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)

Text

Alex L. Javorik Columbia Generating Station P.O. Box 968, 964P Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.2354 aljavorik@energy-northwest.com 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 LC 2.C.(34) is no longer applicable as the Columbia Final Safety Analysis Report (FSAR) has been updated to include the License Renewal (LR) commitments set forth in the reference.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. 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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April 28, 2021 ENERGY

• --- NORTHWEST

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 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 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 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 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 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 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 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 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 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 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 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 Proposed Columbia Operating License Changes (Mark-Up)




   

   

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GO2-19-012 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.

(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 Proposed Columbia Operating License Changes (Re-Typed)




   

   

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GO2-21-012 Renewed License No. NPF-21 Amendment No.




   

   

(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.

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GO2-19-012 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 A.4-1 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 1

Aboveground Steel Tanks Inspection The Aboveground Steel Tanks Inspection is a new program.

The Aboveground Steel Tanks Inspection detects and characterizes the conditions on the bottom surfaces of the condensate storage tanks. The program provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred in inaccessible areas.

A.1.2.1 Within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.1 January 19, 2010 Columbia Letter GO2-10-173 RAI B.2.1-3 December 7, 2010 2

Air Quality Sampling Program The Air Quality Sampling Program is an existing program that will be continued for the period of extended operation.

A.1.2.2 Ongoing LRA Appendix B.2.2 January 19, 2010 3

Appendix J Program The Appendix J Program is an existing program that will be continued for the period of extended operation.

A.1.2.3 Ongoing LRA Appendix B.2.3 January 19, 2010 4

Bolting Integrity Program The Bolting Integrity Program is an existing program that will be continued for the period of extended operation.

A.1.2.4 Ongoing LRA Appendix B.2.4 January 19, 2010 5

Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

Revise the site program document to include:

x cracking, loss of material and loss of pre-load of bolting as aging effects managed by the program.

x loss of material for (buried) stainless steel piping and piping components as an aging effect managed by the program.

x components that are located underground (below grade) in areas, such as outdoor vaults, valve pits and inside guard pipes where access for inspection is restricted.

x buried concrete and polymeric piping to confirm the absence of significant aging effect.

x Revise the site program document to:

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 A.1.2.5 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.5 January 19, 2010 Columbia Letter GO2-10-094 First Annual Update July 16, 2010 Columbia Letter GO2-10-179 RAI 3.4.2.3-1 December 21, 2010 Columbia Letter GO2-11-028 RAI B.2.5-2 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-2 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 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:

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:

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.

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 Material/Location (buried or underground)

Number or percentage of Inspections (per 10-Year interval through end of the period of extended operation)

Code-Class/ Safety-Related/ Other Hazmat 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




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-3 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 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.

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.

x 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 BWR Feedwater Nozzle Program The BWR Feedwater Nozzle Program is an existing program that will be continued for the period of extended operation.

A.1.2.6 Ongoing LRA Appendix B.2.6 January 19, 2010 7

BWR Penetrations Program The BWR Penetrations Program is an existing program that will be continued for the period of extended operation.

A.1.2.7 Ongoing LRA Appendix B.2.7 January 19, 2010 8

BWR Stress Corrosion Cracking Program The BWR Stress Corrosion Cracking Program is an existing program that will be continued for the period of extended operation.

A.1.2.8 Ongoing LRA Appendix B.2.8 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-4 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 9

BWR Vessel ID Attachment Welds Program The BWR Vessel ID Attachment Welds Program is an existing program that will be continued for the period of extended operation.

A.1.2.9 Ongoing LRA Appendix B.2.9 January 19, 2010 10 BWR Vessel Internals Program The BWR Vessel Internals Program is an existing program that will be continued for the period of extended operation.

A.1.2.10 Ongoing LRA Appendix B.2.10 January 19, 2010 11 BWR Water Chemistry Program The BWR Water Chemistry Program is an existing program that will be continued for the period of extended operation.

A.1.2.11 Ongoing LRA Appendix B.2.11 January 19, 2010 12 Chemistry Program Effectiveness Inspection The Chemistry Program Effectiveness Inspection is a new activity.

