPRI Sealing Technology and Plant Reduction Series (TR-1 14761)," provides the guidance for categorizing each leak based on severity and the frequency for monitoring based on this categorization. If the leak rate changes then the category designation is re-evaluated and may be revised. Revision to the category

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 50 designation would also have a corresponding change in monitoring frequency (up or down). Additionally, equipment operator rounds (twice daily) provide opportunities for monitoring of the identified leaks. The Leak Reduction Program has a designated Fluid Leak Coordinator (FLC) as a single point contact for the program with the responsibility to coordinate with the Work Control department to schedule and repair identified leaks in a time frame based on severity categorization and per the work management process. Thus, the monitoring of leaks in non-ASME bolted connections at Columbia is managed through robust plant programs that meet the intent of the GALL XI.M18 monitoring and trending" element.

RAI B2.4-2

Background

The GALL Report aging management program (AMP) XI.M18, "Bolting Integrity," states that the staff's recommendations and guidelines for comprehensive bolting integrity programfor all safety-related bolting are delineated in NUREG-1339. The GALL AMP also notes EPRI NP-5769, with the exceptions noted in NUREG-1339, and EPRI TR-104213 as the industry's technical basis for this program. The Nuclear Regulatory Commission (NRC or the staff) Generic Letter GL 91-17 concerning the

'*resolution of GSI-29 "Bolting Degradation or Failures in Nuclear Power Plants," notes the response of Nuclear Management and Resources Council on behalf of the industry.

That response (in 1989) stated both the NP-5769 and the NP-5067, and not just the latter, to be the industry's technical basis for the resolution, and encouraged the use of both these documents. Further assessment of these documents and other industry experiences by the NRC staff resulted in NUREG-1339 and by EPRI led to TR-104213.

Issue In element 1 (Scope of Program) and element 2 (Preventive Actions) of the LRA AMP the applicant states that it does not explicitly address the guidelines outlined in EPRI NP-5769, or as delineated in NUREG-1339, and instead relies on the recommendations contained in related EPRI document NP-5067. It is not clear that these statements are consistent, or the two bases are equivalent, since the single document used by the applicant is an earlier report and forms a subset of the GALL referenced three newer documents.

Other elements affected by the NP-5067 exception are: 4, 7, and 10. Also affected are the Program Description and final safety analysis report (FSAR) Supplement description for noting (change/exception) of the basis documents. These are not noted in the LRA exception.

In its white paper, issued in January 2010, comparing certain aspects of NP-5067 with the GALL reference/basis documents, the applicant states the scope and focus of NP-5067 adequacy was on the aging mechanism of loss of preload in pressure

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 50 retaining mechanical joints, which is only a subset of aging mechanisms and types of bolting covered under GALL XI.M18. Also, it is to be noted that NP-5067 is primarily "good practices" (maintenance) manual for solving maintenance problems as they occur and not necessarily focused on long-term management of aging issues-as the manual itself is well predated to license renewal effort-such as an evaluation procedure for assuring integrity, appropriate acceptance criteria, and managing of stress corrosion cracking in non-ASME bolting (unless the cracking leads to a leak that is detected).

Request (a) Provide the justification for this exception and give basis for element by element equivalence of the NP-5067 with the other industry consensus documents and with the GALL XI.M18 elements based on these.

(b) Include in the LRA description all elements affected by the exception.

Energy Northwest Response (a) The Bolting Integrity program at Columbia is consistent with the recommendations provided in NUREG-1801, XI.M.18 'Bolting Integrity'. These recommendations are addressed at Columbia by following the comprehensive good bolting practices established in Electric Power Research Institute (EPRI) NP-5067, Vol. 1 'Large Bolt Manual' and Vol. 2 'Small Bolt Manual'.

Though NP-5067 is not directly referenced in XI.M18 the recommendations set forth in NP-5067 Vols. 1 and 2 form an important basis to the industry documents referenced in XI.M18 such as EPRI NP-5769 and NUREG-1339.

Both EPRI NP-5769 and NUREG-1339 defer to EPRI NP-5067 for the identification of bolting practices associated with disassembly and assembly of bolted joints and identification of bolting practices for minimizing bolted joint problems such as leaks, vibration loosening, fatigue and stress corrosion cracking. The GL 91-17 which issued NUREG-1 339 as an enclosure identified that significant safety improvements and cost reductions could be achieved in bolted connections with the implementation of recommendations contained in both EPRI NP-5769 and NP-5067. Thus, the use of EPRI NP-5067 for achieving a good bolted connection program is recognized by the industry and NRC staff.

This is also evident by previous. NRC staff acceptance of EPRI NP-5067 as the basis for bolting integrity in past license renewal applications such as Millstone and Susquehanna.

An element by element comparison between EPRI NP-5769 and EPRI 5067 based on the recommendations found in NUREG-1801,Section XI.M18 "Bolting Integrity" has been previously performed by Dominion in response to an open item (01-3.0.3.2.18-2) during the Millstone license renewal process. This comparison was provided in a docketed letter (ML051020128) dated April 1, 2005 and demonstrated that EPRI NP-5067 provides the same information as EPRI NP-5769 for addressing the bolting integrity recommendations in

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 50 NUREG-1801,Section XI.M18. Based on this comparison the NRC staff concluded that NP-5067 provided adequate guidance for addressing bolting integrity and that Millstone's program was consistent with the recommendations of NUREG-1 801,Section XI.M1 8 and closed the open item as documented in the SER issued under NUREG-1838 (dated October 2005). EPRI NP-5769 and EPRI NP-5067 were issued about the same time frame (1988 and 1987, respectively) and they have not been revised. Therefore, this comparison is still valid and applicable to Columbia and exception for use of EPRI NP-5067 is acceptable for Columbia.

(b) Elements #4 and #7 mention the guidelines and recommendations of EPRI NP-5769 while element #10 only references EPRI NP-5769 as a source of information. Thus, Amendment 2 to the LRA Appendix B, section B.2.4 notes exception to elements #4 and #7 for the reliance on EPRI NP-5067 rather than EPRI NP-5769 at Columbia. Amendment 2 is provided in Enclosure 1.

RAI B2.4-3 Issue The "Operating Experience" (OE) described in LRA Section B2.4 notes that loss of preload, leaking joints and closures, corroded bolting connections have been identified and corrective actions taken. The staff noted several other instances of these aging effects in. recent years, not discussed in the basis document. There is no consolidated list of these occurrences and their frequency over time to judge the effectiveness of this program, although the applicant states that the experience was reviewed and found to be effective.

Since ONLY leaks have been found, and NO cracking in ANY bolting application under the license renewal scope, these must come from improper assembly and/or loss of preload, reflecting on the training and implementation (under NP-5067).

I Also, from the description in LRA Section B2.4 or the applicant's general review of industry-wide OE it is not clear if the applicant had addressed operating experience related to bolting integrity issues identified after issuance of the GALL Report. For instance, support bolt failure found in certain plants due to hydrogen-induced stress corrosion cracking.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 50 Request (a) Provide the basis for concluding from the OE the effectiveness of existing program to manage the aging effects over the extended period of operation.

(b) Provide justification for the timing'and frequency of Columbia Generating Station (CGS) training in support of the implementation of proper procedures of assembly/disassembly or installation and inspection of the bolting.

(c) Provide an assessment to assure the effectiveness of the procedures to manage the bolting preload over the extended period of operation.

(d) Provide confirmation as to the adequacy of monitoring and detection of bolting degradation in those locations that are normally in submerged condition.

Energy Northwest Response (a) Energy Northwest (EN) performed a plant-specific and industry-wide operating experience (OE) review for the 9-year period from 01/01/2001 to 12/31/2009.

The review used a keyword search based on words that would most likely validate the aging effects listed in industry guidance documents or reveal aging effects at Columbia that might not have been previously identified as being age related. One example of a keyword search that would pertain to this request and the Bolting Integrity Program was a search based on 'leak' which would also have found 'leaking', 'leaks' and 'leakage' since a Boolean logic search tool was used. Other keywords of relevance to this request include 'bolting or bolted,'

'corrosion or corroded or corroding,' 'crack or cracked or cracking,' 'drip or dripping,' and 'stress corrosion or SCC.' (Note: 'Preload' was not used as a keyword at Columbia as the loss of preload would result in a 'leak' or 'drip' in mechanical systems.)

The results of the search were reviewed by the EN License Renewal team leads for applicability to license renewal and aging related degradation. For potential OE related to this specific program (Bolting Integrity) particular attention was given to the results for 'leak,' 'crack,' and 'stress corrosion or SCC' as these are potential aging effects related to bolting as identified in GALL XI.M 18.

The results provide instances of potential age related degradation at Columbia and are compiled by the keyword used in the search. A word search of these results was performed using the word 'bolt'. All results ('hits') found based on this search were reviewed and 17 potential events related leaking of mechanical bolted connections were found. Per Table 2-1 of EPRI guidance document TR-1 14761 'Establishing an Effective Fluid Leak Management Program,' the typical number of fluid leaks for 'best' and 'typical' plants are less than 50 and between 51-250, respectively. This EPRI document does not specify if these values are for the life of the plant or an annual average, but since Columbia's

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 50 number is for an nine year time frame even if extrapolated out for a forty year life that number (-75 leaks) would still show that Columbia has an effective Bolting Integrity Program and continuing with that program will yield similar or better results for the period of extended operation (PEO).

(b) Disassembly and reassembly of mechanical bolted connections is performed by mechanical craft at Columbia. The mechanical maintenance training program is an accredited program that is goes through accreditation renewal every four years (ACAD 02-001, Accreditation Objectives and Criteria). Craft personnel are qualified during their initial qualifications and that training includes both classroom and hands-on (mockup) settings in functional areas such as torquing of fasteners and assembly of gasketed joints (which includes additional torque training). They receive this.training before they are allowed to perform the work activities. The mechanical craft also receive training throughout their employment at EN to maintain worker performance, based on the EN systems approach to training. The results of the OE review support effectiveness of the skill of the craft. Also, the Leak Reduction Program addresses the responsibilities for the Fluid Leak Coordinator (FLC) as:

"Evaluate industry practices and, incorporate effective maintenance and repair strategies into Energy Northwest work practices.

Reference INPO good practices, EPRI Fluid Leak Sealing Technology, etc." and "Coordinate with the Valve Team and the Mechanical Training Advisory Group (TAG) to provide guidance for training to assure the station maintenance personnel are using the latest techniques when performing leak repairs on bolted joints, packing, etc."

The implementation of training requirements by Mechanical Maintenance training group combined effort of FLC will ensure that EN mechanical craft remain proficient at assembly/disassembly of mechanical joints and that the Bolting Integrity Program remains effective in identifying bolting issues into the PEO.

Additional craft supplied by the site support contractor during outages are not trained by the EN Mechanical Maintenance training group. However, torquing is considered a basic skill with many of these crafts and their status as journeyman (as certified by the applicable union) provides an equivalent qualification to the EN mechanical qualification. During their assignment at Columbia, the additional support craft is required to perform tasks in compliance with approved plant procedures.

(c) As noted in b) above, the FLC is chartered with keeping current with industry best practices and then coordinating with Maintenance training to ensure that Columbia maintenance personnel are trained to use the best and latest techniques related to bolted joints. Additionally, Columbia's existing procedure

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 50 on torquing utilizes industry practice for application of torque. That is, install all bolts/nuts finger-tight and tighten to ensure good contact between all parts and then torque is applied to all bolts in three passes in the sequence based on total number of bolts in the pattern. The three part installation and sequence patterns are based on EPRI guidance documents. Continued use of these techniques and additional training as identified in the future to keep current with industry best practices will ensure that EN effectively manages bolting preload through the PEO.

(d) Per the tables in section 3 of the LRA, the bolting identified as being exposed to raw or treated water environments (i.e., submerged) are limited to the Fuel Pool Cooling (FPC) and Main Steam (MS) systems and anchor bolts for ASME Class 1, 2, 3 and MC support bolting (i.e., SW piping and ring header in the Spray Ponds) under 'Bulk Commodities.' The ASME bolting listed under 'Bulk Commodities' calls out the Inservice Inspection (ISI)-IWF program as the applicable AMP. The OE discussion provided in section B.2.35 of Columbia's application states that this program has been effective in managing the aging effects and that no age-related concerns for systems and components within the scope of the program have been identified in the most recent program health reports. Per Table 3.4.2-4 of the application the MS bolting is associated with the quenchers in the suppression pool. These can only be accessed by divers and a random selection (-15 degree arc) were visually inspected during the refueling outage 19 (R19) (May-June 2009). The underwater inspection was videotaped and reviewed by a civil/structural engineer. No evidence of loss of material or cracking was noted. The bolting was checked by hand to confirm tightness of bolt materials, but no torque check was performed. No loose bolts were noted.

The submerged bolting in the FPC system is located in the spent fuel pool (treated water environment) which makes this bolting inaccessible due to dose concerns. However, this bolting is the same material (stainless steel) and environment (treated water) as the MS bolting in the suppression pool and could be expected to be in similar condition.

RAI B2.4-4

Background

The "Acceptance Criteria" element of GALL XI.M 18, Bolting Integrity program states that "Any indications of aging effects in ASME pressure retaining bolting are evaluated in accordance with Section Xl of the ASME Code. For other pressure retaining bolting, nuclear steam supply system (NSSS) component support bolting and structural bolting, indications of aging should be dispositioned in accordance with the corrective action process."

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 50 Issue The applicant's program does not specify acceptance criteria for evidence of degradation particularly in the case of non-ASME evaluated bolting.

Request Justify the lack of acceptance criteria to be adequate for the bolting integrity management and why the corrective action process is not implemented.

Energy Northwest Response As noted in section B.2.4 of the application, the Bolting Integrity Program at Columbia consists of existing activities and programs that address the management of aging for mechanical and structural bolted connections within the scope of license renewal. This section also documented exceptions to the program; one of which is to element 6,

'Acceptance Criteria,' of the Bolting Integrity program. This exception states that the Bolting Integrity Program does not specify acceptance criteria for evidence of degradation in bolting, but that the ISI-IWF, Structures Monitoring and External Surfaces Monitoring programs will direct the periodic visual inspections of mechanical and

.structural components (including bolting) within the scope of license renewal. These two programs (do or will) include acceptance criteria for evidence of degradation prior to the PEO. However, the exceptions discussed in the Bolting Integrity Program do not include an exception to the corrective action element (element 7).

The ISI-IWF is an ASME code program and, as such, has well defined acceptance criteria. NUREG-1801 discussion of acceptance criteria for both Structures Monitoring and External Surfaces Monitoring programs states that acceptance criteria are selected or defined to ensure that the need for corrective actions will be identified before loss of intended function. The program documents for Structures Monitoring and External Surfaces Monitoring programs have not yet been written, but plant procedures that reflect these requirements for current licensing basis contain the requirement to initiate a condition report under Columbia's CAP for any unacceptable, questionable or undesired condition discovered during Maintenance rule or system walkdowns. These procedures also contain guidelines for evaluating and documenting as-found condition of bolted connections. Thus, acceptance criteria are currently available and will be available for the PEO. Additionally EN will continue to utilize the CAP with the implementation of the Bolting Integrity program.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 50 RAI B2.4-5

Background

The "Detection of Aging Effects" program element of GALL XI.M18 notes that the potential for stress corrosion cracking (SCC) of structural bolts/fasteners of NSSS component supports should be assessed -based on the actual yield strength and for the identified high strength bolting (greater than 1-inch nominal diameter) volumetric examination comparable to that of Examination Category B-G-1 is required in addition to visual examination.

Issue From the review of on-site documentation the staff could not confirm if the potential for SCC in the applicable bolting was evaluated and whether the actual yield strength values were factored in the evaluation. Based on the staffs discussion with applicant's technical staff it appears that only visual examination of these bolting is covered under the applicant's bolting program.

Request Provide confirmation that the applicant has ascertained the high strength classification of NSSS bolting based on the actual yield strength values. Also, provide confirmation that so classified high strength bolting have been and will be inspected with visual and volumetric examinations as required, or provide justification for adequacy of waiver of the volumetric examination so that their intended function will be maintained consistent with the current licensing basis (CLB) for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Energy Northwest Response Energy Northwest did not attempt to identify if any Class 1 bolts were high-strength.

Rather, Energy Northwest conservatively assumed all Class 1 bolts were susceptible to stress corrosion cracking (SCC). See the response to RAI B.2.4-6 for additional discussion.

Energy Northwest will not perform volumetric examinations of high strength bolting.

This position is not considered an exception to NUREG-1801,Section XI.M18 which states in the third paragraph of "Detection of Aging Effects," that the requirement to do volumetric examination of high strength structural bolts may be waived based on adequate site-specific information. The waiver is also consistent with the position recently approved by the staff in the Safety Evaluation Report Related to the License Renewal of Beaver Valley Power Station, Units 1 and 2, June 2009, which states, in part:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 50 "Since the GALL Report "detection of aging effects" program element includes the option of waiving volumetric examination of cracking of high strength bolts if adequate justification is provided, the applicant provided justification in its program evaluation document. The applicant's justification includes an evaluation on the environments at Units 1 and 2 where high-strength structural bolting or threaded fasteners are exposed, and whether stress-corrosion cracking (SCC) is an applicable aging effect for those conditions. Based on these evaluations, the applicant stated that SCC was not identified as an AERM. Based on a review of the applicant's completed evaluation and justification, the staff finds the applicant's response to be acceptable because it is consistent with the-recommendations provided in GALL AMP XI. 18."

The waiver is justified because Energy Northwest has not identified cracking as an aging effect for high strength structural bolting. This position is presented in LRA Section 3.5, where cracking of structural bolting is not identified as an aging effect requiring management at Columbia. As indicated in LRA Table 3.5.2-13, all aging effects for structural bolting at Columbia are managed by the Inservice Inspection (ISI)

Program - IWF (ASME Class 1, 2, 3 and MC supports) and the Structures Monitoring Program (non ASME supports).

,High strength bolting applications are in seismic category I structures and in securing Class 1 component supports (e.g., reactor pressure vessel skirt flange, RCS components) to the building structure. Structural bolting used at Columbia includes ASTM A 36 SAE GR 1, A 307, A 320 GR L-7, A 325, A 354 GR BD, A 449 SAE GR 5, A 490, A 540 GR B23-6, 8, and 10 Class 1, A 572 GR 50, and A 588. The use of lubricants on structural fasteners at Columbia is prohibited. Therefore, structural bolting at Columbia is not susceptible to SCC since there is no use of lubricants containing molybdenum disulfide (MoS2).

As indicated in LRA Table 3.5.1, Item number 3.5.1-51, three parameters are required for SCC to occur: (1) a corrosive environment, (2) a susceptible material, and (3) tensile stresses greater than or equal to the yield strength of the material. Corrosive environments containing sodium hydroxide, seawater, nitrate solutions, sulfuric acids, or aggressive groundwater (chlorides > 500 ppm, sulfates > 1,500 ppm) are not present at Columbia. The internal environment of in-scope structures does not contain aggressive chemicals or contaminants under normal operating conditions. Therefore, the environmental conditions necessary for SCC to occur do not exist.

Review of plant-specific operating experience identified no occurrences of SCC on high strength structural bolting.

Energy Northwest identified four environments for structural bolts and threaded fasteners in LRA Table 3.5.2-13, rows 113-139, and SCC is not an applicable aging effect for the environments.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 50 Threaded Fasteners Air-indoor Environment - The internal environments of in-scope structures at Columbia do not contain aggressive chemicals under normal operating conditions. Therefore, the corrosive environmental conditions necessary for SCC to occur do not exist.

Threaded Fasteners Air-outdoor Environment - The air-outdoor environment at Columbia is mildly aggressive and was determined to be non-significant. As stated in LRA Section 3.5.2.2.2.1 part (2), annual rain water data summary from the National Atmospheric Deposition Program/National Trends Network (sample well located in Columbia River Gorge Skamania County) indicates the pH of precipitation sampled was 5.4, which is mildly acidic. The external surfaces are not continuously wetted (annual precipitation only amounts to less than 7 inches) or exposed to an aggressive ambient environment (such as a saltwater atmosphere, sulfur dioxide, etc.) or industrial locations. Rain water results in exposure for only intermittent periods of time; therefore, its mildly acidic aggressiveness is non-significant. Therefore, the corrosive environmental conditions necessary for SCC to occur was determined to be non-significant.

Threaded Fasteners Exposed to Raw Water - Structural threaded fasteners exposed to raw water are located in the. Spray Pond. The EPRI 1015078 Structural Tools state that no industry-reported failures of high strength bolts due to SCC occurred in bolts of less than 1.25 inch diameter and recommended only bolts or studs greater than 1 inch nominal diameter be considered. No high-strength bolts of greater than 1-inch diameter have been identified in submerged structural applications in raw water at Columbia.'

Therefore, cracking due to SCC is not an aging effect requiring management for high strength threaded fasteners exposed to raw water.

Threaded Fasteners Exposed to Treated Water - Potential for SCC for structural threaded fasteners exposed to treated water is only possible in the suppression chamber (wetwell) and the Spent Fuel Pool. In the suppression chamber the structural threaded fasteners greater than 1-inch in diameter are SA-320 Grade L7 which has a specified yield strength of 105 ksi. Therefore there are no high-strength structural bolts of greater than 1-inch diameter in the suppression chamber. The Spent Fuel Pool is maintained below 125 degrees F during normal operations which is below the 140 degrees F threshold for SCC to occur. Therefore, cracking due to SCC is not an aging effect requiring management for high strength threaded fasteners exposed to treated water.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 12 of 50 RAI B2.4-6

Background

GALL XI.M 18, Bolting Integrity program, states that GALL Program XI.S3, "ASME Section Xl Subsection IWF" manages inspection of safety-related bolting. This includes high strength bolting for which EPRI NP-5769 and EPRI TR-104213 recommend inspections for SCC to prevent or mitigate degradation and failure of structural bolting with actual yield strength greater than or equal to 150 ksi.

Request (a) Provide confirmation that high strength bolting with yield strength greater than or equal to 150 ksi are employed as structural bolting, ASME component and piping supports bolting, NSSS support bolting, safety-related bolting and other pressure-retaining bolting under CGS aging management programs.

(b) Also, explain how the GALL recommendations to prevent or mitigate the degradation and failure of these bolts are implemented in the applicant's program to confirm that the aging effects of high strength bolting are adequately managed so that their intended function will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Energy Northwest Response (a) Bolting at Columbia falls into one of three license renewal categories: Class 1 bolting, non-Class 1 mechanical bolting, and structural bolting. Each category is discussed separately below.

