GO2-11-030, Response to Request for Additional Information License Renewal Application to Support RAI 3.1.2.3.1-2: Difference between revisions
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{{#Wiki_filter:Sudesh K. Gambhir Vice President, Engineering | {{#Wiki_filter:Sudesh K. Gambhir ENERGY ' Vice President, Engineering P.O. Box 968, Mail Drop PE04 NORTHW EST Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgam bhir@energy-northwest.com January 28, 2011 G02-11-030 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 | ||
==Subject:== | ==Subject:== | ||
| Line 24: | Line 24: | ||
==References:== | ==References:== | ||
: 1) Letter, G02-10-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application" 2) Letter dated September 16, 2010, NRC to SK Gambhir (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML102450727) | : 1) Letter, G02-10-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application" | ||
: 2) Letter dated September 16, 2010, NRC to SK Gambhir (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML102450727) | |||
: 3) Letter dated December 21, 2010, SK Gambhir (Energy Northwest) to NRC, "Columbia Generating Station, Docket No. 50-397 Response to Request for Additional Information License Renewal Application" (ADAMS Accession No. MLI103620326) | : 3) Letter dated December 21, 2010, SK Gambhir (Energy Northwest) to NRC, "Columbia Generating Station, Docket No. 50-397 Response to Request for Additional Information License Renewal Application" (ADAMS Accession No. MLI103620326) | ||
==Dear Sir or Madam:== | ==Dear Sir or Madam:== | ||
By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. | By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. | ||
Based on discussions with the NRC staff, Energy Northwest is providing additional information to support the response to RAI 3.1.2.3.1-2 provided in Reference 3.No new commitments are included in this response. | Based on discussions with the NRC staff, Energy Northwest is providing additional information to support the response to RAI 3.1.2.3.1-2 provided in Reference 3. | ||
Amendment 27 to the License Renewal Application is provided in the enclosure to this letter.If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197. | No new commitments are included in this response. Amendment 27 to the License Renewal Application is provided in the enclosure to this letter. | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.RspectfuIly, K Gambhir Vice President, Engineering | If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197. | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter. | |||
RspectfuIly, K Gambhir Vice President, Engineering | |||
==Attachment:== | ==Attachment:== | ||
Supplemental Information | Supplemental Information | ||
==Enclosure:== | ==Enclosure:== | ||
License Renewal Application Amendment 27 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a) | |||
BE Holian - NRC NRR RR Cowley - WDOH | |||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 1 of 1 SUPPLEMENTAL INFORMATION Supplemental information for RAI 3.1.2.3.1-2: | |||
This supplement adds more detail regarding aging management of the reactor vessel BG and BM welds and the two indications discussed in LRA section 4.7.1.For note H, "Cracking | This supplement adds more detail regarding aging management of the reactor vessel BG and BM welds and the two indications discussed in LRA section 4.7.1. | ||
-Flaw Growth" means that postulated flaws are considered to exist that are below the ASME code requirement for evaluation. | For note H, "Cracking - Flaw Growth" means that postulated flaws are considered to exist that are below the ASME code requirement for evaluation. Flaws that are being managed through TLAA are identified as separate rows in the Tables 3.1.2-1 and 3.1.2-3. | ||
Flaws that are being managed through TLAA are identified as separate rows in the Tables 3.1.2-1 and 3.1.2-3.The BG and BM welds are managed as part of the RPV shell (shell Rings) in Table 3.1.2-1 row 17 through 23 as a part of the reactor pressure vessel. In order to clarify this further, Table 3.1.2-1 is revised to add plant specific row 20a for welds BG and BM.A plant specific note K is added to clarify that the ISI program will continue to manage the specific indications in RPV shell welds BG and BM. The amended table is provided in the enclosure. | The BG and BM welds are managed as part of the RPV shell (shell Rings) in Table 3.1.2-1 row 17 through 23 as a part of the reactor pressure vessel. In order to clarify this further, Table 3.1.2-1 is revised to add plant specific row 20a for welds BG and BM. | ||
Energy Northwest is required by | A plant specific note K is added to clarify that the ISI program will continue to manage the specific indications in RPV shell welds BG and BM. The amended table is provided in the enclosure. | ||
