GO2-21-012, License Amendment Request to Remove License Condition 2.C.(34) and Revise License Condition 2.C.(35)

License Amendment Request to Remove License Condition 2.C.(34) and Revise License Condition 2.C.(35)

ML21118A812
Person / Time
Site:	Columbia
Issue date:	04/28/2021
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-21-012
Download: ML21118A812 (36)

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ENERGY Alex L. Javorik Columbia Generating Station P.O. Box 968, 964P

• --- NORTHWEST Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.2354 aljavorik@energy-northwest.com April 28, 2021 10 CFR 50.90 GO2-21-012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO REMOVE LICENSE CONDITION 2.C.(34) AND REVISE LICENSE CONDITION 2.C.(35)

Reference NUREG-2123, "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station," published May 2012

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Energy Northwest hereby requests an amendment to the Columbia Generating Station (Columbia) Renewed Facility Operating License (RFOL)

NPF-21. This amendment request is to remove license condition (LC) 2.C.(34) and revise LC 2.C.(35). LC 2.C.(34) is no longer applicable as the Columbia Final Safety Analysis Report (FSAR) has been updated to include the License Renewal (LR) commitments set forth in the reference. The revision to LC 2.C.(35) clarifies that future changes to the license renewal commitments (LRC), as dictated by operating experience (OE), are made under the provisions of 10 CFR 50.59. The proposed changes do not result in changes to the Technical Specifications or operating requirements of Columbia.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that these changes involve no significant hazards considerations. The bases for these determinations are included in Enclosure 1 of this submittal.

The proposed RFOL markup pages are included as Enclosure 2 to this submittal. Clean pages of the proposed RFOL change are included as Enclosure 3 of this submittal.

Enclosure 4 is provided for information and is a copy of the recently added FSAR Table A-1 identifying the Columbia LR commitments.

This letter does not contain any new regulatory commitments. Approval of the proposed amendment is requested within one year of the date of the submittal. Once approved, the amendment shall be implemented within 90 days.

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GO2-21-012 Page 2 of 2 In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.

If there are any questions or additional information required, please contact Mr. R. M.

Garcia, Licensing Supervisor, at 509-377-8463.

I declare under penalty of perjury that the foregoing is true and correct.

 !  

Executed this ______ day of _________ 2021.

Respectfully, Alex. Javorik Vice President Engineering Projects

Enclosures:

As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH

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GO2-21-012 Enclosure 1 Page 1 of 11 1.0

SUMMARY

DESCRIPTION This evaluation supports Energy Northwests application to amend Renewed Facility Operating License (RFOL) NPF-21 for Columbia Generating Station (Columbia) by removing license condition (LC) 2.C.(34) and revising LC 2.C.(35). These LCs were included in Columbias RFOL to identify programs and activities required to support operation into the period of extended operation (PEO). Since the issuance of the RFOL, Columbia's Final Safety Evaluation Report (FSAR) has been updated to include the License Renewal (LR) commitments set forth in NUREG-2123, Reference 1 except for Commitments 55, 56, 57, and 71 discussed in Section 2.2.

2.0 DETAILED DESCRIPTION Energy Northwest is proposing to delete LC 2.C.(34), which is no longer required, and make the following wording change to LC 2.C.(35) which clarifies (by removal of language in the RFOL LC tied to specific commitments) that 10 CFR 50.59 is the governing regulatory change process for license renewal commitment changes.

2.C.(35) The licensee's FSAR supplement submitted pursuant to 10 CFR 54.21(d) and Appendix A of NUREG-2123, as revised pursuant to the criteria set forth in 10 CFR 50.59, describes certain future programs and activities to be completed before the period of extended operation. Energy Northwest shall complete these activities no later than July 20, 2023 and shall notify the NRC in writing when implementation of these activities is complete.

The proposed wording also includes a change in the date when these activities are required to be complete to allow time at the end of refueling outage 26 to review and validate completion prior to the required notification.

2.1 Background

By letter dated January 19, 2010, Energy Northwest submitted its application to the U.S.

Nuclear Regulatory Commission (NRC) for renewal of the Columbia operating license for an additional 20 years. The NRC based the safety review for Columbia's license renewal on the Columbia License Renewal Application (LRA) and responses to the staffs requests for additional information (RAI). Energy Northwest supplemented the LRA and provided clarifications through responses to the RAIs, in audits, meetings, and docketed correspondence. Reference 1 provides a list of commitments in Appendix A related to the Aging Management Programs (AMPs) used to manage aging effects of structures and components (SCs) prior to, and during, the PEO. The table in Appendix A of Reference 1 listed these commitments along with the implementation schedules and the sources for each commitment.

On May 22, 2012, Energy Northwest was issued a renewed facility operating license for Columbia which contained three new LCs in Section 2.C as shown below.

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GO2-21-012 Enclosure 1 Page 2 of 11 C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(34) The information in the FSAR supplement, submitted pursuant to 10 CFR 54.21 (d), as supplemented by Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123, "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station" dated May 2012, is henceforth part of the FSAR which will be updated in accordance with 10 CFR 50.71 (e). As such, the licensee may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1,5,13,14,17,18, 23, 24, 26, 27, 28, 32, 36, 38 ,40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123 provided the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

(35) The licensee's FSAR supplement submitted pursuant to 10 CFR 54.21 (d),

as revised during the license renewal application review process, and as supplemented by Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123, describes certain future programs and activities to be completed before the period of extended operation. Energy Northwest shall complete these activities no later than June 20, 2023 and shall notify the NRC in writing when implementation of these activities is complete.

(36) To prevent lateral motion of the core plate, the licensee shall install core plate wedges around the periphery of the core plate within the shroud on or before December 20,2021. Upon completion of the core plate wedge installation, the licensee shall submit a written report to the NRC staff summarizing the results of the installation. The licensee shall also submit a written report regarding any corrective action taken related to core plate rim hold-down bolts or core plate wedges and the results of extent of condition reviews on or before December 20, 2021.

2.2 Updates to Columbia's FSAR 10 CFR 54.21(d) requires that an FSAR supplement for the facility 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 determined by paragraphs (a) and (c) of this section, respectively. LC 2.C.(34) states that the information in the FSAR supplement, submitted pursuant to 10 CFR 54.21 (d),

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GO2-21-012 Enclosure 1 Page 3 of 11 as supplemented by Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123, "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station" dated May 2012, is henceforth part of the FSAR which will be updated in accordance with 10 CFR 50.71(e).

The December 2013 FSAR update included the supplement required by 10 CFR 54.21(d). This update did not include all the commitments identified in the NUREG-2123 commitment table. On March 4, 2020, an additional change was made to the Columbia FSAR to include aging management information from Table A-1 of NUREG-2123 as Appendix A Table A-1 of the FSAR. The March 4, 2020 update did not include the following four commitments.

Commitment 55 is a one-time action to incorporate the FSAR supplement into the Columbia FSAR was not included in this update as updating the FSAR is not an aging management program and was completed by the December 2013 FSAR update.

Commitment 56 to apply the elements of corrective action, confirmation process, and administrative controls in the Operational Quality Assurance Program Document (OQAPD) to required aging management programs for both safety and non-safety related structures and components determined to require aging management during the period of extended operation was not included in this update as the OQAPD is not an aging management program and changes to the OQAPD are controlled by 10 CFR 50.54.

Commitment 57 is a one-time action to track the commitments identified in association with the Columbia license renewal in Columbias regulatory commitment management program was not included in this update as managing Columbia's regulatory commitments is not an aging management program.

Commitment 71 to perform a site-specific analysis to resolve the loss of preload due to stress relaxation and cracking or inspect the core plate bolts using an NRC approved method was not included because Columbia LC 2.C.(36) requires the core plate wedges to be installed on or before December 20, 2021.

3.0 JUSTIFICATION FOR REMOVING LC 2.C.(34) AND REVISING LC 2.C.(35)

NUREG-1800 Revision 2 states in Section 3.1.3.5 that if the applicant updates the FSAR to include the final FSAR supplement before the license is renewed, no [license]

condition will be necessary. Columbia's RFOL was issued on May 22, 2012 and the FSAR update did not occur until after the RFOL was issued. With the December 2013 update and the addition of NUREG-2123 Table A-1 to the Columbia FSAR, any proposed changes to the information in that table are required to be assessed pursuant to the criteria set forth in 10 CFR 50.59. Therefore, LC 2.C.(34) is no longer required to control changes to the license renewal (LR) aging management program (AMP)

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GO2-21-012 Enclosure 1 Page 4 of 11 information identified in the Columbia FSAR. Removing this LC will eliminate any confusion between the statement in the RFOL and the FSAR.

