ML082730958
| ML082730958 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  (DPR-072) |
| Issue date: | 10/03/2008 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Young D Florida Power Corp |
| Saba F, NRR/DORL/LPL2-2, 301-415-1447 | |
| References | |
| RIS-00-017, TAC MD9222 | |
| Download: ML082730958 (29) | |
See also: RIS 2000-17
Text
October 3, 2008
Mr. Dale E. Young, Vice President
Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs
15760 W. Power Line Street
Crystal River, Florida 34428-6708
SUBJECT
CRYSTAL RIVER NUCLEAR PLANT, UNIT3 - AUDIT OF THE LICENSEE=S
MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD9222)
Dear Mr. Young:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power
Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory
Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document
NEI 99-04, Aguidelines for Managing NRC Commitment Changes,@ contains acceptable
guidance for controlling regulatory commitments and encouraged licensees to use the NEI
guidance or similar administrative controls to ensure that regulatory commitments are
implemented and that changes to the regulatory commitments are evaluated and, when
appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of
licensees commitment management programs once every 3 years to determine whether the
licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory
commitments are being effectively implemented.
An audit of Florida Power Corporation=s commitment management program was performed at
the plant site during the period of August 6 and 7, 2008. Based on the audit, the NRC staff
concluded that (1) Crystal River Nuclear Plant, Unit 3 (CR-3) has implemented NRC
commitments on a timely basis, and (2) CR-3 has implemented an effective program for
managing NRC commitment changes. Details of the audit are set forth in the enclosed audit
report.
Sincerely,
/RA/
Farideh E. Saba, Senior Project Manager
Plant Licensing Branch II-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-302
Enclosure: Audit Report
cc w/encl: See next page
October 3, 2008
Mr. Dale E. Young, Vice President
Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs
15760 W. Power Line Street
Crystal River, Florida 34428-6708
SUBJECT
CRYSTAL RIVER NUCLEAR PLANT, UNIT3 - AUDIT OF THE LICENSEE=S
MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD9222)
Dear Mr. Young:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power
Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory
Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document
NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable
guidance for controlling regulatory commitments and encouraged licensees to use the NEI
guidance or similar administrative controls to ensure that regulatory commitments are
implemented and that changes to the regulatory commitments are evaluated and, when
appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of
licensees commitment management programs once every 3 years to determine whether the
licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory
commitments are being effectively implemented.
An audit of Florida Power Corporation=s commitment management program was performed at
the plant site during the period of August 6 and 7, 2008. Based on the audit, the NRC staff
concluded that (1) Crystal River Nuclear Plant, Unit 3 (CR-3) has implemented NRC
commitments on a timely basis, and (2) CR-3 has implemented an effective program for
managing NRC commitment changes. Details of the audit are set forth in the enclosed audit
report.
Sincerely,
/RA/
Farideh E. Saba, Senior Project Manager
Plant Licensing Branch II-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-302
Enclosure: Audit Report
cc w/encl: See next page
DISTRIBUTION:
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ACCESSION No.: ML082730958
NRR-106
OFFICE
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LPL2-2\\BC
NAME
FSaba
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DATE
10/3/08
10/3/08
10/3/08
OFFICIAL RECORD COPY
Florida Power Corporation
Crystal River Nuclear Plant, Unit 3
cc:
Mr. R. Alexander Glenn
Associate General Counsel (MAC-BT15A)
Florida Power Corporation
P.O. Box 14042
St. Petersburg, Florida 33733-4042
Mr. James W. Holt
Plant General Manager
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Mr. Jim Mallay
Framatome ANP
1911 North Ft. Myer Drive, Suite 705
Rosslyn, Virginia 22209
Mr. William A. Passetti, Chief
Department of Health
Bureau of Radiation Control
2020 Capital Circle, SE, Bin #C21
Tallahassee, Florida 32399-1741
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee, Florida 32304
Mr. Craig Fugate, Director
Division of Emergency Preparedness
Department of Community Affairs
2740 Centerview Drive
Tallahassee, Florida 32399-2100
Chairman
Board of County Commissioners
Citrus County
110 North Apopka Avenue
Inverness, Florida 34450-4245
Mr. Stephen J. Cahill
Engineering Manager
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Mr. Daniel R. Westcott
Supervisor, Licensing & Regulatory
Programs
Crystal River Nuclear Plant
15760 W. Power Line Street
Crystal River, FL 34428-6708
Mr. Jon A. Franke
Director Site Operations
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Senior Resident Inspector
Crystal River Unit 3
U.S. Nuclear Regulatory Commission
6745 N. Tallahassee Road
Crystal River, Florida 34428
Ms. Phyllis Dixon
Manager, Nuclear Assessment
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Mr. David T. Conley
Associate General Counsel II - Legal Dept.