Class 1 bolting: Energy Northwest did not attempt to identify if any Class 1 bolts were high-strength. Rather, Energy Northwest conservatively assumed all Class 1 bolts were susceptible to stress corrosion cracking. This is presented in LRA Table 3.1.2-1, line item 321, and LRA Table 3.1.2-3, line item 9. The cracking due to SCC for the Reactor Head Closure Studs is handled separately by the Reactor Head Closure Stud Program, as indicated in LRA Table 3.1.2-1, line item 325.

Non-Class 1 bolting: The bolting used at Columbia is typically carbon or alloy steel (with yield strengths well below 150 ksi), such as ASME SA1 93 or ASTM A193 Grade B7. Certain high strength bolts (e.g., yield strength > 150 ksi) are listed in site procedures and, therefore, periodic inspections include looking for indications of cracking.

Structural bolting: See response to RAI B2.4-5 for the discussion of high strength structural bolts.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 13 of 50 (b) The management of the bolting again falls into three categories.

Class 1 bolting: LRA Table 3.1.2-1, line item 321, and LRA Table 3.1.2-3, line item 9 show that cracking due to SCC for Class 1 bolts is managed by the Bolting Integrity Program. The actual inspections of the bolting are done by the Inservice Inspection Program and meet the requirements of the ASME Code Section IWB.

Non-class 1 bolting: The Bolting Integrity Program includes periodic inspection of Class 2 and 3 safety-related bolting for leakage, loss of material, loss of pre-load, and cracking through the Inservice Inspection (ISI) Program. The Inservice Inspection Program monitors Class 2 and 3 bolts in accordance with the ASME Code, Sections IWC and IWD. There are no Class 2 bolts greater than 2 inches in diameter at Columbia; therefore, volumetric examination of studs and bolts is not applicable. The Bolting Integrity Program also includes periodic inspection of pressure-retaining components, including bolting, for signs of leakage through the External Surfaces Monitoring Program.

NUREG-1801,Section XI.M18, "Detection of Aging Effects." says "High strength structural bolts and fasteners (actual yield strength 150 ksi) for NSSS component supports, may be subject to stress corrosion cracking (SCC). For this type of high strength structural bolts that are potentially subjected to SCC, in sizes greater than 1-inch nominal diameter, volumetric examination comparable to that of Examination Category B-G-1 is required in addition to visual examination. This requirement may be waived with adequate plant-specific justification." At Columbia, no instances of cracking have been identified for bolting or fasteners, although some corroded bolting and facing surfaces (e.g., from general corrosion or as a result of leakage) have been identified at Columbia and corrected.

Stress corrosion cracking of bolts is not expected for the majority of plant bolting, as supported by plant operating experience. Cracking of Class 2 or 3 mechanical bolting would be detected by the ISI inspections. Cracking of non-code bolting would be detected by walkdowns in the External Surfaces Monitoring Program.

Structural bolting: See the response to RAI B2.4-5 for the management of structural bolting.

RAI B.2.24-1

Background

LRA Section B.2.24 states that the Columbia Fatigue Monitoring program acceptance criteria are to maintain the number of counted transient cycles below the analyzed number of cycles for each transient. The LRA further states that when the accumulated cycles approach-the analyzed design cycles, corrective action is required to ensure the

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 14 of 50 analyzed number of cycles is not exceeded. Also, as part of the corrective action, the fatigue usage calculations may be updated.

The report further states that maintaining the fatigue usage factor below the design code limit and considering the effect of the environment will provide adequate margin against fatigue cracking of reactor coolant system components due to anticipated cyclic strains. The "detection of aging effects" program element of the GALL Report states that the program provides periodic update of the fatigue usage calculations.

Issue This program is a preventive measure to mitigate fatigue cracking of metal components by maintaining the fatigue usage factor below the design code limit. One of the corrective actions when cumulative fatigue usage exceeds 1.0 is to refine the analysis to increase accuracy and decrease conservatism. This is achieved by using more realistic values for transient cycles and loading parameters such as strain rate and temperature during the transient. It is not clear whether the Columbia program includes more detailed local monitoring of the plant transient to obtain accurate values of the loading parameters for each transient and to validate the loading parameters that were used for the fatigue analysis, including environmental effects, for the critical components identified in NUREG/CR-6260. Also, in program element 7 "corrective action," the

-GALL Report recommends to include a review of additional affected reactor coolant pressure boundary.

Request (a) Clarify how the Fatigue Monitoring program provides ongoing assessment of transients on plant components and monitors all plant transients that cause cyclic strains, which are significant contributors to fatigue usage.

(b) Address how periodic plant cycle tracking and trending lead to updating plant design basis fatigue analyses.

(c) Discuss corrective actions taken when the design code limit is projected to be exceeded during the period of extended operation.

Energy Northwest Response (a) Columbia meets the usage limit of the design code rather than projecting a cumulative usage periodically throughout the plant operation. Energy Northwest does not project cumulative usage factors based upon the transients that have occurred. Energy Northwest uses an enveloping number of design cycles to determine a maximum usage over the plant life, and therefore does not project that a design code fatigue limit will be exceeded. The Fatigue Monitoring Program does not provide an ongoing assessment of transients and does not calculate real-time cumulative usage factors. Energy Northwest counts cycles that are significant to fatigue as evaluated in the fatigue analyses of record.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 15 of 50 Significant transients are in the fatigue analysis and those transients are counted.

See part (c) of the response for further discussion.

Analyses were performed for the critical NUREG/CR-6260 locations at the projected number of cycles for 60 years. The locations selected utilized the maximum usage locations for all components analyzed. The analyses met the design code limit when accounting for the projected cycles and accounting for the effect of environment on usage. This gives Energy Northwest confidence that future reanalysis of other components will produce acceptable results. Some cycle limits are projected to be lower than the original value and some remain unchanged for 60 years of operation. Some of the cycle limits that are increasing are startups and shutdowns (including hot standby and reduction to 0% power);

these transients are slow and less significant fatigue generating occurrences.

Cycles for two scram events are also projected to increase while other scram cycles are projected to decrease. Critical NUREG/CR-6260 components impacted by the change in scram cycle count were evaluated and shown to meet the design code limit. Reanalysis of the remaining components will be performed prior to reaching the existing thermal cycle values.

(b) Plant cycles are tracked and trended annually, including a projection of what the number of events will be at the end of 60 years. If the projected number of events has the potential to exceed the number of design events, the issue is entered into the CAP to advise plant management. The actions needed, such as reanalysis, procedural changes to minimize transients, or hardware repair or replacement, will be documented in the CAP.

(c) The design code limit is that cumulative usage factors (CUFs) do not exceed 1.0.

Energy Northwest does not project CUFs; Energy Northwest projects the number of incurred transients. The CUFs of record are calculated in fatigue analyses based on the design number of cycles. If a projection says the design number of cycles will be exceeded, it means the CUF of record will be exceeded; but not necessarily that the CUF will exceed the design limit of 1.0. When a projection says the number of design cycles may be exceeded, and before the design number of cycles is actually reached, the analysis will be refined to ensure that the resultant CUF does not exceed 1.0 for the projected number of cycles for 60 years.

The reanalysis will be done using the revised projected cycles. If the design code limit is projected to be exceeded, then a refined analysis may be required to increase accuracy and decrease conservatism. This will be done by using more realistic values for transient cycles and loading parameters such as strain rate and temperature during the transient based upon plant on-line fatigue monitoring data. Only if reanalysis is unsuccessful will other options, such as repair or replacement, be implemented.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 16 of 50 RAI B.2.25-1

Background

Element 4 of the LRA AMP and the basis document states that the sequential starting/controller function tests for the diesel-driven fire pump is performed once every 5 years. In the GALL Report, it states periodic tests are performed at least once every refueling outage, such as flow and discharge tests, sequential starting capability tests, and controller functions tests for the diesel-driven fire pump.

Issue The test interval of the sequential starting/controller function tests for the diesel-driven fire pump in the LRA AMP is much longer than the test interval recommended in the GALL Report. Degradation may not able be detected in a timely manner before there is a loss of component intended function due to the prolong test interval.

Request Provide justification of the test interval of 5 years in the LRA AMP as compared to the interval of at least once every refueling outage recommended in the GALL Report.

Energy Northwest Response The five-year frequency was only documented in the basis document. The purpose of five-year frequency test is related to the plant loss of offsite power testing. Columbia also performs a sequential start/controller function test every 18 months. This surveillance tests the two electric fire pumps and the two diesel driven fire pumps. This is an existing surveillance that was not discussed in the LRA.

RAI B.2.25-2

Background

Element 5 of the LRA AMP and the basis document states that there are no aging effects that require management for fire barrier walls/floors/ceiling, fire wraps, and fire proofing. It further states that the LRA Fire Protection Program will be used to confirm the absence of significant aging effects for the period of extended operation. The GALL Report states loss of material caused by chemical attack, reaction with aggregates, cracking, and spalling are aging effects for management of fire barriers (walls/floors/ceilings). The applicant's procedure for inspection of fire wraps states that the inspection is to ensure no obvious degradations such as splits, tears, holes, gaps or missing pieces. The applicant procedure for inspection of Thermo-lag states that the inspection is to verify Thermo-lag free of obvious holes, cracks, splits, voids, gouges, or broken pieces.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 17 of 50 Issue The applicant does not provide any justification that for fire barrier walls/floors/ceilings, fire wraps, and fire proofing, there are no aging effects that requires aging management Request Provide justification why these aging effects mentioned above for fire barrier walls/floors/ceiling, fire wraps, and fire proofing, are considered not to require aging management during the extended period of operation.

Energy Northwest Response EPRI Report 1015078 "Aging Effects for Structures and Structural Components (Structural Tools)" and review of plant operating experience were used as guidance to identify and evaluate potential aging effects based on material and environment combinations.

Fire Barrier Walls/Floors/Ceilinq:

The aging effects determination for concrete fire barrier walls/floors/ceiling is contained

-in LRA Section 3.5.2.2.2.1 parts (1), (2), (4), (5), (6) and (7). While most concrete fire

'barriers have no aging effects requiring management, there are aging effects (cracking and change of material properties) for concrete walls in the Radwaste Building (LRA Table 3.5.2-8 line 12) and cracking of concrete block walls (LRA Table 3.5.2-4, line 12; Table 3.52-8, line 10; and Table 3.5.2-10, line 11). Corresponding line items for concrete fire barrier walls/floors/ceiling are in the following LRA tables: Tables 3.5.2-2, 3.5.2-5, 3.5.2-8, and 3.5.2-10 with Plant Specific Note 0501. Plant Specific Note 0501 committed the identified aging management program(s) (Structures Monitoring Program and Fire Protection Program) to confirm the absence of significant aging effects for the period of extended operation.

As stated in LRA Section 3.5.2.2.2.1, Energy Northwest agrees and complies with the staff guidance that concrete structures and components that are in the scope of license renewal include an aging management program to provide confirmation of the absence of aging effects requiring management. Energy Northwest concurs with Interim Staff Guidance ISG-3 that sound engineering practices during material (concrete mix) design

.and construction together with sound inspection programs, in which the performance and condition of plant structures are periodically evaluated and monitored, are both necessary to maintain the serviceability of concrete nuclear structures.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 18 of 50 Fire Wraps, and Fireproofinq:

Fire wraps and fireproofing at Columbia are located inside plant buildings and are exposed to the ambient (Air-indoor) environment within the buildings.

Loss of material due to flaking is not an aging effect requiring management for fire wraps or fireproofing. Based on industry and Columbia experiences, rigid fire wrap materials (trowelable grades with smooth, hard finishes) have not been observed to readily release fibers from the surfaces and are not susceptible to flaking. Fireproofing material at Columbia is applied by trowel technique built up to desired thickness. The texture of the finished application is trowelled smooth. Fireproofing and fireproofed members at Columbia are not exposed to strong airflow or induced vibrations.

Loss of material due to abrasion is not an aging effect requiring management for fire wraps and fireproofing. Fire wraps and fireproofed members at Columbia are not in contact with vibrating items or exposed to continuous movement or vibration (self excited or imposed vibration from adjacent components) that can cause abrasion.

Cracking and delamination due to vibration is not an aging effect requiring management for fire wraps and fireproofing. Fire wraps and fireproofed members at Columbia are not in contact or exposed to continuous movement or vibration (self excited or imposed Vibration from adjacent components).

Cracking/delamination and change in material properties due to gamma irradiation exposure is not an aging effect requiring management for fire wraps and fireproofing since this aging mechanism applies to elastomeric material. The reported radiation damage threshold discussed in the Structural Tools refers to organic polymers and not fiber boards, cementitious fireproofing, and ceramic fibers. Therefore, these components are not prone to irradiation damage.

The corresponding line items for fire wraps and fireproofing are in the LRA Table 3.5.2-13, lines 164-168, with Plant Specific Note 0501. Plant Specific Note 0501 committed the identified aging management program (Fire Protection Program) to confirm the absence of significant aging effects for fire wraps and fireproofing the period of extended operation.

RAI B.2.25-3

Background

Section B.2.25 of the LRA states that the Fire Protection Program will detect and manage loss of material, cracking, delamination, separation, and change in material properties for susceptible components. The LRA further states that the Fire Protection Program provides reasonable assurance that the aging effects will be managed such that components subject to aging management review will continue to perform their

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 19 of 50 intended functions consistent with the current licensing basis for the period of extended operation. An independent search by the staff identified an event in which 15 to 20 gallons of water spilled onto the floor of the Radwaste Building Cable Spreading Room (CSR), and leaked down into the Remote Shutdown Room and the Division II switchgear room below the CSR floor (LER 2002-003-00). The pathway for leakage through the floor of the CSR was through cracks in the concrete that allowed a penetration flood seal to be bypassed, and through shrinkage and flexural cracks in the concrete floor slab. The root cause of the event was unsealed cracks in the concrete floor slab.

Issue The "operating experience" program element of the LRA AMP does not include a description of this LER or discuss any follow-up corrective action as a result of this event. The concrete floor fire barriers in the CSR appeared to have lost their intended function during this event.

Request Describe the root cause evaluation of this event and the follow-up corrective action to ensure the intended function of the CSR floor fire barrier will be maintained in the period of extended operation.

Energy Northwest Response The root cause of the 15 to 20 gallons of water spilled from a firewater drain line onto the floor of the radwaste building 484' elevation cable spreading room and into the remote shutdown room and the Division II switchgear room is a result of cracks in the concrete floor. The cracks in the concrete floor resulted from flexing and shrinkage of the floor. In the case of the spalled concrete around a penetration seal, the material was degraded to the point that cracks provided a pathway for water to bypass the penetration seal and enter the remote shutdown room. The degradation was caused by cracking of the concrete during installation of the concrete anchors adjacent to the penetration seal.

The cracking occurred due to insufficient distance between the concrete anchors which allowed the formation of tensile shear cracks. This occurrence dealt with event driven (spilled water), design issue (unsealed floor), and improper anchorage installation (not age related). The floor in the radwaste building 484' cable spreading room has been sealed (finish coat). Plant procedures were revised to 1) include inspection criteria for essential flood barriers, coatings and seal, 2) include inspection of surrounding concrete for degradation, and 3) to incorporate the essential flood barriers into the existing 18-month essential fire barrier inspection program.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 20 of 50 Based on the sealing of the cable spreading room and procedure revisions for inspection of flood barriers, coating and seal, the intended function of the cable spread room floor barrier will be maintained through the period of extended operation.

RAI B2.25-4

Background

The LRA AMP and basis document states that neither the carbon dioxide suppression system nor the halon 1301 fire suppression systems is in the scope of license renewal.

The GALL Report states that management of the aging effects of carbon dioxide suppression system and the halon 1301 fire suppression systems is included in the XI.M26 Fire Protection program.

Issue During the audit, the applicant stated neither carbon dioxide suppression system nor the halon 1301 fire suppression systems is in the scope of license renewal because they are not required in the post-fire safe shutdown. However, it is not clear whether there were any systems or components added in the LRA when the halon 1301 fire suppression systems were removed from the scope of license renewal. If no systems and components were added, clarify which fire suppression system is being used for the control room.

Request Clarity whether there were any systems or components added in the LRA when the halon 1301 fire suppression systems were removed from the scope of license renewal.

If no systems and components were added, clarify which fire suppression system is being used for the control room.

Energy Northwest Response The automatic fire protection carbon dioxide system was not originally within the scope of license renewal because Energy Northwest did not determine that the system performed a license renewal intended function. After further review, Energy Northwest established that the fire protection carbon dioxide system is relied upon to demonstrate, compliance with, and meet the 10 CFR 54.4(a)(3) scoping criteria, for the fire protection (10 CFR 50.48) regulated event. The revised boundary drawings showing the increase in scope are provided in Enclosure 2.

The Halon 1301 suppression system and associated components are included within the scope of license renewal; however, this distinction is not clear within the LRA. The revised boundary drawings provided in Enclosure 2 clarify that the Halon 1301 system is within the scope of license renewal.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 21 of 50 Also, LRA section 2.3.3.22, Amendment 1, states the following: "Halon cylinders are within the scope of license renewal. The principal design criterion for these bottles is Department of Transportation Standards (DOT). The Halon cylinders comply with the requirements of the DOT standards. The Halon cylinders are consumables, replaced periodically in accordance with DOT standards, and are not subject to AMR." The Halon cylinders are not replaced periodically and therefore, are subject to AMR. The LRA Amendment 2, provided in Enclosure 1 specifies that the Halon cylinders are subject to AMR.

RAI B.2.26-1

Background

In Columbia AMP B.2.26, the GALL AMP XI.M27 has been expanded to (a) include components constructed of copper alloys, copper alloys >15% Zn, and stainless steels, (b) manage loss of material due to erosion and macrofouling of all materials, (c) manage cracking due to SCC/IGA of copper alloy >15% Zn components exposed to raw water (with ammonia), and (d) manage loss of material due to selective leaching for the copper alloy >15% Zn components exposed to raw water.

Issue The scope of the GALL AMP includes managing the loss of material due to corrosion, MIC, or biofouling of carbon steel and cast iron components exposed to raw water. It does not include cracking due to SCC or loss of material due to erosion, macrofouling, or selective leaching. This inclusion of other materials and other aging effects should be considered exceptions because GALL AMP program scope has been expanded to include other aging effects and components constructed of other materials. However, the LRA does not provide justification that the GALL AMP is adequate to manage loss of material due to corrosion, erosion, MIC, or biofouling, as well as selective leaching, and cracking due to SCC of components constructed of these materials.

Request Provide justification that the Columbia AMP B.2.26, with the enhancement, is adequate to manage (a) loss of material due to erosion and macrofouling of carbon steel, cast iron, copper alloys, copper alloys >15% Zn, and stainless steels, and (b) loss of material due to corrosion (including MIC) as well as cracking due to SCC/IGA of copper alloys, copper alloys >15% Zn, and stainless steels exposed to raw water.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 22 of 50 Energy Northwest Response NUREG-1801, Revision 1,Section XI.M27 indicates, for the Scope of Program element, that "The AMP focuses on managing loss of material due to corrosion, MIC, or biofouling of carbon steel and cast-iron components in fire protection systems exposed to water." However, no other discussion in Section XI.M27 is material specific.

In addition, the line items in NUREG-1801, Revision 1, Chapter VII (VII.G-12, VII.G-19, and VII.G-24), that cite the Fire Water System Program include carbon steel, copper alloy, and stainless steel piping, piping elements and piping components exposed to raw water with the following aging effect / mechanisms:

Loss of material / general, pitting, crevice, and microbiologically influenced corrosion, and fouling.

NUREG-1801, Revision 1,Section IX.C defines steel and includes carbon steel, alloy steel, cast iron, gray cast iron, malleable iron, and high strength low alloy steel within that definition. Only when selective leaching is being considered as the aging mechanism is gray cast iron specifically called out.

NUREG-1801, Revision 1,Section IX.F defines fouling and indicates that "Biofouling, as a subset of fouling, can be caused by either macro-organisms (such as barnacles, Asian clams, zebra mussels, and others found in fresh and salt water) or micro-organisms, e.g., algae."

As such, the Columbia Fire Water Program is consistent with NUREG-1 801, Revision 1,Section XI.M27, as described in LRA B.2.26 and no exception is needed. The program scope includes components constructed of carbon steel, cast iron, copper alloy, and stainless steel materials. Also, macrofouling is a form of biofouling as described above.

The enhancement of the Columbia Fire Water Program, from that described in NUREG-1801 XI.M27, is limited to (a) management of a loss of material due to erosion for the various materials of construction for components in the scope of the program and (b) the inclusion of copper alloy >15% Zn components in the scope of the program, which are susceptible to cracking due to SCC in raw water environments.

(a) Erosion is another mechanism for loss of material in raw water environments (due to large amounts of particulates and in locations of high fluid velocities and flow discontinuities). The Fire Protection System is in standby mode during normal plant operation. Also, the Fire Water Program includes periodic system flushing, flow testing, and visual inspections that manage corrosion and macrofouling. Since the system is normally in a standby mode, erosion may be possible in those portions of the system that experience flow during periodic tests.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 23 of 50 Columbia operating experience has identified the Fire Protection System piping and components system portions most susceptible to a loss of material due to erosion during periodic tests. As a result, periodic (5-year interval) wall thickness measurements are taken. However, explicit credit for these wall thickness examinations was not included as part of the Fire Water Program.

In order to more accurately described the management of a loss of material due to erosion in portions of the system that experience flow during periodic tests, the Fire Water Program is enhanced to credit the periodic preventive maintenance (PM) activity to perform ultrasonic wall thickness measurements at the most susceptible locations.

(b) As described above, loss of material due to crevice corrosion, pitting corrosion, MIC and macrofouling is managed for copper alloy Fire Protection System components, including copper alloy >15% Zn, that are exposed to raw water. In addition to loss of material, as described in (a) above, copper alloys with >15% Zn are susceptible to cracking (due to stress corrosion cracking (SCC)) in environments containing ammonia. As described in LRA Table 3.3.2-22, in particular plant specific note 0308, "For conservatism, it is assumed that ammonia or ammonium compounds are present in the raw water environment as a by-product of organic decay, as a by-product of MIC, or possibly from fertilizers."

