GO2-11-164, Response to Request for Additional Information License Renewal Application
| ML11285A042 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/05/2011 |
| From: | Swank D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-11-164 | |
| Download: ML11285A042 (13) | |
Text
EDavid ENERGY A. Swank Acting Vice President, Engineering P.O. Box 968, Mail Drop PE23 NORTHW EST Richland, WA 99352-0968 Ph. 509-377-2309 F. 509-377-4173 daswank @energy-northwest.corn October 5, 2011 G02-11-164 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 September 8, 2011, NRC to Energy Northwest, "Summary of Telephone Conference Call held on August 22, 2011, Between the U.S. Nuclear Regulatory Commission and Energy Northwest, Concerning Topics Pertaining to the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML11250A015)
Dear Sir or Madam:
By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, Energy Northwest stated that they would provide supplementary information concerning the polar crane as a Time-Limited Aging Analysis (TLAA) line item.
Transmitted herewith is supplementary information mentioned in Reference 2. contains Amendment 43 to the Columbia License Renewal Application. No new or revised commitments are included in this response.
If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
Respectfully, DA Swank Acting Vice President, Engineering
Enclosure:
License Renewal Application Amendment 43 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 AMENDMENT 43 Section Page RAI Number Number Number 3.3.2.2.1 3.3-50 Supplement Table 3.3.1 Line Item 3.3-57 Supplement 3.3.1-01 Table 3.5.2-13 3.5-121 Supplement New Line Item Table 3.5.2-13 3.5-121 a Supplement Line Item 76a NUREG-1800, 4.1-4 Supplement Table 4.1-3 Section 4.7.5 4.7-3 Supplement Section 4.7.5 4.7-3b Supplement Section 4.7.5 4.7-3c Supplement Section 4.7.5 4.7-3d Supplement Section 4.7.5 4.7-3e Supplement
Columbia Generating Station 3.3.2 Results License Renewal Application Technical Information
--Add new sections 3.3.2.1.45 through 47
- External Surfaces Monitoring Prograr as shown on pages 3.3-50a through d 3.3.2.2 Further Evaluation of Aging Management as Recommended by NUREG-1801 For the Auxiliary Systems, those items requiring further evaluation are addressed in the following sections.
3.3.2.2.1 Cumulative Fatigue Damage Fatigue is a time-limited aging analysis, as defined in 10 CFR 54.3. Time-limited aging analyses are required to be evaluated in accordance with 10 CFR 54.21(c). Time-limited aging analyses identified for fatigue in the Auxiliary Systems are evaluated in Section 4.3.4. *K IThe evaluation of crane load cycles as a TLAA for cranes and hoists is discussed in ISection 4.7.5 3.3.2.2.2 Reduction of Heat Transfer due to Fouling As described in Table 3.3.1, the Fuel Pool Cooling System has stainless steel heat exchanger tubes in treated water which are evaluated under item number 3.3.1-03.
Fouling of stainless steel heat exchanger tubes in treated water is managed by the BWR Water Chemistry Program, in conjunction with the Heat Exchangers Inspection.
3.3.2.2.3 Cracking due to Stress Corrosion Cracking (SCC) 3.3.2.2.3.1 BWR Standby Liquid Control System The treated water environment for the Standby Liquid Control System uses an aqueous solution of sodium pentaborate decahydrate. The system is normally in standby with the fluid temperature maintained above the 601F saturation temperature in an area where the ambient temperature is less than 100°F during normal plant operation. Since the temperature is below 1401F during normal plant operation, cracking due to SCC is not an aging effect requiring management for the stainless steel components of the Standby Liquid Control System.
3.3.2.2.3.2 Heat Exchanger Components As described in Table 3.3.1, there are no components compared to item number 3.3.1-
- 05. The Reactor Water Cleanup regenerative and non-regenerative heat exchangers at Columbia have no stainless steel components subject to AMR. Therefore, cracking of these components due to stress corrosion cracking is not an aging effect requiring management. Refer to item 3.3.1-48 (no further evaluation required) for the aging effects that do require management for these components.