Progress Energy Service Company, LLC
Post Office Box 1551
Raleigh, North Carolina 27602-1551
Mr. Daniel L. Roderick
Vice President, Nuclear Projects &
Construction
Crystal River Nuclear Plant (SA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Mr. David Varner
Manager, Support Services - Nuclear
Crystal River Nuclear Plant (SA2C)
15760 W. Power Line Street
Crystal River, Florida 34428-6708
Mr. Robert J. Duncan II
Vice President, Nuclear Operations
Progress Energy
Post Office Box 1551
Raleigh, North Carolina 27602-1551
Mr. Brian C. McCabe
Manager, Nuclear Regulatory Affairs
Progress Energy
Post Office Box 1551
Raleigh, North Carolina 27602-1551
Enclosure
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION
LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS
CRYSTAL RIVER NUCLEAR PLANT, UNIT 3
DOCKET NOS. 50-302
1.0
INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power
Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory
Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document
NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable
guidance for controlling regulatory commitments and encouraged licensees to use the NEI
guidance or similar administrative controls to ensure that regulatory commitments are
implemented and that changes to the regulatory commitments are evaluated and, when
appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of
licensees commitment management programs once every 3 years to determine whether the
licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory
commitments are being effectively implemented.
The document, NEI-99-04, defines a Aregulatory commitment@ as an explicit statement to take a
specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to
the NRC. NRR guidelines direct the NRR Project Manager to audit the licensees commitment
management program by assessing the adequacy of the licensees implementation of a sample
of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,
etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0
AUDIT PROCEDURE AND RESULTS
An audit of the Crystal River Nuclear Plant, Unit 3 (CR-3) commitment management program
was performed at the plant site during the period of August 6 and 7, 2008. This was the first
audit recorded; the audit reviewed commitments made since 2003. The audit consisted of two
major parts: (1) verification of the licensees implementation of NRC commitments that have
been completed, and (2) verification of the licensees program for managing changes to NRC
commitments.
2.1
Verification of Licensee=s Implementation of NRC Commitments
The primary focus of this part of the audit is to confirm that the licensee has implemented
commitments made to the NRC as part of past licensing actions/activities. For commitments not
- 2 -
yet implemented, the NRC staff determines whether they have been captured in an effective
program for future implementation.
2.1.1 Audit Scope
The audit addressed a sample of commitments made during the review period. The audit
focused on regulatory commitments (as defined above) made in writing to the NRC as a result
of past licensing actions (amendments, exemptions, etc.), or licensing activities (bulletins,
generic letters, etc.). Before the audit, the NRC staff searched the Agencywide Documents
Access and Management System for the licensees submittals the last 5 years and selected a
representative sample for verification. The licensee was also asked to provide a list of
regulatory commitments related to licensing actions from its commitment management system.
The licensee provided the list and the documentation to support the NRC staffs audit. The
licensees documentation included summary sheets providing the status of the commitment and
appropriate backup documentation, as needed.
The audit excluded the following types of commitments that are internal to licensee processes:
(1)
Commitments made on the licensees own initiative among internal organizational
components.
(2)
Commitments that pertain to milestones of licensing actions/activities (e.g., respond to
an NRC request for additional information by a certain date). Fulfillment of these
commitments was indicated by the fact that the subject licensing action/activity was
completed.
(3)
Commitments made as an internal reminder to take actions to comply with existing
regulatory requirements such as regulations, technical specifications (TSs), and updated
final safety analysis reports. Fulfillment of these commitments was indicated by the
licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results
The licensees commitment management program is described in the Progress Energy
Corporation (PEC), Nuclear Generation Group, Standard Procedure REG-NGGC-0110,
Revision 2, Regulatory Commitments. The PEC procedure is applicable to regulatory
commitments made or modified after the effective date of this procedure.
The NRC staff reviewed the licensees procedure REG-NGGC-0110 and found that it includes
the following statements, which provide guidance to the licensee that is consistent with the
intent of NEI 99-04, and ensure that CR-3 is appropriately implementing regulatory
commitments:
In the case where a third party (e.g., NEI, an owners group, or another
organization) has been authorized to make Regulatory Commitments on behalf
of the Licensee, the affected Licensee shall ensure that statements represented
as Regulatory Commitments are appropriately documented and are
subsequently managed in accordance with REG-NGGC-0110.
- 3 -
Docketed correspondence containing action items shall also contain an explicit
statement concerning the existence of any Regulatory Commitment.
Each Regulatory Commitment shall be captured in a PassPort© Action
Request (AR).
The Responsible Licensing Supervisor, or designee, shall ensure the accuracy of
any implicit or explicit re-statement of a Regulatory Commitment in docketed
correspondence received from the NRC to ensure that written or oral
communication has not been misconstrued.
Except for discretionary enforcement situations, advise the NRC that an oral
statement to take a certain action represents an intent to make a Regulatory
Commitment but does not constitute a Regulatory Commitment until submitted by
the Licensee in writing on the docket.
An Assignment associated with a Regulatory Commitment must include
appropriate reference to implementing documentation to provide traceability for
The Responsible Licensing Supervisor, or designee, shall consider the need to
incorporate the Regulatory Commitment into an NRC mandated licensing basis
document such as the UFSAR [Updated Final Safety Analysis Report], Quality
Assurance Program, Emergency Plan, Security Plan, Fire Protection
Program, etc.
If a Regulatory Commitment is not implemented as described by the due date or
if non-compliance with Regulatory Commitment occurs, the Responsible
Licensing Supervisor, or designee, shall initiate a Nuclear Condition Report
[NCR], and, if necessary, notify the NRC.