Columbia operating experience has not identified cracking of copper alloys > 15% Zn exposed to raw water, but the aging effect could not be eliminated from aging management with adequate justification. It was concluded, therefore, that the Fire Water Program, as enhanced, would manage cracking of copper alloy > 15% Zn through the same activities that manage loss of material for other materials.

The Fire Water Program includes enhancements to perform ultrasonic or internal visual inspection of above ground piping that are exposed to water, but do not normally experience flow, and to replace sprinkler heads or submit representative samples to a recognized laboratory for field service testing. The spray nozzles (sprinkler heads) in the scope of license renewal are fabricated of copper alloy > 15% Zn, as are strainers and valve bodies that are exposed to raw water during normal plant operation.

In order to explicitly include copper alloy >15% Zn in the scope of the Fire Water Program, in addition to the NUREG-1801, XI.M27 materials, and to describe the management of cracking of copper alloy >15% Zn exposed to raw water, the Fire Water Program is enhanced to include visual inspection of a representative sample of susceptible components (spray nozzles, strainer bodies, and valve bodies) for evidence of cracking.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 24 of 50 The LRA is amended to include enhancements for a) periodic wall thickness measurement of a representative sample of Fire Protection locations susceptible to erosion during periodic tests and b) visual examination of copper alloy >15% Zn components exposed to raw water. The revision to the LRA is shown in Amendment 2, provided in Enclosure 1.

RAI B.2.26-2

Background

The scope of GALL AMP XI.M27 states that the Fire Water System program manages loss of material due to corrosion, microbiologically influenced corrosion (MIC), or biofouling of carbon steel and cast-iron components in the fire protection system exposed to raw water. The scope of Columbia AMP states that the Fire Water program manages loss of material due to crevice, galvanic, general, and pitting corrosion, erosion and cavitation erosion, as well as MIC and macrofouling of susceptible materials in the Fire Protection system, including water supply components, which are exposed to raw (impure) water.

Also, the GALL AMP applies to water-based fire protection systems that consist of

,sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and above and underground piping and components that are tested in accordance with the applicable National Fire Protection Association codes and standards. The Columbia AMP is applicable to 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 (piping), sprinklers (spray nozzles), pump casings, and hydrants.

In addition, the GALL AMP recommends periodic flow testing of the fire water system or wall thickness evaluations (e.g., volumetric or visual inspections) be performed to ensure that the system maintains its intended function; and that these inspections be performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation. The Columbia B.2.26 AMP states that the existing program will be enhanced to perform either ultrasonic testing or internal visual inspection of representative portions of above ground fire protection piping that are exposed to water, but do not normally experience flow, after the issuance of the renewal license, but prior to the end of the current operating term and at reasonable intervals thereafter, based on engineering review of the results.

Issue The Columbia LRA or the basis document does not provide sufficient details regarding the aging management for portions of fire water systems that are (a) normally empty (dry) and (b) below ground. Also, it is not clear whether normally-dry components are indoors or outdoors.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 25 of 50 Request Provide a list of fire water system piping and components (and whether they are indoor or outdoor), that are (a) normally empty (dry) and (b) below ground, and describe the aging management program(s) for each of these two type of components.

Energy Northwest Response The Fire Protection piping and components within the scope of license renewal and subject to AMR are included in LRA Table 3.3.2-22, including fire water suppression piping and components, diesel-driven fire pump support piping and components (e.g.,

cooling, fuel, lubricating oil, exhaust, etc.) and Halon suppression piping and components. The applicable portions of the table, that provide the information requested are included in the response to this RAI.

The Fire Protection System piping and components that are a) normally empty (dry) and b) below ground are listed with the following environments in LRA Table 3.3.2-22:

(a) 'Air-indoor uncontrolled (Internal)' for piping and components that are normally empty and open to the ambient conditions inside the various buildings, or located outside without being open to outdoor ambient conditions; or "Air-Outdoor (Internal)' for piping and components that are normally empty and located outdoors and open to ambient outdoor conditions (above ground).

(b) 'Soil (External)' for piping and components that are buried (below ground-level).

The Fire Protection System piping and components within the scope of license renewal that are normally empty (dry), and assigned an 'Air-Indoor Uncontrolled (Internal)'

environment, include those downstream of relief valve discharge lines, lines downstream from closed vent and drain valves, and sprinklers that are normally drained and contain an internal environment that corresponds to the ambient environment inside the various buildings on site. Halon suppression piping and components downstream of the bottles are also normally empty (dry) and assigned an 'Air-Indoor Uncontrolled (Internal)' environment. The majority of the Fire Protection System piping and components within the scope of license renewal, including those with an 'Air-Indoor Uncontrolled (Internal)' environment, are located above ground inside various buildings on site and as such, were assigned "Air-Indoor Uncontrolled (External)' environments.

No normally empty Fire Protection System piping or components are located below ground (buried).

The Fire Protection System piping and components that are normally empty (dry), and assigned an 'Air-Outdoor (Internal)' environment, include the fire protection fuel oil tanks and associated components that are vented to atmosphere outside of their respective buildings and the fire protection diesel exhaust piping and components outside of their respective buildings. The external surfaces of these Fire Protection System piping and components located outside, are above ground, and assigned an 'Air-Outdoor (External)' environment.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 26 of 50 The Fire Protection System piping and components that are below ground (buried) include piping, hydrants and valve bodies and are assigned a "Soil (External)'

environment. All of these components contain fire water, and are assigned a 'Raw Water (Internal)' environment. License Renewal Boundary Drawings LR-M515-1, and LR-M573-2 identify the piping and components that are located outdoors (above ground or buried) in the yard. Other Fire Protection System piping and components within the scope of license renewal are located indoors as shown on boundary drawings LR-M515-1, LR-M515-2, LR-M515-4, LR-M515-5, LR-M544, LR-M545-3, and LR-M548-1.

The Fire Protection System piping and components that are normally empty (dry) and those that are below ground are described in the table below, rows taken from LRA Table 3.3.2-22, along with the corresponding row for the other surface (external for empty, internal for buried) of that component.

The rows extracted from LRA Table 3.3.2-22 were reorganized to list empty components and buried components, and to align internal and external surfaces for each component type. Where an aging effect requires management for the empty or buried Fire Protection System piping and components, the credited AMP is identified in the row for that component, as are the consistency with NUREG-1 801 and any pertinent plant specific note. The plant specific notes that are referenced in the extracted rows are also included herein.

NUREG-1801, Revision 1,Section VII line items credit the Fire Water System AMP (XI.M27) for components exposed to a raw water environment only. Columbia LRA Table 3.3.2-22 is consistent with NUREG-1801 in that the Fire Water Program (LRA B.2.26) is credited with managing the aging of Fire Protection System piping and component surfaces exposed to a 'Raw water (Internal)' environment.

As described in the table below (excerpts from LRA Table 3.3.3-22), the following programs are credited for managing the aging of Fire Protection System piping and components that are normally empty (dry):

Diesel-Driven Fire Pumps Inspection - for diesel exhaust piping and components normally exposed to predominantly outdoor air with infrequent, and for short duration, exposure to diesel exhaust (environment is different than the external environment).

The Diesel-Driven Fire Pumps Inspection detects and characterizes the material condition of the interior of the Fire Protection System diesel engine exhaust piping. The inspection provides direct evidence as to whether, and to what extent, a loss of material due to corrosion has occurred. The inspection also determines whether cracking due to SCC of susceptible materials has occurred.

The Diesel-Driven Fire Pumps Inspection is a new one-time inspection that will be implemented prior to the period of extended operation. The inspection activities will be conducted within the 10-year period prior to the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 27 of 50 e External Surfaces Monitoring Program - for the external surfaces of fire suppression piping and components located above ground in the various buildings onsite or in the yard and exposed to ambient conditions. Also, as described in plant specific notes 0302 and 0309, the monitoring of the external surface condition will be used to characterize the aging effects on the internal surfaces (where the material and environment is the same).

The External Surfaces Monitoring Program consists of observation and surveillance activities intended to detect degradation resulting from loss of material due to corrosion for mechanical components. The External Surfaces Monitoring Program is a condition monitoring program.

0 Aluminum alloy components that are exposed to outdoor air on both surfaces do not have aging effects that require management. Likewise, glass, copper alloy, copper alloy >15%Zn, and stainless steel piping and components exposed to uncontrolled indoor air on both surfaces do not have any aging effects that require management.

As described in the table below (excerpts from LRA Table 3.3.3-22), the following programs are credited for managing the aging of Fire Protection System piping and components that are below ground (buried):

" Buried Piping and Tanks Inspection Program - for hydrants, piping and valve bodies that are buried in the yard and exposed to a soil environment.

The Buried Piping and Tanks Inspection Program manages the effects of loss of material due to corrosion on the external surfaces of piping and tanks exposed to a buried environment. The Buried Piping and Tanks Inspection Program is a combination of a mitigation program (consisting of protective coatings) and a condition monitoring program (consisting of visual inspections). An inspection of buried piping will be performed within the 10-year period prior to entering the period of extended operation. An additional inspection of buried piping will be performed within 10 years after entering the period of extended operation.

Fire Water Program - for hydrants, piping and valve bodies that are buried in the yard and contain fire (raw) water.

The Fire Water Program (sub-program of the overall Fire Protection Program) is described in Appendix F of the FSAR, and is credited with managing loss of material due to corrosion, erosion, macrofouling of susceptible water-based fire suppression components in the scope of license renewal. Periodic inspection and testing of the water-based fire suppression systems provides reasonable assurance that the systems will remain capable of performing their intended function. Periodic inspection and testing activities include hydrant inspections, fire main flushing, flow tests, and sprinkler inspections. The Fire Water Program is a condition monitoring program, comprised of tests and inspections based on NFPA recommendations.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 28 of 50 Selective Leaching Inspection - for gray cast iron hydrants, piping and valve bodies that are buried in the yard and contain fire (raw) water.

The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water and soil 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, a loss of material due to selective leaching has occurred. The Selective Leaching Inspection is a new one-time inspection that will be implemented prior to the period of extended operation. The inspection activities will be conducted within the 10-year period prior to the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 29 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended M

E R

M 1801 1

Notes No.

Type Function(s) Material Environment Requiring Management Volume Item 2VItemeIm Exhaust Pressure Air-outdoor Loss of airePmseD18 0

9 telFire Pumps VII.H2-2 3.3.1-2E Silencer boundary Steel (Internal) material Inspection Exhaust Pressure

'Air-outdoor Loss of External 3.3.1-Silencer boundary Steel (External) material Monitoring

__._1_9_58 A

1, Flame Pressure Aluminum Air-outdoor None None N/A N/A G

Arrestor boundary Alloy (Internal) 12 Flame Pressure Aluminum Air-outdoor None None N/A N/A G

Arrestor boundary Alloy (External)

FlexibleDislrve 1 Cecion Pressure Air-outdoor Loss of Diesel-Driven 3.3.1-E 17 Connection Steel Fire Pumps VII.H2-2 18 0322 (exhaust) boundary (Internal) material Inspection Flexible Pressure Air-indoor Loss of External 3.3.1-18 Connection boundary Steel uncontrolled material Surfaces VII.I-8 58 A

Connection_

boundary_

(External)

Monitoring 58 Pressure Gray Raw water Loss of Fire Water VII.G-24 3.3.1-A 57 Hydrant boundary Cast Iron (Internal) material 68 Selective 3.3.1 A

58 Hydrant Pressure Gray Raw water Loss of Leaching VII.G-14 boundary Cast Iron (Internal) material Inspection 85

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 30 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System NUREG-Row Component Intended Aging Effect Aging 1801 Table Material Environment Requiring Management Volume item jManagement Program 2Item External 59 Pressure Gray Air-outdoor Loss of Surfaces VII.9 3.3.1-A Hydrant boundary Cast Iron (External) material Monitoring V58 MoitriedPpng Pressure Gray Soil Loss of Buried Piping 3.3.1-A 60 ydrntand Tanks VII.G-25 19, 60 Hydrant boundary Cast Iron (External) material Inspection 19 Selective 6t Pressure Gray Soil Loss of Leaching VII.G-15 3.3.1-A 61 Hydrant boundary Cast Iron (External) material Inspection 85 1

Air-indoor External Pressure Ai-nor Loss of Exenl3.3.1 C

64 Orifice Peure Steel uncontrolled Lossrofl Surfaces VII.1-8 3.3.1-2 boundary (Internal) material Monitoring 58 0302 Air-indoor External Pressure Air-indoLoss of 3.3.1-65 Orifice boundary Steel uncontrolled m

Surfaces VII.I-8 58 A

(External) material Monitoring Air-indoor External 67 Orifice Throttling Steel uncontrolled Loss of Surfaces VII.I-8 3.3.1-C (Internal) material Monitoring 58 0302 Air-indoor External Pressure Gray uncontrolled Loss of 3-1Surfaces VII.C-8 3.3.1 68 Piping boundary Cast Iron (Introll) material Monitoring 58 0302 (Internal)

Mntrn Presue Gay Air-indoor External 71Pressure Gray uncontrolled Loss of Surfaces 3.3.1-A boundary Cast Iron material Surfae 58 L_

I______

(External)

Monlitoring I____

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 31 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended Aging E

Mana Aging 1801 1

Notes No.

Type Function(s) Material Environment Requiring ManagementVolume Management Program Volue m

2 Item I

Pressure Gray Raw water Loss of Fire Water VIIG-24 68 A

69 Piping boundary Cast Iron (Internal) material F3 Selective 331 70 Piping Pressure Gray Raw water Loss of Leaching VII.G-14 85 A

boundary Cast Iron (Internal) material Inspection-Buried Piping 3.3.1-73 Piping Pressure Gray Soil Loss of and Tanks VII.G-25 1

A boundary Cast Iron (External) material Inspection 19 Selective 331 74 Piping Pressure Gray Soil Loss of Leaching VIG-153.3.1-A boundary Cast Iron (External) material Lechi85 Inspection_

75 Piping Pressure Raw water None None N/A N/A F

boundary Polymer (Internal) 76 Piping Pressure Polymer None None N/A N/A F

boundary (External)

Air-indoor External 79 Piping Pressure Steel uncontrolled Surfaces VII.I-8 3.3.1-C boundary (Internal) material Monitoring 58 0302 Air-indoor External Pressure Loss of 3.3.1-88 Piping boundary Steel uncontrolled Surfaces VI1.1-8 58 A

I ouday(External) material Monitoring 5

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 32 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended Material Environment Requiring Management 1801 1

Notes SExternal Pressure Air-outdoor Loss of Surfac 3.3.1-C 80 Piping boundary Steel (Internal) material Surfaces VII.I-9 58 0324 Monitorihng Pressure Air-outdoor Loss of External 331 -

Surfaces VII.I-9 5

81 Piping boundary Steel (External) material Monitoring 58 Diesel-Driven Piping Pressure Steel Air-outdoor Loss of Dies i

VIe.n2-2 (exhaust) boundary (Internal) material Inspection 18 0322 87 Ppn Pressure Ste Raw water Loss of Fire Water VllG24 3.3.1-A iping boundary ee (Internal) material 68 lLoss of Buried Piping 89Pressure Steel and Tanks VII.G-25 3.3.1-A boundary (External) material Inspection 19 Air-indoor External Structural Ai-nor Loss of Exenl3.3.1-C 90 Piping integrity Steel uncontrolled Lossrofl Surfaces VII.I-8 3.3.1-2 (Internal) material Monitoring 58 0302 Air-indoor Etra Structural Stelincor Loss of External 3.3.1-92 Piping integrity Steel uncontrolled Surfaces VII.I-8 58 A

(External) material Monitoring Pump Air-indoor Loss of External 3.3.1-C 93 Casing (F Pressure Gray uncontrolled Lossrofl Surfaces VII.I-8 58 0302 P-1,2A,2B) boundary Cast Iron Monitoring

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 33 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended Aging Managemein 1801 Notes No.

Type Function(s)

Material Environment Requiring Management Volume Item Management Program 2 Item Pump Pressure Gray Raw water Loss of 3.3.G4 P-i,2A,2B) boundary Cast Iron (Internal) material Fire Water VII.G-24

3.

A Pump Pressure Gray Raw water Loss of Selective 3.3.1-95 Casing (FP-Leaching VII.G-14 85 A

P-1,2A,2B) boundary Cast Iron (Internal) material Inspection Pump Pressure Air-indoor Loss of External 3.3.1-A 96 Casing (FP-boury Gray uncontrolled material Surfaces VII.I-8 58 P-1,2A,2B) boundary Cast Iron (External)

Monitoring Pump Pressure Gray Raw water Loss of 3.3.G-P-i,2A,2B) boundary Cast Iron (External) material Fire Water VII.G-24

3.

A Pump Pressure Gray Raw water Loss of Selective 3.3.1-98 Casing (FP-Leaching VII.G-14 85 A