3.3.2.2.3.3 Diesel Engine Exhaust Piping, Piping Components, and Piping Elements During normal plant operations, diesel exhaust piping, piping components, and piping elements are exposed to diesel exhaust infrequently and for short durations. For the remaining time, these components are exposed internally to outdoor air. As such, temperatures above 1401F occur only infrequently and for short durations. Therefore, cracking due to SCC is not identified as an aging effect requiring management for Aging Management Review Results Page 3.3-50 Janua. 2010
]Amendment 43 IAmPendment -
Columbia Generating Station License Renewal Application Technical Information Table 3.3.1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Further Item Aging Aging Management Evaluation Discussion Number Component/Commodity Effect/Mechanism Programs Recommended 3.3.1-01 Steel cranes - structural girders Cumulative fatigue TLAA to be evaluated Yes, TLAA Net pplieable-exposed to air - indoor damage for structural girders of uncontrolled (external) cranes. See the PFRR- IRAL4 ey6les aFe net a Standard Review Plan, Section 4.7 for generic Fatigue is a Time-Limited Aging guidance for meeting Analysis (TLAA). Further evaluation is the requirements of 10)CFR 54.21(c*(1V. documented in Section 3.3.2.2.1.
3.3.1-02 Steel and stainless steel piping, Cumulative fatigue TLAA, evaluated in Yes, TLAA Fatigue is a TLAA.
piping components, piping damage accordance with elements, and heat exchanger 10 CFR 54.21(c) Refer to Section 3.3.2.2.1 for components exposed to air - further information.
indoor uncontrolled, treated borated water or treated water 3.3.1-03 Stainless steel heat exchanger Reduction of heat Water Chemistry and Yes, detection of Consistent with NUREG-1 801.
tubes exposed to treated water transfer due to One-Time Inspection aging effects is fouling to be evaluated The BWR Water Chemistry Program, in conjunction with the Heat Exchangers Inspection, is credited to manage reduction in heat transfer for stainless steel heat exchanger tubes that are exposed to treated water.
Refer to Section 3.3.2.2.2 for further information.
Results Review Results Page 3.3-57 Je~uefy-2O4O Management Review Aging Management Page 3.3-57 Janua*y 2010
Columbia Generating Station License Renewal Application Technical Information Table 3.5.2-13 Aging Management Review Results - Bulk Commodities Aging EffectNUE-80 Row Component / Intended Requiring gt Aging Management NUREG-1801 Table 1 No. Commodity Functioni Material Environment Program Volume 2 Item Notes No CmmdiyManagement Ie 65 HVAC Duct SNS, SRE, Stainless Steel Air-indoor None None II1.B2-8 3.5.1-59 A Supports SSR 66 Instrument Line SNS, SRE, Carbon Steel Air-indoor Loss of material Structures Monitoring III.B2-10 3.5.1-39 A Supports SSR Program 67 Instrument Line SNS, SRE, Galvanized Air-indoor None None III.B2-5 3.5.1-58 A Supports SSR Steel 68 Instrument Line SNS, SRE, Stainless Steel Air-indoor None None III.B2-8 3.5.1-59 A Supports SSR 69 Instrument Line SNS, SRE, Carbon Steel Air-outdoor Loss of material Structures Monitoring III.B2-10 3.5.1-39 A Supports SSR Program 70 Instrument Line SNS, SRE, Galvanized Air-outdoor Loss of material Structures Monitoring III.B2-7 3.5.1-50 A Supports SSR Steel Program 71 Instrument Line SNS, SRE, Stainless Steel Air-outdoor None Structures Monitoring III.B2-7 3.5.1-50 0 Supports SSR Program 0525 72 Instrument Racks SNS, SRE, Carbon Steel Air-indoor am1.B3-7 Loss of material Structures Monitoring 3.5.1-39 C and Frames SSR Program 73 Instrument Racks SNS, SRE, Galvanized Air-indoor None None III.B3-3 3.5.1-58 C and Frames SSR Steel 74 Instrument Racks SNS, SRE, Carbon Steel Air-outdoor am1.B3-7 Loss of material Structures Monitoring 3.5.1-39 C and Frames SSR Program 75 Instrument Racks SNS, SRE, Galvanized Air-outdoor am1.B2-7 Loss of material Structures Monitoring 3.5.1-50 C and Frames SSR Steel Program Monorails, Hoists 76 and Miscellaneous SNS Carbon Steel Air-indoor Loss of material Structures Monitoring I1.B5-7 3.5.1-39 A Cranes Program
