ML11147A157
| ML11147A157 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 05/26/2011 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G02-11-098 | |
| Download: ML11147A157 (8) | |
Text
David A. Swank ENERG~Y Acting Vice President, Engineering P.O. Box 968, Mail Drop PE23 Richland, WA 99352-0968 Ph. 509-377-2309 F. 509-377-4173 daswank@ energy-northwest.com May 26, 2011 G02-11-098 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 March 15, 2011, NRC to Energy Northwest, "Summary of Telephone Conference Call Held on March 8, 2011, Between the US Nuclear Regulatory Commission and Energy Northwest, Concerning the Responses to the Request for Additional Information Pertaining to the Columbia Generating Station, License Renewal Application (ML110690997)"
- 3) Letter dated April 21, 2011, Energy Northwest to NRC, "Columbia Generating Station, Docket No.50-397 Response to Request for Additional Information License Renewal Application (G02-11-083)"
Dear Sir or Madam:
By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. A conference call was conducted with the NRC on March 8, 2011 (Reference 2) which specifically addressed License Renewal Application (LRA) Table 3.1.2-3, row numbers 182 and 183 for Cast Austenitic Stainless Steel (CASS) valves less than 4 inches in the In-Service Inspection (ISI) program at Columbia. However, during the review of documentation for preparing the response to the NRC, it was determined that there are no American Society of Mechanical Engineers (ASME) III Class 1 CASS valves less than 4 inches installed at Columbia.
Therefore, the LRA was amended (Amendment 31 via Reference 3) to remove row numbers 182 and 183.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 There are other rows in LRA Table 3.1.2-3 (rows 128 through 135) that address CASS valves less than 4 inches. The response in Reference 3 was focused on rows 182 and 183 only when, in fact, it should have addressed all of the ASME III Class I CASS valves less than 4 inches.
The LRA has been amended to remove all references to ASME III Class 1 CASS valves less than 4 inches. Amendment 35 is provided in the Enclosure. No new commitments are included in this letter.
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.
P~pe tfully, Acting Vice President, Engineering
Enclosure:
License Renewal Application Amendment 35 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
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDENT 35 Section Page RAI Number Number Number Table 3.1.1 3.1-24 Supplement to Line Item 3.1.1-55 RAI 3.1.2.3-01 Table 3.1.2-3 3.1-109 Supplement to Line Items 128-135 RAI 3.1.2.3-01 Supplement to A.1.2.49 A-24a RAI 3.1.2.3-01 Table B-1 B-12 Supplement to Line Item XI.M12 RAI 3.1.2.3-01 B.2.49 B-1 87a Supplement to RAI 3.1.2.3-01
Columbia Generating Station License Renewal Application Technical Information Table 3.1.1 Summary of Aging Management Programs for Reactor Vessel, Internals, and Reactor Coolant System Evaluated in Chapter IV of NUREG-1801 m
A g E Further Item Component/Commodity Aging Effecth Aging Management Evaluation Discussion Number
_Mechanism Programs Recommended 3.1.1-54 Copper alloy piping, piping Loss of material due Closed-Cycle Cooling No TNot applicable.
components, and piping to pitting, crevice, Water System elements exposed to closed and galvanic The reactor coolant pressure cycle cooling water corrosion boundary does not have any copper alloy components.
3.1.1-55 1 Cast austenitic stainless steel Class 1 pump casings, and valve bodies and bonnets exposed to reactor coolant >250 'C (>482 0F)
Loss of fracture toughness due to thermal aging embrittlement Inservice inspection (IWB, IWC, and IWD).
Thermal aging susceptibility screening is not necessary, inservice inspection requirements are sufficient for managing these aging effects.
ASME Code Case N-481 also provides an alternative for pump casings.
No Consistent with NUREG-1801.
Loss of fracture toughness for Class 1 pump casings and valve bodies is managed by the Inservice Inspection (ISI)
Program.
fnr ~
0'U~
flAS~*
- nlo, aet 1 inch4 e is included in this item and managed by the Small Bore Clas's 1 I~Piping InPciOn.
f-<
3.1.1-56 Copper alloy >15% Zn piping, Loss of material due Selective Leaching of No Not applicable.
piping components, and piping to selective leaching Materials elements exposed to closed The reactor coolant pressure cycle cooling water boundary does not include any copper alloy >15% Zn components.
