ML102520048

Response to Requests for Additional Information on License Renewal Application

ML102520048
Person / Time
Site:	Columbia
Issue date:	09/03/2010
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G02-10-128
Download: ML102520048 (34)

Text

Sudesh K. Gambhir ENERGY Vice President, Technical Services P.O. Box 968, Mail Drop PE04 NORTHWEST Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@energy-northwest.com September 3, 2010 G02-10-128 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION

References:

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

2) Letter dated July 7, 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. ML101730468)

Dear Sir or Madam:

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

Transmitted herewith in the Attachment to this letter is the Energy Northwest response to a Request for Additional Information (RAI) contained in Reference 2.

One new commitment is included in this response. Two commitments in Table A-i, items 50 and 53 are being revised, and are included in Amendment 4, in the enclosure to this letter. If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.

A0351~

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, SK Gambhir Vice President, Technical Services : Response to Request for Additional Information : Commitment

Enclosure:

License Renewal Application Amendment 4 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EJ Leeds - NRC NRR EFSEC Manager RN Sherman - BPA/1 399 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 22 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"

(ADAMS Accession No. ML101730468)

RAI B.2.34-1

Background:

Generic Aging Lessons Learned (GALL) Report, AMP XI.S1, "ASME Section XI, Subsection IWE," Program Element 10, "operating experience," states that implementation of ASME Section XI, Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

Issue:

Program Element 10 for the Columbia Generating Station (CGS) ASME Section XI, Subsection IWE aging management program (AMP) states that CGS has committed to monitor humidity levels in the sand pocket region and that a procedure to survey the relative humidity of air drawn from within the containment annulus sand pocket region has been implemented. This issue is also discussed in the Aging Management Program Evaluation Results, Inservice Inspection (ISI) Program - IWE, LRPD-05, Attachment 3.2, Revision 3, which references PPM Number: 10.24.206, Containment Annulus Sand Pocket Humidity Measurement [Reference IWE.12].

Section 6 in PPM Number: 10.24.206 defines the acceptance criteria as follows:

The acceptance criteria for this procedure is that Table 7.9a of Section 7.9 is complete and signed by Systems Engineering Staff and the Systems Engineering Manager or designee, indicating a review of test data was determined acceptable.

Procedure PPM Number: 10.24.206 does not address the following issues.

• acceptance criteria for humidity level values including limits of acceptability used by System Engineering to determine if test data are acceptable

• procedures that are followed when humidity level values do not meet acceptance criteria

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 22

• the frequency that humidity measurement data are acquired at each of the eight drain lines

" other tests, measurements, or corrective actions to be performed when humidity level values do not meet acceptance criteria In addition, page 5 of enclosure 2 to the letter from B. Benney, NRC to J. V.

Parrish, Energy Northwest,

Subject:

Columbia Generating Station - Issuance of Amendment RE: One-time Extension of Appendix J Type A Integrated Leakage Rate Test Interval (TAC No. MC3942) dated April 12, 2005, includes the following statement.

From the data reviewed, the worst case (maximum) dew point temperature of the sand pocket air was about 54 degrees Fahrenheit.

The temperature of the containment shell in the sand pocket area is essentially the same temperature as the suppression pool water. The suppression pool water temperature is normally maintained above 54 degrees Fahrenheit.

These data indicate that the relative humidity in the sand pocket area could be as high as 100% under certain operating conditions. Humidity of this magnitude could cause general corrosion of the outside surface of the metal containment shell in the sand pocket area.

Request:

The applicant is requested to provide details of its humidity monitoring program including the acquisition frequency of humidity measurement data, limits of acceptability for humidity level values, and follow-up actions that the applicant will take when humidity levels exceed the acceptance criteria. In addition, the applicant is requested to explain how humidity measurements acquired before and after refueling demonstrate that there is no water in the sand pocket area since it will take some time for the water to flow through the flexible urethane foam sheets located between bio-shield wall and steel containment and affect the humidity of the sand pocket region. The applicant is also requested to describe potential aging effects including loss of material resulting from exposure of the metal containment shell to humidity levels that are measured during the plant outages.

Energy Northwest Response:

Humidity monitoring of the sand pocket region is performed in accordance with plant procedure PPM 10.24.206, "Containment Annulus Sand Pocket Humidity Measurement" under periodic preventative maintenance (PM) tasks. These PM tasks are performed on a two year cycle to coincide with the Columbia Generating

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 22 Station (Columbia) two year refueling cycle as noted in section 4.3 of PPM 10.24.206 and by the frequency code (A02) assigned to each task.

Section 6.0 of PPM 10.24.206 states that the test data is to be reviewed by Systems Engineering staff and manager for acceptability. This procedure does not provide any specific acceptance criteria for humidity level. The basis for acceptability is contained in section 4.3 of the procedure which provides the precaution that abnormally high humidity level could indicate water is being introduced into the containment annulus from a leak in the bellows seal or drain lines in the refueling pool. What is considered 'abnormally high' is left up to the judgment of the system engineer and manager. However, any humidity levels that would be determined to be abnormally high would be documented using Columbia's corrective action process (CAP). The CAP assigns each employee the responsibility to identify any issue or condition that doesn't look as if it is right. At such time follow-up actions would be developed and documented as corrective actions. Energy Northwest recognizes this potential procedure weakness and has initiated a condition report under the corrective action process to provide more definitive acceptance criteria.

As per the letter referenced in the 'Issue' discussion above (ML050620553), the NRC staff concluded that this action in conjunction with the monthly surveillances of the sand pocket drains discussed below are acceptable for monitoring for potential leakage between the containment vessel and biological shield wall and alerting the licensee of potential degradation of the primary containment vessel.

