GO2-11-014, Response to Request for Additional Information License Renewal Application
| ML110190657 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/18/2011 |
| From: | Gambhir S Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-11-014 | |
| Download: ML110190657 (19) | |
Text
Sudesh K. GaRbhir ENERGY Vice President, Engineering NORTHW EST P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 Sgambhir@energy-northwest.com January 18, 2011 G02-11-014 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, G02-10-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"
- 2) Letter dated October 14, 2010, NRC to SK Gambhir (Energy Northwest),
"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML102800426)
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 is the Energy Northwest response to the Request for Additional Information (RAI) contained in Reference 2. Enclosure 1 contains Amendment 17 to the Columbia License Renewal Application. One new commitment and one revised commitment are included in this response. These commitments are reflected in the changes to Table A-1 in this amendment.
If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.
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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.
Respectfull SK Gambhir Vice President, Engineering
Attachment:
Response to Request for Additional Information
Enclosure:
License Renewal Application Amendment 17 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn EH Gettys - NRC NRR (w/a)
BE Holian - NRC NRR RR Cowley - WDOH
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 8 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"
(ADAMS Accession No. ML102800426)
RAI 3.2.2.3.1-1
Background:
In License Renewal Application (LRA) Tables 3.2.2-1 and 3.2.2-2, the applicant stated that steel piping exposed to moist air (internal) are being managed for loss of material by the Supplemental Piping/Tank Inspection Program. The aging management review (AMR) line item cite Generic Note G. Line items associated with steel piping in LRA Table 3.2.2-1 cite plant specific Note 0201 which states that the Supplemental Piping/Tank Inspection will manage loss of material at the air-water interface on the piping at the surface of the suppression pool. The staff notes that the Supplemental Piping/Tank Inspection Program is a new one-time inspection program which focuses on detection and characterization of the material condition for steel and stainless steel components exposed to moist air environments, such as at air-water interfaces or air spaces of piping and tanks.
The staff notes that given the definitions in LRA Table 3.0-1, moist air is susceptible to condensation. The staff also notes that the GALL Report recommends that steel piping exposed to an air-indoor uncontrolled or condensation internal environment will be managed by GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components."
The staff notes that the GALL recommended AMP Xl. M38 consists of periodic inspections which are based on the (a) "detection of aging effects" program element, "Inspection intervals are established such that they provide timely detection of degradation", (b)-"operating experience" program element, "The elements that comprise these inspections (e.g., the scope of the inspections and inspection techniques) are consistent with industry practice and staff expectations. However, because the inspection frequency is plant-specific and depends on the plant operating experience, the applicant's plant-specific operating experience or applicable generic operating experience is further evaluated for the extended period of operation. The applicant is to evaluate recent operating experience andprovide objective evidence to support the conclusion that the effects of aging are adequately managed", and (c) "monitoring and trending" program element, "Maintenance and surveillance activities provide for monitoring and trending of aging degradation. Inspection intervals are dependent on component material and environment, and take into consideration industry and plant-specific operating experience. Results of the periodic inspections are monitored for indications of various corrosion mechanisms and fouling."
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 8 Issue:
The staff notes that the applicant has proposed a one-time inspection program instead of the periodic inspections recommended by GALL AMP XI.M38 and has not provided sufficient plant-specific or industry operating experience information to justify a one-time inspection program nor justified why monitoring and trending need not be performed.
Request:
Provide sufficient plant-specific or industry operating experience to justify the use of a one-time inspection program in lieu of a periodic inspection program, and justify why the monitoring and trending recommendations of GALL AMP XI.M38 need not be met.
Energy Northwest Response:
Item #53 of LRA Table 3.2.2-1 refers to piping from that portion of the RHR System associated with the deactivated steam condensing mode that penetrates the surface of the suppression pool. Item #55 of LRA Table 3.2.2-2 refers to the air-filled lines in the Reactor Core Isolation Cooling System that enter the suppression pool, such as the turbine exhaust lines.
The air-water interface has the potential to be an aggressive environment where contaminants can concentrate due to alternate wetting and drying. The same air-water interface that exists on the internal surfaces of the subject piping also exists at the external surfaces of the pipe and is also managed by the Supplemental Piping/Tank Inspection, as indicated in Table 3.2.2-1 row #58 and Table 3.2.2-2 row #62.