P-1,2A,2B) boundary Cast Iron (External) material Inspection Pressure Air-indoor 114 Sight Glass Glass uncontrolled None None VII.J-8 3.3.1-A 114Sight sboundary (Internal) 93 0306 Air-indoor 116 Sight Glass Pressure Glass uncontrolled None None VII.J-8 3.3.1-A 116 Sight Glass boundary (External) 93 Pressur.e Air-indoor Loss of External 3.3.1-C 117 Sight Glass Prsure Steel uncontrolled Surfaces VII.I-8 boundary material 58 0302

~~~~(Internal)

Monitoring

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 34 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended Aging Managemein 1801 1

Notes No.

Type Function(s) Material Environment Requiring Management Volume Item Management Program

- 2 Item Pressure Air-indoor Loss of External 3.3.1-119 Sight Glass boundary Steel uncontrolled m

Surfaces VII.I-8 58 A

(External) material Monitoring Spray Pressure Copper Air-indoor 120 Pressury Alloy >

uncontrolled None None N/A N/A G

Nozzle boundary 15% Zn (Internal)

Spray Pressure Copper Air-indoor 123 Nozzy boury Alloy >

uncontrolled None None N/A N/A G

Nozzle boundary 15% Zn (External)

Spray Copper Air-indoor 124 Nozzy Spray Alloy >

uncontrolled None None N/A N/A G

Nozzle 15% Zn (Internal)

Copper Air-indoor 127 Spray Spray Alloy >

uncontrolled None None N/A N/A G

Nozzle 15% Zn (External)

Air-indoor 128 Strainer Pressure Copper uncontrolled None None N/A N/A G

(body) boundary Alloy (Internal)

Strainer Pressure Copper Air-indoor 130 (body) boury Aoy uncontrolled None None N/A N/A G

(body) boundary Alloy (External)

Strainer Pressure Copper Air-indoor Alloy >

uncontrolled None None N/A N/A G

(body) boundary 15% Zn (Internal)

I

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 35 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended Aging Managemein 1801 1

Notes No.

Type Function(s) Material Environment Requiring Management Volume Item Management Program 2 Item Strainer Pressure Copper Air-indoor 135 Alloy >

uncontrolled None None N/A N/A G

135(body) boundary 15% Zn (External)

Air-indoor Extorng Strainer Prsue Ga i-nor Loss of External 331 139 6 trainer Pressure Gray uncontrolled Lossrof Surfaces VII.I-8 3.3.1-A (External) material Monitoring Air-indoor External 139 Strainer Pressure Gray uncontrolled Loss of Etrnal 3.3.1-A 142

_____Steel__

uncon__(Eternal)d maeilSurfaces VII.I-8 58 (body) boundary (Csternal) material Monitoring 58_0302 oLoss of External 140 Taine(rd Pressure Steel uncontrolled LossrofSurfaces VII.I-8 3.3.1-C (body7) boundary (Internal) material Monitoring 58 0302 Tak DO resueAir-intdoor LsofExternal3.1-C StraineriLossno 145 Tank (DO-Pressure Steel Fuel oil Loss of Fire VII.G-21 3.3.1-D TK-3,7) boundary (Internal) material Protection 64 146 Tank (DO-Pressure Steel Fuel oil Loss of Fuel Oil VII.G-21 3.3.1-D TK-3,7) boundary (Internal) material Chemistry 64

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 36 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended 1801 1

Notes No.

Type Function(s) Material EnvironmentaRequiring Management Volume Item 2 Item Air-indoor Etra 147 Tank (DO-Pressure Steel uncontrolled Loss of External 3.3.1-A TK-3,7) boundary (External) material Monitoring 58 Pressure Stainless Air-indoor 151 Tubing uncontrolled None None VII.J-15 3.3.1-A boundary Steel (Internal) 94 0306 Air-indoor 3.3.1-153 Tubing boundary Steel uncontrolled None None VII.J-15 94 A

boundarySteel (External)

Air-indoor 331 Structural Stainless Ai-nor3.3.11-A 154 Tubing uncontrolled None None VII.J-15 0306 integrity Steel (Internal) 94 0306 Structural Stainless Air-indoor 3.3.1-156 Tubing uncontrolled None None VII.J-15 A

integrity Steel (External) 94 Pressure Copper Air-indoor 159 Valve Body boundary Alloy >

uncontrolled None None N/A N/A G

15% Zn (Internal)

Pressure Copper Air-indoor 163 Valve Body Alloy >

uncontrolled None None N/A N/A G

16yboundary 15% Zn (External)

Ai r-i ndo00r Etra Pressure Loss of External3.3.1 C

173 Valve Body boundary Steel uncontrolled Surfaces VII.I-8 58 0302 (Internal) material Monitoring

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 37 of 50 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Table Row Component Intended-AigEfc Ain 1801

{TNot s

No.

Type Function(s)

Material Environment Requiring Management Volm 1

Notes Management Program Volume Item 2 Item Pressure Air-indoor Loss of External 178 Valve Body boundary Steel uncontrolled m

Surfaces VII.l-8 58 A

b d(External) material Monitoring Valve Body Pressure Air-outdoor Loss of Diesel-Driven 174 Bd Pesue Steel Fire Pumps VII.H2-2 3.3.1-E 174 (exhaust) boundary (Internal) material Inspection 18 0322 Pressure Air-outdoor Loss of External 3.3.1-179 Valve Body boundary Steel (External) material Surfaces VII.I-9 58 A

Monitoring 177 Valve Body Pressure Steel Raw water Loss of Fire Water VIG-24 31-boundary (Internal) material 68 Pressure Soil Loss of Buried Piping 3.3.1-180VaveBodSteland Tanks VII.G-25

• 19 180 Valve Body boundary Steel (External) material Inspection 19 Generic Notes:

A Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect.

AMP is consistent with NUREG-1 801 AMP.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 38 of 50 Generic Notes:

D Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect.

AMP takes some exceptions to NUREG-1 801 AMP.

E Consistent with NUREG-1801 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

F Material not in NUREG-1 801 for this component.

G Environment not in NUREG-1 801 for this component and material.

H Aging effect not in NUREG-1 801 for this component, material and environment combination.

I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.

Plant-Specific Notes:

0302 The aging effect determination for the Air-indoor uncontrolled (Internal) environment is the same as the NUREG-1801 determination for an Air-indoor uncontrolled (External) environment because the material is the same and the internal environment is equivalent to the external environment evaluated in the NUREG-1801 item Monitoring of the external surface condition will be used to characterize the aging effects on the internal surfaces.

0303 The Supplemental Piping/Tank Inspection will manage loss of material at the air-water interface.

0306 The aging effect determination for the Air-indoor uncontrolled (Internal) environment is NUREG-1801 determination for an Air-indoor uncontrolled (External) environment because same and the internal environment is equivalent to the external environment evaluated in item There are no aging effects requiring management.

the same as the the material is the the NUREG-1801

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 39 of 50 Plant-Specific Notes:

0309 For the purposes of this NUREG-1801 comparison, outdoor air as an internal environment is essentially the same as the uncontrolled indoor air environment because the subject internal surfaces are not exposed to weather. Therefore, the aging effect determination for the Air-outdoor (Internal) environment is the same as the NUREG-1801 determination for an Air-indoor uncontrolled (External) environment because the material is the same and the internal environment is equivalent to the external environment evaluated in the NUREG-,

1801 item. Monitoring of the external surface condition will be used to characterize the aging effects on the internal surfaces.

0322 Environment is predominantly outdoor air with infrequent, and for short duration, exposure to diesel exhaust.

0324 The aging effect determination for the Air-outdoor (Internal) environment is the same as the NUREG-1801 determination for an Air-outdoor (External) environment because the material is the same and the internal environment is equivalent to the external environment evaluated in the NUREG-1801 item. Monitoring of the external surface condition will be used to characterize the aging effects on the internal surfaces.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 40 of 50 Further clarification of each component type in the above table is as follows:

" Exhaust Silencer (Steel) - Fire pump diesel engines exhaust component located above ground indoors, but open to the ambient outdoor air.

" Flame Arrestor (Aluminum) - Diesel fuel tank vent located above ground outdoors.

" Flexible Connection (Steel) - Fire pump diesel engines exhaust component located above ground indoors, but open to the ambient outdoor air.

" Hydrant (Gray Cast Iron) - Partially buried in the yard, filled with fire suppression water.

" Orifice (Steel) - Dry portions of the deluge for Standby Gas Treatment (SGT),

Reactor Building Exhaust Air (REA), Radwaste Building Mixing Air (WMA) components located indoors.

" Piping (Gray Cast Iron) - Sprinkler piping downstream of the closed valve located inside buildings

" Piping (Steel) - Empty discharge, vent and drain piping (as well as halon suppression piping) located above ground inside buildings.

" Piping (Steel) - Empty vent, fill, etc. piping for the diesel engine fuel tanks located above ground outside.

E Piping (Gray Cast Iron) - Main and header piping buried in the Yard (contains raw fire suppression water)

" Piping (Polymer) - connecting the fire protection bladder tank (FP-TK-1 10) to its level gage buried and above ground in the yard (contains raw fire suppression water)

" Piping (exhaust) - Fire pump diesel engines exhaust component located above ground indoors, but open to the ambient outdoor air.

" Pump Casing (Gray Cast Iron) - Suction bowl and discharge head above the water line in the circulating water basin inside the Circulating Water Pumphouse Sight Glass (Glass) - Located indoors with no aging effects.

Spray Nozzle (Copper Alloy, Copper Alloy >15% Zn) - Located indoors, aboveground with no aging effects. Note Supplement 1 to the LRA credits the Fire Water Program (B2.26) since all Fire Protection System sprinkler heads (spray nozzles) are addressed by the enhancement for sprinkler head testing/replacement per NFPA 25.

Strainer (Copper Alloy, Copper Alloy >15% Zn, Gray Cast Iron, Steel) - Dry portions of sprinkler systems located indoors and above ground.

Tank (Steel) - Diesel Fuel Tanks located above ground and indoors but vented to the outside atmosphere.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION.

Page 41 of 50

" Tubing (Stainless Steel) - Instrument tubing in dry portions of sprinkler/deluge systems located above ground, indoors.

" Valve Body (Copper Alloy >15% Zn, Steel) - In empty (dry) portions of sprinkler systems located above ground, indoors.

" Valve Body (Steel) - Buried in the yard (contains raw fire suppression water)

" Valve Body (exhaust) (Steel) - Exhaust silencer drain open to ambient outdoor conditions.

RAI B2.33-1

Background

The "Program Description" of the GALL AMP XI.M1 states that Title 10 of the Code of Federal Regulations, (10 CFR 50.55a), imposes the inservice inspection (ISI) requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, for Class 1, 2, and 3 pressure-retaining components and their integral attachments in light-water cooled power plants, and that the inspection, repair, and replacement of these components are covered in Subsections 1WB, IWC, and IWD, respectively, in the 2001 edition including the 2002 and 2003 Addenda. The GALL AMP XI.M1 also indicates that an applicant may refer to the Statement of Consideration for an update of 10 CFR 50.55a to justify use of a more recent edition of the Code.

Issue The applicant's "Program Description" of the ISI program under its LRA Section B2.33 does not specify the applicable Code edition(s) in current use and for the extended period of operation for the ISI program.

Request Clarify the ASME Code edition currently incorporated in the existing ISI program, and if different from that specified under GALL AMP XI.M1, provide the basis. Also, confirm if the ASME Code edition, to be incorporated by CGS for the future inspection intervals during the period of extended operation, would be the ASME Section XI Code editions and addenda, as modified and limited in the 10 CFR 50.55a rule, that are considered acceptable by the staff in the Federal Register Notice for future 10 CFR 50.55a amendments.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 42 of 50 Energy Northwest Response The ASME Section Xl Code incorporated in the current Columbia Generating Station (CGS) Inservice Inspection (ISI) Program is the 2001 Edition including the 2002 and 2003 Addenda. This is the edition/addenda specified in GALL AMP XI.M1.

Energy Northwest confirms that the ASME Code edition, to be incorporated by Columbia for the future inspection intervals during the period of extended operation, will be the ASME Section XI Code editions and addenda, as modified and limited in the 10 CFR 50.55a rule, that are considered acceptable by the staff in the Federal Register Notice for future 10 CFR 50.55a amendments.

RAI B2.33-2

Background

Inspections under the ASME Section XI, Subsections IWB, IWC, and IWD, in general, and the GALL AMP XI.M1, in particular, provide for the detection of aging effects to reveal cracking, loss of material due to corrosion, leakage of coolant and indications of degradation due to wear or stress relaxation, but not the reduction of fracture toughness. Also, the "Program Description" of GALL AMP XI.M1 does not include thermal embrittlement or the resulting loss of fracture toughness.

Issue The applicant's ISI program under its LRA Section B2.33 and the FSAR Supplement Section A1.2.33 indicates that it manages the reduction of fracture toughness due to thermal embrittlement of cast austenitic stainless steel pump casings and valve bodies.

Request The applicant should cover this addition of aging management issue as an enhancement to its existing ISI program and provide the basis and justification for the enhancement.

Energy Northwest Response As discussed in a recent NRC draft of the GALL Report, Revision 2, management of reduction of fracture toughness for cast austenitic stainless steel (CASS) pump casings and valve bodies is accomplished via the ASME Code required inspections without augmentation. Inservice inspection does not directly monitor for loss of fracture toughness that is induced by thermal aging; instead, the impact of loss of fracture toughness on component integrity is indirectly managed by using visual or volumetric examination techniques to monitor for cracking in the components.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 43 of 50 In the current revision of NUREG-1801, line item IV.C1-3 recommends managing reduction of fracture toughnessof Class 1 pumps and valve bodies using XI.M1:

Inservice Inspection. NUREG-1801,Section XI.M12 states "For pump casings and valve bodies, based on the assessment documented in the letter dated May 19, 2000, from Christopher Grimes, Nuclear Regulatory Commission (NRC), to Douglas Walters, Nuclear Energy Institute (NEI), screening for susceptibility to thermal aging is not required. The existing ASME Section XI inspection requirements, including the alternative requirements of ASME Code Case N-481 for pump casings, are adequate for all pump casings and valve bodies."

Because the ISI program continues to perform ASME Code required inspections, and because NUREG-1 801 states in multiple locations that this is acceptable for managing reduction of fracture toughness; Energy Northwest does not consider this an enhancement to the ISI program. NUREG-1801, as quoted above and the Grimes letter are justification for using this aging management technique.

RAI B2.33-3

Background

The intergranular stress corrosion cracking (IGSCC) of boiler [sic] water reactor (BWR) piping components, discussed in NRC GL 88-01, continues to be a significant aging effect also addressed in the applicant's LRA Section B2.33 and the Final Safety Analysis'Report (FSAR) Supplement Section A1.2.33, with augmented ASME Section XI ISI program.

Issue The nature and scope of augmented ISI program to address GL 88-01 were not apparent from the LRA program description. Also, in particular, if the applicant is crediting any mitigation measures, what these measures are, what is the impact on the scope of related inspections as required by the ASME Section Xl ISI, and what is the justification for their adequacy over the extended period of operation.

Request Clarify the extent of augmented ISI program to manage the GL 88-01 impacted components. Justify any current or planned reduction in ISI scope (frequency and locations) originally identified in response to the GL 88-01, as a result of plant-specific mitigation measures or related industry initiatives, and why the augmentation is considered to be adequate to manage this IGSCC issue over the extended period of operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 44 of 50 Energy Northwest Response The EN response to GL 88-01 is discussed in LRA Section B.2.8, "BWR Stress Corrosion. Cracking Program, rather than in LRA Section B.2.33, "Inservice Inspection (ISI) Program." This is consistent with NUREG-1 801, which discusses GL 88-01 in Section XI.M7, BWR Stress Corrosion Cracking" and does not discuss GL 88-01 in Section XI.M1, "ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD."

As discussed in LRA Section B.2.8, the Columbia program detects and sizes cracks in accordance with the requirements of the ASME Code, Section Xl, supplemented by guidelines of approved Boiling Water Reactor Vessel and Internals Project (BWRVIP) documents. Inspection of piping to detect and size cracks is performed in accordance with the staff positions on schedule, methods, personnel, and sample expansion included in GL.88-01 and BWRVIP-75. If indications are found, sample expansion occurs per BWRVIP-75.

Mitigation measures are discussed in LRA Section B.2.8. The mitigation measures did not reduce the scope of the ISI examinations required by 10 CFR 50.55a. These mitigation measures, in addition to the industry initiative of BWRVIP-75, did reduce the scope of the original GL 88-01 response. The current scope is in accordance with NRC approved BWRVIP-75.

Columbia has implemented Hydrogen Water Chemistry (HWC) and Noble Metal Chemical Addition (NMCA) to mitigate IGSCC, but to date Columbia has not requested any scope reduction based on chemistry. Any future reduction of GL 88-01 examination scope based on HWC/NMCA will be submitted, as required, to the NRC for approval prior to implementation.

The Columbia BWR Stress Corrosion Cracking Program is considered adequate for the PEO because:

1. It is in accordance with the staff positions on GL 88-01 and BWRVIP-75.

2. It is consistent with NUREG-1801 Section XI.M7.

3. Industry operating experience to date (See LRA Section B.2.8) confirms the program is effective.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 45 of 50 RAI B2.33-4 Issue The FSAR Section 5.2.4, which describes the applicant's ISI Program only by reference, indicates (page 5.2-22 of the FSAR) that about 16% of the vessel weld volume is inaccessible.

Request Clarify the location and distribution of the inaccessible weld regions of the vessel.

Justify the adequacy of existing ISI program coverage to manage the aging related degradation of these regions so that their intended function will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Enerqy Northwest Response The following table describes the location and distribution of the inaccessible areas of the reactor pressure vessel. This table shows that 84% of the RPV weld material is

.accessible for volumetric examination.

BWRVIP-74-A reviewed NRC-approved inspection and aging management programs requirements found in ASME Section Xl and BWRVIP-05 for the current licensing term.

The review found that the existing programs are adequate to ensure RPV integrity for an additional 20-year period of extended operation. The total weld volume that is examined represents a large and representative sample of the reactor pressure vessel.

The integrity of the RPV can be verified by examination of this sample. Thus the existing ISI program coverage is adequate to manage the aging related degradation of the RPV so that its intended function will be maintained consistent with the CLB for the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 46 of 50 Reactor Pressure Vessel Weld Examination Coverage Code Category B-A Weld Weld Volume Weld Area Volume Examined Ident. Code Length (square (cubic Percent (cubic No.

Category Description (in) inches)

Inches Accessible Inches)

AA B1.11 BTM HD-SC#1 WD 840 71.8 60312 99.8 60191 AB B1.11

1. 1-#2 SC CRC WD 840 70.5 59220 79.7 47198 AC B1.11

1. 2-#3 SC CRC WD 840 57.9 48636 92.4 44940 AD B1.11

1. 3-#4 SC CRC WD 840 60.7 50988 83.6 42626 B1.30

1. 4 SC-FLG CRC AE WD 792 74.3 58846 49.4 29070 B1.40 TOP HD-FLG AG WELD 783 36.6 28658 95.1 27254 B1.21 TOP HD DOL AH PLATE 516 31.4 16202 100 16202 B1.21 BOT HD DOL AJ WELD 684 70.4 48154 100 48154 B1.12

1. 1 SC VRT BA WD@45 130 119.8 15574 90.8 14141 B1.12

1. 1 SC VRT

,BB WD@135 130 119.8 15574 91.9 14313 B1.12

1. 1 SC VRT BC WD@225 130 119.8 15574 91.2 14203 B1.12

1. 1 SC VRT BD WD@315 130 119.8 15574 92.8 14453 B1.12

1. 2 SC VRT WD@

BE 10 175 53.2 9310 98.1 9133 B11.12

1. 2 SC VRT BF WD@100 175 53.2 9310 95.6 8900 B1.12

1. 2 SC VRT BG WD@190 175 53.2 9310 98.1 9133 B1.12

1. 2 SC VRT BH WD@280 175 53.2 9310 93.7 8723 B1.12

1. 3 SC VRT WD@

BJ 50 169 61.9 10461 91.7 9593 B 1.12

1. 3 SC VRT BK WD@170 169 61.9 10461 96.8 10126 B1.12

1. 3 SC VRT BM WD@290 169 61.9 10461 92.1 9635 B1.12

1. 4 SC VRT BN WD@330 146 66.8 9746 100 9746 B1.12

1. 4 SC VRT WD@

BP 90 146 66.8 9746 100 9746 B1.12

1. 4 SC VRT BR WD@210 146 66.8 9746 100 9746

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 47 of 50 Reactor Pressure Vessel Weld Examination Coverage Code Category B-A Weld Weld Volume Weld Area Volume Examined Ident. Code Length (square (cubic Percent (cubic No.

Category Description (in) inches) Inches Accessible Inches)

B1.22 BOT HD MRD DA

@272 56 62.7 3499 78.6 2750 B1.22 BOT HD MRD DB

@332 56 62.7 3499 78.6 2750 B1.22 BOT HD MRD @

DC 32 56 62.7 3499 78.6 2750 B1.22 BOT HD MRD@

DD 92 56 62.7 3499 78.6 2750 B1.22 BOT HD MRD DE

@152 56 62.7 3499 78.6 2750 B1.22 BOT HD MRD DF

@212 56 62.7 3499 78.6 2750 DG B1.21 BOT HD DOL/270 219 77.3 16944 16.7 2830 B1.22 TOP HD MRD DH

@15 78 41 3198 100 3198 B1.22 TOP HD MRD DJ

@75 78 41 3198 100 3198 B1.22 TOP HD MRD DK

@135 78 41 3198 100 3198 B1.22 TOP HD MRD DM

@195 78 41 3198 100 3198 B1.22 TOP HD MRD DN

@255 78 41 3198 100 3198 B1.22 TOP HD MRD DP

@315 78 41 3198 100 3198 DR B1.21 BOT HD DOL /90 219 77.3 16944 16.7 2830 Totals 605243 84%

508574 Abbreviations:

BOT / BTM - bottom CRC-circumferential DOL - dollar plate FLG - flange HD

- head MRD - meridian SC - shell course VRT - vertical WD - weld

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 48 of 50 RAI B.2.45-1 Background.

In LRA Section B.2.45 Program Description, the applicant stated that the Columbia Reactor Head Closure Studs program 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 applicant further stated that the B.2.45 program is an existing Columbia program that is consistent with the 10 elements of an effective management program as described in NUREG-1801,Section XI.M3 "Reactor Head Closure Studs" program.

The GALL Report states that the Reactor Head Closure Studs program includes ISI to detect cracking due to SCC or IGSCC, loss of material due to wear, and coolant leakage from reactor vessel closure stud bolting for both BWRs and pressure water reactors. The "detection of aging effects" program element of the GALL AMP states that inspection can reveal cracking, loss of materials due to corrosion or wear, and leakage of coolant.

Issue The program description in LRA Section B.2.45 states that the program manages loss of material due to corrosion. Loss of material due to wear is not mentioned either in the program description or "detection of aging effects" program element.