The humidity in the sand pocket area is measured prior to reactor cavity flood-up and after reactor cavity drain-down to ensure water has not been introduced into the sand pocket area during refueling activities. This is a commitment made by Energy Northwest to the NRC in response to GL 87-05 in a letter dated February 8, 1988, GC Sorensen (Energy Northwest) to NRC, "Response to Generic Letter 87-05." The construction of the containment at Columbia utilized a polyurethane foam material in the annulus between the biological shield wall and primary containment vessel.

Energy Northwest agrees this method of construction would inhibit, if not prevent, the free flow of moisture to the sand pocket regions and drain lines from the refueling bellows area. However, an abnormally high differential in the flood-up and drain down humidity readings would be indicative of moisture being introduced into the annulus area between the containment vessel and biological shield wall. This moisture could be from a significant leak in the outer refueling bellows seal, drain lines from the reactor pool cavity or a through-wall leak in the containment shell below the suppression pool water level. Additionally, the sand pocket drains are checked monthly (28 day frequency) for the presence of water. This was also a commitment to the NRC in response to GL 87-05 and provides additional monitoring for potential leakage in the annulus area and a forewarning of potential degradation of the containment vessel. No water has been documented to date as being found during the drain line surveillances, but such a discovery would warrant being

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 22 documented and addressed under the Columbia CAP. Energy Northwest successfully performed the primary containment Integrated Leak Rate Test (ILRT) during the most recent refueling outage (R19) in 2009. Successful completion of this test and absence of any water in the sand pocket region provides evidence of the structural integrity of Columbia's containment as concluded by the NRC staff in the letter dated April 12, 2005, NRC to JV Parrish, Energy Northwest, "Issuance of Amendment RE: One-Time Extension of Appendix J Type A Integrated Leakage Rate Test Interval (TAC No. MC3942)" (ML050620553).

The stress analysis performed for Columbia assumed a reduction in the thickness of the vessel plate of 1/16" from actual design thickness in accordance with the Pittsburgh-Des Moines Steel Company (PDM) vessel stress report and the design specification as a 'metal allowance'. This metal allowance provides a corrosion tolerance of 62.5 mils. Based on plant specific corrosion rates for carbon steel exposed to raw water (i.e., SW piping) the maximum average corrosion rate is 1.5 mils per year (mpy). Therefore, a corrosion rate of 1.5 mpy will be assumed for the containment steel plate in the sand pocket region. This is conservative as the plate is not continuously wetted based on the results of the monthly surveillances on the sand pocket drains not finding any water. The resultant loss of material extrapolated out for 60 years will be 90 mils (1.5 x 60). A review of the stress report for the containment vessel found that for the worst case stresses there is at least about a 1.9% margin between actual and allowable stress. This worst case stress case does not occur in the vessel plate material in the sand pocket region, but will be used as the bounding condition for added conservatism. This 1.9% margin when applied to the thickness of the plate in the sand pocket region will result in a corrosion allowance of approximately 27.5 mils [0.019 x (1-1/2"- 1/16")]. The total corrosion allowance will be the 62.5 mils provided by original design methodology and the 27.5 mils per this design.margin for a total of 90 mils. Thus, assuming 100%

humidity in the sand pocket region the project total corrosion for 60 years would be 90 mils which is equal to the 90 mil corrosion allowance documented above. This is a conservative estimation as the projected corrosion assumes the sand pocket region contains moisture at all times during the 60 years and would not credit the insoluble corrosion product layer that would form on the steel plate that is a characteristic of uniform corrosion on carbon steel surfaces. Therefore, though the humidity checks performed before and after Columbia's outages may not provide immediate evidence of any potential leaks during reactor cavity flooding there is sufficient corrosion allowance inherent to the design of the containment vessel to ensure the containment vessel maintains its integrity under a 100% humidity (treated water) environment in the sand pocket region.

LRA Table 3.5.1, line item 3.5.1-05 and LRA section 3.5.2.2.1.4 discuss potential aging effects for the metal containment shell exposed to high humidity levels which include loss of material due to general, pitting and crevice corrosion.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 22 RAI B.2.34-2

Background:

GALL Report, AMP XI.S1, "ASME Section XI, Subsection IWE," Program Element 1, "scope of program," states that ASME Section XI, Subsection IWE-1 000 specifies the components of steel containments and steel liners of concrete containments within its scope.

Issue:

Program Element 1 of the CGS ISI Program-IWE includes examination of pressure-retaining bolting within its scope. In addition, the GALL AMP XI.M18, Bolting Integrity aging management program follows information as delineated in NUREG-1339, published EPRI NP-5769 guidelines, and industry recommendations.

NUREG-1 339 recommends inspections for stress corrosion cracking (SCC) to prevent or mitigate degradation and failure of structural bolts with actual yield strength greater than 150,000 pounds per square inch.

Request:

Describe the methods that CGS is implementing to examine pressure-retaining bolting including structural bolts with actual yield strength greater than 150,000 pounds per square inch.

Energy Northwest Response:

The scope of the ISI-IWE program at Columbia is visual examination of all accessible surface areas of the steel containment and its integral attachments and containment pressure-retaining bolting regardless of bolt material or properties (yield strength).

