GO2-11-031, Response to Request for Additional Information for the Review of License Renewal Application

Response to Request for Additional Information for the Review of License Renewal Application

ML110320505
Person / Time
Site:	Columbia
Issue date:	01/28/2011
From:	Gambhir S Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-11-031
Download: ML110320505 (34)

Text

Sudesh K.Gambhir SENERGY Vice President, Engineering P.O. Box 968, Mail Drop PE04 i EST PNORTHW Richland, WA 99352-0968 509-377-8313 F. 509-377-2354 sgambhir @energy-northwest.com January 28, 2011 G02-11-031 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Subject. COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION

References:

1) Letter, G02-1 0-11, dated January 19, 2010, WS Oxenford (Energy Northwest) to NRC, "License Renewal Application"

2) Letter dated December 20, 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. ML103540022)

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.

Transmitted herewith in the Attachment is the Energy Northwest response to the Request for Additional Information (RAI) contained in Reference 2. Enclosure 1 contains Amendment 28 to the Columbia License Renewal Application. Two new commitments are included in this response.

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.

Respectfuly,

/SK rambhir Vice President, Engineering

Attachment:

Response to Request for Additional Information

Enclosure:

License Renewal Application Amendment 28 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C EFSEC Manager RN Sherman - BPA/1 399 WA Horin - Winston & Strawn AD Cunanan - NRC NRR (w/a)

BE Holian - NRC NRR RR Cowley - WDOH

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 11 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "Request for Additional Information for the Review of the Columbia Generating Station, License Renewal Application,"

(ADAMS Accession No. ML103540022)

RAI 4.2-1

Background:

The Columbia Generating Station (Columbia) reactor vessel (RV) N12 water level instrumentation nozzles (4 nozzles) are considered to be in the beltline region of the RV 2

because they are projected to experience neutron fluence greater than 1 x 1017 n/cm (E> 1.0 MeV) at the end of the period of extended operation, corresponding to 54 effective full power years (EFPY) of facility operation. The staff had requested in a previous request for additional information (RAI) that the applicant supplement license renewal application (LRA) Sections 4.2.1, 4.2.2, and 4.2.3 to include data for the neutron fluence, Charpy upper shelf energy (USE) evaluation, and adjusted nil-ductility reference temperature (ART) analysis for the four N12 instrumentation nozzles. The applicant's RAI response provided some information concerning a fluence value and a projected USE decrease for one of the four N1 2 nozzles; however, the RAI response did not provide sufficient data for the staff to conclude that the projected USE and ART analyses for these N12 nozzles would remain acceptable for the period of extended operation (54 EFPY), in accordance with 10 CFR 54.21 (c)(1)(ii) and 10 CFR Part 50, Appendix G requirements.

The staff has also determined that the applicant has not demonstrated that the use of the BWRVIP-74-A, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal," equivalent margins analysis (EMA) for plate material is a valid EMA acceptance criterion for nozzle forgings. Furthermore, the staff found that the applicant has not provided analyses of either the ART or the USE for the N12 instrumentation nozzle-to-RV welds for the period of extended operation.

Issue:

The requirements of 10 CFR Part 50, Appendix G apply to "ferritic materials of pressure-retaining components of the reactor coolant pressure boundary ... "The 10 CFR Part 50, Appendix G requirements do not apply to austenitic-phase materials, such as nickel-based alloys and austenitic stainless steels. Therefore, if the N12 nozzles and the associated N12 nozzle-to-RV welds are composed of an austenitic material, then the N12 nozzles and their associated welds are not subject to 10 CFR Part 50, Appendix G requirements, and they do not need to be analyzed for neutron fluence, USE, or ART in LRA Section 4.2.

However, if the N12 nozzles and the associated N12 nozzle-to-RV welds are composed of a ferritic material (such as an ASME Code,Section II, SA-508 alloy steel or carbon

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 11 steel), then the 10 CFR Part 50, Appendix G requirements are applicable to these nozzles and their associated nozzle-to-RV welds, and the N12 nozzles and their associated welds must be analyzed for the USE and the ART in Sections 4.2.2 and 4.2.3 of the Columbia LRA.

Request:

(a) Please state the general type of material (e.g., austenitic nickel-based alloy, austenitic stainless steel, or a ferritic carbon or low alloy steel) from which the N12 water level instrumentation nozzles and their associated nozzle-to-RV welds are fabricated. If all N12 nozzles and associated N12 nozzle-to-RV welds are composed of an austenitic material, then no further information is required concerning the N12 instrumentation nozzles.

The following questions apply only if the N12 instrumentation nozzles are fabricated from a ferritic-phase material such as carbon or low alloy steel.

(b) Please provide the following information, if available, for the N12 RV beltline instrumentation nozzle forgings and their associated nozzle-to-RV weld materials:

iL The ASME Code,Section II Material Specification (e.g., SA-###, Grade ##

and/or Class ##) for each N12 RV beltline nozzle forging; ii. the heat number for each N12 RV beltline nozzle forging; iii. the heat number of wire and flux lot number used to fabricate each N12 RV beltline nozzle-to-RV weld; iv. the chemical composition (i.e., the weight percent (wt%) of copper and nickel) for each N12 RV beltline nozzle forging;

v. the chemical composition (i.e., the wt.% of copper and nickel) for each N12 RV beltline nozzle-to-RV weld; vi. the unirradiated nil-ductility reference temperature (RTNDT) for each N12 RV beltline nozzle forging; vii. the unirradiated RTNDT for each N12 RV beltline nozzle-to-RV weld; and viii. the method of determining the unirradiated reference temperature from the Charpy and drop weight tests for each N12 RV beltline nozzle forging and associated nozzle-to-RV weld.

(c) Based on the information provided in part (b) above for the N12 RV beltline nozzle forgings and associated nozzle-to-RV welds, please provide a calculation of the 54 EFPY ART values for the N12 RV beltline nozzle forging and associated nozzle-to-RV weld materials. If actual values for the wt.% copper and nickel are not available for any of these N12 nozzle forgings or associated nozzle-to-RV welds, then 54 EFPY ART values must be calculated for these materials based on a determination of acceptable wt.% copper and nickel values from the evaluation of a statistically significant set of representative materials or based on limiting values for the wt.%

copper and nickel listed in the applicable ASME Code,Section II material specifications for these N12 nozzle forging and associated nozzle-to-RV weld materials.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 3 of 11 (d) Appendix G to 10 CFR Part 50, "Fracture Toughness Requirements," states that RV beltline [ferritic] materials have Charpy USE in the transverse direction for base metal and along the weld for weld metal of no less than 75 ft-lb initially and must maintain USE throughout the life of the RV of no less than 50 ft-lbs unless it is demonstrated in a manner approved by the Director, Office of Nuclear Reactor Regulation, that lower values of Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code.

The applicant's RAI response concerning the USE evaluation for the N12 water level instrumentation nozzles states that that the BWRVIP-74-A EMA acceptance criterion for plate material was used to determine that N12 instrumentation nozzle forgings meet the USE requirements of 10 CFR Part 50, Appendix G. In BWRVIP-74-A, Appendix B, Section B.2, EMA for BWR/3-6 plates, the materials addressed in the analysis included: ASME Code,Section II, SA-302 Grade B and Grade B Modified low allow steel plate and SA-533 Grade B, Class 1 low alloy steel plate. Nozzle forging materials, including nozzle-to-RV welds, were not included in the BWRVIP-74-A, Appendix B analysis. Therefore, the staff does not find the application of BWRVIP-74-A acceptable for demonstrating compliance with Appendix G to 10 CFR Part 50 for the Columbia nozzle materials. The methodology contained in BWRVIP-74-A is applicable only to the materials analyzed in the report.

iFor all ferritic N12 instrumentation nozzle forgings, the staff requests that the applicant submit EMAs to demonstrate that the 54 EFPY Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code.

ii. For all ferritic N12 instrumentation nozzle-to-RV welds, the staff requests that the applicant provide an evaluation of the 54 EFPY USE values, based on either a direct calculation of the 54 EFPY USE values, or, if initial USE value are unknown, EMAs to demonstrate that the 54 EFPY Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code.