Aging Management Review, Results Page 3.11-24
-a~uar' 2010 FAmendment 35
'Amendr'ment 7
Columbia Generating Station License Renewal Application Technical Information Table 3.1.2-3 Aging Management Review Results - Reactor Coolant Pressure Boundary dAging Effect NNUREG-Row Material Environment Requiring Aging Management 1801 Table 1 Notes No.
Type Function(s)
Malagenent Program Volume 2 Item
_Management Item PressureAir-Indoor 127 Tubing boundary Stainless Steel Uncontrolled None None IV.E-2 3.1.1-86 A
(External)
.Vqlv BdiRa tPressureor Cracking -
inches boundary (Internal)
Fatigue I
Reactor i39 Valve Bodies Pressure Reac torl,.
Cracking - Flaw I Small Bore Class 1 3,,
4
< 4 inches boundary (Internal)
Growth Piping,inepeeti 1 0 V a l v e B o d i e s P r e s s u r e R e a c t or^*÷w, C r a c k i n g -_
, \\ /._ *"
8,
<4inches boundary (Internal)
SCC/IGA.........
T E
Reactor Valve Bodies Pressure Crackina -
Small Bore Class 1 k*
i
- u]
< 4 inches boundary SCC/IGA Piping 4 feRAt
_. ;A Por (Internal)
SCCIG
- -ro Reactor
,,, Valve Bodies Pressure Reactor...
- "A 3*
~
Vave odes Presue ASS 6e at
-Loss of Matera BWPR Water Chemisti-y -1+0-4-1-4-31. 4 6g -A-
< 4 inches boundary (Internal)
___I_.v
_,v,,,,,,,,sr Reactor Chemistry Program Valve Bodies Pressure
.1 1
- A A 5
A 13 5,,
o 4*
ud in h s b u d ryIJU0t LU Z f,,zt,
- ,M10 Efc,, ivens, I*
v A I*
,- I-
<4 inches boundary (Internal)
Inspection Valve Bodies Pressure Reactor Reduction of Small Bore Class 1 134 Fale W
B e
3 1rcurS 1-55 F:
em.
Ii
~1
,v
< 4 inches boundary (Internal)
Toughness Piping Fspeee<__
91~ a0111 Valve Bodies Pressure Air-Indoor
< 4 inches boundary (External)
HUI M:
Aging Management Review Results Page 3.1-109 Aging Management Review Results Page 3.1-109 jaRuaFy 2010 1 A dmi, &-4
__3 I'
Amendment 5
Columbia Generating Station License Renewal Application Technical Information Insert A to Page A-24 The Small Bore Class 1 Piping Program will detect and characterize cracking of small bore Class 1 piping components that are exposed to reactor coolant.
This periodic program will provide physical evidence as to whether, and to what extent, cracking due to SCC or to thermal or mechanical loading has occurred in small bore Class 1 piping components.
It will
,also verify, by inspections for cracking, that reduction of fracture tougqhnAesse to thermal dubrittlenent require no*
(a*dAd'l aging management for smnall Class I c-*ast austentic stainless steel valve, bod The Small Bore Class 1 Piping Program will be a condition monitoring program with no actions to prevent or mitigate aging effects. The program will include visual and volumetric inspection of a representative sample of small bore Class 1 piping, including butt welds and socket welds.
The Small Bore Class 1 Piping Program is a new program that will be implemented prior to the period of extended operation. Inspection activities will start during the fourth 10-year inservice inspection interval and continue through the period of extended operation. The Small Bore Class 1 Piping Program will credit portions of the Inservice Inspection Program.
The Small Bore Class 1 Piping Program will verify the effectiveness of the BWR Water Chemistry Program in mitigating cracking of small bore piping and piping components.
Insert B into page A-24 The Service Air System Inspection Program manages the effect of loss of material due to corrosion of steel piping and valve bodies exposed to an "air (internal)" (i.e., compressed air) environment within the license renewal boundary of the Service Air System.
The Service Air System Inspection Program is a new plant-specific program that will be implemented via baseline inspection of a sample population followed by opportunistic inspections when components are opened for periodic maintenance, repair, or surveillances when surfaces are made available for inspection.
These inspections ensure that the existing environmental conditions are not causing material degradation that could result in a loss of component intended function during the period of extended operation. Inspection of a sample population will be conducted within the 10-year period prior to the period of extended operation and will serve as a baseline for future inspections.