The one-time Supplemental Piping/Tank Inspection Program is appropriate in lieu of a periodic program for managing the effects of aging for the subject components with an air-water interface since:
- The Supplemental Piping/Tank Inspection is a new one-time inspection activity for which plant operating experience has not shown the occurrence of the aforementioned aging effect. The activity provides confirmation of conditions where degradation is not expected, has not evidenced as a problem, or where the aging mechanism is slow acting.
" A review of Columbia operating experience did not identify any aging effects that were attributed to air-water interfaces or other susceptible locations. The site corrective action program and an ongoing review of industry operating experience will be used to ensure that the program is effective in managing the identified aging effects.
In addition, other periodic programs are credited for managing the effects of aging of subject components above and below the air-water interface, as follows:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 8
" Above the air-water interface the subject piping is exposed to air-indoor uncontrolled environment. As indicated in LRA Table 3.2.2-1 row #52 and Table 3.2.2-2 row #52, the External Surfaces Monitoring Program and the Preventive Maintenance - RCIC Turbine Casing Program will manage the effects of aging for subject components above the air-water interface.
- Below the air-water interface the subject piping is exposed to a treated water environment. As indicated in LRA Table 3.2.2-1 rows 55 and 56 and LRA Table 3.2.2-2 rows 59 and 60, the BWR Water Chemistry Program with the Chemistry Program Effectiveness Inspection will manage the effects of aging for subject components below the air-water interface.
Additionally, for consistency with row #53 of LRA Table 3.2.2-1, the LRA is amended to add plant-specific note #0201 to Table 3.2.2-2 row #55.
SS Components RAI 3.3.2.3.16-1
Background:
LRA Tables 3.3.2-16, 3.3.2-42 and 3.4.2-3 state that for stainless steel flexible connections, nozzles, orifices, piping, valve bodies, and tubing exposed to air-outdoor (internal), there is no aging effect and no aging management program (AMP) is proposed. The AMR line items cite Generic Note G.
Issue:
The staff notes that the GALL Report does not address stainless steel components in an outdoor air environment; however, given the stations location to arid land, agriculture, road salt compound, and cooling tower vapor, trace compounds (e.g.,
chlorides) could be contained in the outside air supply that could cause loss of material in stainless steel components.
Request:
Justify why the outside air environment does not contain trace compounds that could cause loss of material in stainless steel components, or propose an AMP to manage the aging of stainless steel flexible connections, nozzles, orifices, piping, valve bodies, and tubing exposed to air-outdoor (internal).
Energy Northwest Response:
While the air may contain small amounts of airborne contaminants (corrosive chemicals) such as halides, sulfates, ozone, and other aggressive substances (e.g., pesticides, dust, or other crop treatments in rural areas) that can influence the 'nature, rate, and
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 8 severity of corrosion, the components must also be subject to a wetted environment for the aging effects to be applicable. Environments near industrial regions and near the seashore are known to contain large amounts of airborne contaminants. The above components are not normally exposed to a wetted environment since, either by design or configuration; the components are normally drained and therefore are not subject to any aging effects. The nozzles, orifices, piping, valve bodies, and tubing associated with the service water spray header, the still well, and the condensate storage tank level detectors are designed to drain any fluid. The flexible connection DE-FLX-5 is in a line that is configured to minimize the introduction of moisture and is designed to drain any that does enter the line. However, due to the periodic diesel exhaust environment, DE-FLX-5 will be inspected by the Diesel Systems Inspection as documented in RAI 3.3.2.2.3.3-1. Based on a teleconference with the NRC staff on October 26, 2010, Energy Northwest is reevaluating the use of one-time inspections described in the License Renewal Application. A comprehensive response to-this issue will be provided under separate cover letter and will include the Diesel Systems Inspection.
For completeness and consistency, the license renewal application (LRA) is amended to include rows with environments of "Moist air (Internal)" for the stainless steel still well piping and the tubing in the level sensing lines of COND-TK-1A and 1B to address the air-water interface. The air-water interface will be managed by the Supplemental Piping/Tank Inspection Program. A marked up version of the LRA showing these changes is enclosed.