Interviews with the CR-3 personnel provided the information on the existing mechanism for
tracking and managing regulatory commitments. At present, the licensee enters commitments
made to the NRC into a commitment database called PassPort©. The PassPort© database
handles the commitments that are open or active. This database is used to track all
commitments, including commitments to state and other agencies, and also tracks other plant
activities. Each regulatory commitment should be captured in a PassPort© AR, a Nuclear Task
Management (NTM) should be initiated, and appropriate actions to implement regulatory
commitments should be captured in a PassPort© Action Tracking Assignment. The Assignment
type is usually entered as COMM, which indicates that this action is a commitment. Also,
entered are the due date and the responsible individual for meeting the commitment.
In addition, CP-252, Commitment Management, Revision 6, which is a site-specific procedure,
is being utilized at the CR-3 site. The procedure defines a process for identifying, managing
and changing ongoing regulatory commitments. An ongoing commitment is a commitment
requiring ongoing and continuous implementation, whereas a one-time commitment is a
commitment that is to be completed once by a specific date, event, or milestone and has no
- 4 -
future or ongoing action. This procedure also defines the process for creating, maintaining, and
changing active nuclear operations commitment system (NOCS) database entries for the
ongoing regulatory commitments. A computer report from the NOCS database
cross-references commitments to CR-3 implementation.
The NRC staff reviewed documentation generated by the licensee related to the sample items
listed in the attached table that are identified as regulatory commitments in response to different
categories of documents, in order to assess the implementation of the regulatory commitment,
including the completion status. For the sample of commitments selected for the audit, the NRC
staff found that the licensee had adequately captured all of the regulatory commitments in their
PassPort© system, which is a data management and tracking tool. For the on the ongoing
commitments, the NRC staff verified that they have been correctly entered into the NOCS
database, which is a commitment management tool. The review of the sample commitments in
the above database reflected their status consistent with the commitment program. The
attached Audit Summary table provides details of the audit and its results.
2.2
Verification of the Licensees Program for Managing NRC Commitment Changes
The primary focus of this part of the audit is to verify that the licensee has established
administrative controls for modifying or deleting commitments made to the NRC. The NRC staff
compared the licensees process for controlling regulatory commitments to the guidelines in
NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for
managing and changing commitments. The process used at CR-3 is contained in standard
procedure REG-NGGC-0110. This procedure supplemented the CR-3 commitment
management procedure CP-252 for managing ongoing regulatory commitments. The audit
reviewed a sample of commitment changes that included changes that were or will be reported
to the NRC, and changes that were not or will not be reported to the NRC. The audit also
verified that the licensees commitment management system includes a mechanism to ensure
traceability of commitments following initial implementation. This ensures that licensee
personnel are able to recognize that future proposed changes to the affected design features or
operating practices require evaluation in accordance with the commitment change control
process.
2.2.1 Audit Results
The NRC staff reviewed the licensees procedure REG-NGGC-0110 against NEI 99-04. The
REG-NGGC-0110 includes the following statements, which provide guidance to the licensee
that is consistent with the intent of NEI 99-04, and ensure that CR-3 is appropriately
implementing regulatory commitment changes, as well as tracking changes to the commitments:
Once made, Regulatory Commitments shall be considered non-discretionary and
shall be changed only as described in REG-NGGC-0110.
Appropriate actions to implement Regulatory Commitments shall be captured in a
PassPort© Action Tracking Assignment.
- 5 -
Once accepted, any action inherent to the successful implementation of a
Regulatory Commitment shall be considered non-discretionary and shall only be
changed as described in REG-NGGC-0110.
If it becomes apparent that an Assignment cannot be implemented as described
by the due date, the responsible individual/group shall promptly contact the
Responsible Licensing Supervisor, or designee, with a proposed revision.
When notified of the need to change a Regulatory Commitment, the Responsible
Licensing Supervisor, or designee, shall ensure an Assignment is initiated to the
individual/group that includes a Regulatory Commitment Change Evaluation.
The Responsible Licensing Supervisor, or designee, shall review the Regulatory
Commitment Change Evaluation, including any necessary supporting
documents, and verify the actions that need to be taken based on the results.
As appropriate, the Responsible Licensing Supervisor, or designee, shall record
the basis for authorizing or not authorizing the change, as well as submit
docketed correspondence and capture the revised Regulatory Commitment.
The Responsible Licensing Supervisor, or designee, may also authorize revision
of the scope or committed date for a Regulatory Commitment based on related
correspondence submitted to the NRC.
It may be appropriate to track the reporting of the Regulatory Commitment
change(s) consistent with the frequency of the next UFSAR update or biennially.
The Responsible Licensing Supervisor, or designee, shall ensure that any
revised Regulatory Commitment, that satisfies the criteria for reportability to the
NRC in the Regulatory Commitment Change Evaluation, is included on a
summary report of Regulatory Commitment changes which is submitted on a
frequency consistent with 10 CFR 50.71(e) UFSAR updates or biennially.
When making changes to procedures or other documents used to implement a
Regulatory Commitment, the responsible organization ensures that the changes
do not invalidate compliance with the applicable Regulatory Commitment.