Request Verify that the Columbia Reactor Head Closure Studs program also manages the loss of material due to wear, or justify why wear is not considered as a significant degradation mechanism.

Energy Northwest Response The Columbia Generating Station Reactor Head Closure Studs program manages the loss of material due to wear by performing the ASME Code required examinations.

RAI B.2.45-2

Background

In LRA Section B.2.45 the applicant stated that the Reactor Head Closure Studs program examines reactor vessel stud assemblies in accordance with the examination and inspection requirements specified in Table IWB-2500-1. Inspections include VT-i visual examination of the nuts, washers, and bushing and volumetric examination of studs and threads, and VT-2 inspections for leak detection are performed during system

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 49 of 50 pressure tests. The applicant also noted that the inspection of the reactor vessel closure studs, performed in accordance with ASME Code,Section XI, Subsection IWB, Table IWB 2500-1 (2003 addenda), includes volumetric examinations rather than the surface examinations called out in paragraph NB-2545 or NB-2546 of Section III of the ASME Code. The GALL AMP XI.M3 states that the program includes ISI in accordance with the requirements of the ASME Code Section XI, Subsection IWB (2001 edition including 2002 and 2003 addenda), Table IWB 2500-1.

Also, in LRA Appendix C, Table C-1 1, in response to license renewal applicant action item (1) of NRC safety evaluation report for BWRVIP-74 "BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines," the applicant stated:

"The BWR Vessel Internals Program (VIP) requires the inspection and evaluation guidelines of this BWRVIP report to be implemented at Columbia. Site procedures require a technical justification to be documented for any deviation from the guidelines.

Columbia has not identified any deviation from the BWRVIP-74-A guidelines.

Therefore, Columbia is bounded by the BWRVIP-74-A report."

Issue The staff noted that Section 4.1.2 of the BWRVIP-74-A report states that vessel closure

-head studs (Category B-G-1, greater than 2 inches in diameter) require ultrasonic examination inservice when the examination is done in place, and both surface and ultrasonic examination if they are removed for examination. Therefore, since the applicant's program includes only volumetric examination, for its program to be consistent with the GALL AMP XI.M3 and also with BWRVIP-74-A guidelines, the applicant seems to be committing to only one option for ISI of studs, i.e., volumetric examination of the studs in place.

Request Clarify that the existing Reactor Head Closure Studs program being proposed for managing aging degradation of the closure stud assemblies due to cracking and loss of material during the extended period, includes volumetric examination of the studs in place, and that the studs are not examined when they are removed.

Energy Northwest Response The current Reactor Head Closure Studs program includes inspection in accordance with ASME Section X1 2001 Edition, 2003 Addenda. The IWB-2500-1 of this addendum requires only a volumetric examination of the RPV closure studs. This examination can be performed with the studs in place under tension, when the joint is disassembled, or when the stud is removed. Future examinations of the reactor vessel stud assemblies will be in accordance with the examination and inspection requirements specified in ASME Section X1 Table IWB-2500-1 as modified and limited in the 10 CFR 50.55a rule, that are considered acceptable by the staff in the Federal Register Notice for future

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 50 of 50 10 CFR 50.55a amendments. The objective of BWRVIP-74-A is to demonstrate that NRC-approved inspection and aging management programs for the current term are also adequate for a 20-year license renewal term. Since Columbia has not reached the PEO, the requirements are not applicable for the CLB; therefore Energy Northwest has no deviations from BWRVIP-74-A.

The 1989 Edition of the Code required both a volumetric and surface examination when the stud was removed. If at the time of PEO, this is determined to be a BWRVIP-74-A mandatory or needed requirement, Energy Northwest will either comply with the requirement or complete any applicable deviation dispositions. Section 4.1.2 of BWRVIP-74-A describes the examination requirements of ASME Section X1 for the individual items identified by examination category. The discussion in Section 4.1.2 applies to the program requirements as they appear in the 1989 Edition of ASME Section Xl except where noted.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 Examples of Wear Rate Analyses For RAI B.2.28-1

Companyo. ergy Northwest Plant:

Columbia Generating Station Unit:

DB Name: Columbia-Current Report Date/Time:

08-Dec-20

1. 59 am Analysis Date/Time : 07-Dec-2009 3:19 pm CHECWORKS SFA Version: 2.2 SP-1 (build 70)

Wear Rate Analysis: Combined Summary Report Run Name:

HD: FWH3 to FWH2 USCV Ending Period : RFO-21 Total Plant Operating Hours205176 WRA Data Option:

COMP->NFA Line Correction Factor:

1.021 Duty Factor (Global) : 1.000 Exclude Measure Wear: NO Component Name Average Current Geom Wear Rate Wear Rate ---------

Thickness (in) -----------

Code (mils/yr)

(mils/yr)

[nit.

Prd.f1l Thoop Tcrit Comp Predict [1]

Total Lifetime In-Service Comp In-Service Comp Time (hrs)

Time to Tcrit (hrs) Wear (mils)

Wear (mils)

Tmeas, Methlod, Time Last Inspected Prd.[21 Meas.

Prd.[21 Meas.

(in)t4]

131 (hrs)T41 Insoected

===> Grouped by Line: HD: 323: FWH-3A to FWH-2A USCV, Sorted by: Flow Order HD-1101-N HD-1 102-E HD-1103-P U/S HD-1103-P D/S HD-1 104-E HD-1 105-E HD-1106-E (0)

HD-1 107-P HD-1i108-E HD-1 109-T HD-1109-T (BR/SE)

HD-1109-T (D/S)

HD-1201-P HD-1202-V-14A HD-1 203-E HD-1204-P HD-1205-RED HD-1205-RED (D/S)

HD-1206-LCV-3A1 31 4

54 541 3

4 54 5

15 15 15 65 22 4

54 17 17 20 5.809 4.168 3.605 3.605 3.718 3.943 4.168 3.605 6.760 3.380 0.000 3.380 2.253 5.633 4.168 3.605 2.816 3.497 9.713 9.064 0.500 6.505 0.375 5.626 0,375 5.626 0.375 5.801 0.375 6.153 0.375 6.505 0,375 5.626 0.375 10.548 0.375 5.274 0.375 0.000 0.375 5.274 0.375 3.516 0,375 8.790 0.375 6.505 0.375 5.626 0,375 4.395 0.375 5.456 0.365 15.156 0.365 0.396 0.325 0.291 0.288 0.283 0.265 0.301 0.217 0.296 0.375 0.296 0.322 0.243 0.277 0.291 0.309 0.283 0.138 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.027 0.029 0.027 0.027 0.027 0.018 0.019 0.027 357060 No 0.263 102023 Yes 0.027 464284 Yes 0.027 410987 No 0.027 394548 No 0.027 364489 No 0.027 321569 Yes 0.027 426861 Yes 0.027 157833 No 0.027 447152 No 0.027 100000000 No 0.027 447152 No 0.027 736471 No 0.029 213804 No 0.027 337680 No 0.027 410987 No 0.027 562880 No 0.018 425807 No 0.019 68402 No 0.0 60.4 52.2 0.0 0.0 0.0 21.0 18.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 51.0 27.0 0.0 0.0 0.0 42.0 32.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 60.4 52.2 0.0 0.0 0.0 21.0 18.2 0.0 0.0 0.0 0.0

.0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 51.0 27.0 0.0 0.0 0.0 42.0 32.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.448 0.357 0.375 0.375 0.375 0.342 0.367 0.375 0.375 0.375 0.375 0.375 0.375 0.375 0.375 0.375 0.365 0.365 MT 155016 0

US 155016 155016 MT 155016 155016 0

0 0

0 0

0 MT 64872 64872 MT 64872 64872 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0

===> Grouped by Line: HD: 324: FWH-3B to FWH-2B USCV, Sorted by: Flow Order HD-1401-N HD-1402-E HD-1403-P HD-1404-E (0)

HD-1405-P HD-1406-E HD-1407-T HD-1407-T (BR/SE)

HD-1407-T (D0S) 31 5.809 4

4.168 54 3.605 2

4.168 52 2.816 5

6.760 15 3,380 15 0.000 15 3.380 9.064 0.500 6.505 0.375 5.626 0.375 6.505 0,375 4.395 0.375 10.548 0.375 5.274 0.375 0.000 0.375 5.274 0,375 0.364 0.027 0.027 325988 No 0.277 0.027 0.027 337680 No 0.291 0.027 0.027 410987 No 0.264 0.027 0.027 320222 Yes 0.320 0.027 0.027 585232 Yes 0.217 0.027 0.027 157833 No 0.296 0.027 0.027 447152 No 0.375 0.027 0.027 100000000 No 0.296 0.027 0.027 447152 No 0.0 0.0 0.0 21.0 14.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 39.0 24.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 21.0 14.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 39.0 24.0 0.0 0.0 0.0 0.0 0.500 0.375 0.375 0.341 0.372 0.375 0.375 0.375 0.375 0

0 0

MT 64872 MT 64872 0

0 0

0 0

0 0

64872 64872 0

0 0

0 Page 1 ALTRAN SOLUTIONS Technical Report 00107-TR-001 Rev. 5 AppendixD, Sheet D -

11ý

Company~ergy Northwest Plant Columbia Generating Station Unit:

DB Name: Columbia-Current 0

Report Date/Time:

08-Dec-200 9

51 am Analysis Date/Time : 07-Dec-2009 3:16 pm CHECWORKS SFA Version:2.2 SP-1 (build 70)

Wear Rate Analysis: Combined Summary Report Run Name:

COND: FWH-3 to FWH-4 Ending Period : RFO-21 Total Plant Operating Hours205176 WRA Data Option:

COMP->NFA Line Correction Factor:

0.695 Duty Factor (Global) : 1.000 Exclude Measure Wear: NO Component Name Average Current Geom Wear Rate Wear Rate ---------

Thickness (in) -----------

Code (mils/vr)

(mils/vr)

Init.

Prd.[11 Thoop Tcrit Comp Predict [1]

Total Lifetime In-Service Comp Time to Tcrit (hrs)

Wear (mils)

Wear (mils)

Inspected Prd.[2]

Meas.

Prd.[2]

Meas.

In-Service Comp Time (hrs)

Tmeas, Method, Time Last (in)[41

[3]

(hrs)[4]

Inspected Name

===> Grouped by Line: COND: 337: FWH-3A to FWH-4A, Sorted by: Flow Order COND-8301-N COND-8302-E COND-8303-P U/S COND-8303-P D/S COND-8304-E COND-8305-P U/S COND-8305-P D/S COND-8306-E COND-8307-E (0)

COND-8308-N 31 3

53 53 2

52 52 2

4 30 11.560 7.850 5.607 5.607 8.299 5.607 5.607 8.299 8.299 9.248 10.669 1.031 7.245 0.812 5.175 0.812 5.175 0,812 7.659 0.812 5.175 0.812 5.175 0.812 7.659 0.812 7.659 0.812 8.535 1.031 0.760 0.628 0.681 0.743 0.718 0.728 0.681 0.618 0.609 0.814 0.506 0.506 0.506 0.506 0.506 0,506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0,506 0.506 0.506 0.506 0.506 208572 No 147417 No 295308 No 401292 Yes 242017 Yes 375902 Yes 295308 No 127432 No 117021 Yes 316293 No 0.0 0.0 0.0 111.6 165.2 111.6 0.0 0.0 64.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 129.0 111.6 168.5 165.2 107.0 111.6 0.0 0.0 0.0 0.0 59.0 64.9 0.0 0.0 0.0 0.0 0.0 129.0 168.5 107.0 0.0 0.0 59.0 0.0 1.031 0

0 0,812 0

0 0.812 0

0 0.763 US 171792 171792 0.747 US 171792 171792 0.748 MT 171792 171792 0.812 0

0 0.812 0

0 0.738 MT 64872 64872 1.031 0

0

===> Grouped by Line: COND: 338: FWH-3B to FWH-4B, Sorted by: Flow Order COND-4001-N COND-4002-E COND-4003-P COND-4004-E COND-4005-P COND-4006-E COND-4007-E COND-4008-N 31 3

53 2

52 2

4 30 11.560 7.850 5.607 8.299 5.607 8.299 8.299 9.248 10.669 1.031 7.245 0.812 5.175 0.812 7.659 0.812 5.175 0.812 7.659 0.812 7.659 0.812 8.535 1.031 0.760 0.628 0.681 0.618 0.681 0.719 0.940 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.568 0.506 0.506 208572 No 147417 No 295308 No 127432 No 295308 No 243540 Yes 334128 Yes 445339 No 0.0 0.0 0.0 0.0 0.0 150.5 150.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 147.5 150.5 129.0 150.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 147.5 129.0 0.0 1.031 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 US 155016 155016 0.904 MT 155016 155016 0.989 MT 155016 0

===> Grouped by Line: COND: 339: FWH-3C to FWH-4C, Sorted by: Flow Order COND-8601-N (C)

COND-8602-E (C)

COND-8603-P U/S COND-8603-P D/S COND-8604-E COND-8605-P 31 11.560 10.669 1.031 0.726 0.506 0.506 180085 No 3

7.850 7.245 0.812 0.827 0.506 0.506 387283 Yes 53 5.607 5.175 0.812 0.723 0.506 0.506 367113 Yes 53 5.607 5.175 0.812 0.681 0.506 0.506 295308 No 2

8.299 7.659 0.812 0.618 0.506 0.506 127432 No 52 5.607 5.175 0.812 0.681 0.506 0.506 295308 No 0.0 101.4 72.4 0.0 0.0 0.0 0.0 0.0 158.0 101.4 101.0 72.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 158.0 101.0 0.0 0.0 0.0 0.847 MT 107856 0

0.909 MT 107856 107856 0.782 MT 107856 107856 0.812 0

0 0.812 0

0 0.812 0

0 Page 1 ALTRAN SOLUTIONS Technical Report 00107-TR-001 Rev. 5 Appendix D, Sheet D - (ob

Company ergy Northwest Plant:

Columbia Generating Station Unit :

DB Name: Columbia-Current Report Date/Time: 08-Dec-20

52 am Analysis Date/Time : 07-Dec-2009 3:17 pm CHECWORKS SFA Version: 2.2 SP-1 (build 70)

Wear Rate Analysis: Combined Summary Report Run Name:

COND: SS-EV1B SUPPLY Ending Period : RFO-21 Total Plant Operating Hours205176 WRA Data Option:

COMP->ARD->HBD Line Correction Factor:

1.000 Duty Factor (Global) : 0.500 Exclude Measure Wear: YES Component Name Average Current Geom Wear Rate Wear Rate ---------

Thickness (in) -----------

Code (mils/yr)

(mils/yr)

]nit.

Prd.[1]

Thoop Tcrit Comp Predict [1)

Total Lifetime In-Service Comp In-Service Comp Time (hrs)

Time to Tcrit (hrs) Wear (mils)

Wear(mils)

Tmeas, Method, Time Last Inspected Prd.[2]

Meas. Prd.[2]

Meas.

(in)[41

[3]

(hrs)[4]

Inspected

===> Grouped by Line: COND: 424A: Supply to EV-1B, Sorted by: Flow Order COND-9414-T (BR/SE) 15 COND-10207-T (BR/SE) 15 COND-9401-P 64 COND-9402-V-187 22 COND-9403-P 58 COND-9404-SF-2 6

COND-9405-P 56 COND-9406-V-186 25 COND-9407-P 58 COND-9408-T 15 COND-9408-T (BR/SE) 15 COND-9408-T (D/S) 15 COND-9409-P 65 COND-9410-E 2

COND-941 1-P 52 COND-9412-E 2

COND-9413-E 4

COND-9414-T 15 COND-9414-T (D/S) 15 COND-9601-P 65 COND-9602-V-193 22 COND-9603-RED 17 COND-9603-RED (D/S) 17 COND-9604-LCV-32B 24 COND-9605a-P 1.* -5" 58 COND-9605b-EXP 18 COND-9605b-EXP (D/S) 18 COND-9606-V-160B 22 COND-10207-T 15 COND-10207-T (D/S) 15 COND-10208-V-188B 25 COND-10209-E 4

0.000 0.000 1.913 4.782 2.104 0.006 1.264 4.782 2.104 2.869 0.000 2.869 1.913 3.539 2.391 3.539 3.539 2.869 2.869 1.913 4.782 2.391 2.409 8.671 3.815 4.856 2.869 4.782 2.562 2.562 4.270 3.160 0.000 0.000 1.765 4.414 1.942 0.006 1.166 4.414 1.942 2.648 0.000 2.648 1.765 3.266 2.207 3.266 3.266 2.648 2.648 1.765 4.414 2;207 2.224 8.002 3.521 4.481 2.648 4.414 2.364 2.364 3.941 2.916 0.276 0.203 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 01276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.276 0.218 0.344 0.344 0.344 0.276 0.276 0.203 0.203 0.203 0.203 0.276 0.203 0.254 0.220 0.251 0.276 0.255 0.220 0.251 0.242 0.276 0.242 0.254 0.235 0.248 0.235 0.235 0.242 0.242 0.254 0.220 0.248 0.190 0.242 0.239 0.235 0.243 0.220 0.173 0.173 0.153 0.166 0.073 0.073 100000000 No 0.029 0.029 100000000 No 0.073 0.073 897241 No 0.078 0.078 282111 No 0.073 0.073 805569 No 0.075 0.075 100000000 No 0.073 0.193 463173 Yes 0.078 0.078 282111 No 0.073 0.073 805569 No 0.073 0.073 561109 No 0.073 0.073 100000000 No 0.073 0.073 561109 No 0.073 0.073 897241 No 0.073 0.073 433924 No 0.073 0.073 695562 No 0.073 0.073 433924 No 0.073 0.073 433924 No 0.073 0.073 561109 No 0.073 0.073 561109 No 0.073 0.073 897241 No 0.078 0.078 282111 No 0.073 0.073 695562 No 0.060 0.060 510840 No 0.064 0.064 195008 No 0.060 0.060 445856 No 0.060 0.060 341425 No 0.073 0.073 564620 No 0.078 0.078 282111 No 0.029 0.029 535280 No 0.029 0.029 535280 No 0.031 0.031 272215 No 0.029 0.029 412981 No 0.0 0.0 0.0 0.0 0.0 0.0 11.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 30.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 30.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.276 0

0.203 0

0.276 0

0.276 0

0.276 0

0.276 0

0.258 US 155016 0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.276 0

0.218 0

0.344 0

0.256 MT 122856 0.256 MT 122856 0.256 MT 122856 0.276 0

0.203 0

0.203 0

0.203 0

0.203 0

0 0

0 0

0 0

155016 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

Page 1 ALTRAN SOLUTIONS Technical Report 00107-TR-001 Rev. 5 Appendix D, Sheet D -

S-

Company Oergy Northwest Plant:

Columbia Generating Station Unit:

DB Name: Columbia-Current Report Date/Time: 08-Dec-200*.51 am Analysis Date/Time: 07-Dec-2009 3:16 pm CHECWORKS SFA Version: 2.2 SP-1 (build 70)

Wear Rate Analysis: Combined Summary Report Run Name:

COND: FWH-4 to FWH-5 Ending Period : RFO-21 Total Plant Operating Hours205176 WRA Data Option:

COMP->NFA Line Correction Factor:

0.744 Duty Factor (Global) : 1.000 Exclude Measure Wear: NO Component Name Average Current Geom Wear Rate Wear Rate ---------

Thickness (in)...........

Code (mils/yr)

(mils/yr)

Init.

Prd.[1j Thoop Tcrit Comp Predict [1]

Total Lifetime In-Service Comp Time to Tcrit (hrs)

Wear (mils)

Wear(mils)

Inspeected Prd r21 Meas.

Prd.[21 Meas.

In-Service Comp Time (hrs)

Tmeas, Method, Time Last (in)41 (31 (hrs)r4]

Insoected Inspected Prd r2l Meas.

Prd.r2l Meas.

===> Grouped by Line: COND: 340: FWH-4A to Header, Sorted by: Flow Order COND-5601-N 31 14.486 COND-5602-E 4

10.400 COND-5603-P 54 8.994 COND-5604-V-140A 22 14.053 COND-5605-E (0) 4 10.400 COND-5606-P 54 8.994 COND-5607-E 1

9.275 COND-5608-P 51 6.184 COND-5609-E 2

10.400 COND-5610-P U/S 52 7.027 COND-5610-P D/S 52 7.027 COND-5611-E 2

10.400 COND-5612-P U/S

• 3 140- 1 52 7.027 COND-5612-P D/S 52 7.027 COND-5613-E 2

10.400 COND-5614-P 52 7.027 COND-5615-E 2

10.400 13.370 1.031 9.598 0.812 8.301 0.812 12.970 0.812 9.598 0.812 8.301 0.812 8.560 0.812 5.707 0.812 9.598 0.812 6.485 0.812 6.485 0.812 9.598 0.812 6.485 0.812 6.485 0.812 9.598 0.812 6.485 0.812 9.598 0.812 0.692 0.568 0.601 0.483 0.815 0.601 0.595 0.667 0.568 0.647 0.699 o 636 0.745 0.647 0.568 0.647 0.568 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 121536 No 56785 No 100394 No

-15780 No 281697 Yes 100394 No 90615 No 247078 No 56785 No 190751 No 260809 Yes 118848 Yes 322945 Yes 190751 No 56785 No 190751 No 56785 No 0.0 0.0 0.0 0.0 72.4 0.0 0.0 0.0 0.0 0.0 139.9 207.0 139.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 71.0 72.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 121.0 139.9 207.0 207.0 114.0 139.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 71.0 0.0 0.0 0.0 0.0 0.0 121.0 207.0 114.0 0.0 0.0 0.0 0.0 1.031 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.986 MT 57984 57984 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.724 US 171792 171792 0.67 MT 171792 171792 0.770 MT 171792 171792 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0

===> Grouped by Line: COND: 340: FWH-4B to Header, Sorted by: Flow Order COND-5701-N COND-5702-E COND-5703-P COND-5704-V-140B COND-5705-E COND-5706-P COND-5707-E COND-5708-P (Wt) 31 14.486 4

10.400 54 8.994 22 14.053 4

10.400 54 8.994 1

9.275 51 6.184 13.370 1.031 9.598 0.812 8.301 0.812 12.970 0.812 9.598 0.812 8.301 0.812 8.560 0.812 5.707 0.812 0.692 0.568 0.601 0.483 0.568 0.601 0.595 0.801 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 0.506 121536 No 56785 No 100394 No

-15780 No 56785 No 100394 No 90615 No 452865 Yes 0.0 0.0 0.0 0.0 0.0 0.0 0.0 43.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 45.0 43.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 45.0 1.031 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.812 0

0 0.903 US 57984 57984 Page 1 ALTRAN SOLUTIONS Technical Report 00107-TR-001 Rev. 5 Appendix D, Sheet D - 6&

=.,

i i

0 Component 0

Average Current Geom Wear Rate Wear Rate ---------

Thickness (in) -----------

Code (mils/yr)

(mils/yr)

[nit.

Prd.[1]

Thoop Tcrit Comp Predict [1]

Total Lifetime In-Service Comp Time to Tcrit (hrs)

Wear (mils)

Wear (mils)

Insnected Prd. [21 Meas.

Prd.[21 Mea 0

In-Service Comp Time (hrs)

Tmeas, Method, Time Last (in)[4]

[3]

(hrs)[4]

Inspected Insp cte Pr Ls 1`21 HV-9704-E (0) 4451-5 HV-9705-P (I) U/S HV-9705-P D/S HV-9706-E HV-9707-P HV-9708-E HV-9709-P HV-971 0-E HV-971 1-P HV-9712-E HV-9713-P HV-9714-E HV-9715-P HV-9716-N73B 2

52 52 1

511 51 2

52 2

51 1

51 30 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.280 0.432 0.217 0.255 0.280 0.280 0.280 0.280 0.280 0.280 0.280, 0.280 0.280 0.280 0.254 0.355 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.109 100000000 No 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.217 MT 107856 0.255 US 107856 0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.280 0

0.254 MT 171792 0.355 US 171792 0

0 0

0 0

0 0

0 0

0 0

0 0

0

===> Grouped by Line: HV: 458: 1st RHTR A to 6602-T, Sorted by: Flow Order HV-12901-P HV-12902-E HV-12903-P HV-12904-E HV-12905-P HV-12906-E HV-1 2907-P HV-12908-V-38A HV-12909-P 65 0.025 2

0.070 52 0.047 2

0.070 52 0.047 2

0.070 52 0.047 22 0.083 58 0.000 0.038 0.108 0.073 0.108 0.073 0.108 0.073 0.129 0.000 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.084 0.084 0.084 0.084 0.084 0.084 0.084 0.090 0.074 0.084 34860972 No 0.084 12386043 No 0.084 18246652 No 0.084 12386043 No 0.084 18246652 No 0.084 12386043 No 0.084 18246652 No 0.090 9959510 No 0.074 100000000 No 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0.237 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0 0

0

===> Grouped by Line: HV: 459:lst RHTR B to 9602-T, Sorted by: Flow Order HV-14801-P HV-14802-V-38B HV-14901-P HV-14902-E HV-14903-P HV-14904-E 65 0.055 22 0.081 58 0.000 2

0.000 52 0.000 2

0.000 0.085 0.237 0.272 0.084 0.084 19437110 No 0.126 0.237 0.237 0.090 0.090 10207633 No 0.000 0.237 0.237 0.074 0.074 100000000 No 0,000 0.237 0.237 0.074 0.074 100000000 No 0.000 0.237 0.237 0.074 0.074 100000000 No 0.000 0.237 0.237 0.074 0.074 100000000 No 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.272 MT 155016 0.237 0

0.237 0

0.237 0

0.237 0

0.237 0

0 0

0 0

0 0

Notes:

[1] Predictions are based on last Tmeas to analysis ending period.

[2] Predictions are for the time of last known meas. wear. Can be P-to-P value depending on meas. wear method.

[3] GW = Tmeas is minimum thickness from Band, Blanket or Area Method of greatest wear.

MT = Tmeas is component minimum thickness.

PW = Tmeas is Tinit - predicted wear.

US = Tmeas is user specified.

[4] If no Tmeas has been determined from measured data, then Tmeas = Tinit and Time = current component installation time.

Tmeas is used to determine Predicted Thickness and Component Predicted Time to Tcrit.

Page 2 ALTRAN SOLUTIONS Technical Report 00107-TR-001 Rev. 5 Appendix D, Sheet D - "2-

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 3 License Renewal Application Amendment 2 Section no.

Page no.

RAI response 2.3.3.22 2.3-94 RAI 2.3.3.22-6 2.3.3.22 2.3-94 RAI 2.3.3.22-7 2.3.3.22 2.3-94a RAI 2.3.3.22-6 2.3.3.22 2.3-94a RAI 2.3.3.22-7 2.3.3.22 2.3-95 RAI 2.3.3.22-6 2.3.3.22 2.3-95 RAI 2.3.3.22-8 2.3.3.22 2.3-96 RAI 2.3.3.22-7 Table 2.3.3-22 2.3-97 RAI 2.3.3.22-4 Table 2.3.3-22 2.3-97 RAI 2.3.3.22-6 Table 2.3.3-22 2.3-97a RAI 2.3.3.22-4 Table 2.3.3-22 2.3-97a RAI 2.3.3.22-6 2.3.2.1.22 3.3-26 RAI 2.3.3.22-6 2.3.2.1.22 3.3-26 RAI 2.3.3.22-8 2.3.2.1.22 3.3-27 RAI 2.3.3.22-6 2.3.2.1.22 3.3-27 RAI 2.3.3.22-7 2.3.2.1.22 3.3-28 RAI 2.3.3.22-6 3.3.2.2.6 3.3-51 RAI 3.3.2.2.6-1 3.3.2.2.6 3.3-51a RAI 3.3.2.2.6-1 3.3.2.2.10.6 3.3-54 RAI 2.3.3.22-6 Table 3.3.1 3.3-61 RAI 3.3.2.2.6-1 Table 3.3.2-22 3.3-256 RAI 2.3.3.22-6 (rows 184-197, 202-209, 222 - 225, 228-233)

Table 3.3.2-22 3.3-256 RAI 2.3.3.22-8 (rows 198 -

201,208 - 209, 222 - 225)

Table 3.3.2-22 3.3-256a RAI 2.3.3.22-6 rows 184 - 191 Table 3.3.2-22 3.3-256b RAI 2.3.3.22-6 rows 191 - 197 Table 3.3.2-22 3.3-256b RAI 2.3.3.22-8 rows 198 - 200

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 3 License Renewal Application Amendment 2 Section no.

Page no.

RAI response Table 3.3.2-22 3.3-256c RAI 2.3.3.22-8 rows 201 & 208 Table 3.3.2-22 3.3-256c RAI 2.3.3.22-6 rows 202 - 207 Table 3.3.2-22 3.3-256c RAI 2.3.3.22-6 rows 208 Table 3.3.2-22 3.3-256c RAI 2.3.3.22-7 rows 208 Table 3.3.2-22 3.3-256d RAI 2.3.3.22-6 rows 209 Table 3.3.2-22 3.3-256d RAI 2.3.3.22-7 rows 209 Table 3.3.2-22 3.3-256d RAI 2.3.3.22-8 rows 209 Table 3.3.2-22 3.3-256d RAI 2.3.3.22-2 rows 210 - 217 Table 3.3.2-22 3.3-256d RAI 2.3.3.22-5 rows 218 - 219 Table 3.3.2-22 3.3-256e RAI 2.3.3.22-5 rows 220 - 221 Table 3.3.2-22 3.3-256e RAI 2.3.3.22-6 rows 222 - 225

& 228-229 Table 3.3.2-22 3.3-256e RAI 2.3.3.22-8 rows 222 - 225 Table 3.3.2-22 3.3-256e RAI 2.3.3.22-7 rows 226 - 227 Table 3.3.2-22 3.3-256f RAI 2.3.3.22-6 rows 230- 233 Table 3.3.2-22 3.3-400a RAI 2.3.3.22-6 Table 3.3.2-22 3.3-400a RAI 2.3.3.22-7 3.5.2.1.2 3.5-4 RAI 3.3.2.2.6-1 3.5.2.1.2 3.5-4a RAI 3.3.2.2.6-1 3.5.2.1.2 3.5-5 RAI 3.3.2.2.6-1 3.5.2.1.2 3.5-5a RAI 3.3.2.2.6-1

