Text

Nrg Commitment Change Report - June 2016
	ML16167A267
Person / Time
Site:	Crystal River
Issue date:	06/14/2016
From:	Hobbs T; Duke Energy Florida
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	3F0616-02
	Download: ML16167A267 (70)
	v • d • e

(_~ DUKE Crystal River Nuclear Plant

~ ENERGY.

15760 W. Power Line Street Crystal River, FL 34428 Docket 72-1 035 Docket 50*302 Operating License No. DPR*72 Ref: 10 CFR 50_9 June 14, 2016 3F0616-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - NRG Commitment Change Report - June 2016

Reference:

1. CR-3 to NRG letter, "Crystal River Unit 3 - Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor,"

dated February 20, 2013. (ADAMS Accession No. ML13056A005)

2. NRG to CR-3 letter, "Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor, dated March 13, 2013. (ADAMS Accession No. ML13058A380)

Dear Sir:

The purpose of this letter is to provide notification of inactivations or modifications to regulatory commitments contained in previously docketed correspondence from Duke Energy Florida, LLC.,

previously known as Duke Energy Florida, Inc. (DEF), to the NRG. The attached report contains the Crystal River Unit 3 (CR-3) Nuclear Operations Commitment System (NOCS) reference numbers, source of the original commitment, statement of the original commitment, statement of commitment modification, if revised, and justification for the inactivation or modification. This report is being submitted in accordance with Nuclear Energy Institute (NEI) document NEI 99-04, Revision 0, "Guidelines for Managing NRG Commitment Changes," dated July 1999.

Of the five hundred eighty five (585) CR-3 regulatory commitments that were modified or inactivated between January 5, 2014 and January 5, 2016, fifty two (52) modified or inactivated regulatory commitments meet the NEI 99-04 criteria for NRG notification. Attachment 1 contains the NRG Commitment Change Report - May 2016.

No new regulatory commitments are made in this letter.

If you have any questions regarding this submittal, please contact Mr. Phil Rose, Nuclear Regulatory Affairs, at (352) 563-4883.

~~

TerryD.~~

General Manager Decommissioning Crystal River Nuclear Plant TOH/par Attachment NRG Commitment Change Report - May 2016 xc: Regional Administrator, Region I NMSS Project Manager

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 ATTACHMENT NRC COMMITMENT CHANGE REPORT - JUNE 2016

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 1 of 68 Nuclear Operations Commitment System (NOCS) Number: 123 Source Document:

Crystal River Unit 3 (CR-3) to NRC letter, 3F00979-22, dated September 24, 1979.

Original Commitment:

All personnel involved in the shipping of radioactive waste will have as a minimum eight (8) hours of classroom training in the DOT and NRC regulatory requirements, the waste burial license requirements, and in instructions and operating procedures. Training records will be maintained.

Note: Item 5 of IE Bulletin 79-19 states the following: Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material. Maintain a record of training dates, attendees, and subject material for future inspections by NRC personnel.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to other regulations controlling the activity, and a commitment is not required where there is a regulation governing the activity.

Justification for Change:

This 1979 NOCS commitment is now redundant with existing regulatory guidance. DOT regulations listed in 49 CFR 172, Subpart H already require training for those workers who handle radioactive waste material. These training requirements are included in the fleet shipping procedure HPS-NGGC-0001: Radioactive Material Receipt and Shipping Procedure.

CR-3 is in compliance with these regulations. Worker qualifications are tracked in the qualification database. All training records are retained.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 2 of 68 Nuclear Operations Commitment System (NOCS) Number: 1030 Source Document:

CR-3 to NRC letter, 3F0280-15, dated February 15, 1980.

Original Commitment:

With regard to providing an outline of the procedure for measuring in-plant iodine level (on-the-spot vs. taking the sample to the lab), FPC commits to address measuring in-plant iodine levels in EM-208, Duties of the Radiological Emergency Team. The present plans are to replace the charcoal cartridges with silver zeolite cartridges for accident iodine collection. Note:

Both charcoal and silver zeolite cartridges are provided in emergency kits for the following reason: Charcoal cartridges are used for lower activity sampling, but as noble gas activity raises, silver zeolite cartridges are used. Silver zeolite cartridges are not routinely used because of their high cost and of the possibility of explosions under certain conditions.

Note: EM-208 has been cancelled and is now in EM-210A.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

Due to plant closure, this NOCS commitment no longer applies to CR-3 as all previous CR-3 iodine radionuclides of concern have all decayed. The noble gases of concern such as Xe-131, Xe-133, Kr-88, and other short lived noble gases, have also decayed. This commitment no longer applies to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 3 of 68 Nuclear Operations Commitment System (NOCS) Number: 1948 Source Document:

CR-3 to NRC letter, 3F0280-32, dated February 6, 1980.

Original Commitment:

FPC commits to maintaining the retraining schedule covering radioactive waste shipment.

Retraining will be accomplished every two years. The training department will schedule the retraining and will maintain retraining records.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to other regulations controlling the activity, and a commitment is not required where there is a regulation governing the activity.

Justification for Change:

Regulatory guidance in 49 CFR 172, Subpart H allows retraining every three years for non-air shipments of radioactive material. This NOCS commitment was made in 1980 to help ensure training does not expire and that an unaware radioactive material shipper does not ship material with expired qualifications. With new computer tracking of qualifications that were not in place in 1980, the chance of a non-qualified shipper with expired training performing a radioactive material shipment is remote. It is noted that now CR-3 radioactive material shippers also ship radioactive material via air using IATA (International Air Transport Association) regulations.