Reference 2, NEI 99-04, "Guidelines for Managing NRC Commitment Changes,"

Revision 0, dated July 1999 states that commitments that are embodied in the Updated Final Safety Analysis Report as descriptions of the facility or procedures are changed by applying the provisions of 10 CFR 50.59 to determine if a change requiring prior NRC approval exists. Adding the NUREG-2123 commitment table to the FSAR aligns with this guidance. Therefore, LC 2.C.(35) can be revised to clearly state that 10 CFR 50.59 as the governing regulatory change process for license renewal commitments. The change in date in LC 2.C.(35) is justifiable in that it does not substantially change the timing for completion of LR activities and subsequent notification to the NRC. The revised date still ensures completion of these actions months prior to entering PEO.

The third RFOL LC associated with license renewal (2.C.(36)) requires Energy Northwest to install core plate wedges on or before December 20, 2021, and to submit a report to NRC staff summarizing the results of the installation of wedges and, if applicable, corrective action. This RFOL LC is not part of the LAR.

4.0 TECHNICAL EVALUATION

The language in license condition 2.C.(34) allows changes to the listed commitments under the conditions set forth in 10 CFR 50.59. However, the language in license condition 2.C.(35) would suggest that the same commitments that could be changed under 10 CFR 50.59 in license condition 2.C.(34) would require prior NRC approval under license condition 2.C.(35). Consistent with the Standard Review Plan for License Renewal (SRP-LR) NUREG-1800 Revision 2, the NRC staff expected commitments in Appendix A of the Columbia license renewal safety evaluation report (SER) to be included in the FSAR and managed via 10 CFR 50.59. The application of 10 CFR 50.59 process will ensure that any changes to the facility, procedures, testing methods or analyses described in the FSAR are evaluated via a structured and disciplined approach, and records of the changes are maintained available for NRC inspection. The changes proposed to these two LCs will allow Energy Northwest to change the commitments listed in NUREG-2123 pursuant to the criteria set forth in 10 CFR 50.59.

The proposed change to delete Columbia's LC 2.C.(34) and revise Columbia's LC 2.C.(35) does not involve physical changes to the plant or changes to any of the commitments made by Energy Northwest during the license renewal process. The proposed changes to Columbia's LCs 2.C.(34) and 2.C.(35) do not lessen the controls imposed on any changes that may be made to the existing AMPs, specifically the requirement to apply 10 CFR 50.59 to any changes being considered.

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GO2-21-012 Enclosure 1 Page 5 of 11

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements 5.1.1 10 CFR 54.21(d) 10 CFR 54.21(d) requires the LRA FSAR supplement contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analysis (TLAA) for the period of extended operation. The FSAR supplement did not list the additional commitments identified in Appendix A of NUREG-2123.

By letter dated December 30, 2013, Energy Northwest submitted Amendment 62 of the FSAR. FSAR Amendment 62 included the required FSAR program summaries, reviewed as part of the LRA as FSAR Appendix A. The update to the FSAR did not include the additional commitments listed in NUREG-2123.

5.1.2 10 CFR 50.71 Maintenance of Records, Making of Reports 10 CFR 50.71(e)(4) requires licensees to submit revisions of the FSAR. For Columbia, the interval for submission is not to exceed 24 months. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filling.

Columbia maintains the FSAR as a living document. Updates occur regularly throughout the reporting cycle. The last submittal, as required by 10 CFR 50.71, was December 2019. Enclosure 2 contains the current FSAR Appendix A, Table A-1 Columbia License Renewal Commitments which were added to the living FSAR in March 2020. These changes will be reflected in the next 10 CFR 50.71 update in December of 2021.

5.1.3 10 CFR 50.59 Changes, Test, and Experiment This regulation provides the requirements under which the licensee can make changes to the facility as described in the FSAR without prior NRC approval. Included in this regulation is the requirement to submit a report that includes a brief description and evaluation of any changes, test, and experiments. Submittal of the report is not to exceed 24 months. The last submittal was January 2020.

5.2 Applicable Regulatory Guidance 5.2.1 NRR Office Instruction LIC-105 Revision 7 August 22, 2016 (Reference 3)

The Office of Nuclear Reactor Regulation (NRR) stated in Office Instruction LIC-105, Revision 7 that issues concerning the use of regulatory commitments usually center on the legal standing of the commitment and the NRC staffs ability to enforce the action committed to by a licensee. The staff determined that keeping regulatory commitments as an element of licensing basis information should continue because, when handled

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GO2-21-012 Enclosure 1 Page 6 of 11 properly, the commitments support the overall licensing process by adding flexibility, improving efficiency, and maintaining the flow of information between the staff and licensees. These advantages usually outweigh concerns that a licensee is not legally bound to fulfill, and subsequently control, an action appropriately classified as a regulatory commitment.

5.2.2 NRC Regulatory Issue Summary (RIS) 2000-17 September 21, 2000 (Reference 4)

NRC Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments made by Power Reactor Licensees to the NRC Staff," states that the staff has described, in various Commission papers and internal guidance documents, a hierarchal structure for the various elements of a facility's licensing basis. The approach to the hierarchy is presented in terms of the change control, reporting requirements, and other attributes of the different elements of the licensing basis [see NRR Office Letter 807, Control of Licensing Bases for Operating Reactors (ADAMS Accession No. ML003693397)]. The levels of the hierarchy are (1) obligations or regulatory requirements that require prior NRC approval of proposed changes, (2) mandated licensing basis documents, such as the updated final safety analysis report, for which the NRC has established requirements for content, change control and reporting, and (3) regulatory commitments controlled by licensee and NRC administrative processes.

The initial Columbia LRA included 59 commitments. Via the review process, Energy Northwest made 70 commitments. The NRC's SE identified 71 commitments.

Commitment 71 (core plate wedges) resulted in RFOL LC 2.C.(36) as identified in the transcript of the 593rd meeting of the Advisory Committee on Reactor Safeguards (ACRS) page 191 (ADAMS Accession No. ML12115A085). LC 2.C.(36) is not included in this request.

5.2.3 Memorandum "Assessment of Regulatory Processes that Utilize Regulatory Commitments," November 26, 2008 (Reference 5)

This memorandum states in Section 4.1, License Amendments, that routine commitments on technical matters that do not satisfy the criteria for inclusion in technical specifications by 10 CFR 50.36 or inclusion in the license to address significant safety issues where licenses have been amended to capture routine commitments may be revised in future amendment requests to delete the special appendix.

The memorandum goes on to state that for the time being, the staff should continue imposing conditions on license amendments that involve, as a vital element of the staff's approval, the subsequent placement of information in a particular mandated licensing basis document. Commonly, this type of amendment relocates requirements from a facility's technical specification to the FSAR. These conditions are generally not added in the operating license (i.e., Section 2.C).

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GO2-21-012 Enclosure 1 Page 7 of 11 5.2.4 SECY-98-224 September 28, 1998 (Reference 6)

SECY-98-224 "Staff and Industry Activities Pertaining to the Management of Commitments Made by Power Reactor Licensees to the NRC" from September of 1989 provides an approach to the hierarchy of Obligations, Mandated Licensing Basis Documents. Regulatory Commitments, and Non-Licensing-Basis Information as follows:

(1) Obligations - conditions or actions that are legally binding requirements imposed on licensees through applicable rules, regulations, orders, and licenses (including technical specifications and license conditions). The imposition of obligations (sometimes referred to as regulatory requirements) during routine interactions with licensees should be reserved for matters that satisfy the criteria of 10 CFR 50.36 or are otherwise found to be of high safety or regulatory significance. In such matters concerning the adequate protection of the public health and safety, changes cannot be made without prior NRC approval. Some processes such as rulemaking that impose regulatory obligations are currently well defined by regulations, management directives, and other office-level guidance documents.

(2) Mandated Licensing Basis Documents - documents, such as the updated FSAR, the quality assurance program, the security plan, and the emergency plan, for which the NRC has established requirements for content, change control and reporting. What information should be included in these documents is specified in applicable regulations and regulatory guides. The change control mechanisms and reporting requirements are defined by regulatory processes such as 10 CFR 50.59, 50.54, and 50.71.

(3) Regulatory Commitments - explicit, written, docketed statements by a licensee agreeing or volunteering to take specific actions that change the licensing basis of a nuclear power plant. A regulatory commitment is appropriate for matters in which the staff has a significant interest, but which do not warrant either a legally binding requirement or inclusion in the updated FSAR or a program subject to a formal regulatory change control mechanism. Control of such commitments in accordance with licensee programs is acceptable provided those programs include controls for evaluating changes and reporting them to the NRC to maintain the accuracy of the "licensing basis" on the docket.

(4) Non-Licensing-Basis Information - information that is exchanged during routine interactions between the NRC staff and licensees but that does not warrant being considered as part of the "licensing basis." Information provided to NRC staff in regional offices or headquarters pertaining to corrective actions for routine problems with plant equipment or procedures would likely fall into this category.