The Chemistry Program Effectiveness Inspection detects and characterizes the condition of materials in representative low flow and stagnant areas of systems with water chemistry controlled by the BWR Water Chemistry Program or the Closed Cooling Water Chemistry Program, and with fuel oil chemistry controlled by the Fuel Oil Chemistry Program. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.12 Within the 10-year period prior to the period of extended operation.

LRA Appendix B.2.12 January 19, 2010 13 Closed Cooling Water Chemistry Program The Closed Cooling Water Chemistry Program is an existing program that will be continued for the period of extended operation, with the following enhancement:

Ensure that at least one additional reactor closed cooling water corrosion rate measurement is performed and evaluated prior to entering the period of extended operation to provide direct information as to the effectiveness of the chemical treatments. If necessary, based on the results, establish a frequency for subsequent measurements.

A.1.2.13 Enhancement prior to the period of extended operation Then ongoing.

LRA Appendix B.2.13 January 19, 2010 14 Cooling Units Inspection Program The Cooling Units Inspection Program is a new program.

The Cooling Units Inspection Program manages the effects of loss of material of aluminum, steel, copper alloy, and stainless steel cooling unit components that are exposed to condensation. The inspection also manages the effects of a reduction in heat transfer due to fouling of heat exchanger tubes and fins and cracking due to SCC of aluminum components exposed to condensation.

The Cooling Units Inspection Program consists of baseline inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

A.1.2.14 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.14 January 19, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-5 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 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 CRDRL Nozzle Program The CRDRL Nozzle Program is an existing program that will be continued for the period of extended operation.

A.1.2.15 Ongoing LRA Appendix B.2.15 January 19, 2010 16 Diesel Starting Air Inspection The Diesel Starting Air Inspection is a new activity.

The Diesel Starting Air Inspection detects and characterizes the condition of materials for the DSA system air dryers and downstream piping and components (excluding the DSA system air receivers).

The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.16 Within the 10-year period prior to the period of extended operation.

LRA Appendix B.2.16 January 19, 2010 17 Diesel Systems Inspection Program The Diesel Systems Inspection Program is a new program.

The Diesel Systems Inspection Program manages the effects of loss of material due to corrosion and cracking due to stress corrosion cracking of materials for the interior of the steel and stainless steel exhaust piping components for the Division 1, 2, and 3 diesels in the diesel engine exhaust system, including the loop seal drains from the exhaust piping.

The Diesel Systems Inspection Program consists of baseline inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

Following the baseline inspection, inspection findings will be reviewed periodically to 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 performed. Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

A.1.2.17 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.17 January 19, 2010 Columbia Letter GO2-10-094 First Annual Update July 16, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011 Columbia Letter GO2-11-185 RAI B.2.14-1 November 16, 2011 18 Diesel-Driven Fire Pumps Inspection Program The Diesel-Driven Fire Pumps Inspection Program is a new program.

The Diesel-Driven Fire Pumps Inspection Program manages the effects of loss of material, due to corrosion or erosion, and reduction in heat transfer of the interior of the fire protection system diesel engine exhaust piping, and of fire protection system diesel heat exchangers exposed to a raw water environment. The program also manages cracking due to SCC of susceptible materials.

A.1.2.18 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the LRA Appendix B.2.18 January 19, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-6 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source The Diesel-Driven Fire Pumps Inspection Program consists of baseline inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

Following the baseline inspection, inspection findings will be reviewed periodically to 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 performed. Initial interval for review of inspection findings is 5 years and may be adjusted based on operating experience.

period of extended operation.

Then ongoing.

Columbia Letter GO2-11-185 RAI B.2.14-1 November 16, 2011 19 Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program is a new program.

The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Program is an inspection program that detects degradation of electrical cables and connections that are not environmentally qualified and are within the scope of license renewal.

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

A.1.2.19 Implementation prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.19 January 19, 2010 20 Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Program The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Program is a new program.

The Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Program is a monitoring program that detects degradation of electrical cables and connections that are not environmentally qualified and used in circuits with sensitive, low-current applications. The program provides for a review of calibration records for low-current instruments, in order to detect and identify degradation of the cable system insulation resistance. The program retains the option to perform direct cable testing.