When canceling procedures or other documents used to implement a Regulatory
Commitment, the responsible organization ensures that the Regulatory
Commitment is still being met and is properly referenced in another appropriate
document to ensure continued implementation of the Regulatory Commitment.
If the Regulatory Commitment is no longer needed and a change is warranted,
the responsible organization may request a change per the guidance in
REG-NGGC-0110.
- 6 -
The NRC staff found that REG-NGGC-0110 adequately conforms to the guidance and intent of
NEI 99-04 for commitment tracking, the commitment change process, traceability of
commitments, and reporting requirements. Regulatory commitment changes are processed and
tracked by the Responsible Licensing Supervisor, or designee. The evaluation of any
commitment changes is to be done by filling the Regulatory Commitment Change Evaluation
form in Attachment 3 of the procedure. The NRC staff reviewed this form and found it
consistent with the Commitment Evaluation form in NEI 99-04 with minor differences.
During the audit, the NRC staff reviewed the licensees letter dated May 28, 2008, that includes
a summary of the CR-3 regulatory commitment changes for the period of November 9, 2005 to
November 23, 2007. This regulatory commitment change indicates that of the 27 CR-3
regulatory commitments that were modified or inactivated, only two meet the NEI 99-04 criteria
for NRC notification. During the audit, the NRC staff reviewed the Regulatory Commitment
Change Evaluation forms that were filled for the two changes that were reported to the NRC and
a sample of those that did not meet NEI 99-04 criteria. These changes were captured in the
NOCS database and provided in a computer review package, a computer report from the NOCS
database that is maintained by the lead licensing engineer. No deficiencies were identified
during this review.
Discussions with CR-3 staff confirmed that REG-NGGC-0110 is being implemented in its
entirety at the plant, which further supports the NRC staffs conclusion that regulatory
commitments are being handled in accordance with the guidance contained in NEI 99-04. In
addition, the NRC staff reviewed documentation from the licensee related to the sample items
discussed above that involved changes to commitments. The NRC staff found that the licensee
properly addressed each regulatory commitment change selected for this audit and has
implemented an effective program to manage commitment changes.
2.3
Audit Observations and Suggestions
During the audit the NRC staff noticed that:
(1)
PassPort© database is used for all plant activities. Unless other information (such as
action request number) is available, PassPort© is not a friendly tool for identifying
regulatory commitments to the NRC by using a search query.
(2)
In preparation for the audit, the PEC lead licensing engineer requested that a
business objects report be run on PassPort© to identify all assignments (NTM or
NCR) that had their assignment attribute for COMMITTED and marked YES. This
report revealed inappropriate/inconsistent use of the COMMITTED attribute. It
appears that the licensing engineers were marking assignments as COMMITTED
when they were not associated with a regulatory commitment (e.g., submitting
letters).
(3)
No AR was assigned to the regulatory commitments prior to the use of the PassPort©
database. The responsible licensing engineer initiated an AR number if the
commitment required a change or an update in its status (not a regulatory
commitment change).
- 7 -
(4)
Wording in the Regulatory Commitment Change Evaluation form, Attachment 3 of
REG-NGGC-0110, is not identical to the Commitment Evaluation Form in
NEI 99-04 guidance. However, the intent of REG-NGGS-0110 is consistent with the
NEI 99-04 guidance.
(5)
During the audit, examples were identified where forms used to modify/inactivate a
regulatory commitment in NOCS could have been completed in a more rigorous
manner. Additional detail and more thorough explanation for the questions asked
could have expedited understanding of the modification/inactivation bases.
(6)
Although not directly related to the regulatory commitment audit objective, during the
audit the NRC staff pointed out that the licensees letter dated June 5, 2008,
contained the following regulatory commitment: CR-3 will perform a VT-3
examination of the reactor vessel support skirt weld, to the extent practical, when
maintenance or other activities remove the insulation covering the support skirt
weld. The due date specified was 09/30/2008. As a result, the licensee revised this
commitment to clarify that the procedure for performing VT-3 examination will be
updated prior to 09/30/2008.
(7)
Review of the regulatory commitment changes that were not reported to the NRC
shows that some of these commitments (usually, old commitments) should not have
been identified as regulatory commitments because they were either codified
requirements, commitments not related to the NRC, or simply updated submittal
schedules.
During the audit, the NRC staff and the CR-3 licensing engineer discussed ways to improve
efficiency and traceability of the regulatory commitments in PassPort© and NOCS database and
the following items were suggested:
(1)
processing of Commitment Identification Forms and creation of NTM assignments to
ensure that ongoing regulatory commitments are captured in the NOCS upon
completion,
(2)
regulatory commitment development and wording,
(3)
correct usage of the committed attribute in NTM/NCR assignments, and
(4)
expectations for rigor to be applied when implementing the REG-NGGC-0110
process for modifying/inactivating a regulatory commitment in NOCS.
3.0
CONCLUSION
The NRC staff concludes that based on the above audit: (1) CR-3 has implemented NRC
commitments on a timely basis, and (2) CR-3 has implemented an effective program for
managing NRC commitment changes.