LRA Tables 3.1.2-1 and 3.1.2-3 line items that credit the ISI Program for managing"Cracking | Energy Northwest is required by 10CFR50.55a to meet the requirements of the ASME Boiler and Pressure Vessel Code for the Inservice Inspection Program (ISI) and disposition all indications per ASME Section XI at Columbia Generating Station. This requirement is reinforced by Table A-1, Item 33, stating that the ISI Program is an existing program that will be continued for the period of extended operation (PEO). | ||
-Flaw Growth" in the components have a Generic Note H. These line items are referring to postulated crack conditions. | Therefore, a separate commitment to perform the augmented inspections required by the ASME code and outlined in LRA section 4.7.1 is not necessary. | ||
LRA Tables 3.1.2-1 and 3.1.2-3 line items that credit the ISI Program for managing "Cracking - Flaw Growth" in the components have a Generic Note H. These line items are referring to postulated crack conditions. | |||
To date the only indications exceeding ASME XI acceptance criteria found at Columbia are the BM and BG reactor vessel weld indications discussed in LRA section 4.7.1. As no other indications in excess of the ASME XI acceptance criteria have been identified, no other evaluations have been required. | To date the only indications exceeding ASME XI acceptance criteria found at Columbia are the BM and BG reactor vessel weld indications discussed in LRA section 4.7.1. As no other indications in excess of the ASME XI acceptance criteria have been identified, no other evaluations have been required. | ||
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 License Renewal Application Amendment 27 Section No. Page No. RAI Response Table 3.1.2-1 3.1-31 3.1.2.3.1-2 Insert Line Item Table 3.1.2-1 3 1-31a 3.1.2.3.1-2 New Line Item 20a Generic | |||
Program Volume 2 Item Management Item | RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 License Renewal Application Amendment 27 Section No. Page No. RAI Response Table 3.1.2-1 3.1-31 3.1.2.3.1-2 Insert Line Item Table 3.1.2-1 3 1-31a 3.1.2.3.1-2 New Line Item 20a Generic enserinNotes Iotem 3.1-115 3.1.2.3.1-2 Insert Line Item Generic Notes 3.1-115a 3.1.2.3.1-2 Line Item K | ||
RPV Shell Pressure Steel w. S Air-indoor G 16 (Closure Boundary Cladding uncontrolled None None N/A N/A 0101 Flange) (External) | |||
Reactor Cracking 17 | Columbia Generating Station License Renewal Application Technical Information Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Row Component Intended Material Environment Aging Effect Requiring AgIng Management TNUREG-1801 Table 1 Notes No. Type Function(s) Program Volume 2 Item Management Item RPVRPV'hell Shell Pressure Steel w. SS Reactor Reco 15 (Closure Peure Sladding Coolant Loss of material BWR Water Chemistry IV.A1-8 3.1.1-14 A Flange) Boundary Cladding (Internal) | ||
SCC/IGA Inservice Inspection IV.C1-1 3.1.1-48 0103 RPV Shell Pressure Steel w. SS Reactor 19 (Shell Pressury Cladding Coolant Cracking -TLAA IV.A1-7 | RPV Shell Pressure Steel w. S Air-indoor G 16 (Closure Boundary Cladding uncontrolled None None N/A N/A 0101 Flange) (External) | ||
Fatigue | Reactor Cracking 17 Pressure Steel w. S coolant BWR Water Chemistry IV.C1-1 3.1.1-48 C 17RPV(Shell Shell Rings) boundary Cladding (Internal) 0103 Reactor RPV Shell Pressure Steel w. SS Coolant Cracking - C 18 (Shell Rings) Boundary Cladding (Internal) SCC/IGA Inservice Inspection IV.C1-1 3.1.1-48 0103 RPV Shell Pressure Steel w. SS Reactor 3.1.1-02 A 19 (Shell Pressury Cladding Coolant Cracking - TLAA IV.A1-7 (Shell Rings) Boundary Cladding (Internal) Fatigue RPV Shell 20 Pressure Steel w.SS Reactor Coolant Cracking - Flaw 20 (Shell Rings) Boundary Cladding (Internal) Growth Inservice Inspection N/A N/A H RPV Shell Pressure Steel w. SS Reactor Chemistry Program 21 Coolant (Internal) Loss of material Effectiveness Inspection IV.A1-8 3.1.1-14 A (Shell Rings) Boundary Cladding Insert A from Reactor RPV Shell Pressure Steel w. SS 3.1-31a 22 Shell Pressury Cladding Coolant Loss of material BWR Water Chemistry IV.A1-8 3.1.1-14 A 2(Shell Rings) Boundary Cladding (Internal) | ||
Growth Inservice Inspection N/A N/A H RPV Shell Pressure Steel w. SS Reactor Chemistry Program 21 Coolant Loss of material Effectiveness IV.A1-8 3.1.1-14 A (Shell Rings) Boundary Cladding | Aging Management Review Results Page 3.1,-31 | ||
Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.1-31 Aging Management Review Results Page 3.1-31 a Amendment 27 | |||
G Environment not in NUREG-1 801 for this component and material.H Aging effect not in NUREG-1 801 for this component, material and environment combination. | |||
I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable. | Columbia Generating Station License Renewal Application Technical Information Generic Notes: | ||
