ML11195A145
| ML11195A145 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/11/2011 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G02-11-117 | |
| Download: ML11195A145 (11) | |
Text
_ NE GY P. 59-37-239 F.509377-173David A.
Swank Acting Vice President, Engineering P.O. Box 968, Mail Drop PE23 URichland, WA 99352-0968 NORT W ESTPh.
509-377-2309 F. 509-377-4173 daswank@ energy-northwest.com July 11, 2011 G02-11-117 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 May 24, 2011, NRC to DA Swank (Energy Northwest),
"Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML11138A323)
- 3) Letter dated June 23, 2011, DA Swank (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-112)
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. In Reference 3, Energy Northwest responded to Reference 2. Following conversations with Mr. Arthur Cunanan, NRC License Renewal Project Manager, and other NRC staff members, Energy Northwest decided to revise the response to RAI B.1.4-1 provided in Reference 3.
Transmitted herewith in the Attachment is the Energy Northwest revised response to the Request for Additional Information (RAI) contained in Reference 2. contains Amendment 38 to the Columbia License Renewal Application.
The commitment number 72 added in Amendment 37 is deleted in this response.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 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.
DA Swank Acting Vice President, Engineering
Attachment:
Response to Request for Additional Information
Enclosure:
License Renewal Application Amendment 38 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 5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"
(ADAMS Accession No. ML11138A323)
RAI B.1.4-1
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 are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation. Section 3.0.1 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2 (SRP-LR), defines an aging management review as the identification of the materials, environments, aging effects, and aging management programs (AMPs) credited for managing the aging effects. In turn, SRP-LR Section A.1.2.3 defines an acceptable AMP as consisting of ten elements. Element 10, "Operating Experience," in part, is described in SRP-LR Section A.1.2.3.10, paragraph 1, as follows:
Consideration of future plant-specific and industry operating experience relating to aging management programs should be discussed. Reviews of operating experience by the applicant in the future may identify areas where aging management programs should be enhanced or new programs developed. An applicant should commit to a future review of plant-specific and industry operating experience to confirm the effectiveness of its aging management programs or indicate a need to develop new aging management programs (emphasis added). This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.
In addition, 10 CFR 54.21 (d) requires the application to contain a final safety analysis report (FSAR) supplement. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation.
Based on its review of the Columbia Generating Station license renewal application (LRA), the staff determined that Section B.1.4 provides a general description of how the applicant gathered and considered operating experience in preparing its LRA, and Sections B.2.1 through B.2.53 summarize the specific operating experience considered for each AMP.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 5 Issue:
Although LRA Sections B.1.4 and B.2.1 through B.2.53 describe how the applicant incorporated operating experience into its AMPs, they do not fully describe how the applicant will use future operating experience to ensure that the AMPs will remain effective for managing the aging effects during the period of extended operation. The majority of the program descriptions contain statements indicating that future operating experience will be used to adjust the programs as appropriate; however, the details of this process are not fully described. Also, some program descriptions contain no such statements and, for these AMPs, it is not clear whether the applicant currently has or intends to implement actions to monitor operating experience on an ongoing basis and use it to ensure the continued effectiveness of the AMPs. In addition, the LRA does not state whether new AMPs will be developed, as necessary.
Further, none of AMP descriptions provide the staff reasonable assurance that ongoing operating experience reviews will continue to inform AMP updates for license renewal.
Request:
Describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and, as necessary, enhance the AMPs or develop new AMPs for license renewal. In this description, address the following:
a) Describe the sources of plant-specific and industry operating experience that are monitored on an ongoing basis to identify potential aging issues. Indicate whether these plant-specific sources require monitoring: corrective action program, system health reports, licensee event reports (LERs), and the results of inspections performed under the AMPs. Similarly, indicate whether these industry sources require monitoring: vendor recommendations, revisions to industry standards on which the AMPs are based, LERs from other plants, NRC Bulletins, Generic Letters, Regulatory Issue Summaries, Information Notices, Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." Describe the criteria used to classify a particular piece of information as aging related and outline the training provided to plant personnel so that they can adequately make such classifications.
b) Describe how the identified aging issues are further evaluated to determine their potential impact on the plant aging management activities. Indicate whether the affected structures and components and their materials, environments, aging effects, aging mechanisms, and AMPs are identified and documented consistent with the methods used to prepare the LRA. Describe how the results of AMP inspections are considered to adjust the frequency of future inspections, establish new inspections, and ensure an adequate depth and breadth of component, material, environment, and aging effect combinations. Describe the records of these evaluations and indicate whether they are maintained in an auditable and retrievable form.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 5 c) Describe the process and criteria used to ensure that the identified enhancements are implemented in a timely manner.
d) Describe the administrative controls over these programmatic activities.
Provide a summary description of these activities for the FSAR supplement required by 10 CFR 54.21(d). If enhancements for license renewal are necessary, also provide the updates for the FSAR supplement.
