ML11312A247
| ML11312A247 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/04/2011 |
| From: | Sawatzke B Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G02-11-176, TAC ME3058 | |
| Download: ML11312A247 (16) | |
Text
Bradley J. Sawatzke ENERGY Columbia Generating Station P.O. Box 968, PE08 NORTHW ESTRichland, WA 99352-0968 Ph. 509.377.4300 1 F. 509.377.4150 bjsawatzke @ energy-northwest.com November 4, 2011 G02-11-176 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 June 2, 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. ML11140A161)
- 3) Letter dated June 29, 2011, DA Swank (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-113)
- 4) Letter dated August 23, 2011, NRC to Energy Northwest, "Summary of Telephone Conference call held on August 17, 2011, between the U.S.
Nuclear Regulatory Commission and Energy Northwest, concerning the Response to the Request for Additional Information Pertaining to the Columbia Generating Station, License Renewal Application (TAC No.
ME3058)," (ML11230B089)
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. Via Reference 3, Energy Northwest responded to Reference 2.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 Transmitted herewith in the Attachment is supplementary information (requested in Reference 4) for the response to the Request for Additional Information (RAI) contained in Reference 2. Enclosure 1 contains Amendment 44 to the Columbia License Renewal Application. One revised commitment is included in this response.
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.
Respectfully, BJ Sawatzk Vice President, Nuclear Generation & Chief Nuclear Officer
Attachment:
Response to Request for Additional Information
Enclosure:
License Renewal Application Amendment 44 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)
John Daily - NRC NRR (w/a)
BE Holian - NRC NRR MA Galloway - NRC NRR RR Cowley - WDOH
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Telephone Conference Call - Columbia Generating Station License Renewal Application August 17, 2011,"
(ADAMS Accession No. ML ML11230B089)
Issue:
The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Energy Northwest (the applicant), held a telephone conference call on August 17, 2011 to discuss the following response to the request for additional information (RAI) concerning the Columbia Generating Station (Columbia) license renewal application (LRA).
Response to RAI B.2.10-2: Related to the core plate rim hold-down bolts.
The following discussion was related to a follow-up telephone conference call held on August 11,2011.
Discussion:
The applicant clarified what prompted Columbia to verify that core plate wedges were not installed. The applicant will include in its LRA supplement on the core plate rim hold-down bolts time limited aging analysis disposition, a statement that it had reviewed the boiling water reactor vessel internals project (BWRVIP) inspection guidance and ensured that all other inspection guidance from the BWRVIP reports have been captured.
Energy Northwest Response:
The LRA sections for Reactor Vessel Internals are amended to address loss of pre-load and cracking. The amended pages for these sections are provided in the enclosure to Amendment 44. In addition, LRA sections 4.7.4 for core plate rim hold-down bolts disposition is revised to add 10 CFR 54.21 (c)(1)(iii).
An extent of condition was performed for other guidelines directly impacted by the information provided by GE regarding Columbia's configuration, and none were found.