Fire water Follow-up to RAI. B.2.26-2
Background:
The GALL Report recommends GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," to manage loss of material for steel piping and components exposed internally to indoor or outdoor uncontrolled air. The GALL Report recommends GALL AMP XI.M36, "External Surfaces Monitoring," to manage loss of material for steel components exposed externally to indoor or outdoor uncontrolled air. Both GALL AMP XI.M36 and XI.M38 recommend performing periodic visual inspection to manage loss of material.
The Columbia LRA does not include an AMP that is consistent with GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." In its response to RAI B.2.26-2, the applicant stated that it will use inspections of the external surfaces of some components to characterize the aging effects on the internal surfaces where the material and environment is the same. For these components, the applicant credited the External Surfaces Monitoring Program to manage aging for components exposed to an internal environment of indoor or outdoor air.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 8 Issue:
The staff notes that the external surfaces of piping and components are often painted or coated, while the internal surfaces are not usually painted or coated; and therefore an external inspection would not be able to be used to characterize aging on the component's internal surface. It is unclear to the staff whether the applicant has components available for external inspection that are constructed of the same material and exposed to the same environment as all of the components for which the applicant credited the External Surfaces Monitoring Program to manage the internal surfaces of the components.
Request:
- 1. State whether there are components available for inspection that are constructed of the same material and exposed to the same environment as all of the components for which the LRA credited the External Surfaces Monitoring Program to manage aging for the internal surface of the component.
- 2. If there are any components for which there is no external surface available to characterize the condition of the internal surface of the component, state how aging will be managed for the internal surface of the component, including which aging management program will be used and the inspection method (e.g., visual, volumetric).
Energy Northwest Response:
A review of the LRA found the following combinations of materials and internal environments that credit the External Surfaces Monitoring Program to manage the applicable aging effects:
Material Environment Steel Air-indoor Uncontrolled (Internal)
Steel Air-outdoor (Internal)
Steel Air (Internal)
Gray Cast Iron Air-indoor Uncontrolled (Internal)
Elastomer Air-indoor Uncontrolled (Internal)
The only component that has an "Air (Internal)" environment is CN-TK-1. As described in plant-specific note 0323 "The internal environment between the outer and inner vessels of CN-TK-1 is conservatively evaluated as air instead of as a vacuum. Since the external surface is exposed to the more aggressive outdoor air environment, aging effects will occur on the external surface before they occur on the internal surface."
Therefore, it is not necessary to find an external environment that matches the internal environment of the outer vessel of CN-TK-1.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 8 Equivalent, unpainted external locations for all of the internal environment and material combinations have been identified, therefore the internal surface aging effect will be adequately managed by the external surfaces aging management program.
Structures Follow-Up RAI B.2.50-6
Background:
By letter dated September 3, 2010, the applicant responded to RAI B.2.50-6 regarding narrow through wall cracks at the top of the spray pond walls and past inspection results.
Issue:
In the response the applicant stated that inspection of the spray ponds, have been limited to the portions above water, and past inspection results have been documented by stating that the spray ponds remain capable of performing their intended function. The applicant further stated that based on engineering judgment and lack of any signs indicating the cracks are active, the cracks were considered to be cosmetic with no adverse effect on the structural integrity of the walls. The applicant stated that during the period of extended operation, the spray ponds will be monitored by the enhanced Structures Monitoring Program, which will include acceptance criteria developed from the guidelines in ACI 349.3R.
The staff does not consider this adequate, because without a comprehensive, quantitative inspection to capture current levels of degradation, inspections during the period of extended operation have no baseline to compare degradation against.
Request:
Based on the existing degradation noted during the walk down, provide and justify a time-line for conducting a baseline inspection of the spray ponds (including submerged portions), using quantitative acceptance criteria in accordance with ACI 349.3R, prior to the period of extended operation. If a baseline inspection prior to the period of extended operation is not scheduled, explain and justify why it is unnecessary.
Energy Northwest Response:
Energy Northwest will conduct a baseline inspection of the spray ponds (including submerged portions) plus a minimum of one additional inspection prior to entering the period of extended operation. Inspection will use quantitative acceptance criteria in accordance with ACI 349.3R.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 8 LRA Table A-1 is amended to reflect these inspections. A marked up copy of LRA Table A-1 showing these changes is enclosed.