The information should be controlled in accordance with normal licensee programs. There should be mutual understanding by licensees and NRC staff that such information may not need to be updated in docketed correspondence.

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GO2-21-012 Enclosure 1 Page 8 of 11 These four documents support the removal of LC 2.C.(34) and the revision of LC 2.C.(35) because the commitments have been moved into a mandated licensing basis document (FSAR), which represents a higher licensing basis standard. This preserves the use of LCs for matters that satisfy the criteria of 10 CFR 50.36 or are otherwise found to be of high safety or regulatory significance.

6.0 PRECEDENT Although there is no direct precedent in which similar LCs have been removed, there are two NRC safety evaluations that provide support for Energy Northwest's request that LC 2.C.(34) is no longer required and that LC 2.C.(35) revision is acceptable.

6.1 Vermont Yankee Vermont Yankee Nuclear Power Station, "Issuance of Amendment to Renewed Facility Operating License Re: License Condition 3.P and 3.Q Changes," Amendment No. 256 dated April 17, 2013, (ADAMS Accession No. ML13042A272). This amendment allowed the licensee to change license renewal commitments provided they are evaluated in accordance with 10 CFR 50.59.

From Section 3.2 NRC Staff Evaluation Consistent with the SRP-LR, the staff expected that commitments in Appendix A of the VY license renewal SER to be included in the UFSAR and managed via 10 CFR 50.59. The 10 CFR 50.59 process will ensure that any changes to the facility, procedures, testing methods or analyses described in the FSAR are evaluated via a structured and disciplined approach, and records of the changes are maintained available for NRC inspection.

This amendment allows changes to the license renewal commitments to be assessed under the requirements of 10 CFR 50.59. This is similar to the request being made by Energy Northwest in that the removal of LC 2.C.(34) and revision of LC 2.C.(35) clarifies that 10 CFR 50.59 is the process by which changes to the FSAR are reviewed and assessed.

6.2 Cooper Nuclear Station Cooper Nuclear Station, "Issuance of Amendment Re: Modification of Renewed Operating License Condition 2.E," Amendment No. 247 dated September 12, 2013, (ADAMS Accession No. ML13191A105). This amendment required incorporation of the commitments listed in Appendix A of NUREG-1944, "Safety Evaluation Report Related to the License Renewal of Cooper Nuclear Station," dated October 2010, in the updated safety analysis report to be managed in accordance with Section 50.59 of Title 10 of the Code of Federal Regulations.

From Section 3.3 Summary of Technical Evaluation

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GO2-21-012 Enclosure 1 Page 9 of 11 Per the licensee's request in this LAR, the NRC staff concludes that it is acceptable to incorporate the actions in the commitments as part of the USAR for the reasons described in Section 3.2 of this SE, rather than treating the commitments referenced in license condition 2.F as license conditions. Therefore, the commitments can be listed in license condition 2.E.

Once the incorporation of the commitments into the FSAR is completed, the changes are managed under the requirements of 10 CFR 50.59. This is similar to the request being made by Energy Northwest in that removal of LC 2.C.(34) and revision of LC 2.C.(35) clarifies that 10 CFR 50.59 is the process by which changes to the FSAR are reviewed and assessed.

7.0 SIGNIFICANT HAZARDS CONSIDERATION This amendment request would remove license condition (LC) 2.C.(34) from the Columbia Renewed Facility Operating License NP-21 and revise LC 2.C.(35) to clarify that 10 CFR 50.59 is the process by which changes to license renewal commitments contained in the FSAR are reviewed and assessed. Energy Northwest has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed license amendment does not involve a change to any plant equipment that initiates or mitigates a plant accident. The change is administrative and therefore, the proposed change would not affect the functionality of the associated structures, systems, and components (SSC) in the aging management programs (AMP). Changes to commitments or Final Safety Analysis Report (FSAR) summaries describing the programs and activities credited to manage the effects of aging can only be changed under 10 CFR 50.59 or 10 CFR 50.90. These changes are therefore controlled and require justification that the 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.

Therefore, there is no significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?

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GO2-21-012 Enclosure 1 Page 10 of 11 Response: No.

This change does not modify or add any equipment or involve controlling or operating equipment. It is an administrative change that will allow changes to individual license renewal commitments under 10 CFR 50.59. There are no postulated hazards, new or different, contained in this amendment as the amendment does not change design or operational requirements of any SSC.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes do not involve revisions to design codes or design margins of any SSCs. The change is administrative; therefore, the proposed change would not affect the functionality of the associated SSCs in the AMPs Therefore, the proposed change does not involve a significant reduction in the margin of safety.

8.0 CONCLUSION

S Based on the considerations discussed above, Energy Northwest concludes that:

1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner,

2) such activities will be conducted in compliance with the applicable regulations as identified herein, and

3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

9.0 ENVIRONMENTAL CONSIDERATION

Energy Northwest has determined that the proposed amendment would not change requirements with respect to installation or use of a facility component located within Columbia's restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. Energy Northwest has evaluated the proposed change and has determined that the change does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or

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GO2-21-012 Enclosure 1 Page 11 of 11 environmental assessment need be prepared in connection with the proposed amendment.

10.0 REFERENCES

1. NUREG-2123, "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station," published May 2012

2. NEI 99-04, "Guidelines for Managing NRC Commitment Changes, " Revision 0, dated July 1999

3. NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC," Revision 7 dated August 22, 2016

4. NRC Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000

5. NRC Memorandum from J. G. Giitter (Director, Division of Operating Reactor Licensing) to B. A. Boger (Associate Director, Reactor Oversight and Licensing),

"Assessment of Regulatory Processes that Utilize Regulatory Commitment," dated November 26, 2008

6. SECY-98-224 from L. J. Callan (Executive Director for Operations) to The Commissioners, "Staff and Industry Activities Pertaining to the Management of Commitments Made by Power Reactor Licensees to the NRC," dated September 28, 1998

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GO2-21-012 Enclosure 2 Proposed Columbia Operating License Changes (Mark-Up)

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GO2-19-012 Enclosure 2 Page 1 of 1 (34) The information in the FSAR supplement, submitted pursuant to 10 CFR 54.21(d),

as supplemented by Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123, "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station" dated May 2012, is henceforth part of the FSAR which will be updated in accordance with 10 CFR 50.71(e). As such, the licensee may make changes to the programs and activities described in the UFSAR supplement and Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123 provided the licensee evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section. 'HOHWHG

(35) The licensee's FSAR supplement submitted pursuant to 10 CFR 54.21(d) and Appendix A of NUREG-2123, as revised pursuant to the criteria set forth in 10 CFR 50.59, during the license renewal application review process, and as supplemented by Commitment Nos. 1, 5, 13, 14, 17, 18, 23, 24, 26, 27, 28, 32, 36, 38, 40, 41, 42, 43, 48, 49, 50, 53, 55, 58, 59, 60, 61, 63, 64, 65, 66, 67, 68, 69, and 70 of Appendix A of NUREG-2123, describes certain future programs and activities to be completed before the period of extended operation. Energy Northwest shall complete these activities no later than JuneJuly 20, 2023 and shall notify the NRC in writing when implementation of these activities is complete.

(36) To prevent lateral motion of the core plate, the licensee shall install core plate wedges around the periphery of the core plate within the shroud on or before December 20, 2021. Upon completion of the core plate wedge installation, the licensee shall submit a written report to the NRC staff summarizing the results of the installation. The licensee shall also submit a written report regarding any corrective action taken related to core plate rim hold-down bolts or core plate wedges and the results of extent of condition reviews on or before December 20, 2021.

Renewed License No. NPF-21 Amendment No.225

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GO2-21-012 Enclosure 3 Proposed Columbia Operating License Changes (Re-Typed)




 

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GO2-21-012 Enclosure 3 (34) Deleted.

(35) The licensee's FSAR supplement submitted pursuant to 10 CFR 54.21(d) and Appendix A of NUREG-2123, as revised pursuant to the criteria set forth in 10 CFR 50.59, describes certain future programs and activities to be completed before the period of extended operation. Energy Northwest shall complete these activities no later than July 20, 2023 and shall notify the NRC in writing when implementation of these activities is complete.

(36) To prevent lateral motion of the core plate, the licensee shall install core plate wedges around the periphery of the core plate within the shroud on or before December 20, 2021. Upon completion of the core plate wedge installation, the licensee shall submit a written report to the NRC staff summarizing the results of the installation. The licensee shall also submit a written report regarding any corrective action taken related to core plate rim hold-down bolts or core plate wedges and the results of extent of condition reviews on or before December 20, 2021.

Renewed License No. NPF-21 Amendment No.