These guidelines were BWRVIP-25 (BWR Vessel and Internals Project BWR Core Plate Inspection and Flaw Evaluation Guidelines) and BWRVIP-26-A (BWR Vessel and Internals Project BWR Top Guide Inspection and Flaw Evaluation Guidelines). There are no other configuration uncertainties in the BWRVIP program based on inspection results.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDMENT 44 Section Page RAI Number Number Number 3.1.2.1.2 3.1-3 B.2.10-2 Table 3.1.1 Line Item 3.1-19 B.2.10-2 3.1.1-44 Table 3.1.2-2 New Line Item 3.1-93 B.2.10-2 81 Table 3.1.2-2 New Line 3.1-93a B.2.10-2 Items 82 & 83 4.7.4 4.7-3a B.2.10-2 A.1.3.7.4 A-41a B.2.10-2 Table A-1 Line A-68e B.2.10-2 Item 71 B.2.10 B-54 B.2.10-2 B.2.10 B-54a B.2.10-2 Table C-2 C-7 B.2.10-2 Table C-2 C-7a B.2.10-2 Table C-2 C-8 B.2.10-2
Columbia Generating Station License Renewal Application Technical Information
" BWR Stress Corrosion Cracking Program BWR Vessel ID Attachment Welds Program
" BWR Water Chemistry Program Chemistry Program Effectiveness Inspection CRDRL Nozzle Program
" Inservice Inspection (ISI) Program
" Inservice Inspection (ISI) Program - IWF
" Reactor Head Closure Studs Program Reactor Vessel Surveillance Program 3.1.2.1.2 Reactor Vessel Internals Materials The materials of construction for the subject mechanical components of the Reactor Vessel Internals are:
" Cast Austenitic Stainless Steel (CASS)
" Nickel Alloy Stainless Steel
" Stainless Steel and Nickel Alloy Environments Subject mechanical components of the Reactor Vessel Internals are exposed to the following normal operating environments:
" Air-Indoor uncontrolled
" Reactor Coolant with Neutron Fluence Aging Effects Requiring Management The following aging effects require management for the subject mechanical components of the Reactor Vessel Internals:
" Cracking (due to Fatigue, Flaw Growth, Flow Induced Vibration, Stress Corrosion Cracking/Intergranular Attack, and Stress Corrosion Cracking/Irradiation Assisted Stress Corrosion Cracking)
Loss of Material l" 4-Loss of Preload I Aging Management Review Results Page 3.1-3 Je4.y,-*--s20 0 IAmendment 44
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 Further Item Aging Effect/
Aging Management Evaluation Discussion Number Component/Commodity Mechanism Programs Recommended 3.1.1-44 Stainless steel and nickel alloy Cracking due to BWR Vessel Internals No Consistent with NUREG-1 801.
core shroud, core plate, core stress corrosion and Water Chemistry plate bolts, support structure, top cracking, Cracking of the core plate, core guide, core spray lines, intergranular stress spray lines, incore dry tubes, spargers, jet pump assemblies, corrosion cracking, incore guide tubes, jet pump CRD housing, nuclear irradiation-assisted assemblies (cast and non-cast),
instrumentation guide tubes stress corrosion LPCI coupling, shroud, and top cracking guide is managed by the BWR Vessel Internals Program and the BWR Water Chemistry I
Program.
A%
3.1.1-45 Steel piping, piping components, Wall thinning due to Flow-Accelerated No Consistent with NUREG-1 801.
and piping elements exposed to flow-accelerated Corrosion reactor coolant corrosion Loss of material (FAC) of steel piping and steel valve bodies in the reactor coolant system is managed by the Flow-Accelerated Corrosion (FAC)
Program.
At least two years prior to the period of extended operation, Columbia will install core plate wedges unless:
- 1) a site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or
- 2) an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Aging Management Review Results Page 3.1-19 ja
,,L, 2"14 -9 IAmendment 44
-7
Columbia Generating Station License Renewal Application Technical Information Table 3.1.2-2 Aging Management Review Results - Reactor Vessel Internals Aging Effect NUREG-Row Component Intended Material Environment Requiring Aging Management 1801 Table 1 Notes No.