IATA training is required every two years as per IATA Section 1.5 requirements. It is the practice for CR-3 radioactive material shippers to take DOT and IATA requalification training together every two years.

This commitment is redundant with existing DOT regulations.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 4 of 68 Nuclear Operations Commitment System (NOCS) Number: 9656 Source Document:

NRC to CR-3 Letter (ODCM), 3N0592-04, dated May 4, 1992.

Original Commitment:

Radioactive gaseous effluent monitoring instrumentation channels shown in Table 2-3 shall be operable with the effluent release isolation alarm/trip setpoints set to ensure that the limits of specification 2.7 are not exceeded. The setpoints shall be determined in accordance with the Offsite Dose Calculation Manual (ODCM).

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was implemented to ensure CR-3 was properly monitoring gaseous waste tanks and releases. These tanks have been abandoned as part of SAFSTOR. Due to plant shutdown, CR-3 has insignificant gaseous source term activity. This commitment no longer applies to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 5 of 68 Nuclear Operations Commitment System (NOCS) Number: 9713 Source Document:

NRC to CR-3 Letter (ODCM), 3N0592-04, dated May 4, 1992.

Original Commitment:

Waste Gas System: The Waste Gas system shall be used, as required, to reduce the radioactivity of materials in gaseous waste prior to discharge, when projected monthly air doses due to releases of gaseous effluents from the site to areas at or beyond the site boundary (See Figure 5.1-3) would exceed: 1) 0.2 mrad gamma; 2) 0.4 mrad beta Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was implemented to ensure CR-3 was properly monitoring gaseous waste tanks and releases. These tanks have been abandoned as part of SAFSTOR. Due to plant shutdown, CR-3 has insignificant gaseous source term activity. This commitment no longer applies to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 6 of 68 Nuclear Operations Commitment System (NOCS) Number: 9746 Source Document:

NRC to CR-3 Letter (ODCM), 3N0592-04, dated May 4, 1992.

Original Commitment:

Dose - Noble Gases The air dose at or beyond the site boundary (See Figure 5.1-3), due to radioactive noble gases released in gaseous effluents shall be limited to:

A. During any calendar quarter: less than or equal to 5 mrad gamma and less than or equal to 10 mrad beta radiation, and; B. During any calendar year: less than or equal to 10 mrad gamma and less than or equal to 20 mrad beta radiation.

Applicability: At All Times.

A. With the calculated air dose from radioactive noble gases in gaseous effluents exceeding any of the above limits, prepare and submit to the commission, within 30 days, a special report, pursuant to Specification 2.14 which includes:

1. Identification of the cause for exceeding the limit(s);

2. Corrective action taken to reduce the release of radioactive noble gases in gaseous effluents during the remainder of the current calendar quarter and during the remainder of the current calendar year so that average dose during the calendar year is less than or equal to 10 mrad gamma and 20 mrad beta radiation.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

Due to plant shutdown, CR-3 now has an insignificant inventory of radioactive noble gases. The only noble gas left is Kr-85 which exists in very small concentrations that would not impart any measurable dose under any credible circumstance. This commitment no longer applies to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 7 of 68 Nuclear Operations Commitment System (NOCS) Number: 30101 Source Document:

CR-3 to NRC Letter, 3F1080-25, dated October 14, 1980.

Original Commitment:

If these nonradioactive systems are or become contaminated, further use of the system shall be restricted until the cause of the contamination is identified and corrected and the system has been decontaminated. Decontamination should be performed as soon as possible, however, if it is considered necessary to continue operation of the system as contaminated, an immediate safety evaluation of the operation of the system as a radioactive system must be performed in accordance with the requirements of 10 CFR 50.59. The 10 CFR 50.59 safety evaluation must consider the level of contamination (i.e., concentration and total curie inventory) and potential releases (either routine or accident) of radioactivity to the environment. The relationship of such releases to the radioactive effluent limits of 10 CFR 20 and the facility's Technical Specification and to the environmental radiation dose limits of 40 CFR 190 must also be evaluated. The record of the safety evaluation must set forth the basis and criteria on which the determination was made.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was originally made in 1980 to help to monitor contamination levels in clean systems to help ensure no unmonitored gaseous or liquid release occurs. The intent of this commitment no longer applies due to the plant closure and SAFSTOR condition. Most systems have been abandoned or are in the process of abandonment, especially non-contaminated secondary side systems. In general, plant contamination levels will continue to decrease as legacy contamination decays.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 8 of 68 Nuclear Operations Commitment System (NOCS) Number: 30102 Source Document:

CR-3 to NRC Letter, 3F1080-25, dated October 14, 1980.