Ener-tv Northwest Response:

(a) A table including materials for the N12 forgings and welds is provided at the end of the response to RAI 4.2-2. As described in response to item (b) below, N12 nozzle forgings are ferritic but the N12 nozzle-to-vessel weld is austenitic.

(b) As shown in the table, the N12 nozzle forging is ferritic, but the N12 nozzle-to-vessel weld is austenitic. The following sections are answered accordingly.

i. The ASME Code,Section II Material Specification for each N12 nozzle forging is given in the table at the end of the response to RAI 4.2-2.

ii. The heat numbers for each N12 nozzle forging are given in the table at the end of

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 4 of 11 the response to RAI 4.2-2. There are four N12 nozzles, one is from heat 718259 and three are from heat 219972.

iii. The heat number of wire and flux lot number used to fabricate each N12 nozzle-to-vessel weld is unknown, but the weld procedure specifies that this be Inco-82/182 (an austenitic nickel-based alloy material) and therefore these heat numbers are not required.

iv. The chemical composition (i.e., the weight percent (wt.%) of copper and nickel) for each N12 RV beltline nozzle forging is provided in the table at the end of the response to RAI 4.2-2.

For heat 718259 the copper and nickel values were taken from Columbia Certified Material Test Reports (CMTRs).

For heat 219772 the copper and nickel values are unknown. Therefore, a copper value of 0.35 wt.% and a nickel value of 1.00 wt.% were assumed as recommended in Section 1.1 of Regulatory Guide 1.99, Revision 2.

v. N12 nozzle-to-vessel welds are austenitic and therefore the chemistry is not required.

vi. The unirradiated RTNDT for heat 219972 forging is +40°F as taken from NEDO-33144, Table 4-2. The unirradiated RTNDT for heat 718259 forging is -20°F and is also taken from NEDO-33144, Table 4-2. (NEDO-33144, "Pressure-Temperature Curves for Energy Northwest Columbia," April 2004) vii. As the N12 nozzle-to-vessel welds are austenitic no unirradiated RTNDT is required viii. As discussed, in response to vi above, the unirradiated reference temperatures for the N12 nozzle forgings were obtained from NEDO-33144. NEDO-33144 used initial RTNDT values that were determined by methodology found in GE report NEDC-32399-P, "Basis for GE RTNDT Estimation Method," September 1994. This methodology was approved by the NRC in a letter from B. Sheron to R.A. Pinelli, "Safety Assessment of Report NEDC-32399-P, Basis for GE RTNDT Estimation Method, September 1994," December 16, 1994.

(c) Based on the information above, a projection of ART to 54 EFPY for N12 nozzle forgings is provided in the table at the end of the response to RAI 4.2-2. As discussed above, the N12 nozzle-to-vessel weld is austenitic and no projection of ART is required.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 5 of 11 (d) i. Initial USE for the N12 forgings is unknown, and therefore a projected % drop in USE is calculated to demonstrate equivalent margin. A summary of the calculation of the projected % drop in USE for the N12 nozzle forgings is provided in the table at the end of the response to RAI 4.2-2. The predicted drop in USE is 21.1% for heat 219972 and 16.3% for heat 718259 as shown in the table at the end of the response to RAI 4.2-

2. While both of these projected drops meet the acceptance criterion of NEDO-32205 (523.5% for plate material, -<39%for weld material) discussions between the staff, the applicant, and the original equipment manufacturer have confirmed that the NEDO-32205 acceptance criteria cannot be applied to forgings without further study.

Therefore, Energy Northwest commits to perform the necessary Equivalent Margin Analyses for the N12 nozzle forgings prior to the period of extended operation.

ii. As the N12 nozzle-to- vessel welds are austenitic, the 10 CFR 50 requirements do not apply and projected USE is not required.

The LRA has been updated in the enclosed amendment to include the pertinent information described in this response in LRA Sections 4.2, Appendix A, and Table A-I.

RAI 4.2-2

Background:

The Columbia RV N6 residual heat' removal/low-pressure coolant injection (RHR/LPCI) nozzles (3 nozzles) are considered to be in the beltline region of the RV because they are projected to experience neutron fluence greater than 1 x 1017 n/cm 2 (E> 1.0 MeV) at the end of the period of extended operation (54 EFPY). The staff had requested in a previous RAI that the applicant supplement LRA Section 4.2.2 to include data for the USE evaluation for the three N6 RHR/LPCI nozzles. The applicant's RAI response provided information concerning a projected percent decrease in the USE value for these nozzles valid for 54 EFPY. The applicant stated in its RAI response that this value is below the 23.5% USE EMA acceptance criterion established for rolled plate material in BWRVIP-74-A.

Issue:

The staff reviewed the applicant's RAI response and determined that the applicant had' provided an acceptable calculation of the projected percent decrease in the USE value for these nozzle forgings (9.6% at 54 EFPY). However, the staff found that the applicant had not demonstrated that the use of the BWRVIP-74-A EMA for plate material is a valid EMA acceptance criterion for nozzle forgings. Furthermore, the staff found that the applicant had not provided analyses of either the adjusted RTNDT (ART) or the USE for the N6 RHR/LPCI nozzle-to-RV welds for the period of extended operation.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 6 of 11 Request:

(a) Please provide the following information for the N6 RV beltline RHR/LPCI nozzle forging and the associated nozzle-to-RV weld materials, as follows:

The ASME Code,Section II Material Specification (e.g. SA-###, Grade ##

and/or Class ##) for each N6 RV beltline nozzle forging; ii. the heat number of wire and flux lot number used to fabricate each N6 RV beltline nozzle-to-RV weld; Mit. the chemical composition (i.e., the wt.% of copper and nickel) for each N6 RV beltline nozzle-to-RV weld; iv. the unirradiated RTNDT for each N6 RV beltline nozzle-to-RV weld; and.

v. the method of determining the unirradiated reference temperature from the Charpy and drop weight tests for each N6 RV beltline nozzle-to-RV weld.

(b)--Based on the information provided in part (a) above for the N6 RV beltline nozzle-to-RV welds, please provide calculations of the 54 EFPY ART values for the nozzle-to-RC weld materials. If actual values for the wt.% copper and nickel are not available for any of these N6 nozzle-to-RV welds, then 54 EFPY ART values must be calculated for these materials based on a determination of acceptable wt.%

copper and nickel values from the evaluation of a statistically significant set of representative materials of based on limiting values for the wt.% copper and nickel listed in the applicable ASME Code,Section II material specifications for these N112 nozzle forging and associated nozzle-to-RV weld materials.

(c) Appendix G to 10 CFR Part 50, "Fracture Toughness Requirements," states that reactor vessel (RV) beltline [ferritic] materials have Charpy USE in the transverse direction for base metal and along the weld for weld metal of no less than 75 ft-lb initially and must maintain USE throughout the life of the RV of no less than 50 ft-lbs unless it is demonstrated in a manner approved by the Director, Office of Nuclear Reactor Regulation, that lower values of Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code." The applicant's RAI response concerning the USE evaluation for the N6 RHR/LPCI nozzles states that that the BWRVIP-74-A EMA acceptance criterion for plate material was used to determine that N6 RHR/LPCI nozzles forgings meet USE requirements of 10 CFR Part 50, Appendix G. In BWRVIP A, Appendix B, Section B.2, EMA for BWR/3-6 plates, the materials addressed in the analysis include: ASME Code,Section II, SA-302 Grade B and Grade B Modified low allow steel plate and SA-533 Grade B, Class 1 low alloy steel plate.