Similar information regarding bolting materials within the scope of the Bolting Integrity Program was requested in the request for additional information (RAI)

B.2.4-5 (structural) and RAI B.2.4-6 (mechanical) in the 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). The response to those requests was provided in Attachment 3 of letter, G02-10-117, dated August 19, 2010, SK Gambhir (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application. See responses to these RAIs for more detailed information.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 22 The response to the RAIs noted that Energy Northwest made no attempt to distinguish the yield strength (minimum or actual) of bolting material, but rather assumed:

" Class I bolting (mechanical) was susceptible to SCC, and

• All the parameters required for SSC to occur in high strength material for bolting (structural) are not present at Columbia.

RAI B.2.34-3

Background:

GALL Report, AMP XI.S1, "ASME Section XI, Subsection IWE," Program Element 10, "operating experience," states that implementation of ASME Section XI, Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

Issue:

Program Element 10 of the CGS ISI Program - IWE states that "suppression pool wetted surfaces of the submerged area were examined and found acceptable."

However, the applicant did not indicate whether or not repairs to the drywell shell coating or the moisture barrier were performed to achieve compliance with ASME Section XI, Subsection IWE requirements. The applicant also reported in the Containment Visual Examination Data Sheet, Report No. 3COV-26, dated June 12, 2009, the following statement:

All coated surfaces exhibited a light dusting on all surfaces, which was removed prior to the VT-3 examination. It is recommended that a complete wetwell desludge be performed prior to the next VT-3 examination on the bottom head moisture barrier.

Note 3 for ASME Section XI, Subsection IWE, Table IWE-2500-1 states that examination shall include moisture barrier materials intended to prevent intrusion of moisture against inaccessible areas of the pressure retaining metal containment shell or liner at concrete-to-metal interfaces and at metal-to-metal interfaces which are not seal-welded. Containment moisture barrier materials include caulking, flashing, and other sealants used for this application.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 22 Request:

The applicant is requested to provide the inspection frequency for the accessible coated wetwell metal shell surface and the moisture barrier inside the wetwell at the concrete-to-metal interface. In addition, provide the details and number of all coating degradations in the drywell and wetwell, and degradation of the wetwell moisture barrier observed during the previous IWE inspections. The applicant is requested to describe how VT-3 examination of the moisture barrier and steel containment is performed without removing the sludge from the inspected surfaces.

Energy Northwest Response:

Frequency: In accordance with ASME Section XI, Article IWE-2000, 2001 Edition, 2003 Addend, section IWE-2412, "Inspection Program B," Table IWE-2412-1, the frequency of the inspection periods within the 10 year inspection interval are within 3, 7 and 10 calendar years of plant service for Columbia. Energy Northwest visually inspects the accessible wetwell metal shell surface and moisture barrier per the requirements of ASME Section XI, Table IWE-2500-1. The accessible metal shell surfaces and the moisture barrier at the concrete-to-metal interface are inspected during each of the three inspection periods within the 10 year inspection interval.

The submerged area is inspected once during the 10 year inspection interval.

Material condition: During the IWE inspections of the submerged area and the moisture barrier conducted during the 2009 refueling outage (R-1 9), no degradation of the moisture barrier or submerged wetwell shell were identified. The IWE inspections of the accessible surface area (drywell shell and wetwell above the water line) were not performed during the R19. The inspections were performed during the refueling outage in 2007 (R1 8). The examiner found a hanger pad weld with corrosion on the drywell shell near the 520' elevation. There was no evidence of corrosion on the drywell shell. The weld was cleaned and inspected again, before coating. No indications were found on the wetwell shell, above the water line.

Coatings: The drywell shell coating was examined in accordance with the Energy Northwest coatings program during R19. The drywell shell coating degradations identified during that examination are summarized in the following table.

Location Azimuth/Elevation (Degrees/feet) Description 195/501 Localized epoxy coating is peeling away from substrate.

265/501 Hanger plate to shell weld has rust grade 0.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 22 VT-3 Examination: The VT-3 examinations are performed in accordance with plant procedures by certified VT-3 examiners. The procedures and the certification are in accordance with ASME Section Xl. The VT-3 examiner makes an assessment of the target surface at the time of the examination to determine if the VT-3 examination can be performed. If the surface is obstructed so that an adequate examination can not be performed, the examiner cleans the surface or has it cleaned. In the example stated above under "Issue," the examiner found the initial surface condition unacceptable and removed the obstructing material prior to performing the examination. The examination was performed after the sludge was removed from the surface, as required in the procedure. Therefore, neither the inspection in question, nor are other inspections, performed on unacceptably obstructed surfaces.

RAI B.2.35-1

Background:

GALL Report, AMP XI.S3, "ASME Section XI, Subsection IWF," Program Element 1, "scope of program," imposes ISI requirements for Class 1,2, 3, and MC piping and components and their associated supports.

Issue:

Program Element 1 for the CGS ISI Program-IWF aging management program states that the scope of the IWF program includes ASME Class 1, 2, and 3 piping supports and supports other than piping supports (Class 1, 2, 3, and MC). In LRPD-05, Attachment 3.3, Revision 3, Reference IWF.4, the applicant states that "one component in each multiple component group" is selected for examination.

However, Note 3 for Table IWF-2500-1 in ASME Section XI, Subsection IWF states that for multiple components other than piping, within a system of similar design, function, and service, the support of only one of the multiple components are required to be examined.

Request:

The applicant is requested to describe the criteria used to select components for examination under its ISI Program-IWF aging management program and to ensure consistency-with component selection requirements in ASME Section XI, SubsectionIWF, Table IWF-2500-1.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 22 Enerav Northwest Response:

Energy Northwest is required to comply with 10 CFR 50.55a and, as specified in plant procedures, the applicable ASME Boiler and Pressure Vessel Code Section Xl for the third inservice inspection interval at Columbia Generating Station (Columbia) is the 2001 Edition, 2003 Addenda. Energy Northwest selects supports for examination in accordance with ASME Section XI, Subsection IWF, Table IWF-2500-1 (including the notes). In accordance with Note 3 of the table, for components other than piping, components are grouped by component type. Within each component type group, a single component is selected for examination and all supports for that single component are examined. Energy Northwest also complies with the extent and examinations specified in the table.

