ML102450621

Summary of Telephone Conference Call Held on August 26, 2010, Between the U.S. NRC and Energy Northwest, Concerning the Request for Additional Information Pertaining to the Columbia Generating Station, License Renewal Application

ML102450621
Person / Time
Site:	Columbia
Issue date:	09/14/2010
From:	Gettys E License Renewal Projects Branch 1
To:	Energy Northwest
Evelyn Gettys, NRR/DLR/RPB1, 415-4029
References
TAC ME3058
Download: ML102450621 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 14,2010 LICENSEE: Energy Northwest FACILITY: Columbia Generating Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON AUGUST 26, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENERGY NORTHWEST, CONCERNING THE REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. ME3058)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Energy Northwest (EN), held a telephone conference call on August 26, 2010, to discuss and clarify the NRC's request for additional information (RAJ) concerning the Columbia Generating Station, license renewal application (LRA). The telephone conference call was useful in clarifying the intent of the staff's RAls. provides a listing of the participants and Enclosure 2 contains a listing of the D-RAls discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

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

Enclosure:

As stated cc w/encls: Distribution via Listserv

TELEPHONE CONFERENCE CALL COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS August 26,2010 PARTICIPANTS AFFILIATIONS Evelyn Gettys U.S. Nuclear Regulatory Commission (NRC)

Michelle Kichline NRC Bill Holston NRC Dwight Diercks Argonne National Lab (NRC contactor)

Abbas Mostala Energy Northwest (EN)

Marsha Eades EN John Twomey EN Janet Worthington EN ENCLOSURE 1

TELEPHONE CONFERENCE CALL COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION August 26, 2010 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Energy Northwest, held a telephone conference call on August 26, 2010 to discuss and clarify the following requests for additional information (RAls) concerning the Columbia Generating Station, license renewal application (LRA).

External Surfaces Monitoring Program RAI B.2.23-1

Background:

The GALL AMP XI.M36 recommends managing aging effects of steel through visual inspections. Based on observable degradation byproducts intrinsic to steel, the GALL AMP states that "visual inspections are expected to identify loss of material due to general corrosion in accessible steel components. Loss of material due to pitting and crevice corrosion may not be detectable through these same visual inspections, however, general corrosion is expected to be present and detectable such that, should pitting and crevice corrosion exist, general corrosion will manifest itself as visible rust or rust byproducts (e.g., discoloration or coating degradation) and be detectable prior to any loss of intended function." However, within the LRA the applicant has included aluminum, copper, copper alloy (>15% Zn), grey cast iron, elastomers sealants and flexible connections in the heating, ventilation, and air conditioning (HVAC) system and stainless steel within the scope of this aging management program (AMP).

Issue:

The LRA program includes materials not considered by the GALL Report for aging management by this program. Thus the LRA AMP is inconsistent with the GALL Report. Staff notes that the LRA describes the AMP as consistent with the GALL Report with enhancements. However, guidance provided in the SRP-LR describes enhancements as additions to existing AMPs needed to ensure consistency with the GALL Report recommendations, and when describing exceptions it states that any deviations should be described and justified. Further, in LRA Section B.1.2 the applicant describes exceptions to the GALL Report as necessary when the elements of the Columbia program are different from the GALL Report program elements.

Question:

Provide a basis for not taking an exception to the GALL Report in the External Surfaces Monitoring Program for managing aging of aluminum, copper, copper alloy (>15% Zn), grey cast iron, elastomers sealants and flexible connections in the HVAC system and stainless steel within the scope of this AMP.

ENCLOSURE 2

-2 RAI 8.2.23-2 Discussion: The staff is removing this RAI on External Surfaces Monitoring Program. The applicant does not have to respond to this RAI from letter (ML101720623) dated June 30,2010.

Background:

The GALL AMP XI.M36 recommends managing the aging effects of loss of material from general corrosion, pitting and crevice corrosion. Based on observable degradation byproducts intrinsic to steel, the GALL AMP states that "visual inspections are expected to identify loss of material due to general corrosion in accessible steel components. Loss of material due to pitting and crevice corrosion may not be detectable through these same visual inspections, however, general corrosion is expected to be present and detectable such that, should pitting and crevice corrosion exist, general corrosion will manifest itself as visible rust or rust byproducts (e.g., discoloration or coating degradation) and be detectable prior to any loss of intended function." However, within the LRA, the applicant has included management of cracking of aluminum and stainless steel; and hardening and loss of strength of elastomer sealants and flexible connections in HVAC systems.

Issue:

The LRA program includes management of aging effects not considered by the GALL Report for aging management by this program. Thus the LRA AMP is inconsistent with the GALL Report.

Staff notes that the LRA describes the AMP as consistent with the GALL Report with enhancements. However, guidance provided in the SRP-LR describes enhancements as additions to existing aging management programs needed to ensure consistency with the GALL Report recommendations, and when describing exceptions it states that any deviations should be described and justified. Further, in LRA Section B.1.2, the applicant describes exceptions to the GALL Report as necessary when the elements of the Columbia program are different from the GALL Report program elements.

Question:

Provide a basis for not taking an exception to the GALL Report in the External Surfaces Monitoring Program for including the aging management of cracking.

Discussion: The staff is removing this RAI on External Surfaces Monitoring Program. The applicant does not have to respond to this RAI from letter (ML101720623) dated June 30, 2010.

D-RAI 3.4.2.3-1

Background:

In LRA Table 3.4.2-3, row number 33, the applicant proposes to manage loss of material for the external surfaces of steel piping exposed to uncontrolled indoor air using its Buried Piping and Tanks Inspection Program. The applicant cites plant-specific note 0408 which states that the carbon steel piping from the CST is buried and is enclosed in guard pipe. The applicant also cites generic note E and line item 3.4.1-28. The GALL Report recommends GALL AMP XI. 36 "External Surfaces Monitoring" to ensure that these aging effects are adequately managed.

-3 Issue:

The staff notes that GALL AMP XI.36 "External Surfaces Monitoring" recommends periodic direct visual inspections of the surfaces managed by the program. The staff also notes that the applicant's Buried Piping and Tanks Inspection Program provides for visual inspections of the external surfaces of buried piping and tanks to determine coating integrity, but does not include access to or direct inspection of the external surfaces of buried pipe enclosed in an outer guard pipe. The staff further notes that the applicant's Buried Piping and Tanks Inspection Program does not include flow testing, pressure testing, or any other means to manage aging for piping within a guard pipe. It is unclear to the staff how the buried piping within a guard pipe will be adequately managed by the Buried Piping and Tanks Inspection Program.

Request:

Explain how the external surface of buried piping enclosed in an outer guard pipe will be adequately managed for loss of material.

Discussion: The staff discussed with the applicant details that described the guard pipe, the internal pipe and the route of the pipe.

'.. ML102450621 OFFICE PM:RPB1 :DLR LA:DLR BC: RPB1:DLR NAME EGettys YEdmonds BPham DATE 9/10/10 9/10/10 9/14/10

Memorandum to Energy Northwest from E. Gettys dated September 14. 2010.

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON AUGUST 26, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENERGY NORTHWEST, CONCERNING THE REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. ME3058)

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