Nozzle forging materials, including nozzle-to-RV welds, were not included in the BWRVIP-74-A, Appendix B analysis. Therefore, the staff does not find the application of BWRVIP-74-A acceptable for demonstrating compliance with Appendix G to 10 CFR Part 50 for the Columbia nozzle materials. The

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 7 of 11 methodology contained in BWRVIP-74-A is applicable only to the materials analyzed in the report.

i. For all N6 RHR/LPCI nozzle forgings, the staff requests that the applicant submit EMAs to demonstrate that the 54 EFPY Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code.

ii. For all N6 RHR/LPCI nozzle-to-RV welds, the staff requests that the applicant provide an evaluation of the 54 EFPY USE values, based on either a direct calculation of the 54 EFPY USE values, or, if initial USE values are unknown, EMAs to demonstrate that the 54 EFPY Charpy USE will provide margins of safety against fracture equivalent to those required by Appendix G of Section XI of the ASME Code.

Energy Northwest Response:

(a) The following information for the N6 RHR/LPCI nozzle forging and the associated nozzle-to-vessel weld materials are provided.

i. The ASME Code,Section II Material Specification (SA-508 Cl 2) for each N6 nozzle forging is provided in the table at the end of this response.

ii. The heat number of wire and flux lot number used (5P6214B/0331 Linde 124) to fabricate each N6 nozzle-to-vessel weld is provided in the table at the end of this response.

iii. The chemical composition (i.e., the wt.% of copper and wt.% nickel) for each N6 nozzle-to-vessel weld is provided in the table at the end of this response. The best estimate chemistry from the BWRVIP Integrated Surveillance Program was used. ART was calculated with surveillance data per RG 1.99 Position 2.1 and a fitted chemistry factor was calculated based on the surveillance data.

iv. The unirradiated reference temperature for the N6 nozzle-to-vessel weld (heat 5P6214B) is -56 OF; and the associated initial sigma, a1 , is 17 OF.

v. The unirradiated reference temperature for the N6 nozzle-to-vessel weld was determined from integrated surveillance program (ISP) Surveillance data as described in BWRVIP-135. Testing of BWRVIP ISP capsules is performed following the requirements of ASTM El 85. For each ISP representative material (including weld heat 5P6214B) all baseline and irradiated Charpy data have been obtained from past surveillance program and capsule reports. The data were reanalyzed, using consistent analysis standards and protocols.

(b) Calculation of the 54 EFPY ART using Regulatory Guide 1.99 Position 2.1, for the N6 nozzle-to-vessel welds is provided in the table at the end of this response.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 8 of 11 (c) Projection of USE requires an initial (unirradiated) value of USE for the subject material. As the N6 nozzle forgings are SA508 Class 2, an initial USE of 70 ft-lbs is used as determined in Altran Technical Report 96124-TR-01, "N-16 Nozzles Upper Shelf Energy Evaluation" December 1996. This report was approved by the NRC in a letter to CP&L (Brunswick), "Evaluation of the January 17, 1992 Operating Transient at the Brunswick Steam Electric Plant, Unit 1, and Evaluation of Carolina Power & Light Company's Equivalent Margins Analysis of the N-1 6A/B Instrument Nozzles at the Brunswick Steam Electric Plant, Units 1 and 2 (TAC Nos.

MA0399/400)," October 16, 1998.

i. The calculation of projected USE for the N6 RHR/LPCI nozzle forgings is provided in the table at the end of this response. The projected USE exceeds 50 ft-lbs, and thus no equivalent margin analysis is required by Appendix G of 10 CFR 50.

ii. For the N6 RHR/LPCI nozzle-to-vessel welds, the initial USE is unknown and therefore cannot be projected. An equivalent margin analysis is demonstrated by projecting the percent reduction in USE (7.8 %) and comparing it to the weld material acceptance criteria in BWRVIP-74-A (539%). The acceptance criteria are met and these welds therefore have acceptable USE for the period of extended operation.

The LRA has been updated in the enclosed amendment to include the pertinent information described in this response in LRA Sections 4.2, Appendix A, and Table A-I.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 9 of 11 ART projected to 54 EFPY for the N6 and N12 nozzles and their associated nozzle to vessel welds.

Inputs Calculations 54 EFPY Initial 1/4T RTNDT Fluence Chemistry ARTNDT Margin ART Sub-Component Material Heat or Heat/Lot %Cu %Ni OF n/cm2 Factor OF a, oa [F OF FORGIN GS N6 (RHR / LPCI) SA508 C12 Q2Q55W 790S-1,2,3 0.11 0.76 -20 4.48E+17 76.4 21.1 0 10.6 21.1 22.2 N12 (Instrumentation) SA508 Cll 219972 0.35 1.00 40 4.48E+17 272 75.0 0 17.0 34.0 149.0 N12 (Instrumentation) SA508 Cl 718259 65363 0.25 0.24 -20 4.48E+17 130.4 35.9 0 17.0 34.0 49.9 WVELýDSý N6(RHR/LPCI) RAC01NM 5P6214B/0331 0.019 0.828 -56 5.OOE+17 38.72 11.3 17 5.7 35.8 -8.9 RG 1.99 Pos 2.1 M Linde 124 N12 (Instrumentation) Austenitic Austenitic NA NA NA NA NA NA NA NA NA NA USE projected to 54 EFPY, or Equivalent Margin Analyses, for the N6 and N12 nozzles and their associated nozzle to vessel welds.'

54 EFPY EMA:

1/4T Acceptance Unirradiated Fluence  % Drop USE Criteria Sub-Component Material Heat or Heat/Lot %Cu USE n/cm in USE (1/4 T)  % drop Acceptable?

FORGINGS' -

N6 (RHR / LPCI) SA508 C12 Q2Q55W 790S-1, 2, 3 0.11 70 4.48E+17 9.6% 63.3 23.5% NA N12 (Instrumentation) SA508 Cl1 219972 0.35 Unknown 4.48E+17 21.1% EMA 23.5% Yes N12 (Instrumentation) SA508 Cll 718259 65363 0.25 Unknown 4.48E+17 16.3% EMA 23.5% Yes WELDS:-.--

N6 (RHR /LPCI) RAC01NMM 5P6214B /0331 0.019 Unknown 5.OOE+17 7.8% EMA 39% Yes N12 (Instrumentation) Inco-82/182 Unknown NA NA NA NA NA NA NA

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 10 of 11 RAI 4.7.1-1

Background:

For the time-limited aging analysis (TLAA) of the Columbia RV shell indications (i.e.,

flaws), discussed in LRA Section 4.7.1, the staff issued an RAI (RAI 4.7.1-10(b))

requesting that the applicant add a license renewal commitment to re-inspect the subject flaws in 2015 and, based on the results of the 2015 inspection of the subject flaws, re-evaluate the subject flaws for the period of extended operation (54 EFPY) in accordance with ASME Code,Section XI, IWB-3600 flaw evaluation requirements, or continue augmented inspections as required by the ASME Code,Section XI. The staff had determined that this license renewal commitment is necessary, given that the current flaw evaluation referenced in LRA Section 4.7.1 will only remain valid through the end of the current 40-year licensed operating period (33.1 EFPY). In its response to RAI 4.7.1-10(b), the applicant stated that all RV axial welds, including portions of RV axial welds BG and BM with the flaws, will be re-examined in 2015 as part of the NRC-approved Inservice Inspection (ISI) program for the current 10-year ISI interval. The applicant added that these examinations are required to be completed by 2015, well before the beginning of the period of extended operation. The applicant stated further that these examinations are required for the current 40-year license term, regardless of whether or not the Columbia operating license receives 20-year extension. Thus, the applicant concluded in response to RAI 4.7.1-10(b) that "it is not a license renewal commitment to repeat these inspections."