RAI 3.5.2.2.1.4-1
Background:
Industry operating experience has identified water leakage from refueling cavity liners and bellows, which may contact the primary containment vessel.
Issue:
CGS has no leakage detection system or alarm that could identify leakage into the annular space between the steel containment and the shield wall, other than the sand pocket drains. Although leakage has not been detected in the sand pocket drains, leakage may become trapped by the compressible material in the annular space above the sand pocket region and never reach the drains. Without a clear drainage path for possible leak detection, additional inspections should be conducted to verify leakage is not entering the annular region.
Request:
Discuss any additional visual (VT-1 or VT-3) or NDE examinations of the stainless steel refueling cavity liner and the bellows being conducted to verify leakage is not entering the annular space between the containment vessel and the concrete shield wall.
Energy Northwest Response:
The configuration of the outer refueling bellows does not lend itself to visual inspection or NDE examination from the refueling cavity that might be able to detect the potential for leakage. Therefore, no additional visual inspections or NDE examinations of this seal are planned.
However, the containment vessel has eight inspection ports equally spaced around the shell centered at the 570 foot elevation, which is below the elevation of the refueling bellows. These ports are 16" diameter and covered with bolted plates. Removal of these plates will allow visual inspection of the outer containment shell in the area adjacent to these inspection ports. To verify leakage, is not entering the annular space between the containment vessel and the concrete shield wall from the outer refueling bellows seal, visual inspection of portions of the outer containment vessel shell will be performed of the areas made accessible by opening all eight inspection ports in the containment vessel at 570 foot elevation. These inspections will be performed during a refueling outage while the reactor cavity is flooded and completed during the fourth ISI inspection interval prior to the period of extended operation (PEO) and the fifth ISI inspection interval after entering the PEO. This represents a new commitment. The
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 8 enclosed marked up LRA Appendix A reflects this new commitment.
RAI 3.5.2.2.2.3-1
Background:
SRP-LR Section 3.5.2.2.2.3 notes that the GALL Report recommends further evaluation for any concrete elements that exceed the specified temperature limits (>1 50°F general or 200°F local) for normal operation or any other long-term period.
Issue:
LRA Section 3.5.2.2.2.3 states that in-scope concrete is not exposed to temperatures above the GALL Report limits. The LRA further states that the general air temperatures are maintained below the 150°F threshold and the limits are given in FSAR Table 3.11-1. However, while reviewing FSAR Table 3.11-1, the staff noted that several areas (DG 1 and DG2 Day Tank Room, and HPCS Day Tank Room) had temperature limits that exceeded the 150°F threshold.
Request:
Explain how concrete in these areas will be managed for possible aging effects due to elevated temperatures, or explain why additional aging management is unnecessary.
Energy Northwest Response:
FSAR Table 3.11-1 Note Section listed areas DG1 and DG2 Day Tank Room, and HPCS Day Tank Room with an operability temperature limit of 1620F. These limits are accompanied by Note h which states "During design basis events this temperature may be exceeded for a short period of time (<30 days). These room temperatures are used to support the evaluated design capability of equipment during design basis events.
Analysis has confirmed that these rooms will not exceed the temperatures listed."
Appendix A of ACI 349-85 specifies that the concrete temperature limits for normal operation or any other long term period shall not exceed 150°F except for local areas, which are allowed to have increased temperatures not to exceed 200'F. The operability temperature limit of 162 0 F for the DG1 and DG2 Day Tank Room, and HPCS Day Tank Room are not normal operation temperature for these areas but are operability temperature experienced for a short period of time (<30 days) post design basis events.
