ML092080045

Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant License Renewal Application

ML092080045
Person / Time
Site:	Crystal River
Issue date:	08/14/2009
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: ML092080045 (10)

Text

August 14, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, FL 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

ML092080045 OFFICE PM:RPB2:DLR LA:DLR BC:SBPB:DSS BC:RPB2:DLR PM:RPB2:DLR DWrona RKuntz NAME RKuntz IKing GCasto (LRegner for) (Signature)

DATE 07/30/09 07/30/09 07/30/09 08/12/09 08/14/09

Letter to Jon Franke from Robert F. Kuntz dated August 14, 2009

SUBJECT:

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

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

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________

RKuntz DBrittner AJones, OGC LLake, RII MSykes, RII TMorrissey, RII RReyes, RI

Crystal River Unit 3 Nuclear Generating Plant cc:

Mr. R. Alexander Glenn Mr. Daniel R. Westcott Associate General Counsel (MAC-BT15A) Supervisor, Licensing & Regulatory Florida Power Corporation Programs P.O. Box 14042 Crystal River Nuclear Plant St. Petersburg, FL 33733-4042 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. James W. Holt Plant General Manager Senior Resident Inspector Crystal River Nuclear Plant (NA2C) Crystal River Unit 3 15760 W. Power Line Street U.S. Nuclear Regulatory Commission Crystal River, FL 34428-6708 6745 N. Tallahassee Road Crystal River, FL 34428 Mr. William A. Passetti, Chief Department of Health Ms. Phyllis Dixon Bureau of Radiation Control Manager, Nuclear Assessment 2020 Capital Circle, SE, Bin #C21 Crystal River Nuclear Plant (NA2C)

Tallahassee, FL 32399-1741 15760 W. Power Line Street Crystal River, FL 34428-6708 Attorney General Department of Legal Affairs Mr. David T. Conley The Capitol Associate General Counsel II - Legal Dept.

Tallahassee, FL 32304 Progress Energy Service Company, LLC P.O. Box 1551 Mr. Ruben D. Almaguer, Director Raleigh, NC 27602-1551 Division of Emergency Preparedness Department of Community Affairs Mr. Daniel L. Roderick 2740 Centerview Drive Vice President, Nuclear Projects &

Tallahassee, FL 32399-2100 Construction Crystal River Nuclear Plant (SA2C)

Chairman 15760 W. Power Line Street Board of County Commissioners Crystal River, FL 34428-6708 Citrus County 110 North Apopka Avenue Mr. Mark Rigsby Inverness, FL 34450-4245 Manager, Support Services - Nuclear Crystal River Nuclear Plant (SA2C)

Mr. Stephen J. Cahill 15760 W. Power Line Street Engineering Manager Crystal River, FL 34428-6708 Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Mr. Robert J. Duncan II Crystal River, FL 34428-6708 Vice President, Nuclear Operations Progress Energy P.O. Box 1551 Raleigh, NC 27602-1551

Crystal River Unit 3 Nuclear Generating Plant cc:

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

REQUEST FOR ADDITIONAL INFORMATION CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT LICENSE RENEWAL APPLICATION DOCKET NUMBER 50-302 RAI 2.2-01 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

The Hydrogen Monitoring System is mentioned in the Crystal River Unit 3 Nuclear Generating Plant (CR-3) Final Safety Analysis Report (FSAR) in Section 9.11.2.1.2 and in the CR-3 license renewal application (LRA) in Section 2.3.3.61 under the Post Accident Containment Atmospheric Sampling System (PASS) discussion. In both references, the Hydrogen Monitoring System is noted to share two sampling points with the PASS. No separate scoping discussion or scoping result regarding the Hydrogen Monitoring System is presented in the LRA.

Request:

Explain the exclusion of the Hydrogen Monitoring System from scope of license renewal per 10 CFR 54.4.

RAI 2.2-02 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

The Auxiliary Feedwater (AFW) System is discussed in the CR-3 FSAR in Section 10.6.

Scoping drawing 302-081-LR, Sheet 4 shows the entire AFW System in scope. LRA Table 2.3.4-8 indicates that the AFW pump, AFW pump bearing cooler housing, and AFW pump bearing cooler tubes are all included in the aging management review (AMR), however no separate discussion for the AFW System is presented in the LRA.