Issue:

In reviewing the applicant's response to RAI 4.7.1-10(b), the staff acknowledges that the RV axial welds, including the subject flaws, are required to be re-examined prior to the end of the third 10-year ISI interval at Columbia, in accordance with ASME Code,Section XI requirements for the current 40-year license term. However, the analysis of these RV shell indications is a license renewal TLAA that has not yet been projected to remain in compliance with ASME Code,Section XI 'flaw acceptance criteria through the end of the period of extended operation.

Furthermore, the Columbia ISI aging management program description in LRA Section B.2.33 does not specifically address re-evaluation of existing flaws in ASME Code Class 1 components.

Request:

In order to ensure that the effects of aging for the subject RV shell weld flaws will be adequately managed in accordance with the requirements of 10 CFR 54.21 (c)(1)(iii),

the staff requests that the applicant include a license renewal commitment to re-evaluate the subject flaws for the period of extended operation (54 EFPY), in accordance with the requirements of the ASME Code, Section Xl, IWB-3600 based on the results of 2015 ISI.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 11 of 11 Energy Northwest Response:

Energy Northwest will include a license renewal commitment to re-evaluate the subject flaws for the period of extended operation (54 EFPY), in accordance with the requirements of the ASME Code, Section X1, IWB-3600 based on the results of 2015 inservice inspection. The commitment is in the enclosed LRA amendment pages.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 1 of 2 License Renewal Application Amendment 28 LRA Section Page Number RAI Number Number PgNubrRIume Table 4.1-1 Line Item Upper Shelf 4.1-3 4.2-1 & 4.2-2 Energy (USE) _

4.2.1 4.2-2a 4.2-1 & 4.2-2 4.2.1 4.2-3 4.2-1 & 4.2-2 Table Newle4.2-1Item 4.2-3 4.2-1 & 4.2-2 New Line Item 4.2.2 4.2-4 4.2-1 & 4.2-2 4.2.2 4.2-4a 4.2-1 & 4.2-2 Table Newle4.2-2 Item 4.2-5 4.2-1 & 4.2-2 New Line Item 4.2.3 4.2-8a 4.2-1 & 4.2-2 Table ITale 4.2-5 Item 4.2-9 4.2-1 & 4.2-2 Insert Line Item Table 4.2-5 ITabline Im 4.2-10 4.2-1 & 4.2-2 Insert Line Item Table Newblie4.2-5Its New Line Items 4.2-1Oa 4.2-1 & 4.2-2 4.2.6 4.2-14 4.2-1 & 4.2-2 Tables 4.2-8 and 4.2-9 4.2-14a 4.2-1 & 4.2-2 Table 4.2-8 4.2-14b 4.2-1 & 4.2-2 A.1.3.1.1 A-28 4.2-1 & 4.2-2 A.1.3.1.1 A-28a 4.2-1 & 4.2-2 A.1.3.1.2 A-29 4.2-1 & 4.2-2 A.1.3.1.2 A-29a 4.2-1 & 4.2-2 Table ITale A-i Itm A-68c 4.7.1-1 & 4.2-1 Insert Line Items

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION Page 2 of 2 LRA Section Number Page Number RAI Number Table A-1 New Line Items 69 & A-68d 4.7.1-1 & 4.2-1 70 Table Linle IeC-il10 Line Item 10 C-29 4.7.1-1

Columbia Generating Station License Renewal Application Technical Information Table 4.1-1 replace with (ii)

Time-Limited Aging Analyses 10 CF 54.21(c)(1) LRA Results of TLAA Evaluation by Category Pa agraph Section Reactor Vessel Neutron Embrittlement ) 4.2 Neutron Fluence --- gcaTý 4.2.1 Upper Shelf Energy (USE) 4.2.2 Adjusted Reference Temperature (ART) (ii) 4.2.3 Pressure-Temperature (P-T) Limits (iii) 4.2.4 Reactor Vessel Circumferential Weld Examination (ii) 4.2.5 Relief Reactor Vessel Axial Weld Failure Probability (ii) 4.2.6 Metal Fatigue 4.3 Reactor Pressure Vessel Fatigue Analyses (iii) 4.3.1 Reactor Vessel Internals Fatigue Analyses (iii) 4.3.2 Reactor Coolant Pressure Boundary Piping and (iii) 4.3.3 Component Fatigue Analyses Non-Class 1 Component Fatigue Analyses (i) 4.3.4 Effects of Reactor Coolant Environment on Fatigue (iii) 4.3.5 Life of Components and Piping Environmental Qualification of Electrical Equipment (iii) 4.4 Concrete Containment Tendon Prestress Not a TLAA 4.5 Containment Liner Plate, Metal Containments, and Penetrations Fatigue 4.6 Analyses ASME Class MC Components (i) 4.6.1 Downcomers (i) 4.6.2 Safety Relief Valve Discharge Piping (i) 4.6.3 Diaphragm Floor Seal (i) 4.6.4 ECCS Suction Strainers (i) 4.6.5 Other Plant-Specific Time-Limited Aging Analyses 4.7 Reactor Vessel Shell Indications (iii) 4.7.1 Sacrificial Shield Wall (ii) 4.7.2 Main Steam Line Flow Restrictor Erosion Analysis (ii) 4.7.3 (1) A specific 54 EFPY equivalent margins analysis will be performed for N12 nozzle forgings prior to the period of extend operation as explained in Section 4.2.2 and committed in Appendix A.

Time-Limited Aging Analyses Page 4.1-3 IAmendment 28

4.2.1 Neutron Fluence Columbia Generating Station Beltline Evaluation License Renewal Application Technical Information Insert A for Page 4.2-2:

Instrumentation nozzle N12 has a thickness less than 2.5 inches and was not originally evaluated for fracture toughness per ASME Code Appendix G, Section G2223. A discussion of N12 USE is presented in Section 4.2.2 and a discussion of N12 ART is presented in Section 4.2.3. Nozzle N12 is not limiting for P-T curves as discussed in Section 4.2.3. However, as nozzle N12 was evaluated for impact on the P-T curves it meets the definition of a beltline component per 10 CFR 50, A end ýp>

Nozzle N6 is evaluated for USE in Section 4.2.2. Nozzle N6 is evaluated for ART in Section 4.2.3 and Table 4.2-5 below. As shown in Table 4.2-5, the ART for these nozzles is only 22.2 OF, versus 53.8 OF for the highest weld and 73.6 OF for the highest plate. Consequently, nozzle N6 is not the limiting material for the vessel. However, as nozzle N6 was evaluated for ART it meets the definition of a beltline component per 10 CFR 50, Appendix G.

The associate(d nozzle-to-1,cc*

• ^ 1A* ;*- . .-r c.-

+ r ;+; I-V o VVIu I; aiII dl L*l IILIV weld and, therefore, is not The associated nozzle-to-vessel weld is a subject to the fracture ferritic weld and, therefore, is subject to toughness requirements of the fracture toughness requirements of 10 10 CFR 50, Appendix G. CFR 50, Appendix G. The nozzle-to-vessel weld for nozzle N6 is evaluated for USE in Section 4.2.2 and is evaluated for ART in Section 4.2.3 and Table 4.2-5 below.