RAI B.2.35-2

Background:

GALL Report, AMP XI.S3, "ASME Section Xl, Subsection IWF," Program Element 10 "operating experience," states that implementation of ASME Section Xl, Subsection IWF, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

Issue:

Program Element 10 for the CGS ISI Program-IWF AMP states the following: "The Inservice Inspection (ISI) Program - IWF will be capable of detecting and managing loss of material and cracking for ASME Class 1, 2, and 3 component supports."

However, during the onsite audit walkdown, the staff observed evidence of loss of material due to corrosion in the above-water portions of structural steel supports for the spray pond ring header.

Request:

The applicant is requested to describe the inspection frequency and details of the supplemental examinations required in accordance IWF-3200 for the above-water and below-water portions of the structural steel supports for the spray pond ring header. The applicant is also requested to describe the methods used to protect the steel from corrosion, the process used to verify that the corrosion mitigation measures are effective, and the criteria used to initiate the corrective actions program.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 22 Energy Northwest Response:

Frequency: No inspection frequency is specified when applying supplemental examinations per IWF-3200. When visual examinations detect conditions in the structural steel supports of the service water pond spray ring header requiring evaluation, Energy Northwest may supplement these examinations with other examination methods to determine the characteristic of the flaw. Since the supports are initially examined using a visual examination method, supplement examinations, if needed, would be performed by either or both the surface and volumetric methods.

Protection: The structural steel supports of the spray ring header are protected from corrosion by coating the structure and the operation of an anode protective system.

Corrosion migration: The effectiveness of the corrosion protection system is assessed periodically by performing above-water and below-water visual inspections of the structural supports. Additionally, the operation of the anode protective system is verified periodically.

Criteria: The criterion to initiate the CAP, in accordance with plant procedures, is, "Identify any issue or condition that doesn't look as if it is right using the AR-CR process."

RAI B.2.50-1

Background:

The GALL Report XI.S6, "Structures Monitoring Program," notes that for each structure/aging effect combination, the specific parameters monitored or inspected are selected to ensure that aging degradation leading to loss of intended functions will be detected and the extent of degradation determined. Parameters monitored are to be commensurate with industry codes, standards, and guidelines.

ACI 349.3R-96 and ANSI/ASCE 11-90 provide an acceptable basis for selection of parameters to be monitored or inspected for concrete and steel structural components and for steel liners, joints, coatings, and waterproofing membranes.

Issue:

Program Element 3, "parameters monitored or inspected," incorporates provisions for increased monitoring described in RG 1.160. This includes clarifications under Paragraph (a)(1) of 10 CFR 50.65 and includes additional degradation-specific condition monitoring and increased frequency of assessments until ongoing corrective actions are complete and functional performance is assured. The Structures Monitoring Program identifies a recommendation to list ACI 349.3R-96

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 22 and ANSI/ASCE 11-90 as references to indicate that they provide guidance for selection of parameters monitored or inspected. The listing of these documents is provided as a recommended enhancement. The staff is unclear if the recommended enhancements are required to meet GALL criteria or if CGS will commit to the recommended enhancements prior to the period of extended operation. The staff believes recommended enhancements listed in Section 3.2 of LRPD-05, Attachment 3.4, Revision 3 of AMP B.2.50, Structures Monitoring Program should be included in the scope of the program.

Request:

a) Provide information to clarify the distinction between recommended enhancements and in particular describe the criteria that will be used to determine if recommendations will be implemented, b) Specify whether the recommended enhancements are required to meet or exceed GALL provisions (e.g., adoption of ACI 349.3R-96 acceptance criteria), and c) Identify whether CGS will commit to the recommended enhancements prior to the period of extended operation or, if a commitment will not be made to all recommended enhancements, identify which recommended enhancements will be adopted in each of the aging management programs.

Energy Northwest Response:

a) As per the definition in LRA section B.1.2 of the application, a 'required enhancement' is an enhancement to an existing program necessary to ensure consistency with NUREG-1 801 or to expand the scope of the program for license renewal. This aligns with the discussion on AMP enhancements in the Standard Review Plan (NUREG-1 800) which states that an applicant commitment to augment an existing program to satisfy the GALL report element prior to the period of extended operation is an AMP enhancement. Energy Northwest has defined a recommended enhancement as a change or revision to a program or activity that may facilitate the performance and documentation of related activities, but is not necessary for the AMP to be effective or consistent with the GALL.

The required enhancements for the Structures Monitoring Program are commitments under License Renewal and as such are listed in Appendix A of the application.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 12 of 22 b) As discussed in a) above, the recommended enhancements are to facilitate the performance or documentation of activities related to the Structures Monitoring Program, but not necessary for this program to be effective or to be consistent with GALL.

c) The recommended enhancements are not necessary to satisfy GALL requirements, as discussed above. The recommended enhancements are not addressed in the LRA, nor is Energy Northwest making a commitment to implement recommended enhancements. Some recommended enhancements will be implemented as part of the LRA project, prior to the period of extended operation (PEO). The normal business processes will be followed to determine if and when other recommended enhancements may be implemented.

RAI B.2.50-2

Background:

GALL Report XI.S6, "Structures Monitoring Program," notes that ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes.

The plant-specific structures monitoring programs are to contain sufficient detail on acceptance criteria to conclude that this program attribute is satisfied.

