ML110970354

License Renewal Application Second Annual Changes Update

ML110970354
Person / Time
Site:	Columbia
Issue date:	04/05/2011
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G02-11-074, TAC ME2121
Download: ML110970354 (12)

Text

Sudesh K. Gambhir ENERGY Vice President, Engineering P.O. Box 968, Mail Drop PE04 Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgambhir@ energy-northwest.com April 5, 2011 G02-11-074 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE RENEWAL APPLICATION SECOND ANNUAL UPDATE

References:

1) Letter, G02-1 0-011, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter, G02-10-094, dated July 16, 2010, SK Gambhir (Energy Northwest), "License Renewal Application First Annual Update"

3) Letter, G02-1 1-011, dated January 14, 2011, SK Gambhir (Energy Northwest), "Response to Request for Additional Information License Renewal Application"

4) Letter dated May 27, 2010, NRC to JV Parrish (Energy Northwest),

"Issuance of Amendment Re: Changes to Technical Specifications Related to Diesel Generator Fuel Oil Storage and Testing (TAC NO.

ME2121)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. The first annual update was provided to the Nuclear Regulatory Commission (NRC) in Reference 2. The License Renewal Rule, 10 CFR 54.21 (b), requires that each year following submittal of a license renewal application (LRA), and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA.

LICENSE RENEWAL APPLICATION SECOND ANNUAL UPDATE Page 2 of 2 In accordance with this requirement, Energy Northwest performed a review of CLB changes after the LRA First Annual Update reference freeze date of January 2010 that formed the basis for the submittal of Reference 2 to determine if the LRA was affected by these changes. The reference freeze date for this review was November 1, 2010.

This update also includes a review of applicable industry and plant specific operating experience for the same time frame. No changes in the CLB were found that necessitated an amendment to the LRA.

During the reviews, the Energy Northwest discovered several administrative or editorial changes that have been incorporated into Amendment 29 and provided as the enclosure to this letter. The attachment provides a brief explanation of the changes made.

No new commitments are included in this response. However, there are commitments that are changed for consistency or clarification.

If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

ectfully, ambhir Vice President, Engineering

Enclosure:

License Renewal Application Amendment 29

Attachment:

Summary of LRA Changes cc:

NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1 399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a)

BE Holian - NRC NRR RR Cowley - WDOH

LICENSE RENEWAL APPLICATION SECOND ANNUAL UPDATE Attachment Page 1 of 1 AMMENDMENT 29 Summary of LRA Changes LRA LRA Summary Type Section Page A.1.2.32 A-18a Indicated reference information for document Editorial A.1.4 A-41 added in Amendment 16 A. 1.2.47 A-24 Change 10-year period to no earlier than 5 years prior to the period of Table A-i, # 47 A-60 extended operation for consistency with Section B.2.47 Update to reflect complete A. 1.2.54 A-26a response provided in Consistency Amendment 20 cover letter (Reference 3)

Table A-i, #65 A-68c Added the program name Table A-1, #68 A-68d to the item column Consistency

& 69 Table A-i, #65, A-68c Corrected or removed 66, 67, incorrect FSAR Consistency Table A-i, #68 A-68d supplement locations

& 69 Clarified that the "subject Table A-i, #69 A-68d welds" were portions of Editorial the reactor pressure vessel welds BG and BM Revised "Exceptions to NUREG-1 801" for "Parameters Monitored and Inspected" and B.2.29 B-122 "Detection of Aging Consistency Effects" to reflect Technical Specification Amendment 215 (Reference 4)

Update to reflect complete B.2.54 B-208b response provided in Consistency Amendment 20 cover letter

iSection A.1.2.32 I Columbia Generating Station License Renewal Application Technical Information (Reference A. 1.4-3)

Insert A E --

>. 4.__0

,j POwe~r i The Ina *cessible,Mdini*-'Voltage Cables Not Subject to 10 CFR 50.49 EQ Requir,.*ents^,Programw*^ will manage the aging of in-scope, m~ediumveltage

,cables exposed to significant moisture and s First tests or first inspections for license renewal will be completed before the period nded operation. These cables will be tested at least once every ars to provide an indication of the condition of the conductor insulation. The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR -103834-P or other testing that is state-of-the-art at the time the test is performed.

ificant moisture is defined as periodic exposures that last more than a few days (e.g., cable in standing water). Periodic exposures that last less than a few days (e.g., normal rain and drain) are not significant. Signifieant voltage exposure iA-defined as being 66ubjected to system voltage for: mr~e than 25% of the time.