Time-Limited Aging Analyses Page 4.2-2a Ammdnt2 nt 12

[Amendment 28'00

4.2.1 Neutron Fluence I Columbia Generating Station License Renewal Application Technical Information As such, the beltline definition for the period of extended operation includes the lower shell, lower-intermediate shell, associated vertical (longitudinal) welds, the girth (circumferential) weld that connects the lower and lower-intermediate shells, and nozzle-12_l 6s*%---andN12.

Disposition: Neutron fluence is-net-a-L-A-A.l-It-is-a-tiwie-timited-assumatien--used-(including the i-af4euSR utfe*emb*,emeRqt--AAs.

associated nozzle- Replace with "has been projected to the to-vessel welds) end of the period of extended operation Table 4.2-1 RPV Beltline Fluence Values at 54 EFPY PLATES: Identification OT fluence 1/4T fluence (I.D.) No. (n/cm 2) (n/cm 2),

Lower Shell Mk 21-1-1, 4.78E+17 2.71E+ 17 Mk 21-1-2, Mk 21-1-3, Mk 21-1-4 Lower-Intermediate Shell Mk 22-1-1, 1.17E+18 8.10E+17 Mk 22-1-2, Mk 22-1-3, Mk 22-1-4 NOZZLES:

N6 (RHR / LPCI) Mk 64-1 6.49E+17 4.48E+17 (3 nozzles)

WELDS:

Lower Vertical BA, BB, 4.78E+17 2.71 E+17 (Axial / Longitudinal) BC, BD Lower-Intermediate Vertical BE, BF, 1.17E+18 8.10E+17 (Axial / Longitudinal) BG, BH Lower to Lower-Intermediate Girth AB 4.78E+17 3.3E+17 (Circumferential)

Nozzle (N6) to 7.25E+17 5.OOE+17 vessel weld --

Insert row for Nozzles N12 from Insert A on Page 4.2-3a Time-Limited Aging Analyses Page 4.2-3 Jamendmet -1 JAmendmet '-9

Columbia Generating Station License Renewal Application Technical Information 4.2.2 Upper Shelf Energy Evaluation 10 CFR 50 Appendix G requires the USE of the RPV beltline materials to remain above 50 ft-lb at all times during plant operation, including the effects of neutron radiation. If USE cannot be shown to remain above this limit, then an equivalent margin analysis (EMA) must be performed to show that the margins of safety against fracture are equivalent to those required by Appendix G of Section Xl of the ASME Code.

The USE calculation of record for the existing licensed period (33.1 EFPY) is Appendix forgings,ý F of GE NEDO-33144 (Reference 4.8-5). The initial (unirraditated) USE is not known I'forgings,I for all the Columbia vessel plateand welds. For those plates*iind welds for which the initial USE is known, USE was projected using Regulatory Guide 1.99, Revision 2 methods. For the vessel plates and welds for which the initial USE is not known, USE EMAs were performed using the Boiling Water Reactor Owners Group EMA methodology. Results from the testing and analysis of surveillance materials were used in the EMA analyses.<__ in~sert B ýfrom page 4.2-4a The values of USE projected to 54 EFPY are listed in Table 4.2-2. All of the projected USE values from Table 4.2-2 remain above 50 ft-lbs through the end of the period of extended operation (54 EFPY). Replace with Insert A from Page 4.2-4a I I I I~ ~I ~ 1V1fl.J W ~

DO a II~t I o III

• B0 LAJI~

d *

~T.G. .J ~* Ia I t4.~Iar.a-T. I I *~ I ~ ~IVIfl.J III /

Ta ble 4.2-3, and Table 4.2-4 used Uth projetetd 54 EFPY fluence lited inTable 4 .2 -1,

-and tH8 GUFV 36 lattrotivu-M-r-MP 1AYU rigUfe r. -Me-predicled valties we, e co, , pa, ed to

-the FRIMMU Fn 04 "-"P-I= !IS111 VVVTTVn-ý ý-.

For the vessel beltline plates, the maximum decrease in USE was found to be 13.2 percent (see Table 4.2-3). This is less than the assumed decrease of 23.5 percent in the beltline plate equivalent margin analysis. Therefore, the maximum predicted decreases in USE for 54 EFPY for the beltline plates are bounded by the generic 54 EFPY equivalent margin analysis documented in BWRVIP-74-A. The projected USE for the vessel beltline plates is acceptable for the period of extended operation. A specific 54 EFPY For the welds associated with the vessel beltline plates, the maximum decrease in USE equivalent was found to be 21.6 percent (see Table 4.2-4). This is less than the assumed margins decrease of 39 percent in the equivalent margin analysis. Therefore, the maximum predicted decreases in USE for the welds in the vessel beltline region are bounded by analysis will the generic 54 EFPY equivalent margin analysis documented in BWRVIP-74-A. The be performed projected USE for the beltline welds is acceptable for the period of extended operation. for N12 nozzle 1 esselIeasteF upper shelf energy TLAAs forgings prior Disposition: 10 CFR 54.21(c)(1)(ii) -

have been projected to the end of the period of extended operation. to the period 1

of extend ln0or F2-R 12romt 4e-'-Z-- operation.

All other reA(;Jor Time-Limited Aging Analyses Page 4.2-4 Jaf~uaOl~

Jaquaw4M I Amendment 281

Columbia Generating Station License Renewal Application Technical Information Insert A for Page 4.2-4:

and The projected EMAs are listed in Table 4.2-3, T ble 4.2-4v'"able 4.2-8 and Table 4.2 The projected EMAs in Table 4.2-3, Table 4.2- , Table 4.2-8 and Table 4.-29 used the projected 54 EFPY fluence listed in Table 4.2-1, and the curves provided in RG 1.99 Figure 2. The predicted values were compared to the minimum 54 EFPY USE limits in BWRVIP-74-A.

Insert B for Page 4.2-4 For thc vesel beftfine nozzles, the maximum dercase in USE was found to be 1 per-cent (see Tables 4.2 8 and 4.2 9). This is less than the assumed dthatasc ef 23.5 pircnt in the equivalentoe msagn analysis. Thenrforc, the maximum predieted deoreasse in USE fer the niozzles in the vessel belaine region are bounded by the generic 54 EFPY equivalent margin analysis documented in BWRVIP 74 A. The projected USE fothe beltline nezzler tualceptable for the period of extended epeatien.

EAI coAmpr;ed only one N12 nozzle to the equivalent mnargin analysis of BWRVIP 74A because te Ccificd Material Test Repor-ts (CMT-Rs) fer the other three N12 nozzles did net contain the analyzed copper content. Energy Northwest agrees that the N12 instrumentation nozzle must be considered when the licensee develops pressure-temperature limits for Columbia in accordance with 10 CFR Part 50, Appendix G and the ASME Code, Section X1, Appendix G. Columbia will continue to develop future pressure-temperature limit curves considering all beltline plates, welds, and nozzles.

There is no specific EMA available for forgings (i.e., the N12 nozzles) for which initial USE is not known. Consequently, EN will perform a specific 54 EFPY equivalent margin analysis for the N12 instrument nozzle forgings as committed in Appendix A of the License Renewal Application.

