ML092020012

RAI, License Renewal Application

ML092020012
Person / Time
Site:	Crystal River
Issue date:	08/20/2009
From:	Robert Kuntz License Renewal Projects Branch 2
To:	Franke J Florida Power Corp
KUNTZ R, NRR/DLR/RPB2 415-2989
References
TAC ME0274
Download: ML092020012 (7)

Text

August 20, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT, LICENSE RENEWAL APPLICATION (TAC NO. ME0274)

Dear Mr. Franke:

By letter dated December 16, 2008, Florida Power Corporation submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license for Crystal River Unit 3 Nuclear Generating Plant, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Mr. Michael Heath, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3733 or by e-mail at robert.kuntz@nrc.gov.

Sincerely,

/RA/

Robert F. Kuntz, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/encl: See next page

ML092020012 OFFICE PM:RPB2:DLR LA:DLR BC:CPNB:DCI BC:RPB2:DLR PM:RPB2:DLR NAME RKuntz YEdmonds TChan DWrona RKuntz DATE 08/06/09 08/04/09 08/18/09 08/20/09 08/20/09

REQUEST FOR ADDITIONAL INFORMATION CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT LICENSE RENEWAL APPLICATION DOCKET NO. 50-302 RAI 4.3.4-1 Section 4.3.4, Summary Description, Page 4.3-13, states that The remainder of the generic leak before break (LBB) analysis for the B&W operating plants reported in BAW-1847, Revision 1, remains valid for the period of extended operation with the exception of the original qualitative assessment of reduction of fracture toughness by thermal aging of CASS [cast austenitic stainless steel]. The assessment of reduction of fracture toughness by thermal aging of CASS is not considered a TLAA Clarify why the assessment of reduction of fracture toughness by thermal aging of CASS is not a TLAA because Section 4.3.4 does not provide adequate information and explanation to support the above statement that thermal aging of CASS is not a TLAA.

RAI 4.3.4-2 By letter dated May 19, 2000, Christopher I. Grimes of the NRC forwarded to Douglas J.

Walters of Nuclear Energy Institute an evaluation of thermal aging embrittlement of CASS components (ADAMS Accession No. ML003717179). In the NRCs evaluation, the NRC staff provided its positions on how to manage CASS components. Discuss how the CASS reactor coolant pump (RCP) casing satisfies the staff positions in its evaluation dated May 19, 2000.

Discuss how the structural integrity of the RCP casing will be maintained in the period of extended operation.

RAI 4.3.4-3 Section 4.3.4, Page 4.3-14, first paragraph, states that If a transient cycle count approaches or exceeds the allowable design limit, corrective actions are taken. Therefore, the flaw growth evaluation reported in BAW-1847, Revision 1, remains valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i) since CR-3 has not revised the transients defined in the reactor coolant system (RCS) design specification for License Renewal. (a) The cause and effect of the above two statements is not clear. For example, if the transient cycle count exceeds the allowable design limit, the flaw growth evaluation in BAW-1847 becomes invalid.

The plant would then be in violation of the design basis. A program should be implemented to monitor transient cycles before they exceed the design basis. In addition, it is not clear how corrective actions or CR-3 has not revised transients would lead to the validity of the flaw growth evaluation for the period of extended operation. Clarify the above two statements. (b)

Demonstrate the validity of the flaw growth calculations for the period of extension in terms of transient cycles used, instead of relying on the corrective actions to be taken in the future. (c)

Describe the corrective actions that will be taken when the transient cycles approach the design limit.