-41 Page 3.5-121 -- 9' fanwaiL2glg
'Aging Management Review Results j~mendent 4D Insert A from page 3.5-121a
Columbia Generating Station License Renewal Application Technical Information Insert A:
Table 3.5.2-13 Aging Management Review Results - Bulk Commodities AgingEEffect Table1 Row Component / Intended Maeil EvrnetRqrngPoamIm Effect MaterialAging Aging Management NUREG-1801 Notes Function1 Requiring Volume 2 Item No. Commodity Management PormItem Steel and Other Metals Monorails, Hoists Cumulative 76a and Miscellaneous SNS Carbon Steel Air-indoor fatigue damage TLAA VII.B-2 3.3.1-01 A Cranes Amendment 43 Aging Management Aging Review Results Management Review Results Page 3.5-121a Page 3.5-121 a Amendment 43
Columbia Generating Station License Renewal Application Technical Information Table 4.1-2 Review of Generic TLAAs Listed in Tables 4.1-2 and 4.1-3 of NUREG-1800 NUREG-1800 Generic TLAAs Example Applicability to Columbia LRA Section NUREG-1800, Table 4.1-2 Reactor Vessel Neutron Embrittlement Yes 4.2 Concrete Containment Tendon Prestress No - Columbia does not have 4.5 containment tendons Metal Fatigue Yes 4.3 Environmental Qualification of Electrical Yes 4.4 Equipment Metal Corrosion Allowance No - No explicit 40-year basis applies.
Inservice Flaw Growth Analyses that Yes 4.7.1 Demonstrate Structure Stability for 40 Years Inservice Local Metal Containment Corrosion No - No explicit 40-year basis Analyses applies.
High-Energy Line-Break Postulation Based on Yes 4.3.3 Fatigue Cumulative Usage Factor NUREG-1800, Table 4.1-3 Intergranular Separation in the Heat-Affected No - No HAZ analysis was Zone (HAZ) of Reactor Vessel Low-Alloy Steel identified within the CLB.
Under Austenitic Stainless Steel Cladding Low-Temperature Overpressure Protection No - No LTOP analysis was (LTOP) Analyses identified within the CLB.
Fatigue Analysis for the Main Steam Supply No - Columbia is a BWR and Lines to the Turbine-Driven Auxiliary does not have an Auxiliary Feedwater Pumps Feedwater System.
Fatigue Analysis of the Reactor Coolant Pump No -Recirculation System Flywheel pumps do not have flywheels.
Fatigue Analysis of Polar Crane Wo No.xplic.t ba6'i
<475e ape--40 year 4.7.5 Time-Limited Aging Analyses Page 4.1-4 TAmendment 43 A s.e
Columbia Generating Station License Renewal Application Technical Information 4.7.3 Main Steam Line Flow Restrictor Erosion Analyses FSAR Section 5.4.4 indicates that a main steam line flow restrictor is provided for each of the four main steam lines. The restrictor is a complete assembly welded into the main steam line between the last main steam line SRV and the inboard main steam isolation valve (MSIV). The restrictor is 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 a main steam line break occurs outside the containment. The restrictor assembly has no moving parts and consists of a venturi-type nozzle insert welded into the main steam line.
FSAR Section 5.4.4.4 indicates that only very slow erosion of the main steam flow restrictor is expected. 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.
Columbia has projected the erosion of the main steam flow restrictors 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 for the period of extended operation.
Disposition: 10 CFR 54.21(c)(1)(ii) - The TLAA for erosion of the main steam line flow restrictors has been projected to the end of the period of extended operation.