The moisture and voltage eXPosuresdcribe a, signlifiant inthes dfiniion Wrc not significant for medium voltage cables thatr deiged fer thce conditions (e.g., contin..us wetting and continuous energi.ation are not significa.t for submar4ne cables). In addition, inspection for water collection will be performed based on actual plant experience with water accumulation */the manholes. However, the inspection frequency will be at least yefrf-. <\\-

N\\

in electrical manholes Manhole inspections will also be performed periodically, in response to event-driven occurrences (such as heavy rain or flooding).

IIl Final Safety Analysis Report Supplement Page A-18 a Af nmendmenmt2S 9

IA~mend 0Menýt 161 Amenment 29

Columbia Generating Station License Renewal Application Technical Information A.1.3.7.3 Main Steam Flow Restrictor Erosion Analyses The main steam line flow restrictors are designed to limit coolant flow rate from the reactor vessel (before the MSIVs are closed) to less than 200 percent of normal flow in the event of a main steam line break outside the containment.

Erosion of a flow restrictor is a safety concern since it could impair the ability of the flow restrictor to limit vessel blowdown following a main steam line break. Since erosion is a time-related phenomenon, the analysis for the effect it has on the flow restrictors over the life of the plant is a TLAA. Cast stainless steel (SA351, Type CF8) was selected for the steam flow restrictor material because it has excellent resistance to erosion-corrosion from high velocity steam.

The erosion of the main steam flow restrictors has been projected for the period of extended operation. The projection concludes that after 60 years of erosion on the main steam flow restrictors, the choked flow will still be less than 200 percent of normal flow. Therefore, the main steam flow restrictors will continue to perform their intended function and the existing accident radiological release analysis will remain valid for the period of extended operation.

Disposition The TLAA for erosion of the main steam line flow restrictors has been projected to the end of the period of extended operation.

A.1.4 References A. 1.4-1 BWROG Report GE-NE-523-A71-0594-A, Rev 1, "Alternate BWR Feedwater Nozzle Inspection Requirements," May 2000 A. 1.4-2 EPRI Report No. 1011838, "Recommendations for An Effective Flow Accelerated Corrosion Program (NSAC-202L-R3)," May 2006 A.1.5 License Renewal Commitment List A listing of commitments identified in association with Columbia license renewal is provided in Table A-1.

These commitments will be tracked within the Columbia regulatory commitment management program. Any other actions discussed in the LRA represent intended or planned actions. They are described to the NRC for information and are not regulatory commitments.

-l A.1.4-3 EPRI TR-103834-P1-2, "Effects of Moisture on the Life of Power Plant Cables," August 1994 Final Safety Analysis Report Supplement Page A-41 jan.

Q4Q 2.1, JAmendment 29 *1

Columbia Generating Station License Renewal Application Technical Information Energy Northwest follows the requirements of the BWRVIP ISP and applies the ISP data to Columbia. The NRC has approved the use of the BWRVIP ISP in place of a unique plant program for Columbia.

The provisions of 10 CFR 50 Appendix G require Columbia to operate within the currently licensed pressure-temperature (P-T) limit curves, and to update these curves as necessary. The P-T limit curves, as contained in plant technical specifications, will be updated as necessary through the period of extended operation as part of the Reactor Vessel Surveillance Program. Reactor vessel P-T limits will thus be managed for the period of extended operation.

A.1.2.47 Selective Leaching Inspection The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water, treated water, fuel oil, soil, and moist air (including condensation) environments. The inspection provides direct evidence through a combination of visual examination and hardness testing, or NRC-approved alternative, as to whether, and to what extent, a loss of material due to selective leaching has occurred.

The Selective Leaching Inspection is a new one-time inspection that will be implemented prior to the period of extended operation. The inspection activities will be conducted.withinhe 10- year pevie.-prior to the period of extended operation.

Ino earlier than 5 years Se s

tram A.1.2.48 Service Air System Inspection 1rra Insert B from Page A-24a s-e,. piping and valve b.dics expos. d to an "air (internal)" (i.e.,

.mp.css;d air cnirnmnt within the license rcnewal boundary of the Serviee Air System.

The inspection provfides direct evidence as to whcthcr, and to what extent, a loss of material due to corrosion has eeGu~rrd.

The SeR'ice Air System Inspection is a new one time inspeetien that will be 0,mp**4Vlem n

e pUl r

l 1

11V

• ,li

./l..

P d

r e

extende epe.rLf*

TAII fatien 1

l.

l.A IV Th Inp ete ae i

.tis wlgll be*.A onduetd within the 10 year perid prir to the perid of extended operation.

Program A.1.2.49 Small Bore Class 1 Piping h IeAfma 2

Ilnset ýAfro~mPag~eA-2ý4a The Small Bore Class I Piping Inspection wil detect and-charact*l erize the c*onitolns onR the intornlal suirfacos of small bore Class 1 Piping components that arcexpsdt roactor coolant.