If such an operating experience program is determined to be unnecessary, provide a detailed explanation of the bases for this determination.
Energy Northwest Response (revised):
Two current programs are used at Columbia to continually monitor and evaluate plant specific and industry Operating Experience (OE) that includes OE regarding aging issues. These programs are the Corrective Action Program (CAP) and the Operating Experience Program (OEP). The evaluations completed under these two programs ensure that Aging Management Programs (AMP) are and will continue to be effective in managing the aging effects for which they are credited or whether the AMP needs to be enhanced, or new AMPs developed. Revisions to the procedures governing the CAP and OEP are approved by the owner organization, in addition to any other reviews designated by the owner organization, and are reviewed for technical accuracy by a minimum of two technical reviewers who are knowledgeable in the affected subject matter (functional areas).
Plant Specific OE:
The CAP ensures the following: A broad range of issues or conditions can be documented and coded to enable trending for the purpose of addressing broader programmatic or process weaknesses. In accordance with plant procedures, Conditions Adverse to Quality (CAQs) and Significant Conditions Adverse to Quality (SCAQs) are identified, reported to the appropriate level of management, and subsequently corrected. The cause of the condition is determined and corrective actions are taken to preclude recurrence. The CAP implements the requirements of 10 CFR 50, Appendix B, Criterion XVI. As such, the CAP is used to monitor plant-specific OE (and industry OE that is relevant to Columbia, via the OEP, which meets the criteria for an "adverse condition"). The CAP is entered when safety or non-safety related equipment is degraded or is not performing as expected or per design is identified. The definition of degraded includes the effects of aging.
Input sources to the CAP include:
- Adverse trends identified in the system health reports.
Equipment failures that result in Plant-specific LERs.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 5 Adverse results of inspections performed under an AMP.
The CAP identifies required due dates commensurate with the safety significance of the condition provided reasonable efforts are made to complete the corrective actions promptly or at the first available opportunity unless appropriate justification is provided for a longer completion schedule.
Completed CAP evaluations are forwarded to the permanent plant files to be maintained in accordance with appropriate records procedures.
Industry OE:
The OEP implements Nuclear Regulatory Commission (NRC) NUREG 0737, "Clarification of TMI Action Plan Requirements,"Section I.C.5, and is consistent with guidance contained in Institute of Nuclear Power Operations (INPO)10-006, Revision 1, "Operating Experience (OE) Program and Construction Experience (CE) Program Descriptions" and INPO 97-011, "Guidelines for the Use of Operating Experience." As such, the OEP monitors industry OE. Specifically the OEP requires that if the evaluation of an industry OE identifies any safety or non-safety related structures, systems or components at Columbia Generating Station that may be inoperable/non-functional, a condition adverse to quality, or non-conformance, then the condition is entered into the CAP to ensure operability is documented and the condition is promptly reviewed and corrected.
Industry OE documents screened in the OEP for applicability to Columbia include, but are not limited to NRC Bulletins, Information Notices, Generic Letters and Regulatory Issues Summaries, 10 CFR 21 Reports, INPO Event Reports, and vendor information.
All License Event Reports (LER) from other plants are not evaluated under the OEP.
Per INPO 10-006, INPO screens all LERs as an input source for issuance as an INPO Event Report. All INPO Event Reports are reviewed under the OEP.
Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to industry standards on which the AMPs are based are not covered under the OEP because these are not OE. These documents may at best they be lagging indicators based on other OE documents covered above.
Industry OE sources are monitored and OE is entered into the OEP and is categorized as: warrants further evaluation to identify barriers or preventive actions, informational, or not applicable. For OE reviews requiring evaluation; if the evaluation identifies any structures, systems or components at Columbia that may be inoperable, a condition adverse to quality, or non-conformance, the CAP is used to determine the action required. Completed OEP evaluations are forwarded to the permanent plant files to be maintained in accordance with appropriate records procedures.
Department Managers/Supervisors are responsible for ensuring OE evaluations are completed in a timely manner.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 5 Equipment Reliability Process:
The equipment reliability process (which is based on industry guidance) represents the integration and coordination of a broad range of equipment reliability activities into one process for plant personnel to evaluate important station equipment, develop and implement a long-term maintenance plan, monitor equipment performance, and make continuing adjustments to tasks and frequencies based on equipment operating experience. This process includes systems, structures, and components within the scope of License Renewal and address the use of plant specific and industry OE. The equipment reliability process performs system component failure and problem trending using maintenance history, CAP data, and OEP data to adjust tasks or frequencies.
The equipment reliability process also considers what other components are susceptible to the failure mechanism.
Training:
AMP owners for existing and new AMPs were selected based on educational background and job experience or duties. In addition, those that are in the Engineering Support Personnel (ESP) population have received classroom training on component aging. The current AMP owners that are not within the ESP population are qualified due to their job position such as being qualified riggers, in the NDE group, or Chemistry group.