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GO2-19-012 Enclosure 4 Revised FSAR Appendix A Table A-1 Columbia License Renewal Commitments (Information Only)

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 1 The Aboveground Steel Tanks Inspection is a new program. A.1.2.1 Within the 10- LRA Appendix B.2.1 year period prior January 19, 2010 Aboveground The Aboveground Steel Tanks Inspection detects and characterizes the conditions to the period of Steel Tanks on the bottom surfaces of the condensate storage tanks. The program provides extended Columbia Letter GO2-10-173 FINAL SAFETY ANALYSIS REORT Inspection direct evidence as to whether, and to what extent, the relevant effects of aging have operation. RAI B.2.1-3 occurred in inaccessible areas. December 7, 2010 Then ongoing.

2 The Air Quality Sampling Program is an existing program that will be continued for A.1.2.2 Ongoing LRA Appendix B.2.2 the period of extended operation. January 19, 2010 Air Quality Sampling Program 3 The Appendix J Program is an existing program that will be continued for the period A.1.2.3 Ongoing LRA Appendix B.2.3 of extended operation. January 19, 2010 Appendix J COLUMBIA GENERATING STATION Program A.4-1 4 The Bolting Integrity Program is an existing program that will be continued for the A.1.2.4 Ongoing LRA Appendix B.2.4 period of extended operation. January 19, 2010 Bolting Integrity Program 5 The Buried Piping and Tanks Inspection Program is an existing program that will be A.1.2.5 Enhancement LRA Appendix B.2.5 continued for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 Buried Piping and of extended Tanks Inspection Revise the site program document to include: operation. Columbia Letter GO2-10-094 Program First Annual Update x cracking, loss of material and loss of pre-load of bolting as aging effects Then ongoing. July 16, 2010 managed by the program.

x loss of material for (buried) stainless steel piping and piping components as an Columbia Letter GO2-10-179 aging effect managed by the program. RAI 3.4.2.3-1 x components that are located underground (below grade) in areas, such as December 21, 2010 outdoor vaults, valve pits and inside guard pipes where access for inspection is restricted. Columbia Letter GO2-11-028 x buried concrete and polymeric piping to confirm the absence of significant RAI B.2.5-2 aging effect. January 28, 2011 x

Revise the site program document to:

Amendment 66 x confirm (prior to the period of extended operation) that all portions of buried piping and components, except for the diesel fuel oil system, in the scope of license renewal are provided with cathodic protection through the period of December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section extended operation.

x ensure that cathodic protection is operable at least 90% of the time between inspections during the period of extended operation.

x ensure that deviations from cathodic protection criteria are less than 90 days duration during the period of extended operation.

Revise the site program document to:

FINAL SAFETY ANALYSIS REORT x require that inspection of a representative sample of each buried and underground piping material and buried tank be performed within the 10-year period prior to entering the period of extended operation (i.e., between year 30 and end of year 40) and in each 10 year interval of the period of extended operation (i.e., between year 40 and year 50, and again between year 50 and year 60) per the following table:

COLUMBIA GENERATING STATION Number or percentage of Inspections (per 10-Year A.4-2 Material/Location interval through end of the period of extended operation)

(buried or underground) Code-Class/ Safety-Hazmat Related/ Other Polymer/Buried 1 --

Concrete/Buried 1 --

Stainless 1 --

Steel/Buried Steel/Buried 1 2%

Stainless 1 --

Steel/Underground Steel/Underground 2 2%

Steel Tank/Buried 1 --

x require appropriate tactile (e.g., manual) examination of buried polymeric components to supplement visual inspections for confirmation that significant aging effect are not occurring.

Amendment 66 x require wall thickness measurement by a non-destructive examination technique such as ultrasonic testing (UT) and results documentation for further evaluation, if loss of material has been detected.

x require confirmation that backfill is acceptable with regards to degradation of December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section pipe coatings, and thereby, meets the objectives of NACE SP0169-2007.

x include collection of trending information on cathodic protection system effectiveness (e.g., potential difference and current measurements) and adjustment of the program as needed based on the results.

x include trending of the external surface condition or coating condition of buried and underground piping, piping components and buried tanks and adjustment of the program as needed based on the results.

FINAL SAFETY ANALYSIS REORT Revise the site program document for acceptance criteria associated with the inspections:

x criteria for soil-to-pipe potential as listed in NACE Standard SP0169-2007.

x backfill is acceptable with regard to degradation of pipe external coatings and, thereby, meets the objectives of NACE Standard SP0169-2007.

x for coated piping or tanks, either no evidence of coating degradation or the type and extent of coating degradation determined to be insignificant as evaluated by an individual with the qualification to evaluate coatings.

COLUMBIA GENERATING STATION x

A.4-3 If coated or uncoated metallic piping show evidence of corrosion, the remaining wall thickness in the affected area is determined to ensure that the minimum wall thickness is maintained.

x cracking or blistering of polymeric piping is evaluated.

x concrete piping may exhibit minor cracking and spalling provided there is no evidence of leakage or exposed rebar or reinforcing hoop bands.

6 The BWR Feedwater Nozzle Program is an existing program that will be continued A.1.2.6 Ongoing LRA Appendix B.2.6 for the period of extended operation. January 19, 2010 BWR Feedwater Nozzle Program 7 The BWR Penetrations Program is an existing program that will be continued for the A.1.2.7 Ongoing LRA Appendix B.2.7 period of extended operation. January 19, 2010 BWR Penetrations Program 8 The BWR Stress Corrosion Cracking Program is an existing program that will be A.1.2.8 Ongoing LRA Appendix B.2.8 continued for the period of extended operation. January 19, 2010 BWR Stress Corrosion Cracking Program Amendment 66 December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 9 The BWR Vessel ID Attachment Welds Program is an existing program that will be A.1.2.9 Ongoing LRA Appendix B.2.9 continued for the period of extended operation. January 19, 2010 BWR Vessel ID Attachment Welds Program 10 The BWR Vessel Internals Program is an existing program that will be continued for A.1.2.10 Ongoing LRA Appendix B.2.10 the period of extended operation. January 19, 2010 FINAL SAFETY ANALYSIS REORT BWR Vessel Internals Program 11 The BWR Water Chemistry Program is an existing program that will be continued A.1.2.11 Ongoing LRA Appendix B.2.11 for the period of extended operation. January 19, 2010 BWR Water Chemistry Program 12 The Chemistry Program Effectiveness Inspection is a new activity. A.1.2.12 Within the 10- LRA Appendix B.2.12 year period prior January 19, 2010 The Chemistry Program Effectiveness Inspection detects and characterizes the to the period of COLUMBIA GENERATING STATION Chemistry condition of materials in representative low flow and stagnant areas of systems with extended A.4-4 Program water chemistry controlled by the BWR Water Chemistry Program or the Closed operation.

Effectiveness Cooling Water Chemistry Program, and with fuel oil chemistry controlled by the Fuel Inspection Oil Chemistry Program. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

13 The Closed Cooling Water Chemistry Program is an existing program that will be A.1.2.13 Enhancement LRA Appendix B.2.13 continued for the period of extended operation, with the following enhancement: prior to the period January 19, 2010 of extended Closed Cooling Ensure that at least one additional reactor closed cooling water corrosion rate operation Water Chemistry measurement is performed and evaluated prior to entering the period of extended Program operation to provide direct information as to the effectiveness of the chemical Then ongoing.

treatments. If necessary, based on the results, establish a frequency for subsequent measurements.

14 The Cooling Units Inspection Program is a new program. A.1.2.14 Implementation LRA Appendix B.2.14 prior to the period January 19, 2010 The Cooling Units Inspection Program manages the effects of loss of material of of extended Cooling Units aluminum, steel, copper alloy, and stainless steel cooling unit components that are operation and Columbia Letter Inspection exposed to condensation. The inspection also manages the effects of a reduction in initial inspection GO2-11-025 Program heat transfer due to fouling of heat exchanger tubes and fins and cracking due to within the 10-year RAI B.2.14-1 SCC of aluminum components exposed to condensation. period prior to the January 28, 2011 period of Amendment 66 The Cooling Units Inspection Program consists of baseline inspections prior to the extended period of extended operation followed by opportunistic inspections during the period operation.

of extended operation.

Then ongoing.

December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section Following the baseline inspection, inspection findings will be reviewed periodically to ensure that each material exposed to condensation has been examined via opportunistic inspection or actions are taken to ensure inspections are performed.

Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

15 The CRDRL Nozzle Program is an existing program that will be continued for the A.1.2.15 Ongoing LRA Appendix B.2.15 FINAL SAFETY ANALYSIS REORT period of extended operation. January 19, 2010 CRDRL Nozzle Program 16 The Diesel Starting Air Inspection is a new activity. A.1.2.16 Within the 10- LRA Appendix B.2.16 year period prior January 19, 2010 Diesel Starting Air The Diesel Starting Air Inspection detects and characterizes the condition of to the period of Inspection materials for the DSA system air dryers and downstream piping and components extended (excluding the DSA system air receivers). operation.

