ML103090566

Summary of Teleconference Held on September 22, 2010, Between the U.S. NRC and Energy Northwest, Concerning the Responses to the Request for Additional Information Pertaining to the Columbia Generating Station, License Renewal Application

ML103090566
Person / Time
Site:	Columbia
Issue date:	11/19/2010
From:	Gettys E License Renewal Projects Branch 1
To:	Energy Northwest
Gettys E, NRR/DLR, 415-4029
References
TAC ME3058
Download: ML103090566 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 19, 2010 LICENSEE: Energy Northwest FACILITY: Columbia Generating Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON SEPTEMBER 22, 20 10, BETWEEN THE U. S. NUCLEAR REGULATORY COMMISSION AND ENERGY NORTHWEST, CONCERNING THE RESPONSES TO THE REQUEST FOR ADDITIONAL IN FORMATION PERTAIN ING 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, held a telephone conference calion September 22, 2010, to discuss and clarify the responses to the NRC's request for additional information (RAI) concerning the Columbia Generating Station , license renewal application. provides a listing of the participants and Enclosure 2 contains a listing of the draft 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 H. Gettys , Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-397 Enclosures :

As stated cc w/encls: Distribution via Listserv

TELEPHONE CONFERENCE CALL COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS September 22, 2010 PARTICIPANTS AFFILIATIONS Evelyn Gettys U.S . Nuclear Regulatory Commission (NRC)

Bryce Lehman NRC Abdu l Sheikh NRC Barry Naus Oak Ridge National Laboratory Abbas Mostala Energy Northwest (EN)

Doug Ramey EN John Twomey EN Scott O'Connor EN Sing Chu AREVA ENCLOSURE 1

TELEPHONE CONFERENCE CALL COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION September 22, 2010 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Energy Northwest (the applicant), held telephone conference calls on September 22, 2010, to discuss the following follow-up reque sts for additional information (RAls) concerning the Columbia Generating Station (CGS) , license renewal application (LRA).

Follow-up RAI 8.2.34-1

Background:

In response to RAI B.2.34-1 , the applicant stated :

a) "Additionally, the sand pocket drains are checked monthly (28 day frequency) for presence of water."

b) "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 of 1.5 mpy will be assumed for containment steel plate in the sand pocket region."

c) "The 1.9 percent margin when applied to the thickness of the plate in th e sand bed region will result in a corrosion allowance of 27.5 mils."

d) "The construction of the containment at Columbia utilized a polyurethane foam material in the annulus between the biological shie ld wall and primary containment vessel.

Energy Northwest agrees this method of construction would inhibit, if not prevent, the free flow of moi sture to the sand pocket regions and drain lines from the refueling bellows area."

Issue:

It is not clear to staff:

a) How the sand pocket drains are inspected for presence of water.

b) How the plant-specific corrosion rate of 1.5 mpy was established.

c) How the corrosion rate in the sand bed region can be linearly proportional to the drywell thickness .

In addition , presence of moisture in the polyurethane material can lead to corrosion and localized pitting of the steel containment. The localized co rrosion rate due to pitting can be higher than 1.5 mpy over the long term.

Request:

a) Provide details on how the sand pocket drains are inspected. In add ition, does the plant procedures require vacuum of all of the eight sand pockets during inspection.

b) Provide the basis for the plant-specific corrosion rate of 1.5 mpy.

ENCLOSURE 2

c) Justification for assuming that corrosion rate in sand bed region is linearly proportional to the drywell thickness.

d) Plans (if any) for ultrasonic examination of a representative portion of the steel containment and sand pocket region to detect degradation of steel and confirm that corrosion rate is less than 1.5 mpy.

Discussion : The staff will issue a formal RAI.

Follow-up RAI B.2.34-3

Background:

In response to RAI B.2.34-3 , the applicant stated that the VT-3 examinations are performed in accordance with the plant procedures by certified VT -3 examiners. The procedures and certification are in accordance with American Society of Mechanical Engineers (ASME)Section XI.