J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.Insert Afrom 3.1-115a Aging Management Review Results Page 3.1-115 | A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP. | ||
*1 Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.1-115 Generic Notes: | B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP. | ||
C Component is different, but consistent with NUREG-1 801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP. | |||
D Component is different, but consistent with NUREG-1 801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801 AMP. | |||
E Consistent with NUREG-1 801 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program. | |||
F Material not in NUREG-1 801 for this component. | |||
G Environment not in NUREG-1 801 for this component and material. | |||
H Aging effect not in NUREG-1 801 for this component, material and environment combination. | |||
I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable. | |||
J Neither the component nor the material and environment combination is evaluated in NUREG-1 801. | |||
Insert Afrom 3.1-115a Ie, 429ia1y O | |||
Aging Management Review Results Page 3.1-115 j~menment27 | |||
*1 Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.1-115 Generic Notes: BG and BM 4.7.1 the ISI program will continue to manage the specific indications in welds K TAs described in LRA Section Amendment 2727 Amendment Page 3.1-115a Page 3.1-115a Results Management Review Aging Management Aging Review Results}} | |||
Revision as of 04:01, 13 November 2019
| ML110320538 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 01/28/2011 |
| From: | Gambhir S Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GO2-11-030 | |
| Download: ML110320538 (8) | |
Text
Sudesh K. Gambhir ENERGY ' Vice President, Engineering P.O. Box 968, Mail Drop PE04 NORTHW EST Richland, WA 99352-0968 Ph. 509-377-8313 F. 509-377-2354 sgam bhir@energy-northwest.com January 28, 2011 G02-11-030 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION
References:
- 1) Letter, G02-10-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"
- 2) Letter dated September 16, 2010, NRC to SK Gambhir (Energy Northwest), "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application," (ADAMS Accession No. ML102450727)
- 3) Letter dated December 21, 2010, SK Gambhir (Energy Northwest) to NRC, "Columbia Generating Station, Docket No. 50-397 Response to Request for Additional Information License Renewal Application" (ADAMS Accession No. MLI103620326)
Dear Sir or Madam:
By Reference 1, Energy Northwest requested the renewal of the Columbia Generating Station (Columbia) operating license. Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal.
Based on discussions with the NRC staff, Energy Northwest is providing additional information to support the response to RAI 3.1.2.3.1-2 provided in Reference 3.
No new commitments are included in this response. Amendment 27 to the License Renewal Application is provided in the enclosure to this letter.
If you have any questions or require additional information, please contact Abbas Mostala at (509) 377-4197.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.
RspectfuIly, K Gambhir Vice President, Engineering
Attachment:
Supplemental Information
Enclosure:
License Renewal Application Amendment 27 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a)
BE Holian - NRC NRR RR Cowley - WDOH
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Attachment Page 1 of 1 SUPPLEMENTAL INFORMATION Supplemental information for RAI 3.1.2.3.1-2:
This supplement adds more detail regarding aging management of the reactor vessel BG and BM welds and the two indications discussed in LRA section 4.7.1.
For note H, "Cracking - Flaw Growth" means that postulated flaws are considered to exist that are below the ASME code requirement for evaluation. Flaws that are being managed through TLAA are identified as separate rows in the Tables 3.1.2-1 and 3.1.2-3.
The BG and BM welds are managed as part of the RPV shell (shell Rings) in Table 3.1.2-1 row 17 through 23 as a part of the reactor pressure vessel. In order to clarify this further, Table 3.1.2-1 is revised to add plant specific row 20a for welds BG and BM.
A plant specific note K is added to clarify that the ISI program will continue to manage the specific indications in RPV shell welds BG and BM. The amended table is provided in the enclosure.
Energy Northwest is required by 10CFR50.55a to meet the requirements of the ASME Boiler and Pressure Vessel Code for the Inservice Inspection Program (ISI) and disposition all indications per ASME Section XI at Columbia Generating Station. This requirement is reinforced by Table A-1, Item 33, stating that the ISI Program is an existing program that will be continued for the period of extended operation (PEO).