Issue:

Program Element 6, "acceptance criteria," of the CGS Masonry Wall Program, Structures Monitoring Program, and RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program note that inspection criteria used to assess the condition of structures and structural components are found in the structures inspection checklist. A review of referenced program basis documents SYS-4-22, "Maintenance Rule Program (Major Revision 001)," and SYS-4-23, "Maintenance Rule Structural Baseline Inspections (Revision 0)," did not identify information related to acceptance criteria in either document. Program basis document SMP.1 1, "Columbia Maintenance Rule Structural Inspection Checklist,"

provides only a listing of conditions to check related to the concrete, masonry walls, structural steel, liner plate, roof systems, siding, windows/doors, earthen structures/dams, settlement, structure/seismic gap, interfaces, equipment supports, piping, tanks, cable trays/conduits, outside structures, and general. The staff is unclear what criteria are utilized to provide a basis for acceptance of the condition of the structures.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 13 of 22 Request:

Provide the acceptance criteria utilized for the Masonry Wall, Structures Monitoring, and Inspection of Water Control Structures programs to establish whether or not corrective actions are required prior to loss of function, and provide justification that the acceptance criteria utilized for the structures and structural components meet or exceed the criteria provided in ACI 349.3R-96.

Energy Northwest Response:

Masonry Wall Inspection:

As described in Section B.2.38 of the License Renewal application (LRA), the Masonry Wall Inspection requires an enhancement to the Acceptance Criteria program element prior to the period of extended operation. The enhancement will require the extent of observed masonry cracking or degradation of steel edge supports and bracing to be evaluated to ensure that the current evaluation basis is still valid. Corrective action will be required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e.,

acceptance by further evaluation). The Masonry Wall Inspection, with the enhancement, conforms to the recommendations of NUREG-1 801 Rev. 1 Chapter XI.S5, "Masonry Wall Program."

Visual examination of masonry walls is performed to identify indications of cracking, cracks in joints, deteriorated penetrations, missing or broken blocks, and walls with calcium formation. Potential design non-conforming conditions identified during the course of an inspection are documented per the corrective action program.

Since the Masonry Wall Inspection is implemented as part of the Structures Monitoring Program, quantitative acceptance criteria from the Structures Monitoring Program will be utilized during inspection in addition to the enhancement described in LRA Section B.2.38. Refer to Structures Monitoring Program discussion below for additional details on acceptance criteria.

Structures Monitoring Program:

The Structures Monitoring Program inspection criteria used to assess the condition of structures and structural components is found in the structures inspection checklist. A summary of the monitored aging effects is as follow:

• Concrete is inspected for loss of material, cracking and change in material properties aging effects.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 14 of 22

• Masonry walls are inspected for cracking aging effect.

• Steel and other metals including threaded fasteners are inspected for loss of material and cracking aging effects. -,

• Elastomers are inspected for cracking and change in material properties aging effects.

• Earthen structures are inspected for loss of form aging effect.

The responsible engineer identifies problems with structural performance, initiates condition reports and/or recommends corrective action. Acceptance criteria are established such that corrective actions are initiated prior to loss of function. In general, acceptable structures are capable of performing their structural functions, including the protection and support of maintenance rule or license renewal systems or components, and are free of deficiencies or degradation which could lead to possible failure. Unacceptable structures are those which are damaged or degraded such that they are not capable of performing their structural functions. An unacceptable structure or structural component is classified as a functional failure in accordance with the maintenance rule.

Energy Northwest has revised the LRA Structures Monitoring Program to include the recommendation from NUREG-1801 Rev. 1 Chapter XI.S6 acceptance criteria element as a commitment to implement prior to the period of extended operation.

The Structures Monitoring Program implementing procedures will be revised to include additional acceptance criteria details developed from Chapter 5 of ACI 349.3R-96. The enhancement has been added to Table A-1 in Amendment 4, provided in the enclosure to this letter. The revisions to LRA Table A-1 and Section B.2.50 are shown as Amendment 4 provided in the enclosure to this letter.

Inspection of Water Control Structures:

The inspection criteria used to assess the condition of water control structures and structural components are the same as the applicable inspection criteria from the Structures Monitoring Program discussed above. There are no Columbia water control structures that fall under the regulatory jurisdiction of the Federal Energy Regulatory Commission (FERC) or the U.S. Army Corps of Engineers.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 15 of 22 As stated in LRA Section B.2.53, the Water Control Structures Inspection is implemented as part of the Structures Monitoring Program conducted for the Maintenance Rule. Since the Water Control Structures Inspection is implemented as part of the Structures Monitoring Program quantitative acceptance criteria from the Structures Monitoring Program will be utilized during inspection. Refer to Structures Monitoring Program discussion above for additional details on acceptance criteria.

Energy Northwest has revised the LRA acceptance criteria for the Water Control Structures Inspection to address Chapter 5 of ACI 349.3R-96, based on this RAI.

The LRA Amendment 4 for Table A-1 and Section B.2.53 are provided in the enclosure to this letter RAI B.2.50-3

Background:

GALL Report XI.S6, "Structures Monitoring Program," notes that inspector qualifications are to be commensurate with industry codes, standards, and guidelines. ACI 349.3R-96 and ANSI/ASCE 11-90 are identified as providing an acceptable basis for addressing aging effects.