Type Function(s)
Management Program Volume 2 Item Item Reactor Coolant with 77 Top Guide Support Stainless Steel Neutron SCC/IASCC BWR Water Chemistry IV.B1-17 3.1.1-44 A
Fluence (Internal)
Reactor Coolant with Cracking -
78 Top Guide Support Stainless Steel Neutron Fatigue TLAA IV.B1-14 3.1.1-05 A
Fluence Fatigue (Internal)
Reactor Coolant with 79 Top Guide Support Stainless Steel Neutron Loss of Material BWR Water Chemistry IV.B1-15 3.1.1-47 A
Fluence (Internal)
Reactor Coolant with 80 Top Guide Support Stainless Steel Neutron Loss of Material Inservice Inspection IV.B1-15 3.1.1-47 A
Fluence (Internal)
Reactor Core Plate Stainless Coolant with Loss of Pre-81 Hold-down Support Steel Neutron load TLAA N/A N/A H
Bolt Fluence (Internal)
Insert A from page V
3.1-93a Aging Management Review Results Page 3.1-93
Columbia Generating Station License Renewal Application Technical Information Insert A:
Table 3.1.2-2 Aging Management Review Results - Reactor Vessel Internals Row Component Intended IAging Effect NUREG-a Environmen equg Aging Management 1801 Table 1 Notes NuManagement Program Volume 2 Item Item Reactor Core Plate Coolant with 82 Hold-down Support Steel Neutron Cracking Internalss Bolt fluence (Internal)
Reactor Core Plate Coolant with 83 Hold-down Support Steel Neutron Cracking Chemistry Bolt fluence I__
(Internal)
I III Aging Management Review Results Page 3.1-93a Amendment 44
Columbia Generating Station License Renewal Application Technical Information Insert A:
4.7.4 Core Plate Rim Hold-Down Bolts The NRC safety evaluation report that references BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines," (References 4.8.18) for license renewal identifies loss of preload on the core plate rim hold-down bolts as one of the TLAA that must be addressed by applicants seeking license renewal.
1/-10 CFR 54.21 (c)(1 )(iii) -
at least Disposition: 'Columbia will perform either-a the following ¶wo years prior to the period of extended operation:
(14 Install wedgesr to prevent Iate-ral motion of the core plato in the eent oe f
stre s relaxatioAn olf the cor PlAt rim hld down1 b*olrt at least rtwo Years prior to the beginning of the period Of extended operation, or Submit a plant-specific T-1A A addiressing tho stress. relaxation of the core P1249 rimn hold-do-wn _boltS to the NIRC for review and approval at least two years prior to the beginning of the period of extended opeat This TI A shall analyze stress relax*ation of the core plate rim hold-down bolts d'-e to exposure of the pre-loaded bolts to neu-tron r
h l*
ft*rlnt
- ~
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~
~
h~ee~lh consistent With the genric; RWR core plate analysis specified in Appendix B of 81BAW RNI 25."
Columbia will install core plate wedges unless:
- 1) a site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or
- 2) an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Thns-Limited Aging Analyses Page 4.7-3a Amendment36 IAmendment 44
Columbia Generating Station License Renewal Application Technical Information Insert A:
A.1.3.7.4 Core Plate Rim Hold-Down Bolts The NRC safety evaluation report that references BWRVIP-25, "BWR Core Plate Inspection and Flaw Evaluation Guidelines," for license renewal identifies loss of preload on the core plate rim hold-down bolts as one of the TLAA that must be addressed by applicants seeking license renewal.
Disposition For the* cre plate rim hold-doAn bolts, D*vinaion Disposition (DD-09): Variance from BWAIRVIP-25 Gu-idance for Inspection of Core Plate Bolts hags been sent to the N.RC for Co'-umbia. This deviation Will allow Columbia to not inspect tho core plateboIts WAIRVIP_25 requires that 50% of the -ore platAe bolts for plants without repair wedges he examined by enhanced visual (EVT\\1) method from hblow +hO the r
orelat (or hFby UIltraon;i (UT)
I from aovheA the core Plate; one the technique is developed)-. A determination,,eas made that the bolts cannot be inspected by UT d, -A to configuration iss;esM -and-it has rtetentiy been conc, uded that an EVT1-1 exam does not provide meanfingful resls@h WVPi addrs*i'ng this isue and-intends to develop revised guidaAnce I lntil Such uzidanc`;e zdeveloi*ed no additional actionse o%;a rlnnad or are warrantead At least two years prior to the period of extended operation, Columbia will install core plate wedges unless:
- 1) a site-specific analysis is approved by the NRC the resolves core plate bolt loss of preload due to both stress relaxation and cracking, or
- 2) an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Final Safety Analysis Report Supplement Page A-41 a Am36dmont3 jAmendment 44 -0
........ Generating Station License Renewal Application Technical Information Insert A for page A-68d:
FSAR Enhancement Item Number Commitment Supplement or Location Implementation (ILRA App. A)
Schedule
- 71) BWR Vessel Cohumhnbia will perorm either of the following two yoars prior to, A.*1* 2.10 2 years prior to Internals period Of eXtended operation-period of extended Program
-44 install wedges to prevent lateral motion of the core plate in operation.