The inspection provides direct evidence as to whether, and to what extent, the COLUMBIA GENERATING STATION A.4-5 relevant effects of aging have occurred.

17 The Diesel Systems Inspection Program is a new program. A.1.2.17 Implementation LRA Appendix B.2.17 prior to the period January 19, 2010 Diesel Systems The Diesel Systems Inspection Program manages the effects of loss of material due of extended Inspection to corrosion and cracking due to stress corrosion cracking of materials for the operation and Columbia Letter GO2-10-094 Program interior of the steel and stainless steel exhaust piping components for the Division 1, initial inspection First Annual Update 2, and 3 diesels in the diesel engine exhaust system, including the loop seal drains within the 10-year July 16, 2010 from the exhaust piping. period prior to the period of Columbia Letter GO2-11-025 The Diesel Systems Inspection Program consists of baseline inspections prior to the extended RAI B.2.14-1 period of extended operation followed by opportunistic inspections during the period operation. January 28, 2011 of extended operation.

Then ongoing. Columbia Letter GO2-11-185 Following the baseline inspection, inspection findings will be reviewed periodically to RAI B.2.14-1 ensure that each material exposed to air-outdoor and raw water has been examined November 16, 2011 via opportunistic inspection or actions are taken to ensure inspections are performed. Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

18 The Diesel-Driven Fire Pumps Inspection Program is a new program. A.1.2.18 Implementation LRA Appendix B.2.18 prior to the period January 19, 2010 Diesel-Driven Fire The Diesel-Driven Fire Pumps Inspection Program manages the effects of loss of of extended Amendment 66 Pumps Inspection material, due to corrosion or erosion, and reduction in heat transfer of the interior of operation and Columbia Letter GO2-11-025 Program the fire protection system diesel engine exhaust piping, and of fire protection system initial inspection RAI B.2.14-1 diesel heat exchangers exposed to a raw water environment. The program also within the 10-year January 28, 2011 manages cracking due to SCC of susceptible materials. period prior to the December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section The Diesel-Driven Fire Pumps Inspection Program consists of baseline inspections period of Columbia Letter GO2-11-185 prior to the period of extended operation followed by opportunistic inspections extended RAI B.2.14-1 during the period of extended operation. operation. November 16, 2011 Following the baseline inspection, inspection findings will be reviewed periodically to Then ongoing.

ensure that each material exposed to air-outdoor and raw water has been examined via opportunistic inspection or actions are taken to ensure inspections are FINAL SAFETY ANALYSIS REORT performed. Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

19 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ A.1.2.19 Implementation LRA Appendix B.2.19 Requirements Program is a new program. prior to the period January 19, 2010 Electrical Cables of extended and Connections The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ operation.

Not Subject to 10 Requirements Program is an inspection program that detects degradation of CFR 50.49 EQ electrical cables and connections that are not environmentally qualified and are Then ongoing.

Requirements within the scope of license renewal.

Program COLUMBIA GENERATING STATION The program provides for the periodic visual inspection of accessible, non-A.4-6 environmentally qualified cables and connections in order to determine if age-related degradation is occurring, particularly in plant areas with adverse localized environments.

20 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ A.1.2.20 Implementation LRA Appendix B.2.20 Requirements Used in Instrumentation Circuits Program is a new program. prior to the period January 19, 2010 Electrical Cables of extended and Connections The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ operation.

Not Subject to 10 Requirements Used in Instrumentation Circuits Program is a monitoring program CFR 50.49 EQ that detects degradation of electrical cables and connections that are not Then ongoing.

Requirements environmentally qualified and used in circuits with sensitive, low-current Used in applications. The program provides for a review of calibration records for low-Instrumentation current instruments, in order to detect and identify degradation of the cable system Circuits Program insulation resistance. The program retains the option to perform direct cable testing.

21 The Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements A.1.2.21 Within the 10- LRA Appendix B.2.21 Inspection is a new activity. year period prior January 19, 2010 Electrical Cable to the period of Connections Not The Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements extended Subject to 10 CFR Inspection detects and characterizes the material condition of metallic electrical operation.

Amendment 66 50.49 EQ connections within the scope of license renewal. The inspection uses Requirements thermography (augmented by contact resistance testing) to detect loose or Inspection degraded connections that lead to increased resistance for a representative sample of metallic electrical connections in various plant locations.

December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 22 The EQ Program is an existing program that will be continued for the period of A.1.2.22 Ongoing LRA Appendix B.2.22 extended operation. A.1.3.5 January 19, 2010 EQ Program 23 The External Surfaces Monitoring Program is an existing program that will be A.1.2.23 Enhancement LRA Appendix B.2.23 continued for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 External Surfaces of extended Monitoring x add aluminum, copper alloy, copper alloy >15 % Zn, gray cast iron, stainless operation Columbia Letter GO2-10-094 FINAL SAFETY ANALYSIS REORT Program steel (including CASS), and elastomers to the program scope. First Annual Update x add cracking as an aging effect for aluminum components. Then ongoing. July 16, 2010 x add visual (VT-1 or equivalent) or volumetric examination techniques to detect cracking. Columbia Letter GO2-11-025 x add hardening and loss of strength as aging effects for elastomer- based RAI B.2.14-1 mechanical sealants in HVAC systems. January 28, 201 x add physical examination techniques in addition to visual inspection to detect hardening and loss of strength for elastomer-based mechanical sealants in HVAC systems.

24 The Fatigue Monitoring Program is an existing program that will be continued for the A.1.2.24 Enhancement LRA Appendix B.2.24 COLUMBIA GENERATING STATION A.4-7 period of extended operation, with the following enhancements: A.1.3.2 prior to the period January 19, 2010 Fatigue Monitoring A.1.3.4 of extended Program x Columbia has analyzed the effects of the reactor coolant environment on operation.

fatigue for the six locations recommended by NUREG\CR-6260. These analyses are based on the projected cycles for 60 years of operation (plus Then ongoing.

some conservatism) rather than the original design cycles in FSAR Table 3.9-

1. The Fatigue Monitoring Program will be enhanced to ensure that action will be taken when the lowest number of analyzed cycles is approached.

- For each location that may exceed a CUF of 1.0 (due to projected cycles exceeding analyzed, or due to as-yet undiscovered industry issues), the Fatigue Monitoring Program will implement one or more of the following: (1)

Refine the fatigue analyses to determine valid CUFs less than 1.0, (2)

Manage the effects of aging due to fatigue at the affected locations by an inspection program that has been reviewed and approved by the NRC, or (3)

Repair or replace the affected locations before exceeding a CUF of 1.0.

x Correlate information relative to fatigue monitoring and provide more definitive verification that the transients monitored and their limits are consistent with or bound the FSAR and the supporting fatigue analyses, including the environmentally-assisted fatigue analyses.

Amendment 66 25 The Fire Protection Program is an existing program that will be continued for the A.1.2.25 Ongoing LRA Appendix B.2.25 period of extended operation. January 19, 2010 Fire Protection Program December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 26 The Fire Water Program is an existing program that will be continued for the period A.1.2.26 Enhancement LRA Appendix B.2.26 of extended operation, with the following enhancements: prior to the period January 19, 2010 Fire Water of extended Program x perform either ultrasonic testing or internal visual inspection of representative operation. Columbia Letter GO2-10-117 portions of above ground fire protection piping that are exposed to water, but RAI B.2.26-1 do not normally experience flow, after the issuance of the renewed license, but Then ongoing. August 19, 2010 prior to the end of the current operating term and at reasonable intervals FINAL SAFETY ANALYSIS REORT thereafter, based on engineering review of the results. Columbia Letter GO2-11-029 x either replace sprinkler heads that have been in place for 50 years or submit RAI B.2.26-6 representative samples to a recognized laboratory for field service testing in January 28, 2011 accordance with NFPA 25 recommendations. Perform subsequent replacement or field service testing of representative samples at 10-year intervals thereafter or until there are no sprinkler heads installed that will reach 50 years of service life during the period of extended operation.

x perform hardness testing (or equivalent) of the sprinkler heads as part of their NFPA sampling, to determine whether loss of material due to selective leaching is occurring.

COLUMBIA GENERATING STATION x perform ultrasonic testing of representative portions of above ground fire A.4-8 protection piping that is exposed to flowing water during periodic tests, and susceptible to a loss of material due to erosion (wall thinning).

x perform visual inspection of a representative sample of copper alloy.

>15% Zn fire protection components exposed to water for evidence of cracking (presence of ammonia) within the 10-year period prior to entering the period of extended operation (i.e., between year 30 and 40).

x perform an additional visual inspection of a representative sample of copper alloy >15% Zn fire protection component exposed to water for evidence of cracking (presence of ammonia) within the 10-year period after entering the period of extended operation (i.e., between year 40 and 50).

x address loss of material due to cavitation erosion with activities such as scheduled inspections of the fire protection piping locations that have had indications of cavitation erosion in the past.