Original Commitment:

If it is determined in the 10 CFR 50.59 safety evaluation that operation of the system as a radioactive system is acceptable (i.e., does not involve an un-reviewed safety question or a change to the Technical Specification), provisions must be made to comply with the requirements of 10 CFR 20.201, General Design Criterion 64 to 10 CFR 50, Appendix I to 10 CFR 50 and the facility's Technical Specifications. In specific, any potential release points must be monitored and all releases must be controlled and maintained to "As Low As Reasonably Achievable" levels as addressed in Appendix I to 10 CFR 50 and within the corresponding environmental dose limits of 40 CFR 190. However, if, in the 10 CFR 50.59 determination, it is determined that operation of the system as a radioactive system does constitute an un-reviewed safety question or does require a change to the Technical Specification, the system shall not be operated as contaminated without commission approval.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was originally made in 1980 to help monitor contamination levels in clean systems to ensure no unmonitored gaseous or liquid release occurs. The intent of this commitment no longer applies due to the plant closure and SAFSTOR condition. Most systems have been abandoned or are in the process of abandonment, especially non-contaminated secondary side systems. In general, plant contamination levels will continue to decrease as legacy contamination decays.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 9 of 68 Nuclear Operations Commitment System (NOCS) Number: 40022 Source Document:

CR-3 to NRC letter, 3F0188-21, dated January 22, 1988 Original Commitment:

FPC has in place and is maintaining programs to ensure that all components of safety related systems necessary for accomplishing required safety functions are identified and result in the establishment of a programmatic system which contains the 5 elements required in NRC Generic Letter 83-28 for equipment classification of programs.

Modify/Inactivate Commitment:

MODIFY: Remove EGR0005 as an implementing reference. Maintain MCP-0401 as an implementing reference.

Justification for Change:

The source document was to address issues related to reactor trip system reliability and general management capability. CR-3 has submitted certifications required under § 50.82(a)(1) and the subject part 50 license no longer permits operation of the reactor or emplacement or storage of fuel in the reactor vessel. As such, CR-3 is no longer subject to reactor power range trip events, LOCAs, ATWS, or HELB events. The only remaining design basis accidents in the FSAR is a fuel handling accident. CR-3 filed certifications under § 50.82(a)(1) and 10CFR50.49 no longer applies to CR-3 design. Therefore, removing EGR0005 as an implementing reference is acceptable. CR-3 no longer presents a credible threat to the health and safety of the public from an accident perspective. CR-3 has re-classified all active safety related equipment to non-safety. The remaining safety related SSCs are the structures that support the spent fuel pool maintaining inventory and fuel geometry.

The subject commitment was for the following:

In GL 83-28, the staff requested the licensees to implement long-term corrective actions in response to the Salem events. GL 83-28 included two major actions to improve the reliability of the reactor trip system: (1) install a plant modification that provided for the automatic actuation of the shunt trip attachment of the reactor trip breaker (RTB) following any automatic reactor trip signal, and (2) establish a comprehensive program of preventive maintenance and surveillance testing to ensure reliable RTB operation. In addition, items 4.2.3 and 4.2.4 of GL 83-28 requested licensees to perform life testing of RTBs and periodically to replace the breakers or components in accordance with their demonstrated life.

Based on abandonment of Reactor Protection System and no future reactor operations, this commitment is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 10 of 68 Nuclear Operations Commitment System (NOCS) Number: 40164 Source Document:

CR-3 to NRC letter, 3F0688-02, dated June 01, 1988 Original Commitment:

Long term plan for boric acid corrosion damage prevention: Post refuel VII inspection requirements, including priorities and inspection intervals, will be based upon the potential consequences of corrosion damage, past performance of components previously inspected, accessibility, and personnel safety. Design changes or operating procedure changes will be considered to minimize the need for future inspections and maintenance activities.

FPC shall maintain, in auditable form, records of the program and results obtained from implementation of the program and shall make such records available to NRC inspectors upon request Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

Generic letter 88-05 addressed the concern with small borated water leaks from the reactor coolant pressure boundary causing corrosion on susceptible materials that if left unidentified could result in potentially adverse consequences on the RC pressure boundary. Due to decommissioning, CR-3 is no longer authorized to operate the reactor or emplace or retain fuel in the reactor vessel as defined in Duke Energys letter to the NRC (3F0213-07) and NRC's response letter (3N0313-01). With this decision to decommission in place the risk of RC pressure boundary leakage is eliminated therefore this NOCS commitment is no longer applicable.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 11 of 68 Nuclear Operations Commitment System (NOCS) Number: 40220 Source Document:

CR-3 to NRC letter, 3F0189-02, dated January 04, 1989 Original Commitment:

Loss of Decay Heat removal - Response NO. 6 In accordance with approved procedures, the following pumps can be used to add inventory to the RCS:

1. The Waste Transfer Pumps supply water from the Reactor Coolant Bleed Tanks to the purification loop mentioned above, increasing RCS inventory.

2. The Boric Acid Pumps supply highly borated water from the boric acid storage tanks to the DH purification loop, increasing RCS inventory.

3. The Spent Fuel Pumps can transfer water from the Spent Fuel Cooling System to the Decay Heat Removal; System, increasing inventory.

4. The Demineralized Water Pumps can transfer water from Storage Tanks to the DH purification loop, increasing inventory.