- 8 -
4.0
LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
Dennis Herrin
Lead Engineer- Licensing and Regulatory Programs
Dan Westcott
Supervisor - Licensing and Regulatory Programs
Principal Contributor: Farideh E. Saba
Attachment: Audit Summary
Attachment
AUDIT SUMMARY
IMPLEMENTATION OF COMMITMENTS:
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
1
License
Amendment
Request
239412
June 19, 2008
The Control Complex
Habitability Envelope Integrity
Program will be used to verify
the integrity of the Control
Complex boundary. Conditions
that are identified to be adverse
shall be trended and used as
part of the 24-month
assessment of the CCHE
boundary.
60 days after implementation of
this amendment
Active in CR-3
until 9/12/08,
however, it is
withdrawn by
letter dated June
29, 2008
2
Relief Request
281127-01
June 5, 2008
CR-3 will perform a VT-3
examination of the reactor
vessel support skirt weld, to the
extent practical, when
maintenance or other activities
remove the insulation covering
the support skirt weld.
09/30/2008
The regulatory
commitment
should be revised.
3
263132
May 8, 2008
Complete the detailed
walkdowns and ultrasonic
examinations of inaccessible
piping at locations potentially
susceptible to gas
accumulation for systems within
the scope of the GL prior to
startup from the next refueling
outage.
Currently scheduled for
12/19/2009
In progress
- 2 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
4
May 8, 2008
Submit supplemental response
to the NRC within 90 days
following completion of
Refueling Outage R16, which
will describe any changes to
the nine-month GL 2008-01
response resulting from
walkdowns and ultrasonic
examination of inaccessible
piping.
90 days following completion of
Refueling Outage R16
In progress
5
License
Amendment
Request
- 228243-
01
NOCS
- 100507
February 25,
2008
CR-3 will perform procedure
CP-253, "Power Operation Risk
Assessment and Management,"
which requires both
deterministic and probabilistic
evaluation of risk for the
performance of all maintenance
activities. This procedure uses
the Level 1 PSA model to
evaluate the impact of
maintenance activities on core
damage frequency. CR-3 will
not plan any maintenance that
results in "Higher Risk" (Orange
Color Code) during an
extended outage (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) of the LPI, BS, DC or
RW-DC System.
During extended (greater than
a 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the LPI,
BS, DC or RW-DC System
Revised AI-500
6/6/08
6
License
Amendment
Request
- 228243-
02
NOCS
- 100508
February 25,
2008
The Remote Shutdown Panel,
the Appendix R Cooler and the
opposite train of LPI, BS, DC,
RW-DC, EFW, Auxiliary
Feedwater System, Emergency
Feedwater Initiation and
During extended (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the LPI,
BS, DC or RW-DC System
Revised AI-500
6/6/08
- 3 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
Control System, HPI, and their
will be administratively
designated as "protected" (i.e.,
no planned maintenance or
discretionary equipment
manipulation).
7
License
Amendment
Request
- 228243-
03
NOCS
- 100508
February 25,
2008
CR-3 will not initiate an
extended preventive
maintenance outage (greater
than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) on the LPI, BS,
DC or RW-DC System if
adverse weather, as
designated by Emergency
Preparedness procedures, is
anticipated.
During extended (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the LPI,
BS, DC or RW-DC System
Revised AI-500
6/6/08
8
License
Amendment
Request
- 228243-
04
NOCS
- 100508
February 25,
2008
When extended maintenance
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is
performed (scheduled or
emergent) on a train of the LPI
or BS System, CR-3 will limit
transient combustibles in, and
establish a periodic fire watch
in- the decay heat pump vault
of the opposite train, and the
following rooms:
" Non-safety 4160V and 480V
Switchgear Rooms
" Opposite train ES 4160V and
ES 480V Switchgear Rooms
- Opposite train battery room
" Opposite train charger room
- Opposite train Inverters room
- Remote Shutdown Panel
During extended (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the LPI or
BS System
Revised AI-500
6/6/08
- 4 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
Room
- Relay/CRD Room and
Adjoining Corridor " 'B' EFIC
Room
- Cable Spreading Room
9
License
Amendment
Request
- 228243-
05
NOCS
- 100508
February 25,
2008
When extended maintenance
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is
performed (scheduled or
emergent) on a train of the DC
or
RW-DC System, CR-3 will limit
transient combustibles in, and
establish a periodic fire watch
in the seawater room, and the
following rooms:
" Non-safety 4160V and 480V
Switchgear Rooms
- Opposite train 4160V ES and
480V ES Switchgear
Rooms
" Opposite train battery room
- Opposite train charger room
- Opposite train Inverters room
- Remote Shutdown Panel
Room
" Relay/CRD Room and
Adjoining Corridor
" 'B' EFIC Room
" Cable Spreading Room
During extended (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the DC or
RW-DC System
Revised AI-500
6/6/08
10
License
Amendment
Request
- 228243-
16
NOCS
- 100508
February 25,
2008
When extended maintenance
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is
performed (scheduled or
emergent) on a train of the LPI,
BS, DC or RW-DC System,
During extended (greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) outage on the LPI,
BS, DC or RW-DC System
Revised AI-500
6/6/08
- 5 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
CR-3 will limit transient
combustibles and establish a
periodic fire watch in the fire
zones containing routed cables
associated with the pressurizer
Valves. These rooms include: "
PORV/PORV Block Valve
power supply breaker areas
- Cable Spreading Room
- Relay/CRD Room and
Adjoining Corridor "
Intermediate Building 119'
elevation
- Auxiliary Building 119'
elevation
- 'B' ES 4160V Switchgear
Room " Remote Shutdown
Room " 'A'/'B' Battery room
- 6 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
11
License
Amendment
Request
- 228243-
17
NOCS
- 100508
February 25,
2008
There shall be administrative
controls to limit the maximum
time allowed for any
combination of Conditions that
result in a single contiguous
occurrence of failing to meet
the LCO for ITS 3.6.6, Reactor
Building Spray and
Containment Cooling Systems,
ITS 3.7.5, Emergency
3.8.1, AC Sources - Operating,
and ITS 3.8.9, Distribution
Systems - Operating. These
administrative controls shall
ensure that the Completion
Times for those Conditions are
not inappropriately extended.