Amendment 66 December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 27 The Flexible Connection Inspection Program is a new program. A.1.2.27 Implementation LRA Appendix B.2.27 prior to the period January 19, 2010 Flexible The Flexible Connection Inspection Program manages degradation, including the of extended Connection effects of loss of material due to wear and hardening and loss of strength of operation and Inspection elastomer components exposed to treated water, dried air, gas, and indoor air initial inspection Columbia Letter GO2-11-025 Program environments. within the 10-year RAI B.2.14-1 period prior to the January 28, 2011 FINAL SAFETY ANALYSIS REORT The program consists of base line inspections prior to the period of extended period of operation followed by opportunistic inspections during the period of extended extended operation. operation.

Following the baseline inspection, inspection findings will be reviewed periodically to Then ongoing.

ensure that each material and environment combination has been examined via opportunistic inspection or actions are taken to ensure inspections are performed.

Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

28 The Flow-Accelerated Corrosion (FAC) Program is an existing program that will be A.1.2.28 Enhancement LRA Appendix B.2.28 COLUMBIA GENERATING STATION continued for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 A.4-9 Flow-Accelerated of extended Corrosion (FAC) x add the containment nitrogen system components supplied with steam from the operation.

Program auxiliary steam system to the scope of the program.

x Add gray cast iron as a material identified as susceptible to FAC. Then ongoing.

29 The Fuel Oil Chemistry Program is an existing program that will be continued for the A.1.2.29 Ongoing LRA Appendix B.2.29 period of extended operation. January 19, 2010 Fuel Oil Chemistry Program 30 The Heat Exchangers Inspection is a new activity. The Heat Exchangers Inspection A.1.2.30 Within the 10- LRA Appendix B.2.30 detects and characterizes the surface conditions with respect to fouling of heat year period prior January 19, 2010 Heat Exchangers exchangers and coolers that are in the scope of the inspection and exposed to to the period of Inspection treated water, closed cooling water, or indoor air. The inspection provides direct extended evidence as to whether, and to what extent, the relevant effects of aging have operation occurred.

31 The High-Voltage Porcelain Insulators Aging Management Program is an existing A.1.2.31 Enhancement LRA Appendix B.2.31 program that will be continued for the period of extended operation, with the prior to the period January 19, 2010 High-Voltage following enhancement: of extended Porcelain operation. Then Columbia Letter GO2-11-139 Insulators Aging For the in-scope station post insulators located at the Ashe substation, add testing ongoing. RAI B.2.31-1 August 18, 2011 Management for contamination, and cleaning if required, every 8 years.

Amendment 66 Program December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 32 The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements A.1.2.32 Implementation LRA Appendix B.2.32 Program is a new program. prior to the period January 19, 2010 Inaccessible of extended Power Cables Not The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements operation. Columbia Letter GO2-10-173 Subject to 10 CFR Program manages the aging of inaccessible medium- voltage and lower service RAI B.2.32-4 50.49 EQ voltage cables that are not environmentally qualified and are within the scope of Then ongoing. December 7, 2010 Requirements license renewal. The program provides for testing to identify the conditions of the FINAL SAFETY ANALYSIS REORT Program conductor insulation, and also provides for periodic inspection and drainage (if necessary) of electrical manholes. The frequency of the cable testing portion of the program will be once every 6 years, with the first test to be performed prior to the period of extended operation. The frequency of the manhole inspections will be at least annually, with the first inspections to be performed prior to the period of extended operation.

The scope of the AMP will be enhanced to include inaccessible power cables (400V to 2kV), in response to industry and plant-specific operating experience.

33 The Inservice Inspection (ISI) Program is an existing program that will be continued A.1.2.33 Ongoing LRA Appendix B.2.33 for the period of extended operation. January 19, 2010 COLUMBIA GENERATING STATION A.4-10 Inservice Inspection (ISI)

Program 34 The Inservice Inspection (ISI) Program - IWE is an existing program that will be A.1.2.34 Ongoing LRA Appendix B.2.34 continued for the period of extended operation. January 19, 2010 Inservice Inspection (ISI)

Program - IWE 35 The Inservice Inspection (ISI) Program - IWF is an existing program that will be A.1.2.35 Ongoing LRA Appendix B.2.35 continued for the period of extended operation. January 19, 2010 Inservice Inspection (ISI)

Program - IWF 36 The Lubricating Oil Analysis Program is an existing program that will be continued A.1.2.36 Enhancement LRA Appendix B.2.36 for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 Lubricating Oil of extended Analysis Program x Include the following fire protection system components that are exposed to operation.

lubricating oil within the scope of the program: (1) fire protection diesel engine heat exchangers (lube oil coolers), (2) fire protection diesel engine lube oil Then ongoing.

piping, and (3) fire protection diesel engine lube oil pump casings.

37 The Lubricating Oil Inspection is a new activity. The Lubricating Oil Inspection A.1.2.37 Within the 10- LRA Appendix B.2.37 Amendment 66 detects and characterizes the condition of materials in systems and components for year period prior January 19, 2010 Lubricating Oil which the Lubricating Oil Analysis Program is credited with aging management. to the period of Inspection The inspection provides direct evidence as to whether, and to what extent, the extended relevant effects of aging have occurred. operation.

December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 38 The Masonry Wall Inspection is an existing program that will be continued for the A.1.2.38 Enhancement LRA Appendix B.2.38 period of extended operation, with the following enhancements: prior to the period January 19, 2010 Masonry Wall of extended Inspection x Specify that for each masonry wall, the extent of observed masonry cracking or operation. Columbia Letter GO2-10-094 degradation of steel edge supports and bracing are evaluated to ensure that the First Annual Update current evaluation basis is still valid. Corrective action is required if the extent of Then ongoing. July 16, 2010 masonry cracking or steel degradation is sufficient to invalidate the evaluation FINAL SAFETY ANALYSIS REORT basis. An option is to develop a new evaluation basis that accounts for the degraded condition of the wall (i.e., acceptance by further evaluation).

39 The Material Handling System Inspection Program is an existing program that will A.1.2.39 Ongoing LRA Appendix B.2.39 be continued for the period of extended operation. January 19, 2010 Material Handling System Inspection Columbia Letter GO2-10-094 Program First Annual Update July 16, 2010 40 The Metal-Enclosed Bus Program is a new program. The Metal- Enclosed Bus A.1.2.40 Implementation LRA Appendix B.2.40 Program is an inspection program that detects degradation of metal-enclosed bus prior to the period January 19, 2010 COLUMBIA GENERATING STATION Metal- Enclosed within the scope of license renewal. The program provides for the visual inspection of extended A.4-11 Bus Program of interior sections of bus, and an inspection of the elastomeric seals at the joints of operation. Columbia Letter GO2-11-020 the duct sections. The program also makes provision for thermographic inspection Then ongoing. RAI B.2.40-1 of bus bolted connections. The thermography portion of the program will be January 27, 2011 performed once every 10 years, with the initial inspections to be performed prior to the period of extended operation.

The visual inspection portion of the program will also be performed once every 10 years, with the first inspections to be performed prior to the period of extended operation. Infra-red window installation at bolted connections of the in-scope bus will be completed prior to the initial thermography inspection, discussed above.

41 The Monitoring and Collection Systems Inspection Program is a new program. A.1.2.41 Implementation LRA Appendix B.2.41 prior to the period January 19, 2010 Monitoring and The Monitoring and Collection Systems Inspection Program manages the effects of of extended Collection Systems loss of material due to corrosion or erosion for the internal surfaces of subject operation and Columbia Letter GO2-11-025 Inspection mechanical components that are exposed to equipment or area drainage water and initial inspection RAI B.2.14-1 Program other potential contaminants and fluids. The program also manages cracking due within the 10-year January 28, 2011 to stress corrosion cracking of susceptible materials. period prior to the period of The program consists of baseline inspections prior to the period of extended extended operation followed by opportunistic inspections during the period of extended operation.

Amendment 66 operation.

Then ongoing.

Following the baseline inspection, inspection findings will be reviewed periodically to ensure that each material and environment combination has been examined via December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section opportunistic inspection or actions are taken to ensure inspections are performed.

Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

42 The Open-Cycle Cooling Water Program is an existing program that will be A.1.2.42 Enhancement LRA Appendix B.2.42 continued for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 Open-Cycle of extended Cooling Water x Address loss of material due to cavitation erosion (for the standby service water operation.

