ML103550603

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Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application (TAC No. Me3058)
ML103550603
Person / Time
Site: Columbia 
Issue date: 12/27/2010
From: Gettys E
License Renewal Projects Branch 1
To: Gambhir S
Energy Northwest
Gettys E, NRR/DLR, 415-4029
References
TAC ME3058
Download: ML103550603 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 27,2010 Mr. S. K. Gambhir Vice President Technical Services Columbia Generating Station Energy Northwest MD PE04 P.O. Box 968 Richland, WA 99352-0968

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. ME3058)

Dear Mr. Gambhir:

By letter dated January 19, 2010, Energy Northwest submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew operating license NPF-21 for Columbia Generating Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Abbas Mostala and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or bye-mail at evelyn.gettys@nrcgov.

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

Enclosure:

As stated cc w/encl: Distribution via Listserv

COLUMBIA GENERATING STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION Gavula Follow-up to RAls 8.2.26-5 and 8.2.42-3

Background:

Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an aging management review (AMR) will be adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation.

In its review of the Fire Water System and Open-Cycle Cooling Water System Programs, the staff identified that the applicant has plant-specific operating experience for loss of material due to cavitation erosion in both its fire protection and standby service water systems. As a result, the staff issued requests for additional information (RAls) B.2.26-5 and B.2.42-3 regarding the extent of condition review performed to identify the potential for cavitation erosion in other systems at the station and the actions taken to manage the aging effects of cavitation erosion at susceptible locations.

In its response, dated September 27,2010, Energy Northwest stated that the root cause analysis performed in 2002 had incorrectly concluded that high energy systems were addressed by the flow-accelerated corrosion (FAC) program, although it was later determined that the existing FAC program does not check for cavitation erosion. The response also stated that a piping system cavitation guide had been developed using several industry documents; however, the criteria for predicting locations with the potential for cavitation erosion were not provided.

The response further stated that Energy Northwest did not intend to provide justification of the incomplete 2002 extent of condition review, as this is a current license issue which had been entered into the corrective action program and would include an extent of condition review. The response also stated that repetitive preventative maintenance tasks were established to ensure that ultrasonic inspections occur at the locations susceptible to cavitation erosion in the fire protection piping.

License renewal application (LRA) Section 8.2.26 and Commitment No. 26 state an enhancement to the Fire Protection Program to ".. perform either ultrasonic testing or internal visual inspection of representative portions of the above-ground fire protection piping, which normally do not experience flow." The LRA does not include any information regarding what specific examinations will be performed to manage cavitation erosion.

Issue:

Given that the extent of condition review for cavitation erosion at the station was incomplete, the staff cannot evaluate whether all of the aging effects requiring management have been identified for the components in those systems susceptible to cavitation erosion, or whether the existing aging management programs are adequate to manage loss of material due to cavitation erosion for all susceptible components.

In addition, since the criteria for predicting locations with a potential for cavitation erosion were not provided, a comparison with the mechanism-specific criteria in NRC-approved Electric ENCLOSURE

- 2 Power Research Institute (EPRI) TR-112657, "Revised Risk-Informed Inservice Inspection Evaluation Procedure," could not be made.

Given that the Fire Protection Program enhancement allows either ultrasonic testing or visual inspections to detect loss of material, it is unclear to the staff how the ultrasonic inspections at the locations susceptible to cavitation erosion in the fire protection piping are included within the scope of the Fire Protection Program.

Request:

1) Provide the complete list of AMR line items that are susceptible to loss of material due to cavitation erosion and describe any proposed changes to the existing aging management programs required to manage loss of material due to cavitation erosion for these components.
2) Describe the criteria used in the extent of condition evaluation for cavitation erosion, and, if it is different, also describe the criteria in the above referenced piping system cavitation guide. If either set of criteria are less conservative than the mechanism-specific criteria in NRC-approved EPRI TR-112657, "Revised Risk-Informed Inservice Inspection Evaluation Procedure," provide the technical bases to demonstrate that the criteria used will provide reasonable assurance that component intended functions will be maintained during the period of extended operation.
3) Clarify how the repetitive preventative maintenance tasks which perform ultrasonic inspections at the locations susceptible to cavitation erosion in the fire protection piping are included within the scope of the Fire Protection Program.

December 27,2010 Mr. S. K. Gambhir Vice President Technical Services Columbia Generating Station Energy Northwest MD PE04 P.O. Box 968 Richland, WA 99352-0968

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. ME3058)

Dear Mr. Gambhir:

By letter dated January 19, 2010, Energy Northwest submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew operating license NPF-21 for Columbia Generating Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Abbas Mostala and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-4029 or bye-mail at evelyn.gettys@nrc.gov.

Sincerely, IRA!

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

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

See next page ADAMS Accession No.: ML103550603

  • concurrence via e-mail OFFICE LA:DLR PM:RPB1 :DLR BC: RPB1 :DLR PM:RPB1 :DLR NAME IKing*

EGettys BPham EGettys DATE 12/22/10 12/22/10 12/22/10 12/27/10 OFFICIAL RECORD COpy

Letter to S.K. Gambhir from E. Gettys dated December 27,2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE COLUMBIA GENERATING STATION, LICENSE RENEWAL APPLICATION (TAC NO. 3058)

DISTRIBUTION:

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