Issue:

Program Element 4, "detection of aging effects," of the Masonry Wall Program, Structures Monitoring Program, and RG 1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants Program note that inspections are performed by individuals normally assigned to maintenance rule activities or if individuals are used that are not normally assigned to maintenance rule activities they are briefed prior to conduct of inspections or accompanied by a maintenance rule staff engineer. A review of referenced program basis documents SYS-4-22, "Maintenance Rule Program (Major Rev 001)," and SYS-4-23, "Maintenance Rule Structural Baseline Inspections (Revision 0)," did not identify information related to qualifications of inspection personnel. The staff is unclear how the qualifications of the inspection personnel are commensurate with those identified in industry codes, standards, and guidelines.

Request:

Provide qualification criteria of the personnel performing the inspections and demonstrate that they meet or exceed the criteria identified in industry codes, standards, and guidelines.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 16 of 22 Energy Northwest response:

Energy Northwest will revise implementing program documents prior to the period of extended operation to establish minimum qualifications for the individual performing the inspection as a degreed civil/structural engineer with at least 4 years experience associated with nuclear power plant structures. These qualifications are commensurate with those outlined in ACI 349.3R-96 and ANSI/ASCE 11-90.

RAI B.2.50-4

Background:

Industry standards (e.g., ACI 349.3R-96) identified in the GALL Report Structures Monitoring Program recommends a ten-year inspection frequency for below-grade structures and structures in a controlled environment.

Issue:

Program Element 3, "parameters monitored or measured," of the Structures Monitoring Program notes that the Structures Monitoring Program procedure and the excavation procedure will be enhanced to specify that if a below-grade structural wall or structural component becomes accessible through excavation, a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation. Program basis document SMP.12, "Soil Excavation, Backfill and Compaction," does not reference planned or opportunistic inspections to address inaccessible areas. Also the program basis document does not contain provisions to notify the responsible engineer when a below-grade structural wall or structural component is exposed so that an inspection may be performed. The staff is unclear how aging of inaccessible areas will be managed so that the intended functions of the structures and structural components below-grade will be maintained during the period of extended operation.

Request:

Describe how CGS will address aging of inaccessible areas of below-grade structures and structural components during the period of extended operation, consistent with industry standards for inspection.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 17 of 22 Energy Northwest response:

As noted in LRA section B.2.50, the Structures Monitoring Program (SMP) will require multiple enhancements under 'Parameters Monitored or Inspected'. Two of these enhancements are:

1. to specify that if a below grade structural wall or component becomes accessible through excavation a follow-up action is initiated for the responsible (civil/structural) engineer to inspect the concrete surfaces for age-related degradation prior to backfilling and

2. that the responsible engineer review site groundwater and raw water testing results to validate below-grade and raw water environments remain non-aggressive during the period of extended operation (PEO).

As documented in section 3.5 of the application, the below-grade environment at Columbia is non-aggressive. Per GALL table items (e.g., II1.A1-4, III.A1-5) for concrete exposed to an environment of groundwater/soil which is non-aggressive recommend as a minimum the following for aging management program:

1. Examination of the exposed portions of below-grade concrete, when excavated for any reason, and

2. Periodic monitoring of below-grade water chemistry, including consideration of potential seasonal variations.

Energy Northwest will address aging of inaccessible areas of below-grade structures and structural components during the PEO by revising the implementing procedures prior to the PEO to reflect the enhancements contained in the LRA. The revision to the plant procedure will be the vehicle by which the actual notification is made and the follow-up action for inspection is initiated.

Thus, the Columbia SMP, with the noted enhancements and subsequent implementing procedure revisions, will be consistent with industry standards for inspection.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 18 of 22 RAI B.2.50-5

Background:

Element 10, "operating experience," notes that the Structures Monitoring Program has been effective in managing identified aging effects.

Issue:

AR 00026719 (11/09/2004) notes that when the U.S. Nuclear Regulatory Commission asked the question of how often leakage from the fuel pool liner is checked, CGS could not find any surveillances, preventive measures, or operator logs that check for this leakage. The staff is uncertain if leakage of the fuel pool is occurring and if leakage is present that it is being confined to the tell tale drains.

Request:

Provide historical data on fuel pool leakage obtained by checking the tell tale drains and note whether or not the leakage is confined to the tell tale drains. If the leakage is not confined to the tell tale drains, identify any structures or structural components potentially impacted and describe plans to assess the condition and continued functionality of potentially impacted structures and structural components, in particular when entering the renewed license operating term.

Energy Northwest response:

The tell tale drains are checked once per shift, during 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts, in accordance with plant procedures. The acceptance criterion is no flow through the drains.

Should the operator find flow in the tell tale drains, the event would be entered into the CAP. As of August 2010, no instances of leakage through tell tale drains have been entered into the CAP. Therefore, there is no historical data to provide. Liner leakage is directed to the drainage monitoring channels and then to the tell tale drains. Therefore, no other structures or structural components would be potentially impacted by liner leakage.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 19 of 22

Background:

Element 10, "operating experience," notes that the CGS Structures Monitoring Program has been effective in managing identified aging effects.

Issue:

During the walk down of the Spray Pond, the staff noted that there were numerous narrow cracks visible at the top of the reinforced concrete wall that went through the entire thickness of the wall. The cracks appeared to be shrinkage cracks and there was no evidence of corrosion. The staff is unclear of how conditions like this that may be identified during the renewed license operating period will be identified, evaluated and repaired, as necessary.

Request:

a) Has this condition been identified by the Structures Monitoring Program?

If so, on what date was it identified?

b) Is this condition a potentially adverse condition that could impact Spray Pond functionality and hence would be subject to aging management during the renewed license operating period?

c) If this condition was identified by the CGS Structures Monitoring Program, describe the results of the condition assessment and any plans to implement repairs.

d) Describe any extent of condition concerns that may have led to more focused inspection of structures that could be similarly affected.