FINAL SAFETY ANALYSIS REORT Program (SW), circulating water (CW), plant service water (TSW), and tower make-up (TMU) systems) with activities such as opportunistic inspections of portions of Then ongoing.

the systems that have had indications of cavitation erosion in the past.

x Include the non-safety related components within the license renewal scope in the SW, CW, TSW, and TMU systems, and the non-safety related components served by or connected to the TSW system that are in the process sampling, process sampling radioactive, radwaste building mixed air, radwaste building return air, reactor building return air, and reactor closed cooling water systems.

43 The Potable Water Monitoring Program is an existing program that will be continued A.1.2.43 Enhancement LRA Appendix B.2.43 COLUMBIA GENERATING STATION for the period of extended operation, with the following enhancements: and inspection January 19, 2010 A.4-12 Potable Water within the 10-year Monitoring x Include periodic inspection activities for evidence of a loss of material, or to period prior to the Columbia Letter GO2-10-124 Program confirm lack thereof. Based on operating experience, it is necessary that period of RAI B.2.43 inspections be conducted at least once every five years, and include extended August 26, 2010 components of the potable cold water and potable hot water systems that are operation.

located in the reactor building, and components associated with the reactor building outside air (ROA) air washer (ROA-AW-1), including the air washer Then ongoing.

housing.

x Include engineering evaluation of inspection results and adjustment of inspection frequencies.

At least one inspection will be conducted within the 10-year period prior to the period of extended operation.

44 The Preventive Maintenance - RCIC Turbine Casing is an existing program that will A.1.2.44 Ongoing LRA Appendix B.2.44 be continued for the period of extended operation. January 19, 2010 Preventive Maintenance -

RCIC Turbine Casing 45 The Reactor Head Closure Studs Program is an existing program that will be A.1.2.45 Ongoing LRA Appendix B.2.45 Amendment 66 continued for the period of extended operation. January 19, 2010 Reactor Head Closure Studs Program December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 46 The Reactor Vessel Surveillance Program is an existing program that will be A.1.2.46 Ongoing LRA Appendix B.2.46 continued for the period of extended operation. January 19, 2010 Reactor Vessel Surveillance Program 47 The Selective Leaching Inspection is a new activity. The Selective Leaching A.1.2.47 No earlier than 5 LRA Appendix B.2.47 Inspection detects and characterizes the conditions on internal and external year prior to the January 19, 2010 FINAL SAFETY ANALYSIS REORT Selective Leaching surfaces of subject components exposed to raw water, treated water, fuel oil, soil, period of Inspection and moist air (including condensation) environments. The inspection provides extended Columbia Letter GO2-11-074 direct evidence through a combination of visual examination and hardness testing, operation. Second Annual Update or NRC- approved alternative, as to whether, and to what extent, the relevant April 5, 2011 effects of aging have occurred.

48 The Service Air System Inspection Program is a new-program. A.1.2.48 Implementation LRA Appendix B.2.48 prior to the period January 19, 2010 Service Air System The Service Air System Inspection Program manages the effect of loss of material of extended Inspection due to corrosion of steel piping and valve bodies exposed to an "air (internal)" (i.e., operation and Columbia Letter GO2-11-025 COLUMBIA GENERATING STATION Program compressed air) environment within the license renewal boundary of the service air initial inspection RAI B.2.14-1 A.4-13 system. within the 10-year January 28, 2011 period prior to the The program consists of baseline inspections prior to the period of extended period of operation followed by opportunistic inspections during the period of extended extended operation. operation.

Following the baseline inspection, inspection findings will be reviewed periodically to Then ongoing.

ensure that each material and environment combination has been examined via opportunistic inspection or actions are taken to ensure inspections are performed.

Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

49 The Small Bore Piping Program will inspect a sample of ASME Code Class 1 piping A.1.2.49 Implemented LRA Appendix B.2.49 LT NPS 4 to GE to NPS 1. The inspection will include 10% of the weld population prior to the period January 19, 2010 Small Bore Class 1 or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) of extended Piping Program using a methodology to select the most susceptible and risk-significant welds. For operation. Columbia Letter GO2-10-135 socket welds, opportunistic destructive examination can be performed in lieu of RAI B.2.49-1 volumetric examination. Because more information can be obtained from a Inspection September 13, 2010 destructive examination than from nondestructive examination, Columbia may take activities will start credit for each weld destructively examined equivalent to having volumetrically during the fourth Columbia Letter GO2-11-020 Amendment 66 examined two welds. 10-year inservice RAI B.2.49-2 inspection January 27, 2011 interval, then ongoing.

December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 50 The Structures Monitoring Program is an existing program that will be continued for A.1.2.50 Enhancement LRA Appendix B.2.50 the period of extended operation, with the following enhancements: prior to the period January 19, 2010 Structures of extended Monitoring x Include and list the structures within the scope of license renewal that credit the operation. Columbia Letter GO2-10-128 Program Structures Monitoring Program for aging management. RAI B.2.50-2 x Specify that if a below grade structural wall or structural component becomes Then ongoing. September 3, 2010 accessible through excavation; a follow-up action is initiated for the responsible FINAL SAFETY ANALYSIS REORT engineer to inspect the exposed surfaces for age- related degradation prior to Columbia Letter GO2-11-017 backfilling. RAI B.2.50-1, RAI B.2.50-2, x Identify that the term structural component for inspection includes component RAI B.2.50-3 types that credit the Structures Monitoring Program for aging management. January 20, 2011 x Include the potential degradation mechanism checklist in the procedural documents. The checklist also requires enhancement to include aging effect Columbia Letter GO2-11-112 terminology (e.g., loss of material, cracking, change in material properties, and June 23, 2011 loss of form).

x Specify that the responsible engineer shall review site groundwater and raw water testing results for pH, chlorides, and sulfates prior to inspection to validate COLUMBIA GENERATING STATION that the below-grade or raw water environments remain non-aggressive during A.4-14 the period of extended operation. Chemistry data shall be obtained from Columbias chemistry and environmental departments. Groundwater chemistry data shall be collected at least once every four years. The time of data collection shall be staggered from year to year (summer-winter-summer) to account for seasonal variations in the environment.

x Specify additional direction for quantifying, monitoring, and trending of inspection results.

x Provide better alignment with referenced Industry codes, standards, and guidelines regarding terminology and evaluation.

x Revise to add sufficient acceptance criteria and critical parameters to trigger level of inspection and initiation of corrective action. ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structural elements, steel liners, joint, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R-96, will be developed, and added to the inspection procedure.

x Conduct a base line inspection of the structures within the scope of license renewal plus a minimum of one additional inspection prior to entering the period of extended operation.

51 The Supplemental Piping/Tank Inspection is a new activity. The Supplemental A.1.2.51 Within the 10- LRA Appendix B.2.51 Amendment 66 Piping/Tank Inspection detects and characterizes the material condition of steel, year period prior January 19, 2010 Supplemental gray cast iron, and stainless steel components exposed to moist air environments. to the period of Piping/Tank The inspection provides direct evidence as to whether, and to what extent, the extended Inspection relevant effects of aging have occurred. operation.

December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 52 The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel A.1.2.52 Implementation LRA Appendix B.2.52 (CASS) Program is a new program. The Thermal Aging and Neutron Embrittlement prior to the period January 19, 2010 Thermal Aging and of Cast Austenitic Stainless Steel (CASS) Program will manage loss of fracture of extended Neutron toughness due to thermal aging and neutron irradiation embrittlement of CASS operation.

Embrittlement of reactor vessel internals.

Cast Austenitic Then ongoing.

Stainless Steel x The program includes: (a) identification of susceptible components determined FINAL SAFETY ANALYSIS REORT (CASS) Program to be limiting from the standpoint of thermal aging or neutron irradiation embrittlement (neutron fluence), (b) a component specific evaluation to determine each identified components susceptibility to loss of fracture toughness, and (c) a supplemental examination of any component not eliminated by the component specific evaluation.

53 The Water Control Structures Inspection is an existing program that will be A.1.2.53 Enhancement LRA Appendix B.2.53 continued for the period of extended operation, with the following enhancements: prior to the period January 19, 2010 Water Control of extended Structures x Include and list the water control structures within the scope of license renewal. operation. Columbia Letter GO2-10-128 Inspection Include the RG 1.127 Revision 1 inspection elements for the water control RAI B.2.50-2 COLUMBIA GENERATING STATION structures, including submerged surfaces. Ensure descriptions of concrete Then ongoing. September 3, 2010 A.4-15 conditions conform with the appendix to the American Concrete Institute (ACI) publication, ACI 201, "Guide for Making a Condition Survey of Concrete in Columbia Letter GO2-11-014 Service." Add a recommendation to use photographs for comparison of RAI B.2.50-6 previous and present conditions. Add a requirement for the documentation of January 18, 2011 new or progressive problems as a part of the inspection program.

x Specify additional direction for quantifying, monitoring, and trending of inspection results.

x Provide better alignment with referenced Industry codes, standards, and guidelines regarding terminology and evaluation.

x Revise to add sufficient acceptance criteria and critical parameters to trigger level of inspection and initiation of corrective action. ACI 349.3R-96 provides an acceptable basis for developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes. Plant specific quantitative degradation limits, similar to the three-tier hierarchy acceptance criteria from Chapter 5 of ACI 349.3R-96, will be developed and added to the inspection procedure.

x Energy Northwest will conduct a baseline inspection of the spray ponds (including submerged portions) plus a minimum of one additional inspection prior to entering the period of extended operation. Inspection will use quantitative acceptance criteria in accordance with ACI 349.3R.