5. The Makeup (High Pressure Injection) Pumps can inject water directly into the RCS from either the Makeup Tank or the Borated Water Storage Tank. These pumps are normally tagged out of service when the RCS is cooled down and drained.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with a response to a GL 88-17 action to provide at least two available or operable means of adding inventory to the RCS that are in addition to pumps that are a part of the normal DHR systems. CR-3 is no longer authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energys letter to the NRC (3F0213-07) and NRC response (3N0313-01). By permanently removing fuel from the reactor, Modes 1 through 6 will never be achieved and this required commitment is not applicable.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 12 of 68 Nuclear Operations Commitment System (NOCS) Number: 40356 Source Document:

CR-3 to NRC letter, 3F0888-17, dated August 29, 1988 Original Commitment:

Procedure Generation Package (PGP) for Emergency Operating Procedures (EOP)

B.1.A The plant-specific writers guide has been revised to provide additional guidance in this area (guidance for the writer on whether to include information in the body of the EOP or as an enclosure).

B.1.B The plant-specific writers guide describes the contents of the conditions section.

B.2.C The plant-specific writers guide has been revised to delete the reference to Flow Charts.

B.1.D The plant-specific writers guide has been revised to include additional guidance on the subject of place keeping.

B.1.E Appendix 4 of the writers guide has been revised to include the words -Depressurize, align, reduce, cycle, and defeat.

B.3.A The writers guide contains standards for reproduction.

B.3.B Approval, control, and revision of EOPs is contained in plant administrative instructions.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was generated from a request for additional information associated with a response to Generic Letter 82-33, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability" requires each licensee to submit to the NRC a PGP which includes:

Plant-specific technical guidelines with justification for differences from the Generic Technical Guidelines (GTG)

A writer's guide

A description of the program to be used for the validation and verification of the EOPs

A description of the training program for the upgraded EOPs

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 13 of 68 From the PGP, plant specific EOPs were developed that would provide the operator with directions to mitigate the consequences of a broad range of accidents and multiple failures.

Part of the requirements of the GL was associated with training. The EOP training program, associated with implementation, should be expanded to include sufficient detail to determine that the trainees will be capable of executing the EOPs as individuals and as teams under operational conditions. Part of this commitment stated that:

"all upgraded EOP's are included in each annual Licensed Operator requalification program. New Operators receive classroom and simulator training on all the upgraded EOP's. All EOPs are covered on a regular basis in both Licensed Operator Requalification training and in replacement operator training" IOC TRX-00-0103 documents the elimination of the training requirements from the commitment based on using the Systematic Approach to Training Process approved by the NRC (3N0488-27). Also the CR-3 Licensed Operator Training Program will be transitioned to a Certified Fuel Handler Training Program (3F0413-07).

CR-3 is not authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energy's letter to the NRC (3F0213-07) and NRC's response (3N0313-01).

CR-3 FSAR Rev. 34 eliminated all accidents that would be applicable for use with the EOPs.

CR-3 EOPs have been placed in a VOID status per RDC-0002 and will never be required to be revised. Therefore, this commitment can be inactivated because the EOP and support documentation that makeup the Plant-Specific Technical Guidelines are not applicable with the fuel removed from the reactor.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 14 of 68 Nuclear Operations Commitment System (NOCS) Number: 40415 Source Document:

CR-3 to NRC letter, 3F0489-08, dated April 17, 1989 Original Commitment:

Spent Fuel Cooling Pumps On the basis of design reviews and vendor contacts, SFP-1A and SFP-1B have been evaluated for minimum flow considerations relative to single pump and parallel pump operation.

The pump minimum flow currently recommended by the vendor, Ingersoll-Rand, for continuous operation is 750 gpm. A review of SFP-1A, 1B operating modes indicates two cases (i.e., filling and draining the fuel transfer canal) where this recommended flow may not be met. To ensure a flow rate greater than or equal to (GT/EQ) 750 gpm is maintained for these cases requires procedure changes to revise the position of certain SF system valves. These changes do not impact the safety function of the system. During parallel operation the expected flow rate is GT/EQ 750 gpm per pump. With changes to the operating procedure, a flow rate GT/EQ 750 gpm can be achieved during all modes.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with a response to a GL 88-04 to ensure the SF pump minimum flow requirements are met. CR-3 is no longer authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energys letter to the NRC (3F0213-07) and NRC response (3N0313-01). By permanently removing fuel from the reactor, Modes 1 through 6 will never be achieved. This eliminates the requirement to transfer spent fuel from the Spent Fuel Pool to the Reactor Building. Also EC 94476 installed a barrier in the RB side deep end of the refueling canal. Installing the barrier eliminates the use of the transfer tube and the requirement to fill and drain the fuel transfer canal. Also the existing low decay heat conditions for the Spent Fuel assemblies, eliminates the requirements to operate the SF pumps in parallel.

Therefore, this commitment can be inactivated.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 15 of 68 Nuclear Operations Commitment System (NOCS) Number: 40426 Source Document:

NRC to CR-3 letter, 3N0490-05, dated April 06, 1990 Original Commitment:

From SER for CR-3 Procedures Generation Package.

The Staff (NRC) requests that FPC maintain records of all revisions to the Procedure Generation Package and EOPs in an auditable form.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with the conclusion of a Safety Evaluation where the NRC stated that all revisions to the Procedure Generation Package (PGP) should be reflected in plant EOPs within a reasonable period of time. Generic Letter 82-33, "Supplement 1 to NUREG-0737 -

Requirements for Emergency Response Capability" requires each licensee to submit to the NRC a PGP which includes:

Plant-specific technical guidelines with justification for differences from the Generic Technical Guidelines (GTG)

A writer's guide

A description of the program to be used for the validation and verification of the EOPs

A description of the training program for the upgraded EOPs From the PGP, plant specific EOPs were developed that would provide the operator with directions to mitigate the consequences of a broad range of accidents and multiple failures.