The administrative controls will
ensure that Completion Time is
NOT extended beyond the
additive Completion Times of
the two Required Actions for
restoration of OPERABILITY
unless a risk evaluation is
performed. If unit operation
within an LCO will exceed the
maximum Completion Time,
then either the shutdown
Condition within the LCO
should be entered OR a risk
evaluation shall be performed
and the risk impact managed
under CP-253, "Power
Operation Risk Assessment
and Management."
This will be implemented in
conjunction with the license
amendment.
Revised AI-500
6/6/08
- 7 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
12
Relief Request
- 246227-
02
September 13,
2007
After completion of the
ultrasonic examination of the
weld overlays performed in R15
submit to the NRC the
ultrasonic examination results
of the weld overlays and a
discussion of any repairs to the
overlay material and/or
base metal and reason for the
repair.
60 days after completion of the
ultrasonic examination of the
weld overlays performed in
Refueling Outage 15,
scheduled for Fall 2007
Completed on -
1/23/08 see letter
13
Relief Request
- 246227-
04 and 09
September 13,
2007
NRC will be notified as soon as
practical if any cracks are
detected that exceed the
preservice examination
acceptance standards in ASME
Code Section XI Table
Prior to Mode 4 of restart from
Refueling Outage 15,
scheduled for Fall 2007, if
necessary
Completed on -
11/29/07 see
letter 3F1107-02
14
Relief Request
- 246227-
06
September 13,
2007
Submit preliminary analysis of
the residual stresses and flaw
growth of repaired weldment,
including crack growth*
calculations in accordance with
Attachment 3 of CR3 tco
NRC letter 3F0907-05.
Prior to Mode 4 of restart from
Refueling Outage 15,
scheduled for Fall 2007
Completed on -
11/01/07 see
letter 3F1107-01
15
Relief Request
- 246227-
08
September 13,
2007
Submit analysis of the residual
stresses and flaw growth of
repaired weldment, including
crack growth calculations in
accordance with Attachment 3
of CR3 to NRC letter 3F0907-
05.
60 days after plant restart from
Refueling Outage 15,
scheduled for Fall 2007
Completed on -
01/25/08 see
letter 3F01108-11
16
2605571-
01
December 18,
2007
Crystal River Unit 3 will
establish administrative limits
that will increase the minimum
02/09/08
Completed on
01/28/08
SP-300, Revision
- 8 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
inventory of the Borated Water
Storage Tank (BWST) within
the allowed Technical
Specification range during the
requested period of extension.
208, Enclosure 1
17
License
Amendment
Request
- 231028-
02
April 25, 2007
Administrative controls will be
added to CP-500 for situations
where the LEFM CheckPlusTM
system or other specific heat
balance uncertainty inputs is
unavailable. These controls will
address maximum power and
inputs into the heat balance
calculation as well as the
allowed outage time for the
LEFM CheckPlusTM system to
be inoperable. This requirement
will state that if either LEFM or
any low-uncertainty heat
balance input parameters are
inoperable, then reduce power
to < 2568 MWt within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
and reduce the nuclear
overpower - high setpoint
to < 103.3 percent RTP within
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Should the LEFM
system become unavailable,
the current flow nozzle-based
feedwater temperature
instrumentation will be used as
input to the core power
calorimetric, and the core
power will be limited to the
Prior to implementation
Completed on
10/19/07, via ITS,
LCO change to
CP-500, see letter
- 9 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
current licensed power level of
2568 MWt.
18
License
Amendment
Request
- 231028-
09
April 25, 2007
A grid reliability study will be
completed and submitted to the
NRC at the MUR power level
of 2609 MWt.
09/01/2007
Completed on
06/28/07, see
letter 3F0607-05
19
License
Amendment
Request
- 231028-
01
NOCS
100503
April 25, 2007
A preventative maintenance
program will be developed for
the LEFM using the vendor's
maintenance and
troubleshooting manual. This
includes i verifying the
calibration of the 5 MHz clock in
the Acoustic Processor unit and
power supplies.