Time-Limited Aging Analyses Page 4.2-4a Amendmcnt 12 FAmedme n t

4.2.2 Upper Shelf Energy Evaluation Columbia Generating Station License Renewal Application Technical Information Table 4.2-2 USE Projections for 54 EFPY

%T Drop '/4T I.D. Heat Initial Fluence in USE Sub-Componentr 1 ' No. (Single/Tandem wire)  % Cu USE nlcm2 USE (ft-lb)

P LA T E S - ";".". _. _ - '-: . _ . ._ . . ,

Lower-intermediate Mk 22- B5301-1 0.13 98 8.10E+17 12.1% 86.1 Shell (Course #2) 1-1 Lower Vertical AxaLonetuical) BA- 3P4966 (S) 0.025 98 2.71E+17 7.0% 91.1 BD 3P4966 (T) 0.025 98 2.71E+17 7.0% 91.1 Lower-Intermediate Vertical BE- 3P4966 (S) 0.025 98 8.10E+17 9.1% 89.1 (Axial/Longitudinal) BH_______

3P4966 (T) 0.025 98 8.10E+17 9.1% 89.1 Lower to Lower-Intermediate Girth AB 5P6756 (S) 0.080 91 3.30E+17 9.8% 82.1 (Circumferential) 5P6756 (T) 0.080 97 3.30E+17 9.8% 87.5 3P4955 (S) 0.027 90 3.30E+17 7.4% 83.3 A 3P4955 (T) 0.027 95 3.30E+17 7.4% 87.9

-The sub-uompom I 110 I

1.1U U11 II 1I

• I- I iasWI I-*

avve I U J J

-

V". VUI1U UUI I I~a %I being-unknown. %J% ýlt A .1 J I Itn I tJ1t A.. n Y A 'J tI 19 AIfin IVQI*I Ik IllUlUlil anaysee-e-thet miting pIa~~ a.d vvufd7 Replace footnote with Inseit A from Page 4.2-5a IN6 Nozzle forgings SA-508 012 790Q123'0.11 170 14.48E+17 19.6% 63.3 i Time-Limited Aging Analyses Page 4.2-5 Janua,"i 2-01 0

,fldmenment 282 JAmendment2

Columbia Generating Station License Renewal Application Technical Information Table ,4.2-5 ART Values for 54 EFPY Sub-Component Het Lt to Heat or HeatLot e %%CuC  % Nii ChemistryI Factor RTNoT R N T ,/.T Fluence n/cm ? ARTNOT OF a Cr., Margin OF ART OF OFII I pLATES:: 71 Lower Shell C1272-1 1 0.15 0,60 110 28 2.71E+17 22.8 0 11.4 22.8 73.6 (Course #1) C1273-1 0.14 0.60 100 20 271E+17 20.7 0 10.4 20.7 61.4 C1273-2 0.14 0.60 100 4 2.71E+17 20.7 0 10.4 20.7 454 C,1272-2 0.15 0.60 110 0 2.71E+17 22.8 0 11.4 22.8 45.6 Lower-Intermediate B5301-11'2 0.13 0.50 88 -20 8.10E+17 Shell _6.5 33_1 0 3311 46_2 (Course #2) C1336-1 0.13 0.50 88 -8 8,10E+17 .33.1 0 16.5 33.1 58.2 C1337-1 0.15 0.51 105 -20 8.10E+17 39.5 0 17.0 34.0 53.5 C1337-2 0.15 0.51 105 -20 8.10E+17 39.5 0 17.0 34,0 53.5 NOZZLES:

N6 (RHR /LPCI) Q2Q55W 790S 0.11 0,76 76.4 -20 4.48E+17 21.1 10.51 21.1 22.2 (instrument)

~nozzles from Insert

~A on page 4.2-10Oa Time-Limited Aging Analyses Page 4.2-9

• j~mendment 281

Add N6 nozzle-to vessel welds from insert B on Page 4.2-1 Oa Columbia Generating Station License Renewal Application Technical Information Table 4.2-5 (continued),

ART Values for 54 EFPY 1initial I, Chemistry RTNoT Fluence ARTNOT Margin ART Sub-Component(_

_ Heat or__IF Heat/Lot__  % Cu  % Ni- Factor n/cm 2 aF F OF WELDS:i Lower Vertical 04P146/D217A27A 0.0.6 10.9 82 -481 2.71E+17 170 0 18.5 1  : -14O (Axial/Longitudinal) 07L669 / K004A27A 0.03 1.02 41 -50 2.71E+17 8.5 0 1 4.2 8.5 -33.0 3P4966/1214-3482 (S) 0.025 0,91:3 34 -30 2.7iE+7 7.0 3.5 7.0 9 3P4966 / 1214-3482 (T) -48 -33.9 C3L46C/J020A27A 0.02 087 27 I -20 2.71E+17 5.6 0 238 5.6 -8.8 08M365/G128A27A 0.02 1.10 27 -48 2.71E+17 5.6 0 2.8 I 5.6 -36.8 09L853/4A6111A27A 0.03 0_8.6 42 -50 2.71E+17 I 8.5 0 4.2 8.5 -33.0 Lower-_Intermediate 3P4966L i2l4-3481 (S) 0 0.6 34 -20 5.6 Vertical 3P4966 1214-3481 (T) 0.025 0.913 34 -6 1 8.10E+17 12.:8 6.4 12.8 19.7 (Axial/Longitudinal) 04P046 / D21_7A27A 0.06 0.90_ 82 -48 8.16E+17 I 30.8 0 115.4 30.8 13.7 05P0l8 / D211A27A 0.09 0.90 122 -38 8.10E+17 1 45.9 0 22.9 459 53.8 624063/C228A27A. 0.03 1.00 41 -50 8.10E+:17 15.4 0 7.7 15.4_ -19.2 624039/D224A27A I 0.07 1 1.01 1 95 -36 1 8.10E+17 35.7 0 17.91 35.7 135.5 624039./D205A27A I 0.10 0.92 134 -50 J 8.10E+17 I 50.4 0 125.2 50.4 I 50.8 Lower to Lower- 49214871 /A422B27AF 0.03 0.98 41 -50 J 3.30E+17 1 9.5 0 4.8 9.5 1-31.0 Intermediate 04T931 / A423B27AG 0.03 1.00 41 -50 j 3.30E+17 9.5 0 I 4.8 9.5 1-31.0 Girth I 5P675610342-3477 0.08 0.936 153.97"21 -50 3130E+17 35.7 0 77:9 35.7 21.4 Circumferential) 3P4955 10342-3443 (S) 3P4955/0342-3443 (T) 0.027 0.921 _027*.1 37 3

-16

-20 3.30E+t7 1 8.6 0 4.3 8.6 1.2

-2.8 m For weld materials, (S) = Single Wire, (T) = Tandem Wire, (2)

The chemisiry factor for weld 5P675610342-3477 has been modified from the NRC approved (Reference 4.8-2)) chemistry factor in NEDO-3314A Section 4-2.i 1 (Reference 4.8-5U, per a Columbia specific analysis incorporating recent surveillance data from the. Integrated Surveillance. Program (ISP).

Time-Limited Aging Analyses Page 4.2-10 K4~~28

Columbia Generating Station License Renewal Application Technical Information Insert A for Page 4.2-9 Insert B for Paqe 4.2-10 N6 nozzle-to-vessel 5P6214B/0331 0.019 0.828 38.7 -56 5.OOE+17 11.3 17 5.7 35.8 -8.9 (RG 1.99 Pos 2.1) Linde 124 Qa Amendment 28 Time Limited Aging Time Limited Analysis Aging Analysis Page 4.2-1 Page 4.2-10Oa Amendment 28

4.2.6 Reactor Vessel Axial Weld Failure Probability Columbia Generating Station License Renewal Application Technical Information Replace with Insert A from page 4.2-14a.

D3ee intIntionajly lanmil Time-Limited Aging Analyses Page 4.2-14 JcAmendat ment2 28W

[Amendmrnent 28J

Columbia Generating Station License Renewal Application Technical Information h-suPage2-4-.44.

f- .