Amendment 66 54 The Columbia P-T limit curves were revised in 2005 to include the effects of power A.1.3.1.4 Ongoing LRA Appendix B.2.54 uprate to 3486 MWt. The P-T limits are valid for 33.1 EFPY through the end of the January 19, 2010 Pressure- currently licensed period. P-T limits for the period of extended operation will be Temperature calculated using the most accurate fluence projections available at the time of the December 2021 Limits

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section recalculation. The projections may be adjusted if there are changes in core design or if additional surveillance capsule results show the need for an adjustment. The projected ART for the period of extended operation gives confidence that future P-T curves will provide adequate operating margin. License amendment requests to revise the P-T limits will be submitted to the NRC for approval, when necessary to comply with 10 CFR 50 Appendix G, as part of the Reactor Vessel Surveillance Program.

FINAL SAFETY ANALYSIS REORT 58 In accordance with the BWR Vessel Internals Program, Columbia will implement the LRA Upon issuance of LRA Appendix C additional inspection requirements of BWRVIP-42-A once those requirements are Appendix C approved revision January 19, 2010 BWRVIP A, approved by the NRC staff. to BWRVIP-42 AAI#5 that recommends inspection of inaccessible welds 59 Energy Northwest will submit a licensing basis change request to implement the LRA Two years prior LRA Appendix C BWRVIP ISP(E) at least two years prior to the period of extended operation. Appendix C to the period of January 19, 2010 BWRVIP -116 Columbia will implement the ISP(E) as amended by the BWRVIP letter of January extended COLUMBIA GENERATING STATION 11, 2005, including the new capsule test schedule in Table 1 of that letter. operation.

A.4-16 60 Implementation of the BWRVIP ISP(E) for Columbia will include the following details LRA Ongoing LRA Appendix C in support of the contingency plan: Appendix C January 19, 2010 BWRVIP-116

1. Energy Northwest will include the requirement to keep all tested material (irradiated or unirradiated) for possible future reconstitution and testing.

2. The Columbia site procedure, as modified, will continue to require any capsules removed from the reactor vessel to be stored in a manner that would support future re-insertion of these capsules in the reactor vessel.

3. Energy Northwest will notify the BWRVIP prior to any change in the storage of on-site materials. NRC approval will be obtained prior to any change in the storage of surveillance materials that would affect the potential use of the materials under the contingency plan.

61 The Boron Carbide Monitoring Program is an existing program that will be continued A.1.2.54 Initial in situ Columbia Letter GO2-10-117 for the period of extended operation. testing prior to RAI 3.3.2.2.6-1 Boron Carbide the period of August 19, 2010 Monitoring Initial in situ testing of the spent fuel rack neutron absorbing material will be extended Program performed prior to the period of extended operation to determine the current state of operation, then Columbia Letter GO2-11-011 the racks. Additional in situ testing will be based on the results of this initial testing, ongoing. RAI B.2.54-1 but at an interval not to exceed ten years. January 14, 2011 62 The Service Level 1 Protective Coatings Program is an existing program that will be A.1.2.55 Ongoing Columbia Letter GO2-10-180 Amendment 66 continued for the period of extended operation. RAI XI.S8-1 Service Level 1 December 21, 2010 Protective Coatings Program December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 63 Columbia currently relies on acceptable enhanced visual technique (EVT-1) A.1.2.33 Upon availability Columbia Letter GO2-10-179 inspections in accordance with ASME Code Section XI. of acceptable UT RAI 3.1.1.x-1 Inservice technique. December 21, 2010 Inspection (ISI) Ultrasonic Testing (UT) examination of creviced shroud support plate access hole Program cover weld, top hat configuration, will be performed, in addition to EVT-1, once a Then ongoing.

demonstrated acceptable UT technique becomes available.

64 Verify leakage is not entering the annular space between the containment vessel A.1.2.34 During the fourth Columbia Letter GO2-11-014 FINAL SAFETY ANALYSIS REORT and the concrete shield wall from the outer refueling bellows seal. Inspection of the Inservice RAI 3.5.2.2.1.4-1 Inservice portions of the outer containment vessel shell made accessible by opening all eight Inspection (ISI) January 18, 2011 Inspection (ISI) inspection ports in the containment vessel at 570 foot elevation will be performed to interval prior to Program - IWE check for evidence of leakage. These inspections will be performed during a the period of Columbia Letter GO2-11-112 refueling outage while the reactor cavity is flooded. extended June 23, 2011 operation (PEO) and again in the fifth ISI interval after entering the PEO.

COLUMBIA GENERATING STATION 65 Columbia will prepare and submit the ISI Program Plan for the fourth 10- year A.1.2.33 Upon submittal of Columbia Letter GO2-11-020 A.4-17 interval no later than 2015. (The third 10-year ISI interval extends from December the ISI Program RAI B.2.49-2 Inservice 2005 until December, 2015.) The Small Bore Piping Program will be included in the Plan for the January 27, 2011 Inspection (ISI) fourth 10-year interval ISI Program Plan as an augmented inspection. The locations fourth 10-year Program to be inspected, the sample size, the inspection methodology will be included in the interval. Columbia Letter GO2-11-074 program plan. Second Annual Update April 5, 2011 66 Perform a one-time internal inspection of the spent fuel pool telltale drain lines prior A.1.2.50 Prior to the Columbia Letter GO2-11-017 to the period of extended operation to confirm the drain lines are free of period of RAI B.2.50-5 Structure obstructions. Unexpected inspection results of clogged lines will require a condition extended January 20, 2011 Monitoring report be documented and further engineering evaluation of adverse impacts to the operation Program spent fuel pool structure and to identify the periodicity of drain cleaning and maintenance process.

67 Perform a one-time borescope inspection of the containment sand pocket drain A.1.2.50 Prior to 12/31/15 Columbia Letter GO2-11-017 lines to confirm the absence of clogged drain lines and that a flow path exists for RAI B.2.34-1 Structure identification of any potential leakage into the sand pocket region. Unexpected January 20, 2011 Monitoring inspection results (clogged drain lines) will be documented under corrective action Program process. Columbia Letter GO2-11-029 RAI B.2.26-6 January 28, 2011 Amendment 66 December 2021

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 Updated Final Safety Analysis Enhancement Item Number Report or Commitment Source Title (UFSAR) Implementation Supplement Schedule Section/LRA Section 68 Ensure that the condensate (COND) and reactor feedwater (RFW) systems are A.1.2.28 Prior to the Columbia Letter GO2-11-029 screened and evaluated for cavitation prior to entering the period of extended period of RAI B.2.26-6 January 28, Flow-Accelerated operation (PEO). If the in-scope portion of either system is determined to be extended 2011 Corrosion (FAC) susceptible to loss of material due to cavitation erosion, then a program(s) will be operation.

FINAL SAFETY ANALYSIS REORT Program modified or created to manage the loss of material. Columbia Letter GO2-11-074 Second Annual Update 4/5/11 69 Re-evaluate the portions of the reactor pressure vessel beltline welds BG and BM A.1.2.33 Prior to the Columbia Letter GO2-11-031 for the period of extended operation (54 EFPY), in accordance with the period of RAI 4.7.1-1 Inservice requirements of the ASME Code,Section XI, IWB-3600 based on the results of extended January 28, 2011 Inspection (ISI) 2015 inservice inspection. operation.

Program Columbia Letter GO2-11-074 Second Annual Update April 5, 2011 70 Perform a 54 EFPY equivalent margin analysis for the embrittlement (upper shelf A.1.3.1.2 No later than 2 Columbia Letter GO2-11-031 energy) of the reactor vessel N12 (preinstrumentation) nozzle forgings. years prior to the RAI 4.2-1 COLUMBIA GENERATING STATION TLAA - period of January 28, 2011 A.4-18 Embrittlement of extended reactor vessel operation. Columbia Letter GO2-11-084 RAI 4.2-6 April 22, 2011 Columbia Letter GO2-11-195 RAI 4.2-6 December 14, 2011 Note: 1. Commitments 55, 56 and 57 have been completed and were removed from this table.

2. Commitment 71 is reflected in License Condition 2.C.(36) and was removed from this table.

Amendment 66 December 2021