tho ovent of streAsron of the coere plate rim hold -don bolts at least wo years prior to the beginning of the period of extended operation, or 24 Submit a plant-specific T-1A.A ad-dros-sing the stress relaxmation Of the core PlAto rim hold downA bolts to 1119 NRC for rvielwh and approval at leas~t twoQ ye'ars prior to the beginning of the peio of exte-nd-ed operation. This T1LAA shall analyze stre;ss relaxt'ion of the core plate rim hold down bolts due1A to expsur ofthe pro loaded bolts to neutdron radiation over the life of the plant, and the analysis metho-ds shall -be nsient wit tegnri BWR core plate analysis speciied in Appendix B of BRVIP 411225-.
Enrergy NorthWet Mmill enhance the ongoing internal and Withi teR*YearS externaAl operating exeRec reie poesb 4
prior to entering the strengthening the reviewAA Eand dcmntto process relative Period Of extended
`7to license eea gn sus prto At least two years prior to the period of extended operation, Columbia will install core plate wedges unless:
- 1) a site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or
- 2) an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Final Safety Analysis Report Supplement Page A-68e Iendment Amendment jAmendment 4 4
-Inmt3
Columbia Generating Station License Renewal Application Technical Information B.2.10 BWR Vessel Internals Program Program Description The BWR Vessel Internals Program will manage cracking due to SCC/IASCC, SCC/IGA, flaw growth, and flow-induced vibration for various components and subcomponents of the reactor vessel internals.
The Columbia program includes mitigation, inspection, and repair. The BWR Vessel Internals Program incorporates all of the BWRVIP guidance documents, including those specifically called out in NUREG-1801,Section XI.M9.
(a) mitigation Columbia mitigates reactor vessel internals cracking by maintaining water chemistry in accordance with the current BWRVIP guidelines using the BWR Water Chemistry Program.
(b) inspection Inspection is performed by the Inservice Inspection (ISI) Program as required by the ASME Code. Augmented inspections as recommended by the BWRVIP program are performed by the BWR Vessel Internals Program. The BWRVIP requirements typically include more stringent inspections and components beyond the ASME requirements.
The Columbia program includes enhanced visual examinations, including the equipment and environmental conditions necessary to achieve the resolution recommended by the BWRVIP guidelines.
n~sert A from page B-54a Columbia.'..
implements al tl BWRVIP requirements, including re-inpection an6d sample expansion reui
.ens Columbia detects and sizes cracks in accordance with the guidelines of approved BWRVIP documents and the requirements of the ASME Code, Section Xl, 2001 Edition, 2003 Addenda.
Columbia evaluates all flaws in accordance with either the ASME code or BWRVIP guidance. Flaw evaluations that deviate from the guidance in BWRVIP reports are submitted to the NRC for approval.
(c) repair Repair or replacement, as necessary, is performed in accordance with approved BWRVIP documents and ASME Section Xl, as applicable.
Columbia's top guide will have received neutron fluence exceeding the IASCC threshold (5E20, E>1 MeV) before entering the period of extended operation. Columbia complies with BWRVIP-183.
Although BWRVIP-183 has not yet been approved by the NRC staff, it includes the top guide inspections recommended by NUREG-1801.
BWRVIP-Aging Management Programs Page B-54 amn dey n 2
4 41 Amendment
~en 36 4
The only BWRVIP requirement that Columbia does not implement is the inspection of the core plate bolt.
Columbia Generating Station License Renewal Application Technical Information Insert A:
"For the core plate rim hold-down bolts, Deviation Disposition (DD-09): Variance from BWRVIP-25 Guidance for Inspection of Core Plate Bolts has been sent to the NRC for Columbia. This deviation will allow Columbia to not inspect the core plate bol BWRVIP-25 requires that 50% of the core plate bolts for plants thouh20L whtekair wedges be examined by enhanced visual (EVT-1) method from below the core plate (or by Ultrasonic (UT) from above the core plate once the technique is developed).