CR-3 is not authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energy's letter to the NRC (3F0213-07) and NRC's response (3N0313-01).

CR-3 FSAR Rev. 34 eliminates all accidents that would be applicable for use with the EOPs.

CR-3 EOPs have been placed in a VOID status per RDC-0002 and will never be required to be revised. Therefore, this commitment can be inactivated because the EOP and support documentation that make up the Plant-Specific Technical Guidelines are not applicable with the fuel removed from the reactor.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 16 of 68 Nuclear Operations Commitment System (NOCS) Number: 40440 Source Document:

CR-3 to NRC letter, 3F0992-05, dated September 18, 1992 Original Commitment:

The MOV program manual is being revised to incorporate the latest industry information and lessons learned with respect to selecting and setting valve operator switches. Procedures will be reviewed and revised to include the revised switch settings. The MOV program will include the periodic monitoring of MOV performance and adjustment of switch settings.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These NOCS for the MOV program were created as a result of the implementation of Generic letters 89-10 and 96-05.

By letter from the NRC to Florida Power Corporation (FPC) dated March 13, 2013, Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor (ADAMS Accession No. ML13058A380), the NRC acknowledged CR-3s certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Accordingly, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Generic letter 89-10, Safety Related Motor-Operated Valve Testing and Surveillance, recommended that the licensee develop a program to ensure motor-operated valves in specified systems are selected, set, and maintained so the MOV will operate under design basis conditions.

The term safety related refers to those systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in the potential offsite exposures comparable to the guidelines of 10 CFR Part 100.

Generic Letter 96-05 requested licensee to establish a program or ensure the effectiveness of its current program to verify on a periodic basis the safety related MOVs will continue to be capable of performing their safety related functions.

Engineering Change 94154 declassified all motor operated valves to a non-safety classification.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 17 of 68 On October 30 2013, per the directions in the MOV program manual (IAW Generic Letter 96-05), a Maintenance Rule Expert Panel was convened and approved the removal of all MOV from the MOV program.

The MOV program is no longer applicable to Crystal River 3 and will be retired, as a result of the actions described above.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 18 of 68 Nuclear Operations Commitment System (NOCS) Number: 40508 Source Document:

CR-3 to NRC letter, 3F0990-10, dated September 24, 1990 Original Commitment:

FPC conducted a re-evaluation of our vendor interface program in response to concerns raised during a 1989 procurement and vendor interface inspection. FPC's Nuclear Procurement &

Storage Manual (NP&SM) addresses the quality assurance aspects of procurement and vendor services. It is coordinated with FPC's overall QA program to assure reliable equipment is provided. Our vendor interface program contains the following key elements which are consistent with the positions in Generic Letter 90-03.

1. The program with B&W covers all the safety-related components within the NSSS scope of supply. FPC receives all B&W issued information pertinent to its safety-related equipment.

The current program does not assure formal communication of revised test procedures and updated replacement parts information. The technical information program with B&W will be revised to include these items.

2. Technical information submittal agreements have been established with Colt Industries and Asea Brown Boveri to submit all pertinent information related to the diesel generators and electrical switchgear, respectively. This program includes provisions for assuring receipt of all technical information provided by these vendors.

3. FPC will identify a list of key vendors with which to maintain periodic contact.

Note: see responses to generic letter 90-03 for implementation information.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is no longer required due to the permanent defueled condition of CR-3. The requirements of Generic Letter 90-03 apply to safety related Nuclear Steam Supply Systems (NSSS) and other key safety related components as determined by the licensee. With the approval of EC 94154, the only safety related components at CR-3 are the spent fuel pool liners (including sealing devices such as FHX-31 and FHX-34), SFST-1A/1B structures, Auxiliary Building structure and the spent fuel pool storage racks (FHX-28, FHX-30). None of these components are related to NSSS. They are all structural components and there are no applicable vendor manuals associated with them. As such, Duke Energy has determined that the requirements of Generic Letter 90-03 will not be implemented for these components.

Therefore, in the absence of any safety related NSSS components and determination by Duke Energy that there are no other key safety related components to which the requirements of Generic Letter 90-03 will be applied, the requirements for vendor interface are no longer applicable. Vendor manuals and vendor information will continue to be controlled by procedure EGR0006, Vendor Manual Program, to assure vendor information received is properly reviewed and dispositioned.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 19 of 68 Nuclear Operations Commitment System (NOCS) Number: 40622 Source Document:

CR-3 to NRC letter, 3F0191-12, dated January 15, 1991 Original Commitment:

Work on all MOV valves, including RCV-14 is performed in accordance with approved plant preventative and corrective maintenance. The MOV program manual describes the functional responsibilities as they pertain to motor-operated valves. Individual procedures govern the process and perform the actual corrective and preventative maintenance tasks.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These NOCS for the MOV program were created as a result of the implementation of Generic letters 89-10 and 96-05.

By letter from the NRC to Florida Power Corporation (FPC) dated March 13, 2013, Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor (ADAMS Accession No. ML13058A380), the NRC acknowledged CR-3s certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Accordingly, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Generic letter 89-10, Safety Related Motor-Operated Valve Testing and Surveillance, recommended that the licensee develop a program to ensure motor-operated valve in specified systems are selected, set, and maintained so the MOV will operate under design basis conditions.