In the CR-3 FSAR, Section 10.6.1, the AFW pump is designed to provide an additional non-safety grade source of secondary cooling to the once-through steam generators (OTSGs),

should a loss of all main and emergency feedwater (EFW) occur. This "AFW source" was added in response to U.S. Nuclear Regulatory Commission (NRC) concerns on the issue of EFW reliability (Generic Issue 124 and SRP Section 10.4.9).

Request:

Provide clarification if the AFW system should or should not be in scope for license renewal. If the AFW system is in scope, provide a discussion of the AFW system similar to those provided in LRA Section 2.3 for other systems including the specific license renewal intended functions in accordance with 10 CFR 54.4 that the AFW system is credited with performing.

ENCLOSURE

RAI 2.2-03 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

On LRA Figure 2.2-1, CR-3 Plant Structures, the applicant shows structures in light lines, denoting the structure is not in scope of license renewal. Among the structures the applicant depicts as not in scope are the Reactor Building (RB) Maintenance Building and the Health Physics (HP) Office structures. In FSAR Chapter 5, Section 5.1.1.1, the applicant lists Class I structure, system, and components (SSCs). Among the list is the EFW Tank Enclosure, which corresponds to the Dedicated EFW Tank Enclosure Building on LRA Figure 2.2-1. Shown next to this Class I structure, are the RB Maintenance Building and the HP Office. However these structures are shown as not in scope of license renewal. Due to their proximity, these structures could have the potential to interact with the adjacent Class I structure; and if so would be included in scope of license renewal under 10 CFR 54.4(a)(2).

Request:

Explain the exclusion of the RB Maintenance Building and HP Office structures from scope of license renewal per 10 CFR 54.4.

RAI 2.2-04 General Scoping Items

Background:

10 CFR 54.4(a) provides three criteria for determining whether systems or components are in scope for license renewal. The applicant follows their stated methodology to ensure that this regulation is met.

Issue:

In FSAR, Chapter 1, Figure CR3-G86-D, shows an Outage Support Building adjacent to the Borated Water Storage Tank. However, LRA Figure 2.2-1, CR-3 Plant Structures, does not show this structure. Since this structure is adjacent to the Borated Water Storage Tank, which is a Class I structure, it has the potential to interact with the adjacent Class I structure; and if so would be included in scope of license renewal under 10 CFR 54.4(a)(2).

Request:

Explain the exclusion of the Outage Support Building from scope of license renewal per 10 CFR 54.4.

RAI 2.2-05 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

On LRA Figure 2.2-1, CR-3 Plant Structures, the applicant shows structures in light lines, denoting the structure in not in scope of license renewal. Among the structures the applicant depicts as not in scope are the Traveling Screens. In FSAR Chapter 5, Section 5.1.1.1, Class I, the applicant list Class I SSCs. Among the list is the Nuclear Steam Supply Systems intake structure, which corresponds to the Circulating Water Intake structure on LRA Figure 2.2-1. The traveling screens are a part of this Class I structure; however, they are shown as not in scope of license renewal. Due to their proximity, these traveling screens have the potential to interact with the adjacent Class I structure. Therefore, the traveling screens should be included in the scope of license renewal under 10 CFR 54.4(a)(2). In addition, the travel screens may have a filtering function, which may require them to be in the scope of license renewal.

Request:

Explain the exclusion of the traveling screens from scope of license renewal per 10 CFR 54.4.

RAI 2.2-06 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

On LRA Figure 2.2-1, CR-3 Plant Structures, the applicant shows structures in dark lines, denoting the structure is in scope of license renewal. Among the structures the applicant depicts as in scope is the Machine Shop. LRA Section 2.4.1.14, Machine Shop, states that the Machine Shop structure intended function is to Provide structural support and/or functional support to non-safety related components. Also, the Machine Shop structure is shown next to Class I structures, Control Building, Auxiliary Building, and Diesel Generator Building. Due to the proximity, the Machine Shop structure has the potential to interact with the adjacent Class I structure; and if so would be included in the scope of license renewal under 10 CFR 54.4(a)(2).

During the CR-3 plant audit on June 23, 2009, the applicant discussed a portion of the machine shop being in scope for license renewal to support the Appendix R equipment on the roof. The applicants reasoning for excluding the remaining support structure of the machine shop from the scope of license renewal is because the failure of the supporting steel would be hypothetical in nature. However, this explanation conflicts with industry operating experience.