The normal operating temperature for the Diesel Generator Building is shown in FSAR Table 3.11-1 as Area VII which has a maximum normal operating temperature of 120'F (emergency diesel generator engine rooms). This maximum normal operating temperature is within the concrete temperature threshold from Appendix A of ACI 349-85. Therefore, the aging effect due to elevated temperatures is not applicable.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 License Renewal Application Amendment 17 Section No. Page No. RAI Response Table 3.2.2-2 3.2-56 3.2.2.3.1-1 Row 55 Table 3.3.2-42 3.3-390 3.3.2.3.16-1 New row Table 3.3.2-42 3.3-390b 3.3.2.3.16-1 Row 117 Table 3.4.2-3 3.4-53 3.3.2.3.16-1 New row Table 3.4.2-3 3.4-53b 3.3.2.3.16-1 Row 88 Table A-i A-65 B.2.50-6 Item 53 Table A-i A-65a B.2.50-6 Insert B Table A-i A-68b 3.5.2.2.1.4-1 Item 64
Columbia Generating Station License Renewal Application Technical Information Table 3.2.2-2 Aging Management Review Results - Reactor Core Isolation Cooling System dAging Effect NUREG-Row Component Intended Material Environment Aging ffect Aging Management 1801 TableINoe Requiring Agn Ma ge nt 1 0T bl 1 No s No. Type Function(s) Management Program Volume 2 Item. Item 51 Piping Pressure boundary Steel Air-indoor uncontrolled (internal) Loss of External MonitoringSurfaces mtraMoirngV.D2-:16 material 3.2.1-32 E PrsueLoss Air-indoor of Prvntv Preventive 52 Piping boundary Steel uncontrolled Maintenance - RCIC V.D2-16 3.2.1-32 E (Internal) material Turbine Casing 0204 53 Piping Pressure Steel Lubricating Loss of Lubricating Oil V.D2-30 3.2.1-16 A boundary oil (Internal) material Analysis 54 Piping Pressure Lubricating Loss of Lubricating Oil V.D2-30 3.2.1-16 A boundary oil (Internal) material Inspection Pressure Moist air Loss of Supplemental 55 Piping Steel (Internal) material Piping/Tank N/A N/A G gboundary Inspection 56 Piping Pressure SteelSteam Loss of BWR Water VIII.B2-3 3.4.1-37 A 0201 boundary (Internal) material Chemistry Pressure Steam Loss of Chemistry Program 57 Piping Steel (Internal) material Effectiveness VIII.B2-3 3.4.1-37 E gboundary Inspection 58 Piping Pressure Steam Loss of Flow-Accelerated V.02-31 3.2.1-19 A boundary Steel (Internal) material Corrosion (FAC)
Pressure Treated Loss of BWR Water Piping boundary Steel water V.D2-33 3.2.1-14 A E I I (Internal) material Chemistry Aging Management Review Results Page 3.2-56 FAmendment 1
Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-42 Aging Management Review Results - Standby Service Water System
- Aging NUREG-NRG Aging Effect Row Component Intended M 1801 Table I Notes No. Type Function(s) e nvironment Requiring Management Vlm It Management Program 2 Item Item Air-indoor 331- A 105 Valve Body Structural Stainless uncontrolled None None VII.J-15 integrity Steel (Internal) 94 0306 Structural Stainless Raw water Loss of Open-Cycle V C 3.1-integrity Steel (Internal) material Cooling Water 79 Structural Stainless Air-indoor 107 Valve Body. uncontrolled None None VII.J-15 3.3.1- A integrity Steel (External) 94_A Air-indoor External 108 Valve Body Structural Steel uncontrolled LossSurfaces VII.-8 integrity (Internal) material Monitoring 58 0302 109 Valve Body Structural Steel Raw water Loss of Open-Cycle VII.C1-19 33.1- B integrity. Se(Internal) material Cooling Water 76 Structural Air-indoor SurfacesExternl 3.3.1-E 110 Valve Body integrity Steel uncontrolled Loss of Surfaces VII.-8 A interit (External) material Monitoring 1 58 Add new rows 111 Insert new row through 116 shown 117 shown on on page 3.3-390a Page 3.3-390b Aging. Management Review Results Page 3.3-390 January 2ui)7Iu jAmenibdmnent
Columbia Generating Station License Renewal Application Technical Information Table 3.3.2-42 Aging Management Review Results - Standby Service Water System Aging Effect Aging NUREG-Row Component Intended Material Environment Requiring Management 1801 Table Notes No. Type Function(s) Management Program Volume I Item 2 Item Pressure Stainless Moist air Loss of Supplemental 3.3.1- E 117 Piping boundary Steel (Internal) material Inspection VIID-4 54 0303 Amendment 17 Aging Management Review Results Management Review Results Page 3.3-390b Page 3.3-390b Amendment 17
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Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-3 Aging Management Review Results - Condensate (Nuclear) System Aging Effect NUREG-Row Component Intended Material Environment Requiring Aging Management 1801 Table Notes NO. Type Function(s) Management Program Volume I Item 2 Item Structural Stainless Air-indoor 3.4.1-78 Valve Body uncontrolled None None VIII.1-10 A integrity Steel (External) 41 79 Structural Stainless Condensation Loss of External Surfaces N/A N/A G Valve Body integrity Steel (External) material Monitoring Structural Treated water Loss of BWR Water 3.4.1-integrity (Internal) material Chemistry 04 81 Valve Body Structural Treated water Loss of Chemistry Program 341-Steel Effectiveness VIII. E-33 A,4.