A.1.2.20 Implementation prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.20 January 19, 2010 21 Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements Inspection The Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements Inspection is a new activity.

The Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements Inspection detects and characterizes the material condition of metallic electrical connections within the scope of license renewal. The inspection uses thermography (augmented by contact resistance testing) to detect loose or degraded connections that lead to increased resistance for a representative sample of metallic electrical connections in various plant locations.

A.1.2.21 Within the 10-year period prior to the period of extended operation.

LRA Appendix B.2.21 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-7 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 22 EQ Program The EQ Program is an existing program that will be continued for the period of extended operation.

A.1.2.22 A.1.3.5 Ongoing LRA Appendix B.2.22 January 19, 2010 23 External Surfaces Monitoring Program The External Surfaces Monitoring Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x add aluminum, copper alloy, copper alloy >15 % Zn, gray cast iron, stainless steel (including CASS), and elastomers to the program scope.

x add cracking as an aging effect for aluminum components.

x add visual (VT-1 or equivalent) or volumetric examination techniques to detect cracking.

x add hardening and loss of strength as aging effects for elastomer-based mechanical sealants in HVAC systems.

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.

A.1.2.23 Enhancement prior to the period of extended operation Then ongoing.

LRA Appendix B.2.23 January 19, 2010 Columbia Letter GO2-10-094 First Annual Update July 16, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 201 24 Fatigue Monitoring Program The Fatigue Monitoring Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Columbia has analyzed the effects of the reactor coolant environment on fatigue for the six locations recommended by NUREG\\CR-6260. These analyses are based on the projected cycles for 60 years of operation (plus 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.

A.1.2.24 A.1.3.2 A.1.3.4 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.24 January 19, 2010 25 Fire Protection Program The Fire Protection Program is an existing program that will be continued for the period of extended operation.

A.1.2.25 Ongoing LRA Appendix B.2.25 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-8 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 26 Fire Water Program The Fire Water Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x perform either ultrasonic testing or internal visual inspection of representative portions of above ground fire protection piping that are exposed to water, but do not normally experience flow, after the issuance of the renewed license, but prior to the end of the current operating term and at reasonable intervals thereafter, based on engineering review of the results.

x either replace sprinkler heads that have been in place for 50 years or submit representative samples to a recognized laboratory for field service testing in 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.

x perform ultrasonic testing of representative portions of above ground fire 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.

A.1.2.26 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.26 January 19, 2010 Columbia Letter GO2-10-117 RAI B.2.26-1 August 19, 2010 Columbia Letter GO2-11-029 RAI B.2.26-6 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-9 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 27 Flexible Connection Inspection Program The Flexible Connection Inspection Program is a new program.

The Flexible Connection Inspection Program manages degradation, including the effects of loss of material due to wear and hardening and loss of strength of elastomer components exposed to treated water, dried air, gas, and indoor air environments.

The program consists of base line inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

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

A.1.2.27 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.27 January 19, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011 28 Flow-Accelerated Corrosion (FAC)

Program The Flow-Accelerated Corrosion (FAC) Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x add the containment nitrogen system components supplied with steam from the auxiliary steam system to the scope of the program.

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

A.1.2.28 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.28 January 19, 2010 29 Fuel Oil Chemistry Program The Fuel Oil Chemistry Program is an existing program that will be continued for the period of extended operation.

A.1.2.29 Ongoing LRA Appendix B.2.29 January 19, 2010 30 Heat Exchangers Inspection The Heat Exchangers Inspection is a new activity. The Heat Exchangers Inspection detects and characterizes the surface conditions with respect to fouling of heat exchangers and coolers that are in the scope of the inspection and exposed to treated water, closed cooling water, or indoor air. The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.30 Within the 10-year period prior to the period of extended operation LRA Appendix B.2.30 January 19, 2010 31 High-Voltage Porcelain Insulators Aging Management Program The High-Voltage Porcelain Insulators Aging Management Program is an existing program that will be continued for the period of extended operation, with the following enhancement:

For the in-scope station post insulators located at the Ashe substation, add testing for contamination, and cleaning if required, every 8 years.

A.1.2.31 Enhancement prior to the period of extended operation. Then ongoing.