The Small Bore Class I Piping Inspection will ple'V'idc physical evidene as to Whether, and to what extent, cracking duo to SOC or to thermqa! Or mnechanical loading has occurred in; small bore Class 1 piping componentS. Th~e SmallI Bore Class I Piping Inspection will also vent,', by ipetosfor cracking, that Final Safety Analysis Report Supplement Page A-24 Janua.y 2100 JAmendment 29

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

47) Selective Leaching Inspection The Selective Leaching Inspection is a new activity.

The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water, treated water, fuel oil, soil, and moist air (including condensation) environments. The inspection provides direct evidence through a combination of visual examination and hardness testing, or NRC-approved alternative, as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.47 Within the In y,*rnari-lI prior to the period of extended operation.

No earlier than 5 years

48) Service Air The Scvre Air Systcm lncpcctien Is a new activ#iY.

A.1.2.48 System Tho Se.'Hcc Air Systcm Incpcction dctects and charactcizcs thc Inspection mr"aterial condition of steel piping and valve bedies

.xpozd to an "air (intcrnal)" (i.e., cOmqprecccd air) onViFronmont Within the 'iconce renewal bo*undary of the Se-,icc Air System. The ;-in-pectiORn Program pr.Vide. direct

.vidonce as to whether, and to what extent, the relevant iffocts of aging havo occurred-.

Replace with Insert A on page A-60a I

Replace with Insert B on page A-60a Final Safety Analysis Report Supplement Page A-60 2810-JAmendrn nt 29 e-----ý

Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-26 A.1.2.54 Boron Carbide Monitoring Program The Boron Carbide Monitoring Program detects degradation of Boron Carbide (B4C) neutron absorbers in the spent fuel storage racks by monitoring spent fuel racks for potential off-gassing pt.

From the monitoring data, the stability and integrit f Boron Carbide in the storage cells are assessed. Periodic monitoring of B4 C permits early determination of aging degradation.

• c u n Ibut may be

,by in situ testing of discontinued based the spent fuel racks, on in situ testing or by inspecting the results B4C coupons.

Final Safety Analysis Report Supplement Page A-26a AmR4ReRt j~mndmnt29 -'

I abeA-1 Columbia Generating Station License Renewal Application Technical Information Insert A into Page A-68b FSAR Enhancement Item Number Commitment Supplement or Location Implementation (LRA App. A)

Schedule

65)

L-SI Columbia will prepare and submit the ISI Program Plan for the I PA.A.n.rln,,

Upon submittal Inservice fourth 10-year interval no later than 2015. (The third 10-year B

of the ISI Inspection (ISI)

ISI interval extends from December 2005 until December, Program Plan Program 2015.) The small bore piping program will be included in the A.1.2.33 for the fourth fourth 10-year interval ISI program plan as an augmented 10-year interval inspection. The locations to be inspected, the sample size, the inspection methodology will be included in the program plan.

66) Structures Perform a one-time internal inspection of the spent fuel pool tell Prior to the period Monitoring Program tale drain lines prior to the period of extended operation to A.1.2.50 of extended confirm the drain lines are free of obstructions. Unexpected operation.

inspection result of clogged lines will require a condition report be documented and further engineering evaluation of adverse impacts to the spent fuel pool structure and to identify the periodicity of drain cleaning and maintenance process.

67) Structures Perform a one-time boroscope inspection of the containment Prior to 12/31/15 Monitoring Program sand pocket drain lines to confirm the absence of clogged drain A.1.2.50 lines and that a flow path exists for identification of any potential leakage into the sand pocket region. Unexpected inspection results (clogged drain lines) will be documented under corrective action process.

Insert new row 68 from

'---Insert new rows 69 and page A-68d 170 from page A-68d Final Safety Analysis Report Supplement Page A-68c Amdmepnt 22 Ame*dment 18 Amdmntt28 1--Amemenet29

I Table A-Columbia Generating Station License Renewal Application Technical Information Insert into page A-68c FSAR Enhancement Item Number Commitment Supplement or Location Implementation (LRA App. A)

Schedule

68)

Ensure that the condenstate (COND) and reactor feedwater (RFW)

Prior to the period Flow-Accelerated systems are screened and evaluated for cavitation prior to entering A.1.2.28 of extended Corrosion (FAC) the period of extended operation (PEO). If the in-scope portion of operation.

Program either system is determined to be susceptible to loss of material due to cavitation erosion, then a program(s) will be modified or created to manage the loss of material

69)

Re-evaluate the flaw. for the period of extended operation (54 Prior to the period Inservice EFPY), in accordance with the requirements of the ASME Code, A. 1.2.33 of extended Inspection (ISl)

Section X1, IWB-3600 based on the results of 2015 inservice operation.