Final Safety Analysis Report Supplement Page A-24a Amendment ý 24
Columbia Generating Station License Renewal Application Technical Information Table B-1 Correlation of NUREG-1801 and Columbia Aging Management Programs (continued)
Number NUREG-1801 Program Corresponding Columbia AMP XI.M10 Boric Acid Corrosion Not Applicable. Columbia is a BWR and does not use boric acid in any systems. The Standby Liquid Control System uses a sodium pentaborate solution (a mixture of boric acid and borax) that is not aggressive to metals.
XI.M11A Nickel-Alloy Penetration Not Applicable. This program is applicable to PWR Nozzles Welded to the plants, Columbia is a BWR.
Upper Reactor Vessel Closure Heads of Pressurized Water Reactors XI.M12 Thermal Aging Not credited for aging management. The Inservice Embrittlement of Cast Inspection (ISI) Program (See Section B.2,33 P
Austenitic Stainless Steel the Small Bore Class ! Pipnp t
(CASS)
-2.49 is credited for pump casings and valve bodies.
XI.M13 Thermal Aging and Neutron Thermal Aging and Neutron Embrittlement of Cast Irradiation Embrittlement of Austenitic Stainless Steel (CASS) Program Cast Austenitic Stainless See Section B.2.52.
Steel (CASS)
XI.M14 Loose Parts Monitoring Not credited for aging management. The Columbia loose parts detection system has been deactivated and spared in-place, as described in FSAR Section 7.7.1.12.
XI.M15 Neutron Noise Monitoring Not Applicable. This program is applicable to PWR plants, Columbia is a BWR.
XI.M16 PWR Vessel Internals Not Applicable. This program is applicable to PWR plants, Columbia is a BWR.-
XI.M17 Flow-Accelerated Corrosion Flow-Accelerated Corrosion (FAC) Program See Section B.2.28.
XI.M18 Bolting Integrity Bolting Integrity Program See Section B.2.4.
XI.M19 Steam Generator Tube Not Applicable. Columbia is a BWR design that Integrity does not utilize steam generators.
Aging Management Programs Page B-12 I
anuepL-af) 1 Amendment 7 Amendment 35
B.2.49 Small Bore Piping Program I Columbia Generating Station License Renewal Application Technical Information Insert A to Page B-1 87 The Small Bore Class 1 Piping Program will detect and characterize cracking of small bore, less that 4 inches nominal pipe size, Class 1 piping components (piping, fittings, branch connections, and valve bodies) that are exposed to reactor coolant.
This periodic program will provide physical evidence as to whether, and to what extent, cracking due to SCC or to thermal or mechanical loading has occurred in small bore Class 1 piping components. It will also verify, by inspections for "ree--ng, that rc-ductie Of fraCture toughness -'-de to thermal embittle.ent requires n.
dditional aging management for small b[rc Class I cast austenitic stainless steel valIv bodies. The Small Bore Class 1 Piping Program will be a condition monitoring program with no actions to prevent or mitigate aging effects.
While the ASME Code does not require volumetric examination of Class 1 small bore piping, the Small Bore Class 1 Piping Program includes visual and volumetric inspection of a representative sample of small bore Class 1 piping components; the sample will include butt welds and socket welds, and will focus on the bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.
Actual inspection locations will be based on physical accessibility, exposure levels, NDE techniques, and locations identified in NRC Information Notice 97-46.
Volumetric examinations (including destructive and/or nondestructive techniques) will be performed by qualified personnel following procedures that are consistent with Section Xl of the ASME Code and 10 CFR 50, Appendix B.
__. Replace with Insert A from Page B-1 87b In scope components will be grouped to populations based on component type, material and environment. Sample izc,-,ill be 10% of each population (except socket
.. l..) with 4
minimum of one locatien and-a maximu. o Of....
lc aions; the socket weld sample will include three locations. 100% of each sample will be inspected each 10-year ISl interval, with the breakdown of inspections between outages within the interval per ASME Section Xl, Subsection IWB, Program B.
If a qualified non-destructive volumetric examination technique does not become available for socket welds, destructive examination will be conducted.
Opportunistic destructive examination will be performed when socket welds are removed from service for other considerations, such as plant modifications. If socket welds do not become available on opportunistic bases prior to the scheduled inspections within the 10-year interval, then socket welds will be selected for planned destructive examinations.
Unacceptable inspection findings will be evaluated by the Columbia corrective action process. The evaluation of indications will include determining the extent of condition by the expansion of the sample size.
Aging Management Programs Page a-187a A.mendment7 LAmendment 35 dI
.-1