LRA Appendix B.2.31 January 19, 2010 Columbia Letter GO2-11-139 RAI B.2.31-1 August 18, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-10 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 32 Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program is a new program.

The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program manages the aging of inaccessible medium-voltage and lower service voltage cables that are not environmentally qualified and are within the scope of license renewal. The program provides for testing to identify the conditions of the 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.

A.1.2.32 Implementation prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.32 January 19, 2010 Columbia Letter GO2-10-173 RAI B.2.32-4 December 7, 2010 33 Inservice Inspection (ISI)

Program The Inservice Inspection (ISI) Program is an existing program that will be continued for the period of extended operation.

A.1.2.33 Ongoing LRA Appendix B.2.33 January 19, 2010 34 Inservice Inspection (ISI)

Program - IWE The Inservice Inspection (ISI) Program - IWE is an existing program that will be continued for the period of extended operation.

A.1.2.34 Ongoing LRA Appendix B.2.34 January 19, 2010 35 Inservice Inspection (ISI)

Program - IWF The Inservice Inspection (ISI) Program - IWF is an existing program that will be continued for the period of extended operation.

A.1.2.35 Ongoing LRA Appendix B.2.35 January 19, 2010 36 Lubricating Oil Analysis Program The Lubricating Oil Analysis Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Include the following fire protection system components that are exposed to 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 piping, and (3) fire protection diesel engine lube oil pump casings.

A.1.2.36 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.36 January 19, 2010 37 Lubricating Oil Inspection The Lubricating Oil Inspection is a new activity. The Lubricating Oil Inspection detects and characterizes the condition of materials in systems and components for which the Lubricating Oil Analysis Program is credited with aging management.

The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.37 Within the 10-year period prior to the period of extended operation.

LRA Appendix B.2.37 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-11 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 38 Masonry Wall Inspection The Masonry Wall Inspection is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Specify that for each masonry wall, the extent of observed masonry cracking or degradation of steel edge supports and bracing are evaluated to ensure that the current evaluation basis is still valid. Corrective action is required if the extent of masonry cracking or steel degradation is sufficient to invalidate the evaluation 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).

A.1.2.38 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.38 January 19, 2010 Columbia Letter GO2-10-094 First Annual Update July 16, 2010 39 Material Handling System Inspection Program The Material Handling System Inspection Program is an existing program that will be continued for the period of extended operation.

A.1.2.39 Ongoing LRA Appendix B.2.39 January 19, 2010 Columbia Letter GO2-10-094 First Annual Update July 16, 2010 40 Metal-Enclosed Bus Program The Metal-Enclosed Bus Program is a new program. The Metal-Enclosed Bus Program is an inspection program that detects degradation of metal-enclosed bus within the scope of license renewal. The program provides for the visual inspection of interior sections of bus, and an inspection of the elastomeric seals at the joints of the duct sections. The program also makes provision for thermographic inspection of bus bolted connections. The thermography portion of the program will be 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.

A.1.2.40 Implementation prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.40 January 19, 2010 Columbia Letter GO2-11-020 RAI B.2.40-1 January 27, 2011 41 Monitoring and Collection Systems Inspection Program The Monitoring and Collection Systems Inspection Program is a new program.

The Monitoring and Collection Systems Inspection Program manages the effects of loss of material due to corrosion or erosion for the internal surfaces of subject mechanical components that are exposed to equipment or area drainage water and other potential contaminants and fluids. The program also manages cracking due to stress corrosion cracking of susceptible materials.

The program consists of baseline inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

Following the baseline inspection, inspection findings will be reviewed periodically to ensure that each material and environment combination has been examined via A.1.2.41 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.41 January 19, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-12 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 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 Open-Cycle Cooling Water Program The Open-Cycle Cooling Water Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Address loss of material due to cavitation erosion (for the standby service water (SW), circulating water (CW), plant service water (TSW), and tower make-up (TMU) systems) with activities such as opportunistic inspections of portions of 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.