Program inspection. portions of the reactor pressure vessel beltline welds

_BG and BM

70) TLAA -

Perform a 54 EFPY equivalent margin analysis for the embrittlement A.1.3.1.2 Prior to the period Embrittlement of (upper shelf energy) of the reactor vessel N12 (instrumentation) nozzle of extended reactor vessel

forgings, operation Final Safety Analysis Report Supplement Page A-68d Amcndmcnt 26

-- Amendment 291

BColumbia Generating Station License Renewal Application Technical Information combination of ensuring the specified physical and chemical properties of new fuel oil, and periodic cleaning and draining of the storage tanks mitigates corrosion inside the tanks.

" Parameters Monitored and Inspected -

[D27 b09 The program does not include testing of the fuel oil used for the diesel-driven fire pumps for particulates.

Sampling in accordance with ASTM standards 1-796 and D4057 has proven adequate, based on the absence of related problems reported through the corrective action program.

Detection of Aging Effects -

Ilowest point in the tank from the Multi-level sampling of the fuel oil storage tanks is not erformed; rather, a representative fuel stream sample is drawn from the fluchinG "Rno durinRg recirculation al-

.., step 4,.

Required Enhancements None.

Operating Experience The Fuel Oil Chemistry Program is an ongoing program that effectively incorporates the best practices and industry experience in controlling contaminant levels in fuel oil to minimize degradation.

No instances of fuel oil system component failure due to contamination have been identified at Columbia.

With respect to the fuel oil tanks for the emergency diesel generators, review of Columbia operating experience reveals that the Fuel Oil Chemistry Program is adequately preventing a loss of component function of subject components that contain fuel oil.

Fuel oil delivered to the site is sampled and analyzed prior to addition to the fuel oil storage tanks for the emergency diesel generators. Stored fuel oil is periodically sampled and analyzed for both the emergency and fire protection diesel generators.

Water is removed from the stored fuel oil and particulates are filtered. In addition, visual and ultrasonic inspection of an emergency diesel generator fuel oil storage tank, as listed in FSAR Section 9.5.4.4.a, revealed acceptable conditions for the tank internal surfaces; that is, only light corrosion in previously identified areas with no material loss or obvious changes to the condition of the tank.

The fuel oil tanks for the diesel-driven fire pumps are also periodically sampled and analyzed. Water is removed and particulates are filtered based on condition (e.g., when unacceptable levels during periodic sampling necessitate cleaning of the fuel oil).

Review of Columbia operating experience reveals that the Fuel Oil Chemistry Program is adequately preventing a loss of component function of subject components that Aging Management Programs Page B-122 Ja4**ey 291, JAmendment 29

IB.2.54 Columbia Generating Station License Renewal Application Technical Information operating experience. A visual examination of the B4C sample coupons is made to evaluate surface appearance, size, shape and color. Mechanical testing of B4C samples is done on a periodic basis to determine if physical degradation is occurring in the plate material. In addition, chemical testing will take place on a periodic basis to determine if leaching of the boron content is occurring.

Detection of Aging Effects:

The amount of boron loss from the B4C panels is determined through measurement of the boron areal density in the coupons. Visual inspections and measurements, as appropriate, are used to determine and assess the extent of degradation in the Boron Carbide before there is a loss of intended function. This can be supplemented with verification of boron loss in the spent fuel racks through areal density measurement techniques such as the (Boron-1 0 Areal Density Gage for Evaluating Racks) BADGER device.

Ponitoring and Trending:

The periodic inspection measurements and analysis are to be compared to values of previous measurements and analysis to provide a continuing level of data for trend analysis. Also, studies by other utilities using similar B4C material for high density spent fuel racks will be monitored for information.

Acceptance Criteria:

The 5% subcriticality margin of the spent fuel racks is to be maintained for the period of extended operation. Corrective actions are initiated if the test results find that the 5% subcriticality margin cannot be maintained because of the current or projected future degradation. The fuel rack loading pattern will be determined by Reactor Engineering and one or more samples will be analyzed for B-1 0 content. If data continues to suggest less than 5% subcriticality, then blackness testing such as BADGER testing may be performed on the racks as a result of corrective action performed.

Corrective Actions:

The B4C coupon testing will be discontinued if the in situ testing interval is reduced to 6 years or less.

This element is common to with aging management dur discussed in LRA Section B Columbia programs and activities that are credited ing the period of extended operation and is

.1.3.

I Initial in situ testing of the Spent Fuel Rack neutron absorbing material will be performed prior to the period of extended operation to determine the current state of the racks. Additional in situ testing will be based on the results of this initial testing, but at an interval not to exceed ten years.

Aging Management Programs Page 208b Amendment 2 1

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