Therefore, a separate commitment to perform the augmented inspections required by the ASME code and outlined in LRA section 4.7.1 is not necessary.
LRA Tables 3.1.2-1 and 3.1.2-3 line items that credit the ISI Program for managing "Cracking - Flaw Growth" in the components have a Generic Note H. These line items are referring to postulated crack conditions.
To date the only indications exceeding ASME XI acceptance criteria found at Columbia are the BM and BG reactor vessel weld indications discussed in LRA section 4.7.1. As no other indications in excess of the ASME XI acceptance criteria have been identified, no other evaluations have been required.
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Enclosure Page 1 of 1 License Renewal Application Amendment 27 Section No. Page No. RAI Response Table 3.1.2-1 3.1-31 3.1.2.3.1-2 Insert Line Item Table 3.1.2-1 3 1-31a 3.1.2.3.1-2 New Line Item 20a Generic enserinNotes Iotem 3.1-115 3.1.2.3.1-2 Insert Line Item Generic Notes 3.1-115a 3.1.2.3.1-2 Line Item K
Columbia Generating Station License Renewal Application Technical Information Table 3.1.2-1 Aging Management Review Results - Reactor Pressure Vessel Row Component Intended Material Environment Aging Effect Requiring AgIng Management TNUREG-1801 Table 1 Notes No. Type Function(s) Program Volume 2 Item Management Item RPVRPV'hell Shell Pressure Steel w. SS Reactor Reco 15 (Closure Peure Sladding Coolant Loss of material BWR Water Chemistry IV.A1-8 3.1.1-14 A Flange) Boundary Cladding (Internal)
RPV Shell Pressure Steel w. S Air-indoor G 16 (Closure Boundary Cladding uncontrolled None None N/A N/A 0101 Flange) (External)
Reactor Cracking 17 Pressure Steel w. S coolant BWR Water Chemistry IV.C1-1 3.1.1-48 C 17RPV(Shell Shell Rings) boundary Cladding (Internal) 0103 Reactor RPV Shell Pressure Steel w. SS Coolant Cracking - C 18 (Shell Rings) Boundary Cladding (Internal) SCC/IGA Inservice Inspection IV.C1-1 3.1.1-48 0103 RPV Shell Pressure Steel w. SS Reactor 3.1.1-02 A 19 (Shell Pressury Cladding Coolant Cracking - TLAA IV.A1-7 (Shell Rings) Boundary Cladding (Internal) Fatigue RPV Shell 20 Pressure Steel w.SS Reactor Coolant Cracking - Flaw 20 (Shell Rings) Boundary Cladding (Internal) Growth Inservice Inspection N/A N/A H RPV Shell Pressure Steel w. SS Reactor Chemistry Program 21 Coolant (Internal) Loss of material Effectiveness Inspection IV.A1-8 3.1.1-14 A (Shell Rings) Boundary Cladding Insert A from Reactor RPV Shell Pressure Steel w. SS 3.1-31a 22 Shell Pressury Cladding Coolant Loss of material BWR Water Chemistry IV.A1-8 3.1.1-14 A 2(Shell Rings) Boundary Cladding (Internal)
Aging Management Review Results Page 3.1,-31
Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.1-31 Aging Management Review Results Page 3.1-31 a Amendment 27
Columbia Generating Station License Renewal Application Technical Information Generic Notes:
A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1 801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
C Component is different, but consistent with NUREG-1 801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
D Component is different, but consistent with NUREG-1 801 item for material, environment, and aging effect. AMP takes some exceptions to NUREG-1 801 AMP.
E Consistent with NUREG-1 801 item for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.
F Material not in NUREG-1 801 for this component.
G Environment not in NUREG-1 801 for this component and material.
H Aging effect not in NUREG-1 801 for this component, material and environment combination.
I Aging effect in NUREG-1 801 for this component, material and environment combination is not applicable.
J Neither the component nor the material and environment combination is evaluated in NUREG-1 801.
Insert Afrom 3.1-115a Ie, 429ia1y O
Aging Management Review Results Page 3.1-115 j~menment27
- 1 Columbia Generating Station License Renewal Application Technical Information Insert A to Page 3.1-115 Generic Notes: BG and BM 4.7.1 the ISI program will continue to manage the specific indications in welds K TAs described in LRA Section Amendment 2727 Amendment Page 3.1-115a Page 3.1-115a Results Management Review Aging Management Aging Review Results