Insert A from page 4.7-3a Insert B from pages 4.7-3b through 4.7-3e Time-Limited Aging Analyses Page 4.7-3 j.. ,Fy-204,
- Amendment 431
Columbia Generating Station License Renewal Application Technical Information Insert B:
4.7.5 Crane Load Cycle Limit All of the cranes and hoists at Columbia in scope of License Renewal were designed to CMAA 70 "Specification for Top Running and Gantry Type Multiple Girder Electric Overhead Traveling Cranes" standards. All but one of the cranes and hoists were designed to service class A (standby or infrequent service) which provides that the design of the crane or hoist was to be based on a number of expected load cycles between 20,000 to 100,000 cycles. The remaining crane (MT-HOI-40 installed in 2009) was designed to class D (heavy service) standards which has a higher range of load cycles than class A. As such, the design of the in scope cranes and hoists for specified number of load cycles during plant operation is therefore a TLAA.
By definition of CMAA 70, service class A is for standby or infrequent service and covers cranes and hoists which may be used in installations such as powerhouses, public utilities, turbine rooms, motor rooms and transformer stations where capacity loads may be handled for initial installation of equipment and for infrequent maintenance. There are fifteen (15) such cranes and hoist in scope of License Renewal at Columbia as follows:
Equipment Building Description Rated Capacity Number MT-CRA-2 Reactor Reactor building refuel floor bridge 12 5 T / 1 5T crane MT-CRA-6A Service Service water (SW) pump house 8T Water Pump crane MT-CRA-6B House MT-CRA-1 Turbine Turbine deck bridge crane 2 0 0 T / 25 T MT-HOI-6 Reactor Electric trolley hoist - RHR Pumps 6m (A&B)
MT-HOI-7 Reactor Electric trolley hoist - RCIC Pump 5m and turbine MT-HOI-8 Reactor Electric trolley hoist - RHR Pump 6T (C)
MT-HOI-9 Reactor Electric trolley hoist - LPCS Pump 7T MT-HOI-1 0 Reactor Electric trolley hoist - HPCS Pump 20T MT-HOI-1 6 Containment Electric trolley hoist - RRC Pump 30T Time-Limited Aging Analyses Page 4.7-3b Amendment 43
Columbia Generating Station License Renewal Application Technical Information Equipment Building Description Rated Capacity Number MT-HOI-18 Reactor Trolley hoist - Outboard MSIV work and pipe tunnel removal MT-HOI-40 Reactor Gantry crane Rx. 548' Hatch 7.5T MT-CRA-9A Reactor Refueling Platform/Service 1 0 MT-CRA-9B Platform Jib Crane MT-CRA-1 1 Reactor Refueling Platform/Service 200" Platform Channel Handling Boom The cranes and hoists associated with specific plant pumps/motors have seen very limited use to date. For those associated with the emergency core cooling system (ECCS) pump rooms (MT-HOI-6, 7, 8, 9 and 10) the majority of the lifts have been to remove and reinstall one of the three floor plugs in the slab above to provide access for work within the associated pump room during an outage. This has usually been for work activities other than removal of the associated pump or motor as these pumps are only rebuilt approximately every 8-10 years. This has not been required during every outage to date, but assuming all three plugs have been removed and reinstalled during each outage to date (currently 20 refueling outages) and will be during each biannual refueling outage going forward (16 more thru period of extended operation) the resultant number of load cycles for each of these hoists is approximately 220 cycles. Even doubling of this number results in total load cycles of approximately 440 which are well below the allowable maximum number of 100,000 load cycles for service class A. The hoist and cranes associated with the reactor recirculation (RRC), service water (SW) and high pressure core spray (HPCS) pumps (MT-HOI-16 and MT-CRA-6A16B) have been used even less frequently and will be bounded by the 440 cycles evaluated above for the ECCS pump hoists thru the period of extended operation.