A.1.2.42 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.42 January 19, 2010 43 Potable Water Monitoring Program The Potable Water Monitoring Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Include periodic inspection activities for evidence of a loss of material, or to confirm lack thereof. Based on operating experience, it is necessary that inspections be conducted at least once every five years, and include components of the potable cold water and potable hot water systems that are located in the reactor building, and components associated with the reactor building outside air (ROA) air washer (ROA-AW-1), including the air washer 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.

A.1.2.43 Enhancement and inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.43 January 19, 2010 Columbia Letter GO2-10-124 RAI B.2.43 August 26, 2010 44 Preventive Maintenance -

RCIC Turbine Casing The Preventive Maintenance - RCIC Turbine Casing is an existing program that will be continued for the period of extended operation.

A.1.2.44 Ongoing LRA Appendix B.2.44 January 19, 2010 45 Reactor Head Closure Studs Program The Reactor Head Closure Studs Program is an existing program that will be continued for the period of extended operation.

A.1.2.45 Ongoing LRA Appendix B.2.45 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-13 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 46 Reactor Vessel Surveillance Program The Reactor Vessel Surveillance Program is an existing program that will be continued for the period of extended operation.

A.1.2.46 Ongoing LRA Appendix B.2.46 January 19, 2010 47 Selective Leaching Inspection The Selective Leaching Inspection is a new activity. The Selective Leaching Inspection detects and characterizes the conditions on internal and external surfaces of subject components exposed to raw water, treated water, fuel oil, soil, and moist air (including condensation) environments. The inspection provides direct evidence through a combination of visual examination and hardness testing, or NRC-approved alternative, as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.47 No earlier than 5 year prior to the period of extended operation.

LRA Appendix B.2.47 January 19, 2010 Columbia Letter GO2-11-074 Second Annual Update April 5, 2011 48 Service Air System Inspection Program The Service Air System Inspection Program is a new-program.

The Service Air System Inspection Program manages the effect of loss of material due to corrosion of steel piping and valve bodies exposed to an "air (internal)" (i.e.,

compressed air) environment within the license renewal boundary of the service air system.

The program consists of baseline inspections prior to the period of extended operation followed by opportunistic inspections during the period of extended operation.

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

A.1.2.48 Implementation prior to the period of extended operation and initial inspection within the 10-year period prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.48 January 19, 2010 Columbia Letter GO2-11-025 RAI B.2.14-1 January 28, 2011 49 Small Bore Class 1 Piping Program The Small Bore Piping Program will inspect a sample of ASME Code Class 1 piping LT NPS 4 to GE to NPS 1. The inspection will include 10% of the weld population or a maximum of 25 welds of each weld type (e.g., full penetration or socket weld) using a methodology to select the most susceptible and risk-significant welds. For socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, Columbia may take credit for each weld destructively examined equivalent to having volumetrically examined two welds.

A.1.2.49 Implemented prior to the period of extended operation.

Inspection activities will start during the fourth 10-year inservice inspection interval, then ongoing.

LRA Appendix B.2.49 January 19, 2010 Columbia Letter GO2-10-135 RAI B.2.49-1 September 13, 2010 Columbia Letter GO2-11-020 RAI B.2.49-2 January 27, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-14 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 50 Structures Monitoring Program The Structures Monitoring Program is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Include and list the structures within the scope of license renewal that credit the Structures Monitoring Program for aging management.

x Specify that if a below grade structural wall or structural component becomes accessible through excavation; a follow-up action is initiated for the responsible engineer to inspect the exposed surfaces for age-related degradation prior to backfilling.

x Identify that the term structural component for inspection includes component types that credit the Structures Monitoring Program for aging management.

x Include the potential degradation mechanism checklist in the procedural documents. The checklist also requires enhancement to include aging effect terminology (e.g., loss of material, cracking, change in material properties, and 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 that the below-grade or raw water environments remain non-aggressive during 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.

A.1.2.50 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.50 January 19, 2010 Columbia Letter GO2-10-128 RAI B.2.50-2 September 3, 2010 Columbia Letter GO2-11-017 RAI B.2.50-1, RAI B.2.50-2, RAI B.2.50-3 January 20, 2011 Columbia Letter GO2-11-112 June 23, 2011 51 Supplemental Piping/Tank Inspection The Supplemental Piping/Tank Inspection is a new activity. The Supplemental Piping/Tank Inspection detects and characterizes the material condition of steel, gray cast iron, and stainless steel components exposed to moist air environments.