The CAP and OEP procedures provide guidance that the OE evaluation is to be assigned to personnel that possess technical knowledge in the subject area.
Appendix A Update:
Energy Northwest will amend LRA Appendix A, Section A. 1.2, to describe CAP and OEP activities.
Energy Northwest recognized that the description in LRA Appendix B.1.4 may be construed as only addressing how OE was used to develop the LRA. Energy Northwest amended this LRA section to clarify that OE review will be continued through the period of extended operation in Amendment 37.
==
Conclusion:==
Energy Northwest has an implemented operating experience review process under the current licensing basis that ensures new relevant operating experience is reviewed and is factored into the aging management programs. This process will be maintained through the period of extended operation.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDMENT 38 Section Page RAI Number Number Number A. 1.2 A-8 B. 1.4-1 A.1.2 A-8a B.1.4-1 Table A-i Linle Ie 7A-68e B.1.4-1 Line Item 72
Columbia Generating Station License Renewal Application Technical Information Assurance Program Description (OQAPD) for Columbia, which implements the requirements of 10 CFR 50, Appendix B.
Prior to the period of extended operation, the elements of corrective actions, confirmation process, and administrative controls in the OQAPD will be applied to required aging management programs for both safety-related and non-safety related structures and components determined to require aging management during the period of extended operation. /_.n~sert A from ýpage
ýA-8a A.1.2.1 Aboveground Steel Tanks Inspection The Aboveground Steel Tanks Inspection detects and characterizes the conditions on the bottom surfaces of the condensate storage tanks. The inspection provides direct evidence through volumetric examination as to whether, and to what extent, a loss of material due to corrosion has occurred in inaccessible areas (i.e., tank base and bottom surface).
\\-programl The Aboveground Steel Tanks Inspection is a new eRe time inspection that will be implemented prior to the period of extended operation. The inspection activities will be conducted within the 10-year period prior to the period of extended operation.
A.1.2.2 Air Quality Sampling Program The Air Quality Sampling Program is an existing prevention and condition monitoring program that manages loss of material due to corrosion for Diesel Starting Air (DSA) components that contain compressed air through periodic sampling of the air for hydrocarbons, dewpoint, and particulates and periodic ultrasonic inspection of the DSA System air receivers.
In addition, the Air Quality Sampling Program ensures that the Control Air System remains dry and free of contaminants, such that no aging effects require management.
The Air Quality Sampling Program is supplemented by the Diesel Starting Air Inspection, which provides verification of the effectiveness of the program in mitigating the effects of aging in the DSA System dryers and the downstream piping and components (excluding the DSA System air receivers).
A.1.2.3 Appendix J Program The Appendix J Program is an existing monitoring program that detects degradation of the Primary Containment and systems penetrating the Primary Containment, which are the containment shell and primary containment penetrations including (but not limited to) the personnel airlock, equipment hatch, control rod drive hatch, and drywell head.
The Appendix J Program provides assurance that leakage from the Primary Containment will not exceed maximum values for containment leakage.
Final Safety Analysis Report Supplement Page A-8, ja *vny-2 n,
Amendment38 Amendment 16-
Columbia Generating Station License Renewal Application Technical Information Insert A:
Internal and external operating experience is reviewed in accordance with the OQAPD. The review assures the existing, new, and any future required aging management programs necessary to provide reasonable assurance that components within the scope of license renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation.
Final Safety Analysis Report Supplement Page A-8a Amendment 38
Columbia Generating Station License Renewal Application Technical Information Insert A for page A-68d:
FSAR Enhancement Item Number Commitment Supplement or Location Implementation (LRA App. A)
Schedule
- 71) BWR Vessel Columbia will perform either of the following two years prior to the A.1.2.10 2 years prior to Internals period of extended operation:
period of extended Program
- 1) Install wedges to prevent lateral motion of the core plate in operation.
the event of stress relaxation of the core plate rim hold-down bolts at least two years prior to the beginning of the period of extended operation, or
- 2) Submit a plant-specific TLAA addressing the stress relaxation of the core plate rim hold-down bolts to the NRC for review and approval at least two years prior to the beginning of the period of extended operation. This TLAA shall analyze stress relaxation of the core plate rim hold-down bolts due to exposure of the pre-loaded bolts to neutron radiation over the life of the plant, and the analysis methods shall be consistent with the generic BWR core plate analysis specified in Appendix B of BWRVIP-25.
En7ergy NorthwAest Will enhance-tho onoing internal and Within ten years Ixpnre external operating expeience review process by B- -4 prior to entering the strengthening the revie.... ;-and-d.oc..umentation proc.SS relative period of extended to-license renewal agng ies.
Olpnr;;tiorn Final Safety Analysis Report Supplement Page A-68e ndment37-rAmendment 368