Tabk--2-8 UoSEE MriA.I-a*s 23.N6 ,..alent fo 64 EF RY Thcrc is no surveillance mnateria! Wothe N6 nozzle, and ther~efor~e no surnve!ilancedt.

Consequently Psition 1.2 of RG 1.99 will be used to project USE to 54 EFPY.

64eEFP %TFleee 4.48E+ 7!n/cm RG 199-Predictcd Decrease 9-"

Adjusted Decrease ~-N/A Sur,,ellanco-N o .zlo =*

9.6%- 23.5 % (bounding- value fno SER (fr Therefor~e, the N6 nozzle is bounded by Equivalent Margin Analysis in 13WRVIP 71-A.

The acceptance eritcrion of 23.6% was dcrivcd fromn data that ineludcd both rolled plate and nozzle forgings and is thus an appropriate eceeptanec criterion for the Columbia Surveillance-Nozzle-Data There is no surveillanee material far the N 12 nozzle, and therefore no surveillance data; Consequently Position 1.2 of RG 1.99 will be used to project USE to 51 EFPY.

Nozzle-N6 USE

%GC~ 0726 64 EFPY VT Fltietee 4.48E+ 17 nlcm 2 RG 1.99 Predicted Decroase W."

Adjusted Decrase N/A 16.3-%!5 23.5 % (bounding value fromn SER for B3WRV~IP 74 4 Therefore, noezzle N12 is bounded by Equivalent Margin Analysis in BWRVIP 74-A.

The aeceptance criterion of 23.5% was derived from data that included both relled plate and nozzle forgings and is thus an appropriate aeeptan~e cierieon orF the Columbie Time-Limited Aging Analyses Page 4.2-14a AmAndmen 12 e jAmendment 28

Columbia Generating Station License Renewal Application Technical Information Table 4.2-8 N6 nozzle-to-vessel weld USE Equivalent Margin Analysis for 54 EFPY Surveillance Weld:

Heat 5P6214B is a surveillance weld in the BWRVIP Integrated Surveillance program. All seven data points for this heat show less reduction in USE than predicted by RG 1.99, thus the RG 1.99 prediction will be used without correction.

N6 weld USE:

% Cu = 0.02 54 EFPY 1/ 4T Fluence = 5.OOE+17 RG 1.99 Predicted Decrease = 7.8%

Adjusted Decrease = N/A 7.8% < 39% (bounding value from SER for BWRVIP-74-A)

Therefore the N6 nozzle-to-vessel weld is bounded by the equivalent margin analysis in BWRVIP-74-A Time Limited Aging Analysis Page 4.2-14.b Amendment 28

A.1.3.1.1 Neutron Fluence Columbia Generating Station License Renewal Application Technical Information Beltline Evaluation For the extended operating period, ferritic materials for vessel beltline shells, welds, and assembly components are required to be evaluated for neutron irradiation embrittlement if high energy neutron fluence is greater than a threshold value of 1E+17 n/cm 2 (E >1 MeV) at the end of the 60 years. The only vessel assembly items, other than the shells and welds of the beltline region that would experience neutron fluence greater than 1E+17 n/cm 2 during the period of extended operation are instrumentation nozzle N12 (and the and residual heat removal/low pressure coolant injection (RHR/LPCI) nozzle N6 associated nozzle-to-

-lR stFumeRtatiR-Re-zle-N412-has-a-th iekRess-less-thaR-25-c-inEIhes-and-t*eFefeFe-dees-REt vessel

--- welds)

-Nozzte-N6-is-evaitated-for-ART-below--Th e-A.R-T-fe F-t1ýis-ne-zle-is-tess-thhafR-thaat-fe F-th e-

-1tighest-weld-and-plate.--6onsequently ,-rozzte-N6-is-n-ot-th-e-limiting-rraterial-for-the

-vesselt--amnd-thdus-is- not-a-bbeIti ne-eiemp oenet-Hewever--as-n z-z5le-NO-was-evaluaten-de r AR-T-it-meets-the-defi nition-of-a-belttine-comp-onent-per-l-0-e-FR-5(,_A-ppendix--G-

/

The beltline definition for the period of extended operation includes the lower shell (Course #1 / Ring #21), lower-intermediate shell (Course #2 / Ring #22), associated vertical (longitudinal) welds, the girth (circumferential) weld that connects the lower and lower-intermediate shells, and nozzle (and its associated nozzle-to-vessel Disposition weld), and nozzle N12 Neutron fluence is-tat--sids-a--tnme-iite-assumptien-uee--vaFieus- eut0811 11embrittlem eat'T-L-A.$M Replace with Insert A from page A-28a.

.1.3.1.2 Upper Shelf Energy Evaluation 10 CFR 50 Appendix G requires the upper shelf energy (USE) of the vessel beltline materials to remain above 50 ft-lb at all times during plant operation, including the effects of neutron radiation. If USE cannot be shown to remain above this limit, then an equivalent margin analysis (EMA) must be performed to show that the margins of safety against fracture are equivalent to those required by Appendix G of Section XI of the ASME Code.

The initial (unirradiated) USE is not known for all the Columbia vessel plates and welds.

For those plates and welds for which the initial USE is known, USE was projected using Regulatory Guide 1.99, Revision 2 methods. For the vessel plates and welds for which the initial USE is not known, USE equivalent margin analyses were performed using the Boiling Water Reactor Owners Group (BWROG) equivalent margin analysis (EMA) methodology. Results from the testing and analysis of surveillance materials were used in the EMA analyses.

... r----*

erplace

• end of thewith "has been projected to theF28 period of extended operation,,. _T.

Final Safety Analysis Report Supplement Page A-28 JAmendment Januad-2-n1t W

4.2.3 Adjusted Reference Columbia Generating Station Temperature Analysis License Renewal Application Technical Information Insert A for Page A-28:

Instrumentation nozzle N12 has a thickness less than 2.5 inches and was not originally evaluated for fracture toughness per ASME Code Appendix G, Section G2223. Nozzle N12 is not limiting for P-T curves as discussed in Section A.1.3.1.4; however, as nozzle N12 was evaluated for impact on the P-T curves it meets the definition of a beltline component per 10 CFR 50, Appendix G.,_

Nozzle N6 is included in the evaluation for USE in Section A.1.3.1.2. Nozzle N6 is evaluated for ART in Section A. 1.3.1.3 below. Nozzle N6 is not the limiting material for he vessel. However, as nozzle N6 was evaluated for ART it meets the definition of a eltline component per 10 CFR 50, Appendix G.

The associated nozzle- The associated nozzle-to-vessel weld is a to-vessel weld is an ferritic weld and, therefore, is subject to austenitic weld and, the fracture toughness requirements of 10 therefore, is not subject CFR 50, Appendix G. The nozzle-to-to the fracture vessel weld for nozzle N6 is also included toughness in the evaluation for USE in Section requirements of 10 A. 1.3.1.2 and is evaluated for ART in CFR 50, Appendix G. Section A.1.3.1.3.