Prior to implementation
Completed on
02/12/08 PMID-
RQ-7900-01/
Workoder
1278851
20
License
Amendment
Request
- 23102804
April 25, 2007
CR-3 will complete all LEFM
and associated modifications:
Installation of the Caldon
system.
Addition of new Feedwater
and Main Steam pressure
and Main Steam
Temperature
instrumentation.
Modification of AULD
software
The Control Room plant
reference simulator
Prior to implementation
Completed on
12/19/07 by
engineering
changes (EC)
21
License
Amendment
Request
- 231028-
01
April 25, 2007
CR-3 will complete the training
of operators on the LEFM
modification and actions to be
taken if the system is
Prior to implementation
Completed on
12/09/07
- 10 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
22
License
Amendment
Request
- 231028-
10
April 25, 2007
Alden Labs calibration and test
data will be provided to the
NRC once completed.
09/01/2007
Completed on
08/30/07, see
letter 3F0807-05
23
License
Amendment
Request
- 231028
April 25, 2007
FPC will inform the NRC if
there are any changes to
critical operator actions.
09/01/2007
Completed on
06/26/07, see
letter 3F0607-05
25
License
Amendment
Request
- 231347-
10
August 23,
2007
FPC will permanently remove
the missile shields upon
approval of this LAR.
60 days after issuance of
amendment
Per EC 64487,
The missile was
removed on
10/23/07 and
never was
reinstalled.
26
License
Amendment
Request
- 231347-
10
August 23,
2007
Alternate means of complying
with NUREG-0612
requirements will be
established.
Prior to moving heavy loads
near the Spent Fuel Pool,
scheduled during the Fall of
2007
Completed by EC 68398
27
BL 2005-02
- 163849-
03
August 15,
2005
The CR-3 Radiological
Emergency Response Plan and
EAL set will be updated to
reflect the information
corresponding to
NUMARC/NESP-007 Guidance
Attachment 2, pages 6-7.
01/13/2006
Completed and
managed by
NOCS 100477
28
BL 2005-02
- 163849-
06
August 15,
2005
Procedures will be modified to
accomplish onsite protective
measures by defining
arrangements for accounting of
personnel after the attack
01/13/2006
Completed and
managed by
NOCS 100478,
EM-911 and EM-
211
29
BL 2005-02
- 163849-
07
August 15,
2005
The CR-3 Radiological
Emergency Response Plan will
be revised to include provisions
for drills and exercises using
01/13/2006
Completed and
managed by
NOCS 100477
- 11 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
terrorist-based-events.
30
Appendix R
Exemption
None
January 16,
2003
The system is expected to be
returned to service.
Prior to March 15, 2003
Completed on
12/03/03 by letter
31
License
Amendment
Request
148054-01
January 13,
2005
CR-3 will perform compliance
procedure CP-253, "Power
Operation Risk Assessment
and Management," which
requires a deterministic and
probabilistic evaluation of risk
for the performance of all
activities.
CR-3 will select beneficial
Makeup Pump configurations.
Operator attention to the
importance of protecting the
operable redundant train and
support systems will be
increased. Operator attention to
non-safety grade FWP-7 and
Standby Diesel Generator
(MTDG-1) will be increased.
This will be accomplished by on
shift operating crew review of
Emergency Operating
Procedure (EOP- 14),
Enclosure 7, Emergency
Feedwater Pump (EFWP)
Management. CR-3 will not
schedule elective maintenance
in the switchyard that would
challenge the availability of
offsite power. CR-3 will
During one-time extended
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) RWP-
3B Maintenance
A generic special
procedure CP-140
was created
- 12 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
establish fire watches, as
required, in fire zones identified
as containing circuits applicable
to the RWP-3A and RWP-3B
pumps to minimize fire risk in
these areas. CR-3 will not
initiate an extended RWP-3B
maintenance outage if adverse
weather, as designated by
procedures, is anticipated. CR-
3 will evaluate the material
condition of the redundant train
to ensure that there is no
negative trend that could
challenge operability.
32
License
Amendment
Request
148054-02
January 13,
2005
CR-3 will submit supplemental
information regarding the risk
significant fire zones including
additional specific
compensatory measures by
February 11, 2005.
February 11, 2005
Completed on
02/05/05 by letter
- 13 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
33
License
Amendment
Request
148054-04
February 11,
2005
Specific compensatory actions
that will be taken during the
RWP-3B maintenance activity
are provided for each of the fire
zones listed. These actions
supplement those
compensatory actions provided
in the referenced letter. These
compensatory actions will
reduce the risk associated with
the maintenance activity to
return Decay Heat Seawater
Pump RWP-3B to full
qualification.
During one-time extended
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) RWP-
3B maintenance
Completed on
09/03/05 by a
specific procedure
Attachment 4
34
License
Amendment
Request
No AR was
created.