Energy Northwest Response:

a) The Service Water pump houses and their associated spray ponds have been walked down and inspected under MRule since 1996. Frequency was first set at every two years and then changed to every four years in 2006. The inspection of the spray ponds has been limited to that portion

.above the water. The results have been documented by stating that the spray ponds remained capable of performing their intended function as Columbia's ultimate heat sink. No specific mention was made of these shrinkage cracks at the top of the walls. However, these walkdowns and inspections have been performed by degreed civil/structural engineers with at least five years experience at the plant and knowledge that these walls were placed in the mid-1 970s (around 1976). Thus, based on engineering judgment, the presence of these shrinkage cracks in concrete at least twenty years old without any signs of being active (spalled or

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL, APPLICATION Attachment I Page 20 of 22 pop-out pieces of concrete) were considered to be cosmetic in nature rather than adversely affecting the structural integrity of these walls.

b) The condition is not adverse to the function.

The Service Water pump houses and associated spray ponds are in-scope of license renewal. As per Table 3.5.2-3 of the application, the walls of the spray ponds will be managed for potential aging effects (or to confirm the absence of them) under the Structures Monitoring Program -

Water Control Structures Inspection. This monitoring and trending of the walls will ensure these shrinkage cracks do not become a condition adverse to quality and before they adversely affect the intended function of the spray ponds.

c) Based on walkdowns and engineering judgment, the result of the Structures Monitoring Program condition assessment was that these shrinkage cracks are cosmetic and do not affect the structural integrity of the spray pond walls.

As discussed in the response to RAI B.2.50-2, Energy Northwest will enhance the Structures Monitoring Program (which includes the Water Control Structures Inspection) to include acceptance criteria details developed from the guidelines of Chapter 5 of ACI 349.3R-96. Chapter 5 of this industry standard presents a three-tiered approach for condition assessment; acceptance without further evaluation, acceptance after review, and conditions requiring further evaluation. For conditions falling under the latter two, Energy Northwest will utilize the CAP to document the additional review or evaluation and any potential corrective actions (i.e., repairs).

d) Since the cracking discussed under this RAI is shrinkage cracking, the extent of condition would be applicable to any concrete structure.

Potential cracking and other aging effects of concrete structures within the scope of license renewal will be monitored under the Structures Monitoring Program during the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 21 of 22 RAI B.2.50-7

Background:

Program Element 10, "operating experience," of the CGS Structures Monitoring Program AMP states the following:

Visual examinations conducted by the Structures Monitoring Program have found general corrosion on steel components and concrete cracking, flaking, and scaling. Some of the currently identified concrete surface conditions have existed since original construction. These conditions are the results of typical construction practices permitted by the original specifications and design criteria. They include small shrinkage cracks, minor construction joint voids, surface irregularities, and similar conditions determined to be minor degradation that did not require further evaluation. Inspected structures are in good condition and are capable of performing their design functions.

Issue:

CGS document A/R Number 00031540 dated May 24, 2005, addresses wetwell coating repair issues including observed cracks in the concrete that were estimated as being between 1/16 and 1/32 in. wide. During subsequent coating inspections it was noted that the cracks had grown in width, but not length, and the coating appears to be peeling away from the concrete creating a wider crack. It was noted that the cracks were about 1/16 in. wide and were not considered to be a concern unless the width increased to 1/8 in. or greater. The staff is unclear about what criteria were utilized to evaluate these cracks and if there are any plans to repair the cracks in the concrete.

Request:

The applicant is requested to provide the following:

a) The acceptance criteria used to evaluate these cracks b) The results of any further investigations conducted to evaluate the concrete cracks described in CGS document A/R Number 00031540 c) A description of any monitoring and trending of these cracks to ensure timely remediation of such conditions identified by the Structures Monitoring Program

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 22 of 22 Energy Northwest Response:

a) The acceptance criterion for the cracks was 1/8" width based on engineering judgment and plant specific experience of the responsible engineer. This criterion was based on concerns about potential effects on the structural integrity of the wetwell slab versus identification and documentation of potential aging effects. Cracking less than 1/8" wide was considered not to adversely affect the overall structural integrity of the slab.

b) The coating in the area of this crack was repaired during the refueling outage in 2005 and its location noted. The repair was performed under the Columbia Service Level I coatings program. This coating repair was then reinspected during the R18 outage. During the inspection, the coating inspectors could not find or distinguish the crack or the repaired coating from the coatings in the surrounding area.

c) Energy Northwest has a Service Level I coatings program that performs inspections, evaluation, and repairs (as necessary) of the wetwell coatings every two years to ensure Columbia maintains its unqualified coatings within our design basis limits. Thus, for the wetwell slab, the coating program will monitor and trend conditions such as any additional cracking that becomes evident through the discovery of damaged coatings. Remediation or repair would be effected by the coatings program as well as documented in the CAP. See additional information provided by Energy Northwest in response to RAI XI.$8-1, in letter dated August 19, 2010, SK Gambhir to NRC, "Response to Request for Additional Information License Renewal Application," in Attachment 1, page 10.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION' LICENSE RENEWAL APPLICATION Page 1 of 1 COMMITMENT The following table identifies the regulatory commitments in this document. Any other statements in this submittal intended or planned actions, are provided for information purposes, and are not considered to be regulatory commitments Commitment Scheduled Completion Date Energy Northwest will revise implementing Prior to the Period of structures monitoring and water control structures Extended Operation (PEO) programs documents prior to the period of extended operation to establish minimum qualifications for the individual performing the, inspection as a degreed civil/structural engineer with at least 4 years experience associated with nuclear power plant structures. Energy Northwest believes these qualifications to be commensurate with those outlined in ACI 349.3R 96 and ANSI/ASCE 11 90.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDMENT 4 NEW OR REVISED PAGES Section No. Page No. RAI No.