RAI 4.3.4-4 Section 4.3.4, Page 4.3-14, second paragraph, states that The fracture toughness curve of the lower-bound CASS material is below the fracture toughness curves used in the RCS piping LBB analysis. Therefore, the assumption in BAW-1847, Revision 1, that the fracture toughness of the ferritic piping and ferritic weldments bounds the fracture toughness of CASS required further evaluation for License Renewal (a) It appears that the fracture toughness of the piping that was used in the LBB analysis has to be lower (not higher as alluded in the above statement) than the fracture toughness of CASS material in order to bound the fracture toughness of CASS material of the RCP pump casing. Explain the above statements, because it appears that the fracture toughness of the pipe used in the LBB analysis is not bounding. (b)

Provide the fracture toughness of the piping used in the LBB analysis and the lower bound fracture toughness of CASS material of the RCP pump casing per NUREG/CR-6177 as discussed in Section 4.3.4.

RAI 4.3.4-5 The NRC approved two power uprate applications for CR-3 in 2002 and 2007. Discuss the impact of the power uprates on the results of BAW-1847, Revision 1, in terms of fatigue flaw growth evaluation, thermal aging of CASS RCP pump nozzles, and safety margins in SRP 3.6.3. Discuss the impact of the power uprates on the flaw stability analysis in Section 4.3.4, Page 4.3-14. Discuss whether this analysis includes the operating conditions of power uprate.

If not, discuss the impact of power uprate on the validity of the flaw stability analysis.

RAI 4.3.4-6 Identify flaws or indications (location and size) that have remained in service in the LBB-approved RCS piping. Discuss how these flaws will be monitored and inspected during the period of extended operation and discuss the results of growth evaluations of these flaws.

RAI 4.3.4-7 Pressurized water reactors plants have experienced primary water stress corrosion cracking (PWSCC) in Alloy 82/182 dissimilar metal welds in ASME Class 1 piping. PWSCC has an aggressive crack growth rate and is an active degradation mechanism in pressurized water reactors. One of the conditions for which continued approval of LBB is conditioned upon is that active degradation mechanisms such as PWSCC cannot be present. It is not clear whether PWSCC is an issue for the LBB piping at Crystal River. (a) Identify all Alloy 82/182 dissimilar metal welds in the LBB-approved RCS piping. (b) If Alloy 82/182 welds exist in the LBB piping, discuss the actions that have been or will be taken to mitigate and inspect these Alloy 82/182 welds to ensure that PWSCC will not affect the structural integrity of the LBB-approved RCS piping during the period of extended operation. (c) Discuss inspection history, including results, methods used, and examination volume coverage, of the Alloy 82/182 weld material in the RCS piping. (d) In addition to discussing inspection results of Alloy 82/182 welds in the RCS piping, discuss the inspection history of other welds in the LBB piping.

Letter to J. Franke from R. Kuntz, dated August 20, 2009 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT, LICENSE RENEWAL APPLICATION (TAC NO. ME0274)

HARD COPY:

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Crystal River Nuclear Generating Plant, Unit 3 cc:

Mr. R. Alexander Glenn Associate General Counsel (MAC-BT15A)

Florida Power Corporation P.O. Box 14042 St. Petersburg, FL 33733-4042 Mr. James W. Holt Plant General Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, FL 32399-1741 Attorney General Department of Legal Affairs The Capitol Tallahassee, FL 32304 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue Inverness, FL 34450-4245 Mr. Stephen J. Cahill Engineering Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Daniel R. Westcott Supervisor, Licensing & Regulatory Programs Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428-6708 Senior Resident Inspector Crystal River Unit 3 U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River, FL 34428 Ms. Phyllis Dixon Manager, Nuclear Assessment Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. David T. Conley Associate General Counsel II - Legal Dept.

Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, NC 27602-1551 Mr. Daniel L. Roderick Vice President, Nuclear Projects &

Construction Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Mark Rigsby Manager, Support Services - Nuclear Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Robert J. Duncan II Vice President, Nuclear Operations Progress Energy Post Office Box 1551 Raleigh, NC 27602-1551

Crystal River Nuclear Generating Plant, Unit 3 cc:

Mr. Brian C. McCabe Manager, Nuclear Regulatory Affairs Progress Energy Post Office Box 1551 Raleigh, NC 27602-1551