May 6, 2005
Crystal River Unit 3 is making
the following commitment in
addition to those previously
provided in References 1 and
2: Equipment and systems
(including support equipment)
will be designated
administratively "as protected"
(no planned maintenance
beyond that required for the
RWP- 3B refurbishment
activity): Nuclear Services and
Decay Heat Seawater System,
Decay Heat System, Decay
Heat Closed Cycle Cooling
Water System, Nuclear
Services Closed Cycle Cooling
Water, Emergency Diesel
Generators, Emergency
Feedwater System, Emergency
During one-time extended
(greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) RWP-
3B maintenance
Completed on
09/03/05 by a
specific procedure
Attachment 3
- 14 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
Feedwater Initiation and
Controls System (EFIC) and
Auxiliary Feedwater Pump.
35
License
Amendment
Request
- 231028-
16
June 18, 2007
FPC will submit the following
information in support of
License Amendment Request
- 296, Revision 0, Measurement
Uncertainty Recapture Uprate:
1) the results of a grid
reliability analysis for
the uprated conditions,
2) the conclusions of the
FPC evaluation of
impact of the uprated
conditions on operator
actions,
3) clarifications of the
description of the
proposed changes
(Attachments A and D)
relative to the proposed
No Significant Hazards
Consideration
Determination, and
4) withdrawal of the
revised containment
response analysis
(Attachment F) and
corresponding changes
to the CR-3 Improved
Technical
June 29, 2007
Completed by
06/28/05 letter
dated 06/28/071
1 This is not a regulatory commitment, rather a submittal schedule update.
- 15 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
Specifications.
36
License
Amendment
Request
- 231028-
18
October 18,
2007
The In-Plant Setpoint and the
methodology used to develop
the In- Plant Setpoint, the as-
left, as-found, and Allowable
Value setpoints will be
documented in the Crystal
River Unit 3 Final Safety
Analysis Report.
60 days after receipt of the
License Amendment
Completed pn
02/13/08, FSAR
change 2007
Revision 24
37
Relief Request
- 143473-
16
November 10,
2004
3F1 104-02
The methodology used in the
CR-3 RI-ISI application for
assessing TASCS potential
conforms to the updated criteria
described in the EPRI letter to
NRC dated March 28, 2001.
Final materials reliability
program (MRP) guidance on
the subject of TASCS will be
incorporated into the CR-3 RI-
ISI application if warranted.
Once final guidance is
approved by the NRC
Completed on
10/30/2006
39
Relief Request
- 143473-
17
November 10,
2004
3F1 104-02
To ensure the performance of
100% of the required
examinations during the current
ten-year ISI the interval, 64.6%
of the inspection locations
selected for examination per
the RI-ISI process will be
examined over the remainder of
the third ISI interval.
Over the remainder of third ISI
Interval
Completed on
11/08/2005
- 16 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
40
Pursuant to
10 CFR 20.1705
- 190245
NOCS
- 100495
Serial:
PE&RAS-05-
066
May 1, 2006
Based on satisfactory tests
results from applicable
pressure drop tests of the
various combinations of hose
lengths and number and types
of connections that are
representative of those
anticipated to be used, Florida
Power Corporation will
incorporate specific instructions
into the respiratory protection
program to ensure that the air
is supplied to the suit inlet
consistent with the conditions
for which this equipment was
certified.
Prior to first use of this
equipment at Crystal River Unit
3 Nuclear Generating Plant..
Implemented on
03/08/2007 by
HPP-0500,
Respiratory
Protection
Program
41
Pursuant to
10 CFR 20.1705
- 190245
NOCS
- 100495
Serial:
PE&RAS-05-
066
May 1, 2006
Florida Power Corporation will
modify the respiratory
protection program to provide
training and additional written
instructions, as follows: this
equipment at 1) Training: a)
Revise or develop written
lesson plans and train workers
on: i) The features of this
equipment; ii) How to don, use,
and doff this equipment; and iii)
Using the built-in escape strips
for routine and emergency
egress conditions. The training
will include appropriate hands-
on and classroom instruction
and will include actions to be
taken by the user in the event
Prior to first use of Crystal River
Unit 3 Nuclear Generating
Plant.
Implemented on
03/08/2007 by
HPP-0500,
Respiratory
Protection
Program
- 17 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
of equipment malfunction. b)
Provide appropriate training to
personnel responsible for
implementation of the
respiratory protection program
to assist in selection, issuance,
set-up, and operation of this
equipment. 2) Provide written
instructions for storage, repair,
selection, inspection, and use
of this equipment: a) Discard
this equipment after a single
use, b) Do not use in an
environment immediately
dangerous to life and health, c)
Prohibit contact with open
flames or grinding/welding
sparks, d) Use with an
assigned protection factor of
5000, e) Comply with
manufacturer's
recommendations for shelf-life
and storage conditions for this
equipment, f) Perform no
maintenance or repair, g)
Inspect this equipment at or
near time of issue for tears,
defects in material, presence of
required zippers, and integrity
of seams and air distribution
and exhaust systems, and h)
Wearer to perform an
operational check after donning
and before exposure to
- 18 -
No.
Category
Action
Request
No.
Letter Date
No.
Commitment
Scheduled Date
Completion Date
airborne contaminants. 3)
Provide written instructions for
respirator problem identification
and communication: a) Identify
problems in the Corrective
Action Program, b)
Communicate with the vendor
to investigate and resolve
identified problems, and c)
Communicate identified
problems to other licensees
through the Operating
Experience Program.