Issue:

For Title 10 of the Code of Federal Regulations (10 CFR) 50.55(a) which is referenced in the Generic Aging Lessons Learned (GALL) Report XI.S1 states that VT-1 and VT-3 examinations must be conducted in accordance with IWA-2200. Person nel conducting examinations in accordance with the VT-1 or VT-3 examination method shall be qualified in accordance with IWA-2300. The "owner-defined" personnel qualification provisions in IWE-2330(a) for personnel that conduct VT- 1 and VT-3 examinations are not approved for use. It is not clear to the staff whether the persons performing the VT-3 examination at the CGS are qualified in accordance with the IWA-2300 requirements.

Request:

Provide the qualification requirements for the VT-3 examiners at the CSG. Specifically, the staff needs to know if the VT-3 examiners are qualified in accordance with ASM E IWA-2300.

Discussion: The staff will issue a forma l RAI.

Follow-up RAI B.2 .35-2

Background:

In its response to RAI B.2.35-2, dated September 3, 2010, the applicant stated that no inspection frequency is specified when applying supplemental examinations per IWF-3200. The applicant also stated that when visual examinations detect conditions in the structural steel supports of the service water pond spray ring header requiring evaluation , these examinations may be supplemented with other examination methods to determine the characteristic of the flaw. Supplement examinations , .if needed, are performed by either or both the surface and volumetric methods. The applicant further stated that the structural steel supports of the spray ring header are protected from corrosion by coating the structure and a sacrificial anode protective system. 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. The criterion to initiate the corrective action process , 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."

Issue:

The staff reviewed the applicant's response to RAI 8.2.35-2 and wa s concerned that the applicant did not provide the frequency of the periodic inspection of the service water pond spray ring header supports and the anode protective systems. In addition, the criterion used to initiate the corrective action process was very subjective.

Request:

The applicant is requested to provide th e inspection frequency for the above and below water inspection of service water pond spray header supports , and anode protection system. In addition, the applicant to identify quantitative criteria used to initiate the corrective action process. The staff needs this information to confirm that the effects of aging on the intended function of the spray pond header will be adequately managed for the period extended operations in accordance with 1OC FR 54.2 1(c)(iii).

Discussion: The staff will issue a form al RAI.

Follow-up RAls B.2.50-1, B2.50-2, B.2.50-3

Background:

In response to RAls 8 .2.50-1 , 82.50-2 , 8 .2.50-3, the applicant stated th at the req uired en hancements to aging management programs (AM Ps) will be implemented prior to the period of extended operation. In addition , it is not clear from the response which of the recommended enhancements will be adopted for the AMPs.

Issue:

The staff is concerned that the required enhancements to the AMPs will not be implemented until the period of extended operation whi ch begins December 2023. Early implementation of the enhancements is needed to establish a baseline for monitoring and trending the aging of the structures during the period of extended operation . In addition , the applicant has not clearly identified the recommended enhancements that will be incorporated in the AMPs .

Request:

a) Clearly identify the enhancements that will be incorporated into the AMPs .

b) Provide a firm schedule for implementation of the required en hancements, in order to establish a baseline prior to the period of extended operation . If no plans exist to implement the enhancements prior to the period of extended operation explain why early implementation is unnecessary and how an appropriate baseline will be established prior to entering the period of extended operation .

Discussion: The staff will issue a formal RAI.

Follow-up RAI B.2.50-5

Background:

In re sponse to RAI B.2.50-5, the applicant stated that 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 /> shift, 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 corrective action program (CAP) . As of August 2010 , no instances of leakage through tell tale drains have been entered into CAP.

Issue:

The staff is concerned that tell tale drains may be blocked and prevent any leakage to be collected or observed at the drain valves.

Request:

Provide additional information that will demonstrate that tell tale drains are not blocked. This could be boroscope inspection of the drains.

Discussion: The staff will issue a formal RAI.

• .. ML103090566 OFFICE LARPOB:DLR PM:RPB1 :DLR BC: RPB1 :DLR PM:RPB1 :DLR NAME IKing EGettys BPham EGettys (Signature)

DATE 11/10/10 11/11/10 11/18/10 11/19/10

Memorandum to Energy Northwest from Evelyn H. Gettys dated November 19, 2010

SUMMARY

OF TELEPHON E CONFERENCE CALL HELD ON SEPTEMBER 22, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENERGY NORTHWEST, CONCERNING THE RESPONSES TO THE REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE COLUMBIA GENERATING STATION, LICEN SE RENEWAL APPLICATION (TAC NO . ME3058)

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