The term safety related refers to those systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in the potential offsite exposures comparable to the guidelines of 10 CFR Part 100.

Generic Letter 96-05 requested licensee to establish a program or ensure the effectiveness of its current program to verify on a periodic basis the safety related MOVs will continue to be capable of performing their safety related functions.

Engineering Change 94154 declassified all motor-operated valves to a non-safety classification.

On October 30 2013, per the directions in the MOV program manual (IAW Generic Letter 96-05), a Maintenance Rule Expert Panel was convened and approved the removal of all MOV from the MOV program.

The MOV program is no longer applicable to Crystal River 3 and will be retired, as a result of the actions described above.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 20 of 68 Nuclear Operations Commitment System (NOCS) Number: 40712 Source Document:

CR-3 to NRC letter, 3F0492-06, dated April 13, 1992 Original Commitment:

NRC Generic Letter 89-10 requires testing of MOVs based on the maximum design differential pressure. Design differential pressure was determined based on available design documents and administrative controls through procedures. If a procedure is changed and the use of a valve or administrative controls are revised (i.e., LO/LC removed) the NPSE MOV Engineer must be notified.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These NOCS for the MOV program were created as a result of the implementation of Generic letters 89-10 and 96-05.

By letter from the NRC to Florida Power Corporation (FPC) dated March 13, 2013, Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor (ADAMS Accession No. ML13058A380), the NRC acknowledged CR-3s certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Accordingly, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Generic letter 89-10, Safety Related Motor-Operated Valve Testing and Surveillance, recommended that the licensee develop a program to ensure motor-operated valve in specified systems are selected, set, and maintained so the MOV will operate under design basis conditions.

The term safety related refers to those systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in the potential offsite exposures comparable to the guidelines of 10 CFR Part 100.

Generic Letter 96-05 requested licensee to establish a program or ensure the effectiveness of its current program to verify on a periodic basis the safety related MOVs continue to be capable of performing their safety related functions.

Engineering Change 94154 declassified all motor-operated valves to a non-safety classification.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 21 of 68 On October 30 2013, per the directions in the MOV program manual (IAW Generic Letter 96-05), a Maintenance Rule Expert Panel was convened and approved the removal of all MOV from the MOV program.

The MOV program is no longer applicable to Crystal River 3 and will be retired, as a result of the actions described above.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 22 of 68 Nuclear Operations Commitment System (NOCS) Number: 62372 Source Document:

CR-3 to NRC letter, 3F1095-08, dated October 8, 1995 Original Commitment:

FPC has elected to utilize an optical disk imaging system for storage and retrieval of quality assurance records. This system is in addition to hardcopy storage and storage on microfilm, but will be our primary means of records storage. We have addressed each of the appropriate quality controls noted in Generic Letter 88-18 in implementing procedures.

Modify/Inactivate Commitment:

INACTIVATE: Optical disk storage of records is no longer used at CR-3.

Justification for Change:

Optical disk storage of Quality Assurance (QA) records has not been used at CR-3 since the implementation of the RMS records system. Permanent QA records are currently stored on microfilm, not optical disk. The NGG records procedure (RDC-NGGC-0001) removed the section pertaining to optical disk storage in 2006 but the NOCS commitment remained active in error in our tracking database. The CR-3 site specific procedure retained the commitment number reference, also in error.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 23 of 68 Nuclear Operations Commitment System (NOCS) Number: 62391 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

The Intake structure, intake flumes, and RW pits are inspected on a refueling cycle interval.

Time frequency of pit cleanings will be based on operational experience.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase, Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 24 of 68 Nuclear Operations Commitment System (NOCS) Number: 62932 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

The control technique implemented at CR-3 to minimize macroscopic fouling of the Service Water Heat Exchangers (SWHE) and Decay Heat Closed Cycle Heat Exchangers (DCHE) is frequent regular maintenance (FRM). The SWHEs are opened, inspected, and cleaned at a periodicity that minimizes the fouling of the heat exchanger tubesheets and tubes.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 25 of 68 Nuclear Operations Commitment System (NOCS) Number: 62393 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

The existing program monitors blockage and compares as-found data to established criteria for removing macrofouling in additional SWHEs if required.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they affect to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 26 of 68 Nuclear Operations Commitment System (NOCS) Number: 62394 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

The control technique implemented at CR-3 to minimize macrofouling of the Service Water Heat Exchangers (SWHEs) and Decay Heat Closed Cycle Heat Exchangers (DCHE) is frequent regular maintenance (FRM).