A determination was made that the bolts cannot be inspected by UT due to configuration issues and it has recently been concluded that an EVT-1 exam does not provide meaningful results.
The BWRVIP is addressing this issue and intends to develop revised guidance.
Until such guidance is developed, no additional actions are planned or are warranted.
Aging Management Programs Page B-54a Amndman-t 26 jAmendment 44
Columbia Generating Station License Renewal Application Technical Information Table C-2 BWRVIP-25 BWR Core Plate Inspection and Flaw Evaluation Guidelines Applicant Action Item Text Plant-Specific Response (1) The license renewal applicant is to verify that its plant is bounded by the BWRVIP-25 report. Further, the renewal applicant is to commit to programs described as necessary in the BWRVIP-25 report to manage the effects of aging on the functionality of the core plate assembly during the period of extended operation. Applicants for license renewal will be responsible for describing any such commitments and identifying how such commitments will be controlled. Any deviations from the AMPs within the BWRVIP-25 report described as necessary to manage the effects of aging during the period of extended operation and to maintain the functionality of the reactor vessel components or other information presented in the report, such as materials of construction, will have to be identified by the renewal applicant and evaluated on a plant-specific basis in accordance with 10 CFR 54.21(a)(3) and (c)(1).
The BWR Vessel Internals Program requires the inspection and evaluation guidelines of this BWRVIP report to be implemented at Columbia. Site procedur require a technical justification to be documented, and the NRC to be notified for any deviation from the guidelines.
Co!umbna has not idontified any doviatior from the BWRVIP 25 guidelines.
Thoroforo, Columbia ic bounded by the BWRVIP 25 ropot.
res Columbia commits to programs described as necessary in the BWRVIP report to manage the effects of aging during the period of extended operation.
Commitments are administratively controlled in accordance with the requirements of 10 CFR 50 Appendix B.
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(2) 10 CFR 54.21(d) requires that an FSAR supplement for the facility contain a summary description of the programs and activities for managing the effects of aging and the evaluation of TLAAs for the period of extended operation. Those applicants for license renewal referencing the BWRVIP-25 report for the core plate will ensure that the programs and activities specified as necessary in the BWRVIP-25 report are summarily described in the FSAR supplement.
iat4 BWRV!P-25 requires inspection of the cc nlfat rim hold-41down blts fo r thoe
&lant
- Il:4 that use these bolts to prevent latera k
motion of the core plate. As deoribod Ie6PGA re to iMMi
- F1, k9un lliah I
wedges irnstalled to perfo*
r this functioen Thu, Columbia complies2 with the
'econd optier than inspect the coro plate rimn hold down belts.
,l-neBfro rm pageOC7a Tharefor no programr, or acivities a poiein the FSAR supplement, contained in Appendix A of the [ RA The FSAR supplement, contained in Appendix A of the LRA, includes a summary description of the programs and activities as required by this Applicant Action Item. i I
Response to BWRVIP Applicant Action Items Page C-7 jRwe..y -204
-Amendment 441
Columbia Generating Station License Renewal Application Technical Information The BWVAIPIl is ad-dressing th issue of not perforrming ultrasonllic (UT) r OiF;ural IVT) moth Until s*uh guidance is developed, An additional actions are planned or xwarrantd.
Inspection af Core Platel Bolnts wlas developed bee the hold-r don bolts h-Mnr~
K' aftiIM ino nnfrltr A nIont c nnrif it nnn!ic~io,Inmrnntrntnc, th~ot thn I-- --- l-..
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l core piate Do!15 are very ;law toer-ant 2a(_] are no9ectp 0o-8e n-rao11 vt perform thoir safety function.