Appendix A, Table A-1 A-63 B.2.50-2 Item 50 Appendix A, Table A-1 A-63a B.2.50-2 Item 50 Appendix A, Table A-1 A-65 B.2.50-2 Item 53 Appendix A, Table A-1 A-65a B.2.50-2 Item 53 B.2.50 B-194 B.2.50-2 B.2.50 B-1 94a B.2.50-2 B.2.53 B-206 B.2.50-2 B.2.53 B-206a B.2.50-2

Columbia Generating Station License Renewal Application Technical Information Table A-1 Columbia License Renewal Commitments FSAR Enhancement Supplement or Item Number Commitment Location Implementation (LRA App. A) Schedule

50) Structures

• Specify that the responsible engineer shall review site Monitoring groundwater and raw water testing results for pH, chlorides, and Program sulfates prior to inspection to validate that the below-grade or raw (cont'd) water environments remain non-aggressive during the period of extended operation. Chemistry data shall be obtained from Columbia's chemistry and environmental departments.

Groundwater chemistry data shall be collected at least once every four years. The time of data collection shall be staggered from year to year (summer-winter-summer) to account for seasonal variations in the environment.

51) Supplemental he Supplemental Piping/Tank Inspection is a new activity. A.1.2.51 Within the 10-Piping/Tank The Supplemental Piping/Tank Inspection detects and characterizes year period prior Inspection the material condition of steel, gray cast iron, and stainless steel to the period of components exposed to moist air environments. The inspection extended provides direct evidence as to whether, and to what extent, the operation.

relevant effects of aging have occurred.

Insert A from Page A-63a 7 Final Safety Analysis Report Supplement Page A-63 J:am -- a jAmendment-4-----ýý ý -- "--'y -010

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-63

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

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

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

A-63a Amendment 4 PageSupplement Page Final Safety Analysis Report Supplement Final Safety Analysis Report A-63a Amendment 4

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

53) Water Control The Water Control Structures Inspection is an existing program that A.1.2.53 Enhancement Structures will be continued for the period of extended operation, with the prior to the period Inspection following enhancements: of extended

• Include and list the water control structures within the scope of operation.

license renewal. Include the RG 1.127 Revision 1 inspection Then ongoing.

elements for the water control structures, including submerged surfaces. Ensure descriptions of concrete conditions conform with the appendix to the American Concrete Institute (ACI) publication, ACI 201, "Guide for Making a Condition Survey of Concrete in Service." Add a recommendation to Use photographs for comparison of previous and present conditions. Add a requirement for the documentation of new or progressive problems as a part of the inspection program.

llnsert A from Page A-65a I Final Safety Analysis Report Supplement Page A-65 4auay 2011

Columbia Generating Station License Renewal Application Technical Information Insert A to Paqe A-65

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

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

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

Page A-65a Amendment 4 Report Supplement Analysis Report Final Safety Analysis Supplement Page A-65a Amendment 4

Columbia Generating Station License Renewal Application

[Section B.2.50 Technical Information

• Turbine Generator Building

• Water Filtration Building Enhancements to this element for the Structures Monitoring Program also include enhancements that are being made to the Water Control Structures Inspection. See the Water Control Structures Inspection for required enhancement details.

• Parameters Monitored or Inspected -

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

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

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

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

Enhancements to this element for the Structures Monitoring Program also include enhancements that are being made to the Water Control Structures Inspection and the Masonry Wall Inspection. See the Water Control Structures Inspection and the Masonry Wall Inspection for required enhancement details.

Operating Experience lnsert A from Page B-194a The Structures Monitoring Program has been effective in managing the identified aging effects. Although actual experience with Structures Monitoring Program inspections is limited, recent inspection results have shown that plant structures are maintained in good condition. No significant failures have occurred in any Columbia structure to date.

Aging Management Programs Page B-194 ja... n jAmendment 4 .. .

Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-1 94 Acceptance Criteria -

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

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

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

Amendment 4 Aging Management Programs Aging Management Programs Page B-194a Page B-194a Amendment 4

Columbia Generating Station License Renewal Application Technical Information B.2.53 Water Control Structures Inspection Program Description The Water Control Structures Inspection is implemented as part of the Structures Monitoring Program conducted for the Maintenance Rule.

The Water Control Structures Inspection is an existing condition monitoring program for detecting aging and age-related degradation of the Seismic Category I Spray Ponds and the Standby Service Water Pump Houses. It also inspects the Seismic Category II Circulating Water Pump House (including the circulating water basin), the Makeup Water Pump House, and the cooling tower basins.

Columbia is not committed to RG 1.127, "Inspection of Water-Control Structures Associated with Nuclear Power Plants." However, enhancements pertaining to water control structure inspection elements from RG 1.127 Revision 1 will be incorporated into the Structures Monitoring Program consistent with NUREG-1801,Section XI.S7.

NUREG-1801 Consistency The Water Control Structures Inspection 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.S7, "RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants."

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:

• Scope, Parameters Monitored or Inspected -

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

< --- [Insert ýAfrom Page B-206a Aging Management Programs Page B-206 Ja*a-. .*2.1

[Amendment 4

Columbia Generating Station License Renewal Application Technical Information Insert A to Paqe B-206 Acceptance Criteria -

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

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

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

Aging Management Programs Page B-206a Amendment 4