Due to infrequent operation of Raw Water (RW) in the DC systems as compared to continuous flow of RW through the SWHEs, the DCHEs are opened, inspected, and cleaned on a less frequent, but regular interval.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 27 of 68 Nuclear Operations Commitment System (NOCS) Number: 62395 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

Raw Water Pump (RWP) discharge pressure limits have been established to alert operators that excessive macrofouling of the SWHEs is occurring.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 28 of 68 Nuclear Operations Commitment System (NOCS) Number: 62396 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

Similar Pressure limits (similar to the RW Pump discharge pressure limits) will be established for the DCHEs. This action will alert operators that excessive macrofouling of the DCHEs is occurring.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 29 of 68 Nuclear Operations Commitment System (NOCS) Number: 62398 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

CR-3 has an ongoing program for RW piping liner inspection. Readily available RW spool pieces are periodically inspected when the SWHEs and DCHEs are opened for maintenance.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 30 of 68 Nuclear Operations Commitment System (NOCS) Number: 62399 Source Document:

CR-3 to NRC letter, 3F1295-11, dated December 6, 1995 Original Commitment:

Raw Water spool pieces identified with liner delaminations are periodically ultrasonically tested to verify minimum wall thickness. Various inspection methods are used to ensure liner wall thickness erosion is repaired prior to a significant impact on system flow. The following inspection methods may be used but are not limited to: visual, ultrasonic, and cameras mounted on robotic mechanisms.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These commitments are associated with Generic Letter 89-13 Service Water System Problems Affecting Safety-Related Equipment. Since CR-3 has entered its decommissioning phase Engineering Change 94154 has declassified CR-3s cooling water systems and the systems they support to non-safety. Since Generic Letter 89-13 addresses cooling water systems affecting safety related equipment it is no longer applicable to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 31 of 68 Nuclear Operations Commitment System (NOCS) Number: 62692 Source Document:

CR-3 to NRC letter, 3F0697-10, dated June 14, 1997 Original Commitment:

The use, maintenance, and testing of FWP-7 will be controlled by plant procedures that will be approved prior to CR-3 restart to ensure availability and reliability is appropriately addressed commensurate with its importance.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with maintaining FWP-7 available and reliable to mitigate consequence associated with a Small Break Loss of Coolant Accident and "A" Batteries failure.

CR-3 is no longer authorized to operate the reactor or emplace or retain fuel in the reactor vessel as defined in Duke Energy's letter to the NRC (3F0213-07). The FSAR Chapter 14 Accidents have been revised to remove all accidents except a Fuel Handling Accident (Ref FSAR Rev. 34.3). CP-500, Rev 14 removed the applicability of the NOCS requirement. REG 745926 evaluated the CP-500 Rev. 14, Special Actions and Reporting Requirements, changes and the requirement to inactivate this NOCS. With permanent removal of fuel from the Reactor Vessel, eliminating the possibility of a SBLOCA, this commitment is not applicable and can be inactivated.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 32 of 68 Nuclear Operations Commitment System (NOCS) Number: 62722 Source Document:

CR-3 to NRC letter, 3F1297-44, dated December 20, 1997 Original Commitment:

These thermocouples will be required to be operable during Modes 1 through 4, whenever the decay heat generation rate is greater than 2 Megawatts thermal. The thermocouples will be added to NOD-31, Equipment Reliability Improvement Policy, to maintain this equipment commensurate with their recognized importance to safety.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with maintaining Decay Heat (DH) Dropline and Auxiliary Pressurizer Spray (APS) line thermocouples operable during Modes 1 through 4. The thermocouples are used as an indicator of flow through the DH Dropline or the APS line, to facilitate methods of mitigating the consequences of Boron Precipitation in the Reactor Vessel during an accident. Licensing Condition 2.C.(11) identify the DH Dropline and APS line thermocouple as part of the CR-3 operating license. The proposed changes under LAR #316, removed these restrictions (Ref 3F1013-01). The DH System along with the APS portion is out of service and is in the process of being abandoned per AI-9003 process (Ref DTO AR 642168 and REG 689505). This commitment is only applicable with fuel in the Reactor Vessel and the RCS pressurized. CP-500 Rev 14 removed the applicability of the NOCS requirement. REG 745926 evaluated the CP-500 Rev. 14 changes and the requirement to inactivate this NOCS.

With permanent removal of fuel from the Reactor Vessel and Operating License changes under LAR #316, this commitment is not applicable.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 33 of 68 Nuclear Operations Commitment System (NOCS) Number: 62738 Source Document:

CR-3 to NRC letter, 3F1097-27, dated October 29, 1997 Original Commitment:

Add a discussion of the actions to be taken to handle a loss of all subcooling margin display condition to AI-505.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment was made in response to a NRC Request for Additional Information (RAI) regarding Technical Specification Change Request Notice (TSCRN) 209, Revision 1. The response to the NRC's request clarified the design of the Subcooling Margin Monitors and the Safety Parameter Display System (SPDS). CR-3 provided additional information regarding the backup method for calculating subcooling margin. CR-3 is not authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energy's letter to the NRC (3F0213-07) and NRC's response (3N0313-01). Also the RCS System is out of service and is in the process of being abandoned under the AI-9003 process (Ref DTO AR: 647240). Therefore, the use of the Subcooling Margin Monitors will never be required.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 34 of 68 Nuclear Operations Commitment System (NOCS) Number: 62751 Source Document:

NRC to CR-3 letter, 3N0198-20, dated January 20, 1998 Original Commitment:

A system of thermocouples added to the Decay Heat (DH) drop and Auxiliary Pressurizer Spray (APS) lines, capable of detecting flow initiation, shall be operable for Modes 4 through 1.