In addition, in the FSAR, Section 2.4.2.4, Facilities Required for Flood Protection, the applicant describes equipment required to remain functional during a postulated hurricane to assure maintenance of the reactor in a safe condition. The applicant describes five large doors that have an inflatable-type seal that serves as a back-up in the unlikely event of a compression-type seal failure, one of which describes a water-tight door into the Hot Machine Shop. CR-3 FSAR Figure 2.30 shows water-tight doors, but not the machine shop. It is not clear if this component is physically located in the machine shop structure or other structure.

Request:

Explain the exclusion of portions of the Machine Shop, as discussed during the June 23, 2009 audit, and the Hot Machine Shop structures from scope of license renewal per 10 CFR 54.4.

RAI 2.2-07 General Scoping Items

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

In LRA Section 2.2, Table 2.2-1, the applicant lists systems in the scope of license renewal.

The Reactor Building Pressure Sensing and Testing System was listed as not in the scope of license renewal. The applicant does not provide an explicit explanation of what components comprise this system. The applicant did include the Leak Rate Test System in the scope of license renewal, which seems to have the same function as the Reactor Building Pressure Sensing and Testing System. Therefore, the Reactor Building Pressure Sensing and Testing System should be included in scope of license renewal under 10 CFR 54.4.

Request:

Explain the exclusion of the Reactor Building Pressure Sensing and Testing System from scope of license renewal per 10 CFR 54.4.

RAI 2.3.3.33-01 Emergency Diesel Generator System

Background:

10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.

Issue:

The applicant identifies the AFW Pump as being in scope of license renewal and is highlighted as such on LRA drawing 302-081-SH-004. However, the power sources for the AFW pump, the Alternate AC (AAC) diesel and building, are not identified as in scope per LRA Section 2.3.3.33 and structures Table 2.2-2. In the CR-3 FSAR, Section 10.6.1, the AFW pump is designed to provide an additional non-safety grade source of secondary cooling to the OTSGs, should a loss of all main and EFW occur. This "AFW source" was added in response to NRC concerns on the issue of EFW reliability (Generic Issue 124 and SRP Section 10.4.9).

In addition, the AAC may be credited as backup power supply to the emergency diesel generator (EDG) in the event of a loss of all AC. License Amendment 207, regarding technical specification change request for EDG allowed outage time extension (from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days), issued June 13, 2003, indicates that AAC Diesel is intended to provide defense in depth during EDG online maintenance and other times when it is available. The AAC Diesel will be capable of carrying the loads required for safe shutdown, including maintaining adequate voltage and frequency such that the performance of safety systems is not degraded. The technical evaluation for this licensing amendment included a probabilistic safety assessment evaluation which incorporated the availability of the AAC Diesel. License Amendment 228, issued on December 26, 2007, by the NRC, involved the measurement uncertainty recapture power uprate, which referenced the AAC Diesel. The applicant noted that the AAC Diesel can be aligned to either safety-related AC distribution bus.

Though it is noted in the CR-3 FSAR that the AAC Diesel does not have a Station Blackout function, it is evidently relied upon in subsequent license amendment requests to provide defense in depth for the Emergency Diesel Generator System. Also, in LRA Figure 2.2-1, CR-3 Plant Structures, the applicant shows structures in light lines, denoting the structure in not in scope of license renewal. Among the structures the applicant depicts as not in scope is the AAC Diesel Generator Building.

Request:

Explain the exclusion of the AAC Diesel System and AAC Diesel Generator Building from scope of license renewal per 10 CFR 54.4.

RAI 2.3.3.35-01 Fuel Handling System

Background:

10 CFR 54.21(a)(1) requires the applicant to provide a list of structures and components subject to an AMR. The staff reviews the LRA, FSAR, and license renewal boundary drawings to verity that list of components provided for each system is complete.

Issue:

LRA Section 2.3.3.35, Fuel Handling System, states: There are no License Renewal scoping drawings that depict the Fuel Handling System. LRA drawing 302-621 depicts the fuel transfer canal (B-2). The CR-3 LRA Table 2.3.3-35 lists piping and components for the Fuel Handling system.

Request:

Verify that LRA drawing 302-621 depicts all the components for the fuel handling system that are in scope and excluded from scope.