The inspection provides direct evidence as to whether, and to what extent, the relevant effects of aging have occurred.

A.1.2.51 Within the 10-year period prior to the period of extended operation.

LRA Appendix B.2.51 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-15 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 52 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is a new program. The Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program will manage loss of fracture toughness due to thermal aging and neutron irradiation embrittlement of CASS reactor vessel internals.

x The program includes: (a) identification of susceptible components determined 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.

A.1.2.52 Implementation prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.52 January 19, 2010 53 Water Control Structures Inspection The Water Control Structures Inspection is an existing program that will be continued for the period of extended operation, with the following enhancements:

x Include and list the water control structures within the scope of license renewal.

Include the RG 1.127 Revision 1 inspection elements for the water control structures, including submerged surfaces. Ensure descriptions of concrete conditions conform with the appendix to the American Concrete Institute (ACI) publication, ACI 201, "Guide for Making a Condition Survey of Concrete in Service." Add a recommendation to use photographs for comparison of previous and present conditions. Add a requirement for the documentation of 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.

A.1.2.53 Enhancement prior to the period of extended operation.

Then ongoing.

LRA Appendix B.2.53 January 19, 2010 Columbia Letter GO2-10-128 RAI B.2.50-2 September 3, 2010 Columbia Letter GO2-11-014 RAI B.2.50-6 January 18, 2011 54 Pressure-Temperature Limits The Columbia P-T limit curves were revised in 2005 to include the effects of power uprate to 3486 MWt. The P-T limits are valid for 33.1 EFPY through the end of the currently licensed period. P-T limits for the period of extended operation will be calculated using the most accurate fluence projections available at the time of the A.1.3.1.4 Ongoing LRA Appendix B.2.54 January 19, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-16 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 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.

58 BWRVIP A, AAI#5 In accordance with the BWR Vessel Internals Program, Columbia will implement the additional inspection requirements of BWRVIP-42-A once those requirements are approved by the NRC staff.

LRA Appendix C Upon issuance of approved revision to BWRVIP-42 that recommends inspection of inaccessible welds LRA Appendix C January 19, 2010 59 BWRVIP -116 Energy Northwest will submit a licensing basis change request to implement the BWRVIP ISP(E) at least two years prior to the period of extended operation.

Columbia will implement the ISP(E) as amended by the BWRVIP letter of January 11, 2005, including the new capsule test schedule in Table 1 of that letter.

LRA Appendix C Two years prior to the period of extended operation.

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

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.

LRA Appendix C Ongoing LRA Appendix C January 19, 2010 61 Boron Carbide Monitoring Program The Boron Carbide Monitoring Program is an existing program that will be continued for the period of extended operation.

Initial in situ testing of the spent fuel rack neutron absorbing material will be performed prior to the period of extended operation to determine the current state of the racks. Additional in situ testing will be based on the results of this initial testing, but at an interval not to exceed ten years.

A.1.2.54 Initial in situ testing prior to the period of extended operation, then ongoing.

Columbia Letter GO2-10-117 RAI 3.3.2.2.6-1 August 19, 2010 Columbia Letter GO2-11-011 RAI B.2.54-1 January 14, 2011 62 Service Level 1 Protective Coatings Program The Service Level 1 Protective Coatings Program is an existing program that will be continued for the period of extended operation.

A.1.2.55 Ongoing Columbia Letter GO2-10-180 RAI XI.S8-1 December 21, 2010




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-17 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 63 Inservice Inspection (ISI)

Program Columbia currently relies on acceptable enhanced visual technique (EVT-1) inspections in accordance with ASME Code Section XI.

Ultrasonic Testing (UT) examination of creviced shroud support plate access hole cover weld, top hat configuration, will be performed, in addition to EVT-1, once a demonstrated acceptable UT technique becomes available.

A.1.2.33 Upon availability of acceptable UT technique.

Then ongoing.