Channel checks of the thermocouples shall be performed on a monthly basis to demonstrate operability. If either the DH or APS system thermocouples become inoperable, operability shall be restored within 30 days or the NRC shall be informed, in a special report within the following fourteen (14) days, of the inoperability and the plans to restore operability.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with maintaining Decay Heat (DH) dropline and Auxiliary Pressurizer Spray (APS) line thermocouple operable during Modes 1 through 4 to meet Operating Licensing Condition 2.C. (11). The thermocouple is an indication of flow through the DH dropline or APS line, to facilitate methods of mitigating the consequences of Boron Precipitation in the Reactor Vessel during an accident. Licensing Condition 2.C.(11) identifies the DH dropline and APS line thermocouple as part of CR-3 operating license. The proposed changes under LAR #316, will remove these restrictions (Ref 3F1013-01). The DH System along with the APS portion is out of service and is in the process of being abandoned per AI-9003 process (Ref DTO AR 642168 and REG 689505). This commitment is only applicable with fuel in the Reactor Vessel and the RCS pressurized. CP-500 Rev 14 will remove the applicability of the NOCS requirement. REG 745926 evaluated the CP-500 Rev. 14 changes and the requirement to inactivate this NOCS. With permanent removal of fuel from the Reactor Vessel and Operating License changes under LAR #316, this commitment is not applicable.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 35 of 68 Nuclear Operations Commitment System (NOCS) Number: 62802 Source Document:

CR-3 to NRC letter, 3F0998-09, dated September 10, 1998 Original Commitment:

Procedure OP-406 will be revised to require SFV-83 and SFV-84 be closed and locked before the fuel transfer covers are removed. Valves SFV-180 and SFV-181 will be required to be closed and locked before the 30 inch gate valves are opened.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

This commitment is associated with additional information supplied to assist the NRC in its safety enhancement backfit analyses for the CR-3 Spent Fuel Pools as discussed in 3N0996-14. CR-3 is no longer authorized to operate the reactor or place or retain fuel in the reactor vessel as defined in Duke Energys letter to the NRC (3F0213-07) and NRC response (3N0313-01). By permanently removing fuel from the reactor, Modes 1 through 6 will never be achieved. This eliminates the requirement to transfer spent fuel from the Spent Fuel Pool to the Reactor Building. Also, EC 94476 installed a barrier in the RB side deep end of the refueling canal. The EC also states that typically, with water in the deep end, isolation valves SFV-83 and SFV-84 are closed on the 4 drain line and the blind flange is installed on the 6 drain line.

The valves and blind flange function as a barrier to contain water in the deep end during refueling activities. The drain lines will be covered to minimize the possibility of clogging those lines. Installing the barrier eliminates the use of the transfer tubes and the requirement to manipulate the referenced valves.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 36 of 68 Nuclear Operations Commitment System (NOCS) Number: 100242 Source Document:

CR-3 to NRC letter, 3F1297-24, dated December 16, 1997 Original Commitment:

Upon completion of the outlier resolution, there will be no adjacent cabinets that are not bolted or otherwise attached together.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

By letter dated March 13, 2013, the NRC acknowledged CR-3 certification of permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

Therefore, pursuant to 10CFR50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Additionally, the requirements of the commitment for GL 87-02 supplemental response to USI A-46 apply to safety related NSSS safe shutdown components. Appendix R and Safe Shutdown requirements no longer apply to CR-3.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 37 of 68 Nuclear Operations Commitment System (NOCS) Number: 100266 Source Document:

CR-3 to NRC letter, 3F1200-03, dated December 21, 2000 Original Commitment:

FPC will revise MOV program documentation to reflect its participation as a member of the joint owners group (JOG) on motor-operated valve (MOV) periodic verification.

Modify/Inactivate Commitment:

INACTIVATE: This commitment is no longer required due to the permanent defueled condition of CR-3.

Justification for Change:

These NOCS for the MOV program were created as a result of the implementation of Generic Letters 89-10 and 96-05.

By letter from the NRC to Florida Power Corporation (FPC) dated March 13, 2013, Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor (ADAMS Accession No. ML13058A380), the NRC acknowledged CR-3s certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Accordingly, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

Generic letter 89-10, Safety Related Motor-Operated Valve Testing and Surveillance, recommended that the licensee develop a program to ensure motor-operated valves in specified systems are selected, set, and maintained so the MOV will operate under design basis conditions.

The term safety related refers to those systems and components that are relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, and the capability to prevent or mitigate the consequences of accidents that could result in the potential offsite exposures comparable to the guidelines of 10 CFR Part 100.

Generic Letter 96-05 requested licensee to establish a program or ensure the effectiveness of its current program to verify on a periodic basis the safety related MOVs will continue to be capable of performing their safety related functions.

Engineering Change 94154 declassified all motor operated valves to a non-safety classification.

On October 30 2013, per the directions in the MOV program manual (IAW Generic Letter 96-05), a Maintenance Rule Expert Panel was convened and approved the removal of all MOVs from the MOV program.

The MOV program is no longer applicable to Crystal River 3 and will be retired, as a result of the actions described above.

U. S. Nuclear Regulatory Commission Attachment 3F0616-02 Page 38 of 68 Nuclear Operations Commitment System (NOCS) Number: 100268 Source Document:

CR-3 to NRC letter, 3F1200-03, dated December 21, 2000 Original Commitment:

FPC will revise MOV program documentation to reflect that the CR-3 MOV program satisfies the three phases described in topical report MPR-1807.