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 3 License Renewal Application Amendment 2 Section no.

Page no.

RAI response Table 3.5.2-2 3.5-90 RAI 3.3.2.2.6-1 Table 3.5.2-2 3.5-90a RAI 3.3.2.2.6-1 Table 3.5.2-2, 3.5-139 RAI 3.3.2.2.6-1 Note 0510 A.1.2.25 (new)

A-16 RAI 2.3.3.22-6 A.1.2.25 A-16a RAI 2.3.3.22-6 A.1.2.54 A-26 RAI 3.3.2.2.6-1 A.1.2.54 A-26a RAI 3.3.2.2.6-1 Table A-i, A-51 RAI B.2.26-1 Item 26 Table A-i, A-51a RAI B.2.26-1 Item 26 Table A-1 A-68 RAI 3.3.2.2.6-1 Table A-1 A-68a RAI 3.3.2.2.6-1 (new Item 61)

Table B-1 B-18 RAI 3.3.2.2.6-1 Table B-1 B-18a RAI 3.3.2.2.6-1 B.2.04 B-37 RAI B.2.4-2 B.2.25 B-108 RAI 2.3.3.22-6 B.2.25 B-108a RAI 2.3.3.22-6 B.2.26 B-111 RAI B.2.26-1 B.2.26 B-11la RAI B.2.26-1 B.2.26 B-112 RAI B.2.26-1 B.2.26 B-112a RAI B.2.26-1 B.2.30 B-124 RAI 2.3.3.22-6 B.2.54, B-208 RAI 3.3.2.2.6-1 (new section)

B.2.54 B-208a RAI 3.3.2.2.6-1 B.2.54 B-208b RAI 3.3.2.2.6-1 B.2.54 B-208c RAI 3.3.2.2.6-1 B.2.54 B-208d RAI 3.3.2.2.6-1 B.2.54 B-208e RAI 3.3.2.2.6-1

Columbia Generating Station ISection 2.3.3.22 License Renewal Application Technical Information 1301 provides automatic fire protection for the main control room Power Generation Control Cabinet (PGCC) under-floor areas.

Eighteen Halon 1301 systems are installed in the various main control room PGCC sub-floor duct sections to discharge on activation of their associated thermal detector units.

Thermal detector operation also causes a local alarm and indication on the main control room fire control panel. Smoke detectors are located in each PGCC section to provide early warning alarm. Each system includes supervision features that actuate a trouble alarm and indication on the main control room fire control panel in case of a wiring or component failure.

Dry Chemical Fire Suppression System -

A dry chemical suppression system is installed in approved portable hazardous material storage buildings within the plant.

The system automatically actuates by melting of the fusible links or manually by a local pull station.

Reason for Scope Determination The Fire Protection System provides isolation of the fire water supply to the SGT System filter units and to the Radwaste Building Mixed Air System emergency filter units.

These system-intended functions are safety-related.

Therefore, the Fire Protection System meets the scoping criteria of 10 CFR 54.4(a)(1).

The Fire Protection System does not contain any NSR components that perform a 10 CFR 54.4(a)(1) function. The Fire Protection System does, however, contain NSR components that are attached to or located near safety-related SSCs, whose failure creates a potential for spatial interaction that could prevent the satisfactory accomplishment of one or more of the functions identified in 10CFR54.4(a)(1).

Therefore, the Fire Protection System meets the scoping criteria of 10 CFR 54.4(a)(2).

The Fire Protection System is relied upon to demonstrate compliance with, and meets the 10 CFR 54.4(a)(3) scoping criteria for, the Fire Protection (10 CFR 50.48) regulated event.

FSAR References Section F.2.4 of the FSAR describes the Fire Suppression Systems, evaluated for license renewal as the Fire Protection System.

License Renewal Drawinqs The following license renewal drawings depict the evaluation boundaries for the system components within the scope of license renewal:

LR-M515-1, LR-M515-2, LR-M515-4, LR-M515-5, LR-M573-2, LR-M544, LR-M545-3, LR-M548-1 Scoping and Screening Results Page 2.3-94 j

201G IAmendment 2 y

Columbia Generating Station License Renewal Application Technical Information Insert A to Paqe2.3-94 LR-02H13-05,221,2, LR-02H 13-05,221,2A, LR-02H13-05,250,1, LR-M515-3 Scoping and Screening Results Page 2.3-94a Amendment 2

Columbia Generating Station 2.3.3.22 Fire Protection (FP) System License Renewal Application Technical Information The Carbon Dioxide and D' Chemical Fire Supe systems do not contain componentS that perfo Frm a lic i

func4, tion..

, and therefore a*e not Within the Gcope of license renewal.

The diesel fuel oil lines that supply fuel oil to the fire protection pump diesels, designated as DO on the drawings, and the fire protection pump diesel engine exhaust piping, designated as DE on the drawings, are within the evaluation boundaries of the Fire Protection System.

Components Subiect to AMR Table 2.3.3-22 lists the component types that require AMR and their intended functions.

Table 3.3.2-22, Aging Management Review Results - Fire Protection System, provides the results of the AMR.

Portable fire extinguishers are within the scope of license renewal. However, they are periodically inspected and hydrostatically tested, and are replaced if they do not pass an inspection or test. Portable fire extinguishers are short-lived components, subject to replacement based on a qualified life or specified time period, and not subject to AMR.

Fire and smoke detectors, and alarm devices, do not perform a passive mechanical function for the purpose of license renewal. Electrical components that.are subject to AMR (the cables for the detectors and alarms) are addressed in Section 2.5.

Fire barriers, fire dampers, fire doors, and fire penetration seals determined to be within the scope of license renewal and subject to AMR are addressed as structural commodities in Section 2.4.13.

Fire hoses are within the scope of license renewal.

However, they are periodically inspected to ensure that they are in an acceptable operating condition. These ongoing hose station inspections (together with the associated action to repair or replace any fire hose noted to be in a deteriorated condition) establish a qualified life for the hoses.

Therefore, the fire hoses are not subject to AMR.

The pre-action sprinkler systems are connected to the Control Air System. A failure of the air system will place the sprinkler system in a safe position. That is, the fusible link closed sprinkler heads will maintain water inventory in the piping and the sprinkler system will still be able to perform its system-intended function. Therefore, since this portion of the Control Air System, and associated components, does not have any other component intended function, the portion of the air system included within the Fire Protection System boundary is not subject to AMR.

Insert: "fire pump" i

The.diesel engines, except for the attached heat exchanger, are evaluated as active components and not subject to AMR.

Scoping and Screening Results Page 2.3-95

'a' a y_2,&

[Amendment 4-2

Columbia Generating Station License Renewal Application Technical Information The jeekiey pumps arc niet essential firs prcetectin eqipet pcr Columbia Licensee Gontrolled Speefificatiens (LOGS) 1.10.1. Thcrcfors, Sinee the jeckey pum~ps do not have ea mponent intended function, they-are not suibjet to AMR.

f~r her betle 06 epaRe~ GfT-FaSP9at'R idpr The halon cylinders co)mply With the reu rents Of the DOT-standards.

The halonR cylinders are eOnsu~mables, replaced periodically iR accr.Gdance with DOT standards, and arc not subjeet to AMR.

The Fire Protection bladder tank (FP-TK-1 10) is within the scope of license renewal.

However, it has a service life of approximately 20 years and was replaced accordingly in 2008. The replacement tank is of a similar design, with the same limited service life, and is subject to inspections to ensure its timely replacement.

The bladder tank is short-lived, subject to replacement based on a qualified life or specified time period, and is not subject to AMR.

Scoping and Screening Results Page 2.3-96 janwaFy 2OO-9 tAmendment 4-2

___1

Columbia Generating Station License Renewal Application Technical Information Table 2.3.3-22 Fire Protection System Components Subject to Aging Management Review Component Type Intended Function (as defined in Table 2.0-1)

Bolting Pressure Boundary Structural Integrity Exhaust silencer Pressure Boundary Flexible connection Pressure Boundary Heat exchanger (shell)

Pressure Boundary Heat exchanger (tubes)

Heat Transfer Pressure Boundary Hydrant Pressure Boundary Orifice Pressure Boundary Throttling Piping Pressure Boundary Structural Integrity Pump casing Pressure Boundary Spray nozzle Pressure Boundary Spray Sight glass Pressure Boundary Strainer (body @Ad scre@A,)

-Fuftaie-Tank Pressure Boundary Tubing Pressure Boundary Structural Integrity Valve body Pressure Boundary Structural Integrity fmReplace this table row with "Insert A" from page 2.3-97a Ilnsert B from page 2.3-97a Scoping and Screening Results Page 2.3-97

-delury-201-O Amendment--I-2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 2.3-97 Strainer (body)

Pressure boundary Strainer (screen)[

Filtration Insert B to Page 2.3-97 Compressor casing Pressure Boundary Condenser (channel)

Pressure Boundary Condenser (tubes)

Heat Transfer Pressure Boundary Fan Housing Pressure Boundary Filter body Pressure Boundary Pneumatic mechanical timer housing Pressure Boundary Water motor alarm housing Pressure Boundary Scoping and Screening Results Page 2.3-97a Ame4dmemR-t Amendment 2

I Section 3. =

Columbia Generating Station License Renewal Application Technical Information Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Equipment Drains Radioactive System:

Loss of material Loss of pre-load Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the Equipment Drains Radioactive System:

Bolting Integrity Program BWR Water Chemistry Program Chemistry Program Effectiveness Inspection Closed Cooling Water Chemistry Program External Surfaces Monitoring Program Monitoring and Collection Systems Inspection Supplemental Piping/Tank Inspection 3.3.2.1.22 Fire Protection System Materials The materials of construction for subject mechanical components of the Fire Protection (FP) System are:

Copper alloy Copper alloy> 15% Zn Elastomer Glass Gray cast iron Polymer

• Stainless steel

• Steel

[ Aluminum Alloy Aging Management Review Results Page 3.3-26 January 20!

[Amendment 2

I Columbia Generating Station License Renewal Application Technical Information Environments Subject mechanical components of the FP System are exposed to the following normal operating environments:

• Air-indoor uncontrolled

• Air-outdoor Fuel oil Lubricating oil Moist air Raw water Soil Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the FP System:

Cracking Hardening and loss of strength Loss of material Loss of pre-load Reduction of heat transfer Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the FP System:

Bolting Integrity Program Buried Piping and Tanks Inspection Program Chemistry Program Effectiveness Inspection Diesel-Driven Fire Pumps Inspection External Surfaces Monitoring Program Fire Protection Program Fire Water Program Flexible Connection Inspection Aging Management Review Results Page 3.3-27 ja......2019 JAmendment 2

Columbia Generating Station License Renewal Application Technical Information Fuel Oil Chemistry

• Heat Exchangers Inspection Lubricating Oil Analysis Program Lubricating Oil Inspection Selective Leaching Inspection Supplemental Piping/Tank Inspection 3.3.2.1.23 Floor Drain System Materials The material of construction for subject mechanical components of the Floor Drain System is:

• Steel Environments Subject mechanical components of the Floor Drain System are exposed to the following normal operating environments:

Air-indoor uncontrolled Concrete Moist air Raw water Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Floor Drain System:

Loss of material Loss of pre-load Aging Management Programs The following aging management programs manage the aging effects for subject mechanical components of the Floor Drain System:

Bolting Integrity Program External Surfaces Monitoring Program Monitoring and Collection Systems Inspection Supplemental Piping/Tank Inspection Aging Management Review Results Page 3.3-28 j

R va)n

,0n JAmendment 2

Columbia Generating Station License Renewal Application Technical Information stainless steel diesel engine exhaust components. In addition, with the exception of the flexible connection for the HPCS diesel compressor, diesel exhaust piping, piping components, and piping elements are steel, for which cracking due to SCC is not an applicable aging effect.

3.3.2.2.4 Cracking due to Stress Corrosion Cracking and Cyclic Loading The associated items in Table 3.3.1 (including 3.3.2.2.4.1, 3.3.2.2.4.2, 3.3.2.2.4.3, and 3.3.2.2.4.4) are applicable to PWRs only.

3.3.2.2.5 Hardening and Loss of Strength due to Elastomer Degradation 3.3.2.2.5.1 Components of Heating and Ventilation Systems The HVAC systems contain elastomer flexible connections and elastomer mechanical sealants requiring aging management based on plant operating experience. Elastomer flexible connections and elastomer mechanical sealants subject to hardening and loss of strength in HVAC systems are managed by the External Surfaces Monitoring Program.

3.3.2.2.5.2 Spent Fuel Cooling and Cleanup Systems There are no elastomer linings in the Fuel Pool Cooling System that are subject to AMR.

Elastomer flexible connections in the Diesel Cooling Water System refer to Table 3.3.1 item 3.3.1-12. Hardening and loss of strength of these flexible connections is managed by the Flexible Connection Inspection, which is a new one-time inspection to detect and characterize aging of these connections.

3.3.2.2.6 Reduction of Neutron-Absorbing Capacity and Loss of Material due to General Corrosion The spent fuel racks contain a neutron-absorbing medium of boron carbide (B4C) granular material bonded together to form plates. These plates are sealed in a stainless steel rack and are not exposed to treated water. Consequently, there are no aging effects requiring management for the neutron absorber material,:

he stainless steel around the neutron absorber is exposed to treated water and is sus eptible to loss of material due to crevice and pitting corrosion. The BWR Water Chem try Program is credited for aging management.

Ilnsert A from Page 3.3-51a 3.3.2.2.7 Loss of Material due to General, Pitting, and Crevice Corrosion 3.3.2.2.7.1 Reactor Coolant Pump Oil Collection System, Columbia does not have a reactor coolant pump (reactor recirculation pump) oil collection system. Other components exposed to lubricating oil have loss of material mitigated by the Lubricating Oil Analysis Program with the Lubricating Oil Inspection verifying the effectiveness of the program.

Aging Management Review Results Page 3.3-51 e.....y. 24 0

[Amendment2 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.3-51 The Boron Carbide Monitoring Program is credited to address the potential effects of loss of material and loss of neutron absorbing capacity of the boron carbide material.

Aging Management Review Results Page 3.3-51 a Amendment 2

Columbia Generating Station License Renewal Application Technical Information submerged within the suppression pool is managed by the Monitoring and Collection Systems Inspection, which will detect and characterize loss of material.

There are no aluminum components subject to AMR in the Auxiliary systems that are exposed to treated water.

3.3.2.2.10.3 HVAC Piping, Piping Components, and Piping Elements The Open-Cycle Cooling Water Program is credited with the management of loss of material for copper alloy heat exchanger tubes exposed to external condensation. The Cooling Units Inspection is a one-time inspection that will detect and characterize loss of material due to pitting and crevice corrosion for copper alloy HVAC heat exchanger tubes in an external environment with potential for wetting. Loss of material for copper alloy piping and in-line components is managed by the External Surfaces Monitoring Program.

3.3.2.2.10.4 Piping, Piping Components, and Piping Elements - Lubricating Oil Loss of material due to pitting and crevice corrosion for copper alloy piping components exposed to lubricating oil is managed by the Lubricating Oil Analysis Program. Loss of material for copper alloy heat exchanger components exposed to lubricating oil is also managed by the Lubricating Oil Analysis Program.

The Lubricating Oil Analysis Program manages aging effects through periodic monitoring and control of contaminants, including water. The Lubricating Oil Inspection will provide a verification of the effectiveness of the Lubricating Oil Analysis Program to manage loss of material due to pitting and crevice corrosion through examination of copper alloy piping and heat exchanger components.

Copper alloys with less than 15% zinc and less than 8%

aluminum are not susceptible to loss of material due to pitting or crevice corrosion and do not require management.

3.3.2.2.10.5 HVAC Piping, Piping Components, and Piping Elements and Ducting Loss of material for aluminum and stainless steel piping and piping components, heat exchanger components, tanks, and drain pans exposed to condensation is managed by the Cooling Units Inspection, the Open-Cycle Cooling Water Program, or the External Surfaces Monitoring Program. The Cooling Units Inspection is a one-time inspection that will detect and characterize loss of material for these components.

3.3.2.2.10.6 Fire Protection System Loss of material due to pitting and crevice corrosion is an applicable aging effect only if the materials are exposed to an aggressive environment. The only copper or copper alloy fire protection system piping components exposed to internal ambient environments arp-spray nozzles, strainers bodies, pd valve bodies. The components are open to lopal' ambient air conditions such that c 0densation will not occur and are not subject t16 continuous wetting or alternate wetting I nd drying that would constitute flexible connections, I Ftubing Aging Management Review Results Page 3.3-54 Jan-ay 20!0 jAmendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Evaluation Discussion Number Component/Commodity Effect/Mechanism Programs Recommended 3.3.1-12 Elastomer lining exposed to Hardening and loss A plant-specific aging Yes, plant Consistent with NUREG-1801.

treated water or treated borated of strength due to management program specific water elastomer is to be evaluated.

Although there is no elastomer degradation lining exposed to treated water or treated borated water, this item is applied to flexible connections in the Diesel Cooling Water System. The Flexible Connection Replace with "Consistent with Inspection is credited to detect INUREG-1801."

and characterize hardening and loss of strength for these elastomer components.

Refer to Section 3.3.2.2.5.2 for further information.

3.3.1-13 Boral, boron steel spent fuel Reduction of A plant specific aging Yes, plant KoI -1,'

storage racks neutron-neutron-absorbing management program specific absorbing sheets exposed to capacity and loss is to be evaluated.

The spent fuel storage racks treated water or treated borated of material due to contain a neutron-absorbing water general corrosion medium of boron carbide (B4C) granular material bonded together to form plates. These plates are sealed in a stainless steel rack and are not exposed to Refer to Section 3.3.2.2.6 for

]Add "The Boron Carbide Monitoring Program further information.

is credited. A Note E is applied."

Aging Management Review Results Page 3.3-61 IAmendment2 I

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results -Fire Protection System Aging Effect Aging TNUREG-Row Component Intended l

En nt Reuiring M

gnt 1801 Table No.

Type Function(s)

Material Environmen Rquiig Management{Vlme IIe Notes Management Program Volume 1 Item 2 Item Pressure Raw water Loss of 3.3.1-177 Valve Body boundary Steel (Internal) material Fire Water VII.G-24 68A Pressure Air-indoor Loss of External 3.3.1-178 Valve Body boundary Steel uncontrolled material Surfaces VII.I-8 A

(External)

Monitoring 58 Pressure Air-outdoor Loss of External 3.3.1-179 Valve Body boundary Steel (External) material SuMonitoring VII.9 58 A

Pressure Soil Loss of Buried Piping 3.3.1-A 180 Valve Body boundary (External) material Inspection 19 Insert A from Pages 3.3-256a-f Aging Management Review Results Page 3.3-256 Aging Management Review Results Page 3.3-256 jAmendment 2_1--/"ý'

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.3-256 1 Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Row Component Intended Aging Magint 1801 Table No.

Type Function(s)

Material Environment Requiring Management Volume 2 1 Item Notes Management Program Item Compressor Pressure Gray Cast Gas (internal)

None None VII.J-23 3.3.1-A 184 casing (FP-C boundary Iron 97 0328 CO2/1 )

Compressor Pressure Air-indoor External 3.3.1-185 casing (FP-C-GrayCast uncontrolled Loss of material Surfaces V.11.1-8 A

C02/1) boundarI Iron (External)

Monitoring 58 Condenser Pressure 3.3.1-C 186 (channels) (FP-boundary Steel Gas (Internal)

None None VII.J-23 97 0328 CU-C02/1)

Condenser Pressure Air-indoor External 187 (channels) (FP-Steel uncontrolled Loss of material Surfaces VII.I-8

3.

A CU-C02/1) boundary (External)

Monitoring 58 Condenser 3.3.1-C 188 (tubes) (FP-CU-Heat Copper Gas (Internal)

None None VII.J-4 97 0328 C02/1)

Transfer Alloy Condenser Heat Copper Air-indoor ExcaneroNAinAHeat 189 (tubes) (FP-CU-uncontrolled Exchangers N/A N/A C02/1)

Alloy (External) heat transfer Inspection Condenser Pressure 3.3.1-C 190 (tubes) (FP-CU-boury Copper Gas (Internal)

None None VII.J-4 97 0328 (tubes) FPC-.boundary Alloy97 02 C02/1)_____

Condenser Air-indoor 191 (tubes) (FP-CU-Copper uncontrolled None None N/A N/A G

C02/1) boundary Alloy (External)

Agin Maagemnt eviw Reult Pag 3.-25a Amndmnt Aging Management Review Results Page 3.3-256a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results - Fire Protection System Row Component Intended Aging Effect Aging NUREG-No.

Type Function(s)

Material Environment Requiring Management 1801 Table Notes Management Program Item Fan Housing (FP-Pressure Air-indoor External 3.3.1-C 192 FN-C02/1) boundary Steel uncontrolled Loss of material Surfaces VII.I-8 58 0302 (Internal)

Monitoring Fan Housing (FP-Pressure Air-indoor External 3.3.1-193 FaNC2/1) bogeunary Steel uncontrolled Loss of material Surfaces VII.l-8 58 A

FN-CO2/1) boundary (External)

Monitoring Filter body (FP-F-Pressure Steel Gas (Internal)

None None VIIJ-23 3.3.1-A 1

C02/1) boundary S

97 0328 Air-indoor External 195 Filter body (FP-F-Pressure Steel uncontrolled Loss of material Surfaces VII.I-8 331 A

CO2/1) boundary (External)

Monitoring 58 Flexible Pressure Copper 3.3.1-A 196 Connection (FP-boundary Alloy >

Gas (Internal)

None None VII.J-4 97 0328 FLX-C02/1) 15% Zn Flexible Pressure Copper Air-indoor 197 Connection (FP-Alloy >

uncontrolled None None N/A N/A G

FLX-C02/1) boundary 15% Zn (External)

Flexible Pressure Copper Air-indoor 198 Alloy >

uncontrolled None None N/A N/A G

Connection boundary 15% Zn (External)

Flexible Pressure Copper Air-indoor Alloy >

uncontrolled None None N/A N/A G

Connection boundary 15% Zn (Internal)

Air-indoor Flexible Pressure Stainless Air3ndoo 200 Flexion boury Steel uncontrolled None None VII.J-15 3.3.1-A Connection boundary Steel (External) 94 Aging Management Review Results Page 3.3-256b Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Row Component Intended Aging Magint 1801 Table No.

Type Function(s)

Material Environment Requiring Management Volume 2 1 Item Notes Management Program Item Flexible Pressure Stainless 3.3.1-A 201 Connection boundary Steel uncontrolled None None VII.J-15 94 0302 (Internal)

Heat Exchanger Heat Copper 3.3.1-C 202 (tubes) (FP-HX-ater Coy Gas (Internal)

None None VII.J-40328 C02/1)

Transfer Alloy Heat Exchanger Air-indoor 203 (tubes) (FP-HX-Transfer Copper uncontrolled None None N/A N/A G

C02/1)

Alloy (External)

Heat Exchanger P e s rCo p r3.3.1-C 204 (tubes) (FP-HX-Pressure Copper Gas (Internal)