Columbia Letter GO2-10-179 RAI 3.1.1.x-1 December 21, 2010 64 Inservice Inspection (ISI)

Program - IWE Verify leakage is not entering the annular space between the containment vessel and the concrete shield wall from the outer refueling bellows seal. Inspection of the portions of the outer containment vessel shell made accessible by opening all eight inspection ports in the containment vessel at 570 foot elevation will be performed to check for evidence of leakage. These inspections will be performed during a refueling outage while the reactor cavity is flooded.

A.1.2.34 During the fourth Inservice Inspection (ISI) interval prior to the period of extended operation (PEO) and again in the fifth ISI interval after entering the PEO.

Columbia Letter GO2-11-014 RAI 3.5.2.2.1.4-1 January 18, 2011 Columbia Letter GO2-11-112 June 23, 2011 65 Inservice Inspection (ISI)

Program Columbia will prepare and submit the ISI Program Plan for the fourth 10- year interval no later than 2015. (The third 10-year ISI interval extends from December 2005 until December, 2015.) The Small Bore Piping Program will be included in the fourth 10-year interval ISI Program Plan as an augmented inspection. The locations to be inspected, the sample size, the inspection methodology will be included in the program plan.

A.1.2.33 Upon submittal of the ISI Program Plan for the fourth 10-year interval.

Columbia Letter GO2-11-020 RAI B.2.49-2 January 27, 2011 Columbia Letter GO2-11-074 Second Annual Update April 5, 2011 66 Structure Monitoring Program Perform a one-time internal inspection of the spent fuel pool telltale drain lines prior to the period of extended operation to confirm the drain lines are free of obstructions. Unexpected inspection results of clogged lines will require a condition report be documented and further engineering evaluation of adverse impacts to the spent fuel pool structure and to identify the periodicity of drain cleaning and maintenance process.

A.1.2.50 Prior to the period of extended operation Columbia Letter GO2-11-017 RAI B.2.50-5 January 20, 2011 67 Structure Monitoring Program Perform a one-time borescope inspection of the containment sand pocket drain lines to confirm the absence of clogged drain lines and that a flow path exists for identification of any potential leakage into the sand pocket region. Unexpected inspection results (clogged drain lines) will be documented under corrective action process.

A.1.2.50 Prior to 12/31/15 Columbia Letter GO2-11-017 RAI B.2.34-1 January 20, 2011 Columbia Letter GO2-11-029 RAI B.2.26-6 January 28, 2011




   

   

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Columbia License Renewal Commitments Table A-1 LDCN-19-035 A.4-18 FINAL SAFETY ANALYSIS REORT Amendment 66 COLUMBIA GENERATING STATION December 2021 Item Number Title Commitment Updated Final Safety Analysis Report (UFSAR)

Supplement Section/LRA Section Enhancement or Implementation Schedule Source 68 Flow-Accelerated Corrosion (FAC)

Program Ensure that the condensate (COND) and reactor feedwater (RFW) systems are screened and evaluated for cavitation prior to entering the period of extended operation (PEO). If the in-scope portion of either system is determined to be susceptible to loss of material due to cavitation erosion, then a program(s) will be modified or created to manage the loss of material.

A.1.2.28 Prior to the period of extended operation.

Columbia Letter GO2-11-029 RAI B.2.26-6 January 28, 2011 Columbia Letter GO2-11-074 Second Annual Update 4/5/11 69 Inservice Inspection (ISI)

Program Re-evaluate the portions of the reactor pressure vessel beltline welds BG and BM for the period of extended operation (54 EFPY), in accordance with the requirements of the ASME Code,Section XI, IWB-3600 based on the results of 2015 inservice inspection.

A.1.2.33 Prior to the period of extended operation.

Columbia Letter GO2-11-031 RAI 4.7.1-1 January 28, 2011 Columbia Letter GO2-11-074 Second Annual Update April 5, 2011 70 TLAA -

Embrittlement of reactor vessel Perform a 54 EFPY equivalent margin analysis for the embrittlement (upper shelf energy) of the reactor vessel N12 (preinstrumentation) nozzle forgings.

A.1.3.1.2 No later than 2 years prior to the period of extended operation.

Columbia Letter GO2-11-031 RAI 4.2-1 January 28, 2011 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.




   

   

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