GO2-12-064, Response to NRC Information Request, License Renewal Application

Response to NRC Information Request, License Renewal Application

ML12116A150
Person / Time
Site:	Columbia
Issue date:	04/23/2012
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-12-064
Download: ML12116A150 (5)

Text

Alex L. Javorik P.O. Box 968, PE23 NORTHW ESTRichland, WA 99352-0968 Ph. 509-377-8555 F. 509-377-2354 aljavorik@ energy-northwest.com April 23, 2012 G02-12-064 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO NRC INFORMATION REQUEST, LICENSE RENEWAL APPLICATION

References:

1) Letter, G02-10-011, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter dated January 28, 2011, SK Gambhir (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-031)

3) Letter dated November 16, 2011, Al Javorik (Energy Northwest) to NRC, "Response to Request for Additional Information License Renewal Application," (G02-11-185)

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 submitted Amendment 28 to the Columbia License Renewal Application (LRA) which provided amended pages for the FSAR supplement related to Upper Shelf Energy (USE). Per a recent telephone conversation with the NRC staff, Energy Northwest noted that the wording provided in Amendment 28 required revision to clarify the discussion on USE.

Per the request of the NRC staff this revised wording is provided in the attached Amendment 53.

Additionally, based on recent conversations with NRC staff, information provided under Amendment 48 submitted via reference 3 requires clarification. The clarification is also provided in Amendment 53 attached to this letter.

RESPONSE TO NRC INFORMATION REQUEST LICENSE RENEWAL APPLICATION Page 2 of 2 contains Amendment 53 to the Columbia License Renewal Application. No new or revised commitments are included in this letter.

If you have any questions or require additional information, please contact John Twomey at (509) 377-4678.

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

Respectfully, AL Javorik Vice President, Engineering

Enclosure:

License Renewal Application Amendment 53 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)

MA Galloway - NRC NRR RR Cowley - WDOH

RESPONSE TO NRC INFORMATION REQUEST LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 LICENSE RENEWAL APPLICATION AMENDMENT 53 Section Page RAI Number Number Number A.1.3.1.2 A-29 Editorial B.2.5 B-40 Editorial

Columbia Generating Station A. 1.3.1.2 Upper Shelf Energy Evaluation I License Renewal Application Technical Information JAdditionally, a All.e.. pI.-.Jted USE values for thoveo, be..line plates and welds for wh,*h the initial USE is known remnain above 50 ft Ibs through the end of Mhc pcrivd of extended opcrntion (54 EFPY). For the vessel b-"tlin plates - and welds few which the initial USE A pecific 54 Iý

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dccrcacc in USE Wor 64 EFPY fr these b"ltline plates and welds ar,e bounded b, t analyases Th.- .. ....ur predica

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analysis will and w,.elds *9 neeenartble fe the oeried of PW'PtCndod anorationn wr,. ............ r* ..... V be performed Disposition ,er Replace with Insert A from Page A-29a.

for N12 nozzle eshelf energy TLAAs have been projected to the end of the period forgings prior of extended operation __. for all reactor vessel beltline materials. *1 to the period of extend A.1.3.1.3 Adjusted Reference Temperature Analysis operation. All In addition to USE, the other key parameter that characterizes the fracture toughness of Qth@rr --:ar-tQr a material is the RTNDT. This reference temperature changes as a function of exposure to neutron radiation resulting in an adjusted reference temperature, ART.

The initial RTNDT is the reference temperature for the unirradiated material. The change due to neutron radiation is referred to as ARTNDT. The ART is calculated by adding the initial RTNDT, the ARTNDT, and a margin to account for uncertainties as prescribed in nozzle Regulatory Guide 1.99, Revision 2. forgings, The ART evaluations of record for the vessel beltline plates ,,d elds for the currently

\J~/~ S'~-'and licensed period (33.1 EFPY) include power uprate conditions. Based on projected fluence values, the methodology in Regulatory Guide 1.99 was used to project the ART for 54 EFPY. The ART values projected to 54 EFPY are used to develop P-T limit curves. Projected ART values are well below the 200°F end of life ART suggested in Section 3 of Regulatory Guide 1.99 and are, thus, acceptable for the period of extended operation.

Disposition Reactor vessel adjusted reference temperature TLAAs have been projected to the end of the period of extended operation.

A. 1.3.1.4 Pressure-Temperature Limits To ensure that adequate margins of safety are maintained for various modes of reactor operation, 10 CFR 50, Appendix G specifies pressure and temperature requirements for affected materials for the service life of the reactor vessel. The basis for these fracture toughness requirements is ASME Section XI, Appendix G. The ASME Code requires P-T limits be established for hydrostatic pressure tests and leak tests; for operation with the core not critical during heatup and cooldown; and for core critical operation.

Final Safety Analysis Report Supplement Page A-29 t5tAmendment 53

Columbia Generating Station B.2.5 Buried Piping and Tanks Inspection Program License Renewal Application Technical Information 0Dotocation of Aging Effoct5, Require that an inspection of a representatiVc sample of buried piping be pn riurrm e Iwirn T ne 10 y, aFr preFIr PriOF H) cn nr rng n cT pcr lEu orf extcn nu opcration (i.e., between Year 30 and year 10).

in polyvinyl chloride Reqlufire an additional inspectionR of a ropresontatfiye sample of buried piping bee (PVC) performF'ed within 10 years after entering the period of extended operation (i.e.-,

piping in a between year 40 and year 50).

N Inert B fr4a- p...g.- B , stainless steel, portion of Operating Experience . I ... -m p 9 and polymeric the Potable iplant-specific I (PVC)

Water No history of piping degradation dueto external corrosion of buried piping was i',u I System for Columbia through searches of operating experience or discussions with program that is owners. Columbia operating experience demonstrates that the coating of buried steel outside the piping and tanks is effective in managing the effects of aging. Plant design scope of considerations addressed the potential for degradation of buried piping components License through the application of protectiveJorcoatincs internally-- I Insert

• I. to LRA. Section B.2.5

on Page B-40b.

- "

Renewal.

A review was conducted of station piping failures, and w was determined that there had been no documented failures attributed to externall -initiated corrosion. Identified instances of leakage associated with buried piping have been the resulit of internal RQt;4hlQ Insert J to LRA Section B.2.5 on Page B-40b. Insert K to LRA Section B.2.5 on Page B-40b.

The environmental conditions at Columbia are very good base n the sandy soil and System electrolyte resistivity of the soil which is considered very high. This has resulted in that--s minimal degradation of buried piping as evidenced by excavations of certain sections of etsidtewta piping for examination. There have been no significant areas of degradation caused by protective coating failure. This was determined after a section of buried Standby Renpewal Service Water (SW) System piping was excavated and evaluated in 2007.

Conclusion Insert L to LRA Section Replace with Insert 1B.2.5 on Page B-40c. A OR Pag* 9 4/a The tIid Piping adi Tanks Inspection Pogran vvwi ,,,anage lous u, material due to nUfr suseptible piping components and tanks in buried envirnments The Buried Piping and Tanks Inspection Program, with the required enhancements, ovides reasonable assurance that the aging effects will be managed such that mponents subject to aging management review will continue to perform heir int ed functions consistent with the current licensing basis for the period of exten led eration.

MUlnsert to LRA Section B.2.5 on Page B-40c.-I Insert C from pa B a Aging Management Programs Page B-40 Januay2010 53 lAmendmentA:- *49