None None VII.J-4 3.3.1-204 2tube) FPH-boundary Alloy97 02 C02/1)

Heat Exchanger Pressure C

Air-indoor Reduction in Heat 205 (tubes) (FP-HX-boundary opper uncontrolled heat transfer Exchangers N/A N/A G

C02/1)

Alloy (External)

Inspection Pneumatic Mechanical Timer Pressure 3.3.1-C 206 Housing (FP-TM-boundary Steel Gas (Internal)

None None VII.J-23 97 0328 C02/1)

Pneumatic Air-indoor External 207 Mechanical Timer Pressure Steel uncontrolled Loss of material Surfaces VII.I-8 3.3.1-A Housing (FP-TM-boundary (External)

Monitoring 58 C02/1)

Air-indoor Pressure Stainless 3.3.1-A 208 Piping uncontrolled None None VII.J-15 208

_Pipingboundary Steel (Internal) 94 0302 Aging Management Review Results Page 3.3-256c Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Row Component Intended Material Environment Requiring Management 1801 Table Notes No.

Type Functi.on(s)

Maaeet Porm Volume 2 1 Item Management Program Iteume2 1Im Nos Item Pressure Stainless Air-indoor 3.3.1-209 Piping boundary Steel (External)

None None VII.J-15 94A 210 Pump casing (FP-Pressure Gray Cast Raw water Loss of material Fire Water VII.G-24 3.3.1-A P-3) boundary Iron (Internal) 68 211 Pump casing (FP-Pressure Gray Cast Raw water Loss of material Selective VII.G-14 3.3.1-A P-3) boundary Iron (Internal)

Leaching 85 Inspection 212 Pump casing (FP-Pressure Gray Cast Condensation External 3.3.1-P-3) boundary Iron (External)

Loss of material Surfaces VII.I-11 58A Monitoring 213 Pump casing (FP-Pressure Gray Cast Condensation Selective P-3) boundary Iron (External)

Loss of material Leaching N/A N/A G

Inspection 214 Pump Casing Pressure Gray Cast Raw water Loss of material Fire Water VILG-24 3.3.1-A (FP-P-3) boundary Iron (External) 68 215 Pump Casing Pressure Gray Cast Raw water Selective 3.3.1-(FP-P-3) boundary Iron (External)

Loss of material Leaching VII.G-14 85 A

Inspection____

216 Pump casing (FP-Pressure Stainless Raw water Loss of material Fire Water VII.G-19 3.3.1-A P-111) boundary Steel (Internal) 69 217 Pump casing (FP-Pressure Stainless Condensation External 3.3.1-P-111) boundary Steel (External)

Loss of material Surfaces VII.F2-1 27 E

Monitoring 27 218 Pump casing (FP-Pressure Gray Cast Raw water Loss of material Fire Water VII.G-24 3.3.1-A P-1 12) boundary Iron (Internal) 68 219 Pump casing (FP-Pressure Gray Cast Raw water Loss of material Selective VII.G-14 3.3.1-A P-112) boundary Iron (Internal)

Leaching 85 I __ __

_ I__

I IInspection I

rdy~~~~

~~

1.)UIIIHU iI Aging Ivianagemem Review ResuILS rage 3.3-1_56d m'1 tent UI em Lf

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results - Fire Protection System NUREG-Row Component Intended Aging Effect Aging 1801 Table No.

Type Function(s)

Material Environment Requiring Management Volume 2 1 Item Notes Management Program Item 220 Pump casing (FP-Pressure Gray Cast Condensation External 3.3.1-P-112) boundary Iron (External)

Loss of material Surfaces VII.I-1 1 58A Monitoring Pump casing (FP-Pressure Gray Cast Condensation Selective 221 P-112) boundary Iron (External)

Loss of material Leaching N/A N/A G

Inspection Pressure Aluminum Air-indoor 222 Spray Nozzle uncontrolled None None N/A N/A G

222 Spray Nozzle boundary Alloy (Internal)

Pressure Aluminum Air-indoor 223 Spray Nozzle uncontrolled None None N/A N/A G

e boundary Alloy (External)

Aluminum Air-indoor 224 Spray Nozzle Spray Alloy uncontrolled None None N/A N/A G

(Internal)

Air-indoor 225 Spray Nozzle Spray Aluminum uncontrolled None None N/A N/A G

22 SraNzzyAlloy (External) 226 Tank (Halon Pressure Steel Gas (Internal)

None None VII.J-23 3.3.1-C 1301) boundary 97 0328 227 Tank (Halon Pressure Steel Air-indoor Loss of material External 3.3.1-1301) boundary uncontrolled Surfaces VII.I-8 58 A

(External)

Monitoring Pressure 3.3.1-C 228 Tank (FP-TK-1) boundary Steel Gas (Internal)

None None VII.J-23 97 0328 Pressure Air-indoor External 3.3.1-229 Tank (FP-TK-1) boundary Steel uncontrolled Loss of material Surfaces VII.I-8 58A (External)

Monitoring 58 Aging Management Review Results Page 3.3-256e Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-22 Aging Management Review Results - Fire Protection System Aging Effect Aging NUREG-Row Component Intended Aaira Enfemt agint 1801 Table No.

Type Function(s)

Material Environment Requiring Management Volume 2 1 Item Notes Management Program Item Tank (FP-TK-Pressure Steel Gas (internal)

None None VII.J-23 3.3.1-C 230 C02/1,2) boundary 97 0328 Tank (FP-TK-Pressure Air-indoor External 3.3.1-231 C02/1,2) boundary Steel uncontrolled Loss of material Surfaces VII.I-8 58 A

(External)

Monitoring 58 Pressure Copper Gas (Internal)

None None VII.J-4 3.3.1-C 232 Tubing boundary Alloy 97 0328 233 Tubing Pressure Copper Air-indoor None None N/,A N/A G

boundary Alloy uncontrolled (Internal) 234 Water motor Pressure Steel Raw water Loss of material Fire Water VII.G-24 3.3.1-A alarm housing boundary (Internal) 68 235 Water motor Pressure Steel Air-indoor Loss of material External VII.I-8 3.3.1-A alarm housing boundary uncontrolled Surfaces 58 (External)

Monitoring Aging Management Review Results Page 3.3-256f Amendment 2 Aging Management Review Results Page 3.3-256f Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to LRA Page 3.3-400 0325 The~material is not aluminum alloy > 12%Zinc or 6% Magnesium, which is required for the mechanism of cracking due to stress corrosion cracking tobe applicable.

0326 Based on a review of recent operating experience, the bottom portion of the air-handling unit-housings for WMA-AH-51A/B are evaluated as exposed to an internal environment of condensation.

0327 No aging effects requiring management have been identified. However, for all brass (copper alloy> 15% Zn) spray nozzles that are in the scope of license renewal, the Fire Water Program is credited to provide confirmation of the absence of significant aging effects during the period of extended operation.

0328 No aging effects requiring management have been identified. However, the Fire Protection Program is credited to provide confirmation of the absence of significant aging effects for the halon and carbon dioxide jsuppression systems during the period of extended operation.

Aging Management Review Results Page 3-3-400a AmeA4ffie~4t ~i-jAmendment 2

Columbia Generating Station License Renewal Application Technical Information 3.5.2.1.2 Reactor Building Materials Reactor Building structural components subject to AMR are constructed of the following materials:

" Aluminum

" Carbon Steel

" Concrete

" Concrete Block or Brick (freestanding or stacked shield wall)

Galvanized Steel

" Stainless Steel Boron Carbide (B4C)

Materials for bulk commodity components are addressed in Section 3.5.2.1.13.

Environments Reactor Building structural components subject to AMR are exposed to the following environments:

Soil

" Air-indoor

" Air-outdoor

" Treated water

" Raw water Environments for bulk commodity components are addressed in Section 3.5.2.1.13.

Aging Effects Requiring Management The following aging effect associated with the Reactor Building structural components requires management:

Loss of material Aging e ts requiring management for bulk commodity components are addressed in Section 3.5.113.

Aging Management Review Results Page 3.5-4

2. 9

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to page 3.5-4 Loss of neutron absorbing capacity Aging Management Review Results Page 3.5-4a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Aging Management Programs The following programs are credited for managing the effects of aging on the Reactor Building structural components:

Structures Monitoring Program Material Handling System Inspection Program BWR Water Chemistry Program Fire Protection Program Insert A from Page 3.5-5a Aging management programs for bulk commodity components are addressed in Section 3.5.2.1.13.

3.5.2.1.3 Standby Service Water Pump House 1A and 1 B and Spray Pond 1A and 1B Materials Standby Service Water Pump House and Spray Pond structural components subject to AMR are constructed of the following materials:

Carbon Steel Concrete Galvanized Steel

• Stainless Steel

• Teflon Materials for bulk commodity components are addressed in Section 3.5.2.1.13.

Environments Standby Service Water Pump House and Spray Pond structural components subject to AMR are exposed to the following environments:

Soil Air-indoor

• Air-outdoor

• Water-flowing Raw water Environments for bulk commodity components are addressed in Section 3.5.2.1.13.

Aging Management Review Results Page 3.5-5 January 2010

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.5-5 Boron Carbide Monitoring Program Aging Management Review Results Page 3.5-5a Amendment 2 Aging Management Review Results Page 3.5-5a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table 3.5.2-2 Aging Management Review Results - Reactor Building Aging Effect NUREG-Row Component /

Intended Material Environment Requiring Aging Management 1801 Table Notes No.

Commodity Function1 Program Volume 2 Item ManagmentItem EN, FB, Structures Monitoring Reinforced FLB, HELB, Program 1

34 Concrete: Walls, MB, SHD, Concrete Air - indoor None N/A N/A floors, and ceilings SNS, SRE, Fire Protection N 0501 SSR Program EN, SHDStructures Monitoring 35 Shield Plugs EN, SHD, Concrete Air - indoor None Pr oram N/A N/A 0

SSR Program

.0501 Concrete Structures Monitoring 1

36 Shield Walls SHiD, SNS (solid blocks or Air - indoor None S

ronrin N/A N/A 0501 bricks)

Program 0517 37 Structures Monitoring N/A N/A I

Sumps SNS Concrete Air indoor None Program 0501

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Replace row with Insert A from Page 3.5-90a Aging Management Review Results Page 3.5-90 Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.5-90 Table 3.5.2-2 Aging Management Review Results - Reactor Building Row Component Intended M

E1 Aging Effect Requiring Aging NUREG-1801 2Table I No.

Commodity Function1 Material Environme'n Management Management Volume 2 Item Notes Program Item Boron Carbide Loss of material and loss Boron Carbide VII.A2-3 3.3.1-E of neutron absorbing Monitoring Program 13 38 Spent Fuel Rack ABN, SSR Treated capacity Neutron Absorbers water Stainless Steel Loss of material BWR Water VII.A4-11 3.3.1-C

(__sheathing) I I

Chemistry Program 24 0514 Aging Management Review Results Page 3.5-90a Amendment 2 Aging Management Review Results Page 3.5-90a Amendment 2

Replace strikeout text with "Not used."

Columbia Generating Station License Renewal Application Technical Information Plant-Specific Notes:

0510 Agnina i-annagem-ntfar-pmf

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,..sro nat c..anifir.n 051 Te nwtue straetacks har (SIte n -adrymild entironmant. rth intaarthe newfutha storane fvaul tar.

rThe newh fueanlth-torg rack-stare h-dcfromalumintautha rithc-stnainlss steeila fasteera. T e f ta-c-#Rinn sA fa C stat-in -almnu ta avi detrimetar

-Aa ncrr-ado in a redomin la nviton i+has ant ficoa nded Thar-act--s-niac

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.A 0511 The aew elptrage rak are environment as the s e

inside The neW fue strager vault. Th newa fuel stoages racs aef corrosio in a prdmiatlirev ronment, is ai recmmede practic andha beend used uccesasful.o-mn.ersb h material due to crevice and pitt ing corrosion.rakg due to SCC is not applicable. Since the gates are part of the fuel pool water containment boundary, monitoring of fuel pool level and leak chase channels activities also indirectly manage this component.

0514 This NUREG-1801 item specifies the AMP is to be augmented by a "One-Time Inspection." Augmented One-time inspection is not applicable to the spent fuel pool since it is not a low flow or stagnant flow area. Also, NUREG-1 801 Chapter VII.A2 Spent Fuel Storage does not require Water Chemistry to be augmented by a "One-Time Inspection." Augmented inspection applies to piping, piping components, and piping elements, not the spent fuel racks or gates.

0515 Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. Chapter II or Chapter III of NUREG-1 801 does not list exposed to raw water environment for stainless steel components. The identified AMP is used to manage aging effects for the period of extended operation.

0516 The lead panels are encapsulated within stainless steel casing.

0517 The shield walls at Columbia are made up of free-standing or stacked solid bricks (blocks) sandwiched between metal (siding) panels. The panel sections (and blocks) are held in place under all load conditions by angle sections anchored to the concrete wing walls at the pipe chases. Concrete block shield walls do not function like a typical block wall within a structure and are not subjected to degradations found from industry experience (i.e., aging effects cited in IEB 80-11.)

Aging Management Review Results Page 3.5-139 FAmend ment 2

Columbia Generating Station License Renewal Application Technical Information A.1.2.24 Fatigue Monitoring Program Fatigue evaluations for mechanical components are identified as TLAAs; therefore, the effects of fatigue have been addressed for license renewal.

Columbia monitors fatigue of various components (including ASME Class 1 reactor coolant pressure boundary, high energy line break locations, and Primary Containment) via the Fatigue Monitoring Program, which tracks transient cycles and calculates fatigue usage. Columbia has assessed the impact of the reactor coolant environment on the sample of critical components identified in NUREG/CR-6260.

Calculation of fatigue usage values is not required for non-Class 1 SSCs.

Instead, stress intensification factors and lower stress allowables are used to ensure components are adequately designed for fatigue.

In accordance with 10 CFR 54.21(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 period of extended operation.

The Fatigue Monitoring Program is an existing program that requires enhancement prior to the period of extended operation.

A.1.2.25 Fire Protection Program The Fire Protection Program is an existing program, described in Appendix F of the FSAR, that detects degradation of components in the scope of license renewal that have fire barrier functions.

Periodic visual inspections and functional tests are performed of fire dampers, fire barrier walls, ceilings and floors, fire-rated penetration seals, fire wraps, fire proofing, and fire doors to ensure that functionality and operability are maintained.

In addition, the Fire Protection Program supplements the Fuel Oil Chemistry Program and External Surfaces Monitoring Program through performance monitoring of the diesel-driven fire pump fuel oil supply components and testing and inspection of the halon supprcssin SyStc m, spectively. The Fire Protection Program is a condition monitoring program, compris of tests and inspections based on National Fire Protection Association (NFPA) reconendations.

A.1.2.26 Fire Water Program Insert A from Page A-i6a The Fire Water Program (sub-program of the overall Fire Protection Program) is described in Appendix F of the FSAR, and is credited with managing loss of material due to corrosion, erosion, macrofouling, and selective leaching, cracking due to SCC/IGA of susceptible water-based fire suppression components in the scope of license renewal.

Periodic inspection and testing of the water-based fire suppression systems provides reasonable assurance that the systems will remain capable of performing their intended function.

Periodic inspection and testing activities include hydrant and hose station inspections, fire main flushing, flow tests, and sprinkler Final Safety Analysis Report Supplement Page A-16 j

• wany,201

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-16 Halon and carbon dioxide fire suppression systems Final Safety Analysis Report Supplement Page A-16a Amendment 2 1

Columbia Generating Station License Renewal Application Technical Information The Supplemental Piping/Tank Inspection is a new one-time inspection that will be implemented prior to the period of extended operation. The inspection activities will be conducted within the 10-year period prior to the period of extended operation.

A.1.2.52 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will manage reduction of fracture toughness due to thermal aging and neutron irradiation embrittlement of CASS reactor vessel internals.

The program includes: (a) identification of susceptible components determined to be limiting from the standpoint of thermal aging or neutron irradiation embrittlement (neutron fluence), (b) a component-specific evaluation to determine each identified component's susceptibility to reduction of fracture toughness, and (c) a supplemental examination of any component not eliminated by the component-specific evaluation.

The program credits portions of the Inservice Inspection (ISI) Program and the BWR Vessel Internals Program.

The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is a new aging management program that will be implemented prior to the period of extended operation.

A.1.2.53 Water Control Structures Inspection The Water Control Structures Inspection, implemented as part of the Structures Monitoring Program, consists of inspection activities to detect aging and age-related degradation. The Water Control Structures Inspection 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.

The Water Control Structures Inspection is an existing program that requires enhancement prior to the period of extended operation.

A.

3 Evaluation of Time-Limited Aging Analyses In acco ance with 10 CIFR 54.21(c), an application for a renewed operating license ce wit 10 CFRo 5421c)

Tnapiainfrarneeiprtn ies requires a evaluation of TLAAs for the period of extended operation. The following TLAAs have een identified and evaluated to meet this requirement.

Insert A from Page A-26a Final Safety Analysis Report Supplement Page A-26

..... F-2.

.0

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-26 A.1.2.54 Boron Carbide Monitoring Program The Boron Carbide Monitoring Program detects degradation of Boron Carbide (B4C) neutron absorbers in the spent fuel storage racks by monitoring spent fuel racks for potential off-gassing and B4C coupon inspection. From the monitoring data, the stability and integrity of Boron Carbide in the storage cells are assessed. Periodic monitoring of B4C samples permits early determination of aging degradation.

Final Safety Analysis Report Supplement Page A-26a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table A-1 Columbia License Renewal Commitments FSAR Enhancement

,Supplement or Item Number Commitment Location or Location Implementation (LRA App. A)

Schedule

25) Fire Protection The Fire Protection Program is an existing program that will be A.1.2.25 Ongoing Program continued for the period of extended operation.

26) Fire Water Program The Fire Water Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

Perform either ultrasonic testing or internal visual inspection of representative portions of above ground fire protection piping that are exposed towater, but do not normally experience flow, after the issuance of the renewed license, but prior to the end of the current operating term and at reasonable intervals thereafter, based on engineering review of the results.

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 will reach 50 years of service life during the period of extended operation.

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.

A.1.2.26 Enhancement prior to the period of extended operation.

Then ongoing.

Ilnsert A from Page A-51a lInsert B from Page A-51a I Final Safety Analysis Report Supplement Page A-51 Ja.~ua4y-2~4Q Final Safety Analysis Report Supplement Page A-51 jaRuaFy 2910 jAmendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-51 Perform 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).

Insert B to Page A-51 Perform visual inspection of a representative sample of copper alloy > 15% Zn Fire Protection components exposed to water for evidence of cracking (presence of ammonia) within the 10-year period prior to entering the period of extended operation (i.e., between year 30 and 40).

Perform an additional visual inspection of a representative sample of copper alloy > 15% Zn Fire Protection components exposed to water for evidence of cracking (presence of ammonia) within the 10-year period after entering the period of extended operation (i.e., between year 40 and 50).

Final Safety Analysis Report Supplement Page A-51 a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Table A-1 Columbia License Renewal Commitments FSAR Enhancement Item Number Commitment Supplement or

• Location Implementation (LRA App. A)

Schedule

60) BWRVIP-116 Implementation of the BWRVIP ISP(E) for Columbia will include the LRA On-going following details in support of the contingency plan:

Appendix C (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.

(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.

IAdd Insert A from Page A-68a I Final Safety Analysis Report Supplement Page A-68 jAmendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Pagqe A-68 Table A-1 Columbia License Renewal Commitments FSAR Enhancement Item Number Commitment Supplement or Location Implementation (LRA App. A)

Schedule

61) Boron Carbide The Boron Carbide Monitoring Program is an existing program that A.1.2.54 Ongoing Monitoring will be continued for the period of extended operation.

Program Final Safety Analysis Report Supplement Page A-68a Amendment2

Columbia Generating Station License Renewal Application Technical Information Table B-1 Correlation of NUREG-1801 and Columbia Aging Management Programs (continued)

Number NUREG-1801.Program Corresponding Columbia AMP N/A Plant-Specific Program High-Voltage Porcelain Insulators Aging Management Program See Section B.2.31.

N/A Plant-Specific Program Potable Water Monitoring Program See Section B.2.43.

N/A Plant-Specific Program Preventive Maintenance - RCIC Turbine Casing See Section B.2.44.

Insert A from Page B-18a I

Aging Management Programs Page B-18 jaieay 2. 40 jAmendment 2 =1..

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-18 Table B-1 Correlation of NUREG-1801 and Columbia Aging Management Programs (continued)

Number NUREG-1801 Program Corresponding Columbia AMP Boron Carbide Monitoring Program N/A Plant-Specific Program See Section B.2.54.

Aging Management Programs Page B-18a Amendment 2 Aging Management Programs Page B-18a Amendment 2

Columbia Generating Station License Renewal Application Technical Information B.2.4 Bolting Integrity Program Program Description The Bolting Integrity Program is a condition monitoring program that consists of existing Columbia activities that, in conjunction with other credited programs (identified in discussions below), address the management of aging for the bolting of subject mechanical components and structural connections within the scope of license renewal.

The Bolting Integrity Program relies on manufacturer and vendor information and industry recommendations (in EPRI NP-5067, "Good Bolting Practices") for the proper selection, assembly, and maintenance of bolting for pressure-retaining closures and structural connections. The Bolting Integrity Program consists of the 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 SCC and fatigue.

NUREG-1801 Consistency The Bolting Integrity Program is a combination of existing activities that are consistent with the 10 elements of an effective aging management program as described in NUREG-1801 Section XI.M18, "Bolting Integrity," with exceptions.

Exceptions to NUREG-1801 Progqram Elements Affected:

, Detection of Aging Effects, Corrective Actions

" Preventive Actions (and Scope of Program) oen The Bolting Integrity Program does not explicitly address the guidelines outlined in EPRI NP-5769, or as delineated in NUREG-1339.