The Reactor building refuel floor bridge crane (MT-CRA-2) is used extensively during refueling outages and during ISFSI off-loading campaigns. The casks associated with ISFSI activities represent the heaviest loads lifted by this crane. There have been approximately 30 casks to date and approximately 80 more anticipated thru the period of extended operation for a total of 110 casks. Each cask has 20-25 lifts associated with the overhead crane although only about nine (9) of these lifts are greater than 50%
capacity of the crane. However, for this analysis each lift will be treated as a load cycle and the maximum number of 25 will be assumed. Thus, for ISFSI related work activities there will be approximately 2750 load cycles of this crane. Review of reactor disassembly and reassembly procedures revealed that each outage there have been approximately 40 lifts associated with disassembly and reassembly of the vessel that would utilize the main hook and represent the next set of heavy loads associated with this crane. This will result in a total of approximately 1440 load cycles on this crane due to vessel disassembly/reassembly during refueling outages. This total for ISFSI and Time-Limited Aging Analyses Page 4.7-3c Amendment 43
Columbia Generating Station
- License Renewal Application Technical Information outages will be combined and doubled to account for other potential heavy loads and estimate the total thru the period of extended operation. This total number is approximately 8380 load cycles which is well below the allowable maximum number of 100,000 load cycles for a service class A crane. Note that though there are numerous loads picked by the auxiliary hook these were not accounted for as the design of the bridge and structural rail system is based on the larger loads associated with the main hook which cumulative fatigue damage would be more likely to result from.
The turbine deck bridge crane (MT-CRA-1) is also used extensively during outages.
The basis of the design of this crane is loads associated with overhaul of the turbine and generator. The turbine and generator at Columbia have been overhauled less often than the vessel is disassembled and reassembled and ISFSI casks are lifted as discussed above. Thus, the analysis provided above for the Reactor building crane will bound this turbine building bridge crane.
The steam tunnel hoist (MT-HOI-18) is used predominantly during refuel outages for removal of the floor plugs above the pipe (steam) tunnel and movement of valves as necessary. There are sixteen (16) floor plugs above the tunnel, but normal outage activities do not require removal of all plugs to gain access for the scheduled work.
However, to obtain the most conservative estimate Energy Northwest assumed all sixteen floor plugs have been removed and reinstalled (32 load cycles) in past outages and will be removed and reinstalled each outage through the period of extended operation (total of 36 outages) and doubled that number to account for other lifts that may occur during work activities in the steam tunnel. The resultant number of load cycles associated with this hoist is approximately 2304 which is well below the allowable maximum of 100,000 load cycles for a service class A hoist.
The gantry crane (MT-HOI-40) at el. 548 of the Reactor building was installed in 2009 to support outage activities starting in R-19 and going forward. This crane was designed and fabricated to CMAA Class D standard which is defined as service with 10 to 20 lifts per hour with loads approaching 50% of capacity and, in terms of load cycles, by an expected range of 100,000 to 500,000 load cycles. This anticipated hourly lift rate was not realized during the first two outages at Columbia and most likely will not be in future outages, but this rate of 20 lifts per hour will be used to determine the estimated number of lifts thru the period of extended operation. Based on installation and use for R-1 9 outage and going forward this crane will see service in eighteen (18) outages thru the period of extended operation with an expected average duration of 35 days or less for each outage and majority of lifts being at or below 50% capacity. Use of this gantry around the clock during these outages would result in a total number of approximately 302,400 load cycles which is less than the allowable maximum cycles of 500,000 for Class D service.
The remaining three jib cranes (MT-CRA-9A/9B and MT-CRA-1 1) are located on the refuel floor of the Reactor building. They are primarily used for work activities associated with receipt of new fuel. Average number of new fuel bundles handled for an outage is approximately one third (1/3) of the core. However, Energy Northwest Time-Limited Aging Analyses Page 4.7-3d Amendment 43
Columbia Generating Station License Renewal Application Technical Information assumed a full core reload during each outage to account for multiple handling of bundles and other miscellaneous loads. The resultant total of load cycles, for the past 20 refueling outages and 16 additional outages thru the period of extended operation, for each hoist is approximately 27,500 cycles. This number is below the allowable maximum of 100,000 load cycles for service class A as per CMAA 70.
Disposition: 10 CFR 54.21(c)(1)(i) - The analysis remains valid for the period of extended operation.
Analyses Aging Analyses Page 4.7-3e Amendment 43 Time-Limited Time-Limited Aging Page 4.7-3e Amendment 43