Insert C:
lAt least two years prior to the period of extended operation, I
IColumbia will install core plate wedges unless:
Columb-ia will perform either o-f the followixg two years prior to the period of extended operation:
v a site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or 1) 2)
Ir~4~lI ~AIp.(L'1~ t~ PrA'j'P'~ Ig~~rgI motion of thA corn ',Igtn in tho o"nnt of Intallweder ~~.*,n to reen latra MMO Of rim GOIr9 platen hIthe eit Lnt ofAw v..
vvv r-.-...
years prior to the DOl.*ofnp'q ot the period o; extenaea oper*aion, or I
k an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Submit a plant-SPeeeIM 1-6A aoare0MSSIng 114 SOUeSs reia2Xaiion 04 1 m core plate rilm hold-49 down-bots-to-thae NIRC foir re'~Aew and approvla least two easpirto the beginning of the period of etwended oper tim.. This TILAA shall analyze straes relaxaltin of tha nora nl*÷a rim hlddoCwn boQts due to exposure Of the prl*oaded bol to neutron radi-ation ov,,er the life of the plant, and the analysis methods shall be
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D DIAIDWIID Or Insert D:
Columbia deviates from the BWRVIP-25 guidelines by not performing inspections of the core plate hold down bolts. The deviation is documented in plant specific Deviation Disposition DD-09. The BWRVIP is addressing the fact that the current guidance cannot be effectively implemented. As documented in License Renewal Commitment #71 (Appendix A), at least two years prior tot he period of extended operation, Columbia will install core plate wedges unless:
- 1) a site-specific analysis is approved by the NRC that resolves core plate bolt loss of preload due to both stress relaxation and cracking, or
- 2) an NRC approved method is developed to inspect the core plate bolts for cracking and a site-specific analysis for loss of preload due to stress relaxation of the core plate bolts is approved by the NRC.
Response to BWRVIP Applicant Action Items Page C-7a iAmendment 44 A-mnendmant 3
Columbia Generating Station License Renewal Application Technical Information Table C-2 BWRVIP-25 BWR Core Plate Inspection and Flaw Evaluation Guidelines Applicant Action Item Text Plant-Specific Response i
(3) 10 CFR 54.22 requires that each application for license renewal include any technical specification changes (and the justification for the changes) or additions necessary to manage the effects of aging during the period of extended operation as part of the renewal application. In its Appendix B to the BWRVIP-25 report, the BWRVIP stated that there are no generic changes or additions to technical specification associated with the core plate as a result of its AMR and that the applicant will provide the justification for plant-specific changes or additions. Those applicants for license renewal referencing the BWRVIP-25 report for the core plate will ensure that the inspection strategy described in the BWRVIP-25 report does not conflict with or result in any changes to their technical specifications (TS).
If TS changes do result, then the applicant must ensure that those changes are included in its application for license renewal.
No technical specification changes are required for the inspection strategy described in the BWRVIP-25 report.
Inse 1pag rt C from e C-7a V
(4) Due to susceptibility of the rim hold-down StFrec "laxation Of tho c... plato rim hold bolts to stress relaxation, applicants down bolts ic not a TLAA. for Columbia.
referencing the BWRVIP-25 report for license Dn,),,g oGriginal fabFrGation of the Columbia renewal should identify and evaluate the
.. rc--r ineton'-..,
wedgec woro installed to projected stress relaxation as a potential TLAA p....nt lateral moetion f the coro plat, -and issue.
Columbia doee not requiro the coeF plate rimA hold down bolts for thic function (5) Until such time as an expanded technical basis for not inspecting the rim hold-down bolts is approved by the staff, applicants referencing the BWRVIP-25 report for license renewal should continue to perform inspections of the rim hold-down bolts.
BWRVIP-25 requires inspection of the core plate rim hold-down bolts for those plants that use these bolts to prevent lateral motion of the core plate. Ac decsribed in FeROnr~ne to AAI #4t Columbia has eodoot inatal led to perform thi, fuMNctOnR Thuc
- vv nI nl ITRflI r'Amfrlfl in~f TfflFNP nP of 1BWRVIP 25, to install wedges rate than *nS'-cct the ccrc plate Frlm 1491 cw \\
belts.I lnsertnsert A and nsert from page C-7a Response to BWRVIP Applicant Action Items Page C-8 clanwFy-2010 Amnmet4