However, the Bolting Integrity Program does rely on the recommendations of the manufacturer and vendor and the industry, contained in related EPRI document NP-5067, including proper material selection, preload, and assembly.

" Monitoring and Trending Periodic inspection of bolting, other than of the Class 1, 2, 3, and MC bolting performed by the Inservice Inspection (ISI) Program and Inservice Inspection (ISI) Program -

IWF, is performed through the External Surfaces Monitoring Program or Structures Monitoring Program, including follow-up inspections if leakage or degradation is detected.

The frequency of follow-up inspections is established by engineering evaluation of the identified problem.

Aging Management Programs Page B-37 Amendment 2

Columbia Generating Station

[Appendix B Section B.2.25 License Renewal Application Technical Information B.2.25 Fire Protection Program Program Description The Fire Protection Program is an existing program that is described in the Fire Protection Evaluation, Appendix F (Section F.5) of the FSAR, and which is credited with managing loss of material, cracking, delamination, separation, and change in material properties for susceptible components in the scope of license renewal that have a fire barrier function. Periodic visual inspections and functional tests are performed of fire dampers, fire barrier walls, ceilings and floors, fire-rated penetration seals, fire wraps, fire proofing, and fire doors to ensure that functionality and operability are maintained.

In addition, the Fire Protection Program supplements the Fuel Oil Chemistry Program and External Surfaces Monitoring Program through performance monitoring of the diesel-driven fire pump fuel oil supply components and testing and inspection of the halon suppression system, ectively. The Fire Protection Program is a condition monitoring program, comprised tsr and inspections in accordance with National Fire Protection Association (NFPA) recoin dations.

NUREG-1801 Consistency The Fire Protection Program is an existing Columbia program that is consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M26, "Fire Protection," with exceptions.

Exceptions to NUREG-1801 Program Elements Affected:

A

,"'.,'v

• ~,

I, v

,/

pr vi e A

low pressuFe Gaub dioxide system n,,

dumautaaly f*,

ires protection forF the turbine generator exciterf housing, as described in FSAR Section F=.P4 1.

However, nefither the turbine generator exciter nrG the associated carbonR dioxide suppressionR system is in the scoe8 Of license Frenal As such, agin maaemenRt of the carbon dioxide suppression System is not required and the assoc"iated facets of the site Fire Protection ProgramA are not credited for license renewal.

Parameters Monitored or Inspected, Detection of Aging Effects -

Functional tests and inspections of the haon suppresion, system that are included in the Fire Protection Program are performed at an interval gr ter than biannually, which has been demonstrated to be adequate, based on the asence of any related problems as reported through the corrective action program.

Insert A from Page B-1-08a Aging Management Programs Page B-108 Jauary 20!0 I~mndentfl2 4

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-108 halon and carbon dioxide fire suppression systems Aging Management Programs Page B-108a Amendment 2

Columbia Generating Station License Renewal Application Technical Information B.2.26 Fire Water Program Program Description The Fire Water Program (sub-program of the overall Fire Protection Program) is an existing program that is described in the Fire Protection Evaluation, Appendix F (Section F.5) of the FSAR, and which is credited with aging management of the water-based fire suppression components in the scope of license renewal.

The Fire Water Program will manage loss of material due to corrosion, erosion, and macrofouling for all susceptible materials in the Fire Protection System, including water supply components, which are exposed to raw water. The program will also manage cracking due to SCC/IGA of copper alloy > 15% Zn components exposed to raw water.

The Fire Water Program will manage loss of material due to selective leaching for the copper alloy > 15% Zn spray nozzles that are part of a wet-pipe sprinkler configuration that are exposed to raw water. The Selective Leaching Inspection will manage loss of material due to selective leaching of susceptible components other than the wet-pipe spray nozzles.

The Fire Water Program is applicable to 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 (piping),

sprinklers (spray nozzles), pump casings, orifices, and hydrants.

Periodic inspection and testing of water-based fire suppression systems provides reasonable assurance that the systems will remain capable of performing their intended function.

Periodic inspection and testing activities include hydrant and hose station inspections, flushing, flow tests, and spray and sprinkler system inspections. The Fire Water Program is a condition monitoring program, comprised of tests and inspections generally in accordance with NFPA recommendations.

1 )

Following receipt of the renewed license, and prior to the pe iod of extended operation, the Fire Water Program will be enhanced to incor orate prinkler head sampling or replacements, in accordance with NFPA 25, aRd4 either ultrasonic testing or internal visual inspection of representative above ground portions of water suppression piping that are exposed to water-NUREG-1801 Consistency The Fire Water Program is an existing Columbia program that, with enhancement, will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M27, "Fire Water System."

Aging Management Programs Page B-i 11 Januwy 20!0

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-111

, 3) ultrasonic testing of representative portions of water suppression piping that is exposed to flowing water during periodic tests for evidence of erosion, and 4) copper alloy > 15% Zn components exposed to water and visual inspection of a representative sample of same for evidence of cracking.

Aging Management Programs Page B-111 a Amendment 2

Columbia Generating Station License Renewal Application Technical Information Exceptions to NUREG-1801 None.

Required Enhancements Prior to the period of extended operation the enhancements listed below will be implemented in the identified program element:

" Parameters Monitored or Inspected, Detection of Aging Effects -

Perform either ultrasonic testing or internal visual inspection of representative portions of above ground fire protection piping that are exposed to water, but do not normally experience flow, after the issuance of the renewed license, but prior to the end of the current operating term and at reasonable intervals thereafter, based on engineering review of the results.

lInsert A from Page B-1 12a

• Detection of Aging Effects -

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 will reach 50 years of service life during the period of extended operation.

• Acceptance Criteria -

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.

< iocurn.Ilnsert B from Page B-1 12a Operating Experience Water-suppression portions (subsystems) of the Fire Protection System are inspected, tested, and maintained following NFPA recommendations and at the intervals recommended by the corresponding NFPA standards, or as evaluated and adjusted by Columbia.

With one exception (a water hammer event in 1998 that led to a fire protection system valve rupture and subsequent flooding), the water-suppression systems have demonstrated reliable performance with no significant problems in the approximate 20 years since their installation.

The water hammer issue (and valve failure) was not age-related.

The NRC presently conducts triennial fire protection team inspections at the Columbia site to assess whether an adequate fire protection program has been implemented and Aging Management Programs Page B-112 January 20!0

[Amendment 2

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-112 Perform 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, if needed.

Insert B to Page B-1 12 Scope of Program, Detection of Aging Effects -

Perform visual inspection of a representative sample of copper alloy > 15% Zn Fire Protection components exposed to water (with presence of ammonia) for evidence of cracking within the 10-year period prior to entering the period of extended operation, and within 10 years after entering the period of extended operation.

Aging Management Programs Page B-112a Amendment 2 Aging Management Programs Page B-1 12a Amendment 2

Columbia Generating Station License Renewal Application Technical Information B.2.30 Heat Exchangers Inspection Program Description The Heat Exchangers Inspection is a new one-time inspection that will detect and characterize the surface conditions with respect to fouling of heat exchangers and coolers that are in the scope of the inspection and exposed to indoor air or to water with the chemistry controlled by the BWR Water Chemistry Program or the Closed Cooling Water Chemistry Program. The inspection provides direct evidence as to whether, and to what extent, a reduction of heat transfer due to fouling has occurred or is likely to occur on the heat transfer surfaces of heat exchangers and coolers.

Implementation of the Heat Exchangers Inspection will provide assurance (and confirmation) that the heat transfer capabilities of heat exchangers and coolers in the scope of the inspection will be maintained consistent with the current licensing basis during the period of extended operation.

NUREG-1801 Consistency The Heat Exchangers Inspection is a new one-time inspection for Columbia that will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.M32, "One-Time Inspection."

Exceptions to NUREG-1801 None.

Aging Management Program Elements The results of an evaluation of each program element are provided below.

Scope of Program The scope of the Heat Exchangers Inspection includes measures to verify that unacceptable reduction in heat transfer is not occurring for the stainless steel and copper alloy heat transfer surfaces of the following heat exchangers and coolers that are in the scope of license renewal, but are not cooled by raw water:

Diesel Cooling Water (DCW) lube oil coolers and jacket water heat exchangers Diesel (Engine) Exhaust (DE) turbocharger aftercooler Diesel Lubricating Oil (DLO) lube oil cooler Fire Protection (FP) carbon dioxide Fuel Pool Cooling (FPC) heat exchangers (C0 2) condenser and heat exchanger Reactor Core Isolation Cooling (RCIC) lube oil cooler Aging Management Programs Page B-124 jamnden 2...

Columbia Generating Station License Renewal Application Technical Information minor cracking of concrete damwork around the intake bays. No condition was deemed to require immediate or long-term resolution.

Minor "cosmetic" imperfections with the concrete (blemishes, cure voids, surface cracks, etc.) were noted.

These minor imperfections will continue to be monitored, but they currently pose no concern to the structural condition of the area.

The Water Control Structures Inspection, implemented as part of the Structures Monitoring Program, provides reasonable assurance that aging effects are being managed for Columbia's water control structures. This has been demonstrated through inspection reports, program health reports, and the corrective action program.

The site corrective action program and ongoing review of industry operating experience will be used to ensure that the program continues to be effective in managing the identified aging effects.

Conclusion The Water Control Structures Inspection with enhancements, as part of the Structures Monitoring Program, will be capable of detecting and managing aging effects for structures within the scope of license renewal. The continued implementation of the Water Control Structures Inspection, with the required enhancements, provides reasonable assurance that the effects of aging will be managed so that components subject to aging management review will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

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\\,l1nsert: A from Pages 208ato28 Aging Management Programs Page B-208 JetwFy 20.1-.

[Amendment:2

Columbia Generating Station License Renewal Application Technical Information Insert A to Pa-ge B-208 B.2.54 Boron Carbide Monitoring Program Program Description The Boron Carbide Monitoring Program is an existing plant-specific aging management program. The Boron Carbide Monitoring Program provides reasonable assurance that potentially detrimental aging effects will be adequately detected such that the neutron absorber's intended function is maintained consistent with the current licensing basis for the period of extended operation.

NUREG-1801 Consistency The Boron Carbide Monitoring Program is an existing Columbia program, that is plant-specific. There is no corresponding aging management program described in NUREG 1801.

Aging Management Program Elements The results of an evaluation of each program element are provided below.

Scope of Program:

The Boron Carbide Monitoring Program detects degradation of Boron Carbide (B4C) neutron absorbers in the spent fuel storage racks by monitoring spent fuel racks for potential off-gassing and B4C coupon inspection. From the monitoring data, the stability and integrity of Boron Carbide in the storage cells are assessed. Periodic monitoring of B4C samples permits early determination of aging degradation. Adverse conditions will be documented in the Corrective,"

Action Program.

Preventive Actions:

The program is a condition monitoring program that does not include preventive actions. No actions are taken as part of the Boron Carbide Monitoring Program to prevent aging effects or mitigate age-related degradation.

Parameters Monitored/Inspected:

Monitoring of B4C samples for signs of physical and/or chemical degradation.

These actions ensure that degradation of the neutron-absorbing material is identified and corrected so that the spent fuel storage racks will be capable of performing their intended functions during the period of extended operation, consistent with current licensing basis (CLB) design conditions.

The parameters include the physical, mechanical and chemical conditions of the B4C coupons and swelling of the spent fuel racks. The spent fuel racks are vented periodically for the monitoring of potential off-gassing based on industry Aging Management Programs Page 208a Amendment 2

Columbia Generating Station License Renewal Application Technical Information operating experience. A visual examination of the B4C sample coupons is made to evaluate surface appearance, size, shape and color. Mechanical testing of B4C samples is done on a periodic basis to determine if physical degradation is occurring in the plate material. In addition, chemical testing will take place on a periodic basis to determine if leaching of the boron content is occurring.

Detection of Aging Effects:

The amount of boron loss from the B4C panels is determined through measurement of the boron areal density in the coupons. Visual inspections and measurements, as appropriate, are used to determine and assess the extent of degradation in the Boron Carbide before there is a loss of intended function. This can be supplemented with verification of boron loss in the spent fuel racks through areal density measurement techniques such as the (Boron-10 Areal Density Gage for Evaluating Racks) BADGER device.

Monitoring and Trending:

The periodic inspection measurements and analysis are to be compared to values of previous measurements and analysis to provide a continuing level of data for trend analysis. Also, studies by other utilities using similar B4C material for high density spent fuel racks will be monitored for information.

Acceptance Criteria:

The 5% subcriticality margin of the spent fuel racks is to be maintained for the period of extended operation. Corrective actions are initiated if the test results find that the 5% subcriticality margin cannot be maintained because of the current or projected future degradation. The fuel rack loading pattern will be determined by Reactor Engineering and one or more samples will be analyzed for B-1 0 content. If data continues to suggest less than 5% subcriticality, then blackness testing such as BADGER testing may be performed on the racks as a result of corrective action performed.

Corrective Actions:

This element is common to Columbia programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3.

Aging Management Programs Page 208b Amendment 2 v

Columbia Generating Station License Renewal Application Technical Information Confirmation Process:

This element is common to Columbia programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3.

Administrative Controls:

This element is common to Columbia programs and activities that are credited with aging management during the period of extended operation and is discussed in LRA Section B.1.3.

Operating Experience:

The Boron Carbide Monitoring Program is an existing aging management program proposed for the period of extended operation. A review of the Corrective Action Program did not identify instances of Boron Carbide aging at Columbia. Coupon samples have been analyzed and there has been no indication of boron carbide deterioration or loss of boron.

In 1980, LER 50-305/80-039 indicated that another operating plant had problems with off-gassing of the binder material in their B4C SFP racks. During surveillance of SFP rack samples, two sealed specimens exhibited swelling. This swelling was likewise found to be occurring in the fuel racks. The swelling in the spent fuel canister walls reduces the separation (water gap) between canisters. It appears that the bulging of the SFP canisters and specimens is the result of a gaseous product of radiolysis of materials used in the boron carbide plate. This LER indicated that this swelling of sealed B4C canisters happened at another facility. Maximum Keff allowed for the spent fuel pool has not been exceeded.

To prevent distortion of the spent fuel pool rack cavities and binding of spent fuel pool assemblies due to pressure buildup, the Spent Fuel Rack enclosures at Columbia are vented through an arrangement of tubing and sampling valves to above storage pool water surface at the pool curb. Monitoring of gas pressure and venting to relieve pressure are provided for in the plant's work management system.

In 1999, a condition report documented that water was noticed flowing in the vent line while venting the Spent Fuel Racks. The valve was immediately closed and Reactor Engineering was notified. The Tech noted that less than 1/4 cup of water was ejected from the line then the rest of the venting was as normal. Although the racks are designed to be sealed and vented, the presence of water indicates that the rack or the vent line is not water tight. The presence of water in the rack will not affect the neutron absorption characteristics of the boron carbide plates.

There are coupons in the pool that have vented (to the water) plates and one of the coupons was delivered to a testing lab in 1995 and it was determined that there was no depletion of the wetted coupons with respect to the control coupons.

Aging Management Programs Page 208c Amendment 2 Aging Management Programs Page 208c Amendment 2

Columbia Generating Station License Renewal Application Technical Information In October 2009, NRC issued Information Notice (IN) 2009-26 which provides industry operating experience on the degradation of neutron absorbing materials in spent fuel pools. IN 2009-26 addressed issues of degradation of the Carborundum Boron Carbide (B4C) neutron-absorbing materials and the deformation of Boral panels in spent fuel pools. The operating experience on degradation of B4C may be applicable to Columbia. Palisades determined that the apparent cause of the degradation of the Carborundum B4C plates was the environment of the SFP. The exact degradation mechanism or mechanisms are not clearly understood but likely involve changes in the physical properties of the Carborundum B4C plates that occur during prolonged exposure to the SFP environment. The swelling of the racks, which prevents fuel assemblies from being inserted or removed, indicates a potential problem with neutron-absorbing capacity. The-swelling in the racks could result from dimensional changes of the Carborundum, which may be replaced by a gas-filled space, and could challenge the assumptions of the criticality analysis. This unknown impact on the criticality analysis led the licensee to perform BADGER testing of the racks and discover the Carborundum degradation. This degradation may have been occurring as early as 1988 when the first impedance to inserting a fuel assembly was documented at Palisades. Since there was no surveillance of the neutron-absorbing capacity of the material, the start of the degradation and the degradation rate are unknown.

Based on the Palisades operating experience, the conditions noted at Palisades were not found. Conditions similar to those found at Palisades are not expected to occur with the Columbia spent fuel storage racks, since the B4C neutron absorbers used in the spent fuel storage racks at Columbia were manufactured by ESK, while the Palisades B4C neutron absorbers were manufactured by Carborundum, and there is no industry OE to indicate that B4C manufactured by ESK has degraded. Columbia's B4C testing results and have not indicated degradation of the surface condition or B4C areal density.

In May 2010, the NRC issued License Renewal Interim Staff Guidance LR-ISG-2009 01, "Aging Management of Spent Fuel Pool Neutron-Absorbing Materials other than Boraflex," providing guidance as to one acceptable approach for managing the effects of aging during the period of extended operation for neutron-absorber material in spent fuel pools within the scope of the License Renewal Rule. Recent operating experience has documented several instances of degradation and deformation of the neutron-absorber materials in the spent fuel pools of operating reactors, as described in IN 2009 26. LR-ISG-2009-01 highlighted that a plant-specific AMP should be submitted that addresses neutron-absorber material in order to detect and mitigate the aging of the material that could impact the neutron-absorbing function during the period of extended operation. The applicant should consider both plant-specific and industry operating experience.

Required Enhancement:

None

==

Conclusion:==

Aging Management Programs Page 208d Amendment 2

Columbia Generating Station License Renewal Application Technical Information The plant-specific Boron Carbide Monitoring Program will provide reasonable assurance that potentially detrimental aging effects will be adequately detected such that the Boron Carbide neutron absorber intended functions will be maintained consistent with the current licensing basis for the period of extended operation.

Aging Management Programs Page 208e Amendment 2 Aging Management Programs Page 208e Amendment 2

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 New and Revised Boundary Drawings Drawing Number Reason RAI Number LR-M515-1 Revised RAI 2.3.3.22-1 LR-M515-1 Revised RAI 2.3.3.22-2 LR-M515-1 Revised RAI 2.3.3.22-4 LR-M515-2 Revised RAI 2.3.3.22-4 LR-M515-3 New drawing RAI 2.3.3.22-6 LR-M515-3 New drawing RAI B.2.25-4 LR-M515-4 Revised RAI 2.3.3.22-4 LR-M515-5 Revised RAI 2.3.3.22-4 LR-M573-2 Revised RAI 2.3.3.22-2 LR-M573-2 Revised RAI 2.3.3.22-5 LR-02H13-05,221,2 New drawing RAI 2.3.3.22-7 LR-02H 13-05,221,2A New drawing RAI 2.3.3.22-7 LR-02H13-05,250,1 New drawing RAI 2.3.3.22-7

The 27 subsequently listed drawings/figures have been processed into ADAMS.

These drawings can be accessed within the ADAMS package or by performing a search on the Document/Report Number.