Final Safety Analysis Report Supplement Page A-28a Amondment 12 JAmendment 28

Columbia Generating Station A.1.3.1.2 Upper Shelf Energy Evaluation I License Renewal Application Technical Information All of the prejeeted USE values for the vessel beltline plates an-d welds fO whih , the initi; ISE iac - known r.main above 50 ft lbs through the end of the pcriod of extended oporation (54 EFPY). For the vessel beltline plates and welds for whih the ,,,tal U.E A specific 54 isnut knouwni, tli* uidiiinium deurmdse in, USE was fuuid tu be leSs ihan the assumed EFPY i k..................................... -M one! QOQ Tha /

equivalent dccracscs in USE for 54 EFPY for these beltline plates and welds are b-.nded by te /

margins .ui'al'n" margin analyses. Th..cforc, the pr.j..t.d USE for the vesscl bcltlin. plates /'

analysis will a~d welda siseaceptable fer the period of extended OPOration.

be performed Aith Incrfc, wrDrt A frnm Dn in A~Q for N12 D ispositio n i,,J, . . . ... . .. . . . . .. I . . . . .

nozzle PtV vessel upper shelf energy TLAAs have been projected to the end of the period forgings prior of extended operation.

to the period A.1.3.1.3 Adjusted Reference Temperature Analysis of extend operation. All In addition to USE, the other key parameter that characterizes the fracture toughness of other reactor a material is the RTNDT. This reference temperature changes as a function of exposure to neutron radiation resulting in an adjusted reference temperature, ART.

The initial RTNDT is the reference temperature for the unirradiated material. The change due to neutron radiation is referred to as ARTNDT. The ART is calculated by adding the initial RTNDT, the ARTNDT, and a margin to account for uncertainties as prescribed in nozzle Regulatory Guide 1.99, Revision 2. 4 e forging The ART evaluations of record for the vessel beltline plates ad 4elds for the currently licensed period (33.1 EFPY) include power uprate conditions. Based on projected fluence values, the methodology in Regulatory Guide 1.99 was used to project the ART for 54 EFPY. The ART values projected to 54 EFPY are used to develop P-T limit curves. Projected ART values are well below the 200°F end of life ART suggested in Section 3 of Regulatory Guide 1.99 and are, thus, acceptable for the period of extended operation.

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

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

Final Safety Analysis Report Supplement Page A-29 FAmendment 28

Columbia Generating Station License Renewal Application Technical Information Insert A for Page A-29: , nozzle forgings, All of the projected USE values for the vessel beltline plates and welds for which the initial USE is known remain above 50 ft-lbs through tile end of the period of extende and operation (54 EFPY). For the vessel beltline plates; *elds and-nezfes for which the initial USE is not known, the maximum decrease in USE was found to be less than the assumed decrease in the associated equivalent margin analyses. The maximum and predicted decreases in USE for 54 EFPY for these beltline plates-, elds are bounded by the quivalent margin analyses. Therefore, the projected USE for the vessel beltline plates, elds and nozzles is acceptable for the period of extended operation. generic PE euriparuu en ly one IN I tiU--nzzl LU MeW equdivalen ;i;1y;;; analysis et 13"OV.rdr j

';eeauscte Cerifiedý Material Test Rcperts fer the other three N42 nozzles did not

.. ntain the analyzed .. pp.. ntt Energy Northwest agrees that the N12 instrumentation nozzles must be considered when the licensee develops pressure-temperature limits for Columbia in accordance with 10 CFR Part 50, Appendix G and the ASME Code, Section Xl, Appendix G. Columbia will continue to develop future pressure-temperature limit curves considering all beltline plates, welds, and nozzles.

There is no equivalent margin analysis available for forgings for which initial USE is not known (the N12 nozzles). Consequently, Energy Northwest will perform a specific 54 EFPY equivalent margin analysis for the N12 nozzle forgings as committed in Table A-1 of the License Renewal Application.

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Columbia Generating Station License Renewal Application Technical Information Insert A into Paae A-68b FSAR Enhancement Item Number Commitment Supplement or Location Implementation (LRA App. A) Schedule

65) ISI Columbia will prepare and submit the ISI Program Plan for the LRA Appendix Upon submittal fourth 10-year interval no later than 2015. (The third 10-year B of the ISI ISI interval extends from December 2005 until December, Program Plan 2015.) The small bore piping program will be included in the for the fourth fourth 10-year interval ISI program plan as an augmented 10-year interval inspection. The locations to be inspected, the sample size, the inspection methodology will be included in the program plan.

66) Structures Perform a one-time internal inspection of the spent fuel pool tell Prior to the period Monitoring Program tale drain lines prior to the period of extended operation to of extended confirm the drain lines are free of obstructions. Unexpected operation.

inspection result 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.

67) Structures Perform a one-time boroscope inspection of the containment Prior to.1 2/31/15 Monitoring Program 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.

Insert new row 68 from Insert new rows 69 and page A-68d 70 from page A-68d Final Safety Analysis Report Supplement Page A-68c , Amendment 22 .Amondmcnt 18

... .Am endm ent28

Columbia Generating Station License Renewal Application Technical Information Insert into page A-68c FSAR Enhancement Commitment Supplement or Item Number Location Implementation (LRA App. A) Schedule

68) Ensure that the condenstate (COND) and reactor feedwater (RFW) Prior to the period systems are screened and evaluated for cavitation prior to entering of extended the period of extended operation (PEO). If the in-scope portion of operation.

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

69) Re-evaluate the subject flaws for the period of extended operation (54 Prior to the period EFPY), in accordance with the requirements of the ASME Code, of extended Section XI, IWB-3600 based on the results of 2015 inservice operation.

inspection.

70) TLAA - Perform a 54 EFPY equivalent margin analysis for the embrittlement A. 1.3.1.2 Prior to the period Embrittlement of (upper shelf energy) of the reactor vessel N12 (instrumentation) nozzle of extended reactor vessel forgings. operation Final Safety Analysis Report Supplement Page A-68d .A.Me-M-mem--2r

Columbia Generating Station License Renewal Application Technical Information Table C-11 BWRVIP-74-A BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal Applicant Action Item Text Plant-Specific Response (9) Appendix A to the BWRVIP-74 report The Columbia pressure-temperature (P-T) indicates that a set of P-T curves should be limit curves were revised in 2005 to include developed for the heatup and cooldown the effects of power uprate and are valid for operating conditions in the plant at a given 33.1 EFPY. The P-T limits will be revised EFPY in the LR period, when necessary to comply with 10 CFR 50 Appendix G, as discussed in Section 4.2.4 of the LRA.

(10) To demonstrate that the beltline materials The beltline materials meet the meet the Charpy USE criteria in Appendix B of 16riteria in Appendix B of BWRVIP-74.

the report, the applicant shall demonstrate that Details of the Charpy upper shelf energy the percent reduction in Charpy USE for their (USE) evaluation for the reactor vessel beltline materials are less than those specified beltline materials are provided in Section for the limiting BWR3-6 plates and the non- 4.2.2 of the LRA.

Linde 80 submerged arc welds and that the percent reduction in Charpy USE for their surveillance weld and plate are less than or equal to the values projected using the methodology in RG 1.99, Revision 2.

(11) To obtain relief from the inservice (1) The Columbia circumferential welds will inspection of the circumferential welds during satisfy the limiting conditional failure the LR period, the BWRVIP report indicates frequency for circumferential welds in that each licensee will have to demonstrate that Appendix E of the staffs July 28, 1998, (1) at the end of the renewal period, the FSER. Details are presented in Section circumferential welds will satisfy the limiting 4.2.5 of the LRA.

conditional failure frequency for circumferential (2) Columbia has implemented operator*

welds in the Appendix E of the staffs July 28, training and established procedures that 1998, FSER, and (2) that they have limit the frequency of cold overpressure implemented operator training and established events. The details were presented in procedures that limit the frequency of cold Columbia's original request for relief. The overpressure events to the amount specified in NRC approval of that request (see the staffs FSER. Reference 4.8-9 in LRA Section 4.8) agreed that Columbia has implemented the necessary operator training and procedural controls.

A specific 54 EFPY equivalent margins analysis will be performed for N 12 nozzle forgings prior to the period of extend operation as discussed and

,committed in Appendix A. All other Columbia Response to BWRVIP Applicant Action Items Page C-29

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