integrity (Internal) material Inspection .04A Air-indoor Loss of External Surfaces 3.4.1-82 Valve Body integrity Steel uncontrolled material 'Monitoring VIII.H-7 A (External) 28 Structural Condensation Loss of External Surfaces 3 4 1-integrity Te (External) material Monitoring 28 Insert new rows 84 Insert new row through 87 to Table 88 to Table 3.4.2-3 as shown 3.4.2-3 as shown on page 3.4-53a on page 3.4-53b Aging Management Review Results ,Page 3.4-53 dal ical Y20
Columbia Generating Station License Renewal Application Technical Information Table 3.4.2-3 Aging Management Review Results - Condensate (Nuclear) System Aging Effect Aging NUREG-Row Component Intended Aging Magint 1801 Table No. Type Function(s) Material Environment Requiring Management Volume I Item Notes Management Program 2 Item Stainless Moist air Supplemental Pressure 88 Tubing boundary Steel (Internal) Loss of material Piping/Tank N/A N/A G 8 Ls of m l PIp k I NInspection I I Amendment 17 Aging Management Review Aging Management Results Review Results Page 3.4-53b Page 3.4-53b Amendment 17
Columbia Generating Station License Renewal Application Technical Information Table A-1 Columbia License Renewal Commitments I 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.
In-sert Afrom Page A-65aj Add Insert B from Page A-65a Final Safety Analysis Report Supplement Page A-65 JaIzfyj-94 IAmendment 17
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.
Insert B to Page A-65
- Energy Northwest will conduct a baseline inspection of the spray ponds (including submerged portions) plus a minimum of one additional inspection prior to entering the period of extended operation. Inspection will use quantitative acceptance criteria in accordance with ACI 349.3R.
Final Safety Analysis Report Supplement Page A-65a A-MC9nemnt 4 J~mdent 17 1
Columbia Generating Station License Renewal Application Technical Information ColubiaGen Insert A into oaae A-68a Enhancement FSAR Supplement Commitment Location or Item Number (LRA App. A) Implementation Schedule
- 62) Service Level 1 The Service Level 1 Protective Coatings A.1.2.55 Ongoing Protective Coatings Program is an existing program that will be Program continued for the period of extended operation.
- 63) Inservice Inspection Ultrasonic Testing (UT) examination of A.1.2.33 When demonstrated (ISI) Program creviced shroud support plate access hole acceptable UT cover weld, top hat configuration, will be technique is available.
performed once a demonstrated acceptable UT technique becomes available. Then ongoing.
- 64) Inservice Inspection Verify leakage is not entering the annular N/A During the fourth (ISI) Program - IWE space between the containment vessel and Inservice Inspection the concrete shield wall from the outer (ISI) interval prior to the refueling bellows seal. Inspection of the period of extended portions of the outer containment vessel operation (PEO) and shell made accessible by opening all eight again in the fifth ISI inspection ports in the containment vessel at interval after entering 570 foot elevation will be performed to check the PEO.
for evidence of leakage. These inspections will be performed during a refueling outage while the reactor cavity is flooded.
Page Amendment Safety Analysis Final Safety Analysis Report Supplement Report Supplement Page A-68b A-68b Amendment 17
- 3!ý" 45 Sttio