ML093410638

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

ML093410638
Person / Time
Site:	Crystal River
Issue date:	12/03/2009
From:	Franke J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1209-03, TAC ME0274
Download: ML093410638 (32)

Text

~ Progress Energy Crystal River River Nuclear Nuclear Plant Docket No. 50-302 50-302 Operating License No. DPR-72 Ref: 10OCFR 54 Ref: 10 CFR 54 December December 3, 2009 3F1209-03 3F1209-03 U.S. Nuclear Regulatory Regulatory Commission Attn: Document Document Control Desk Washington, DC 20555-0001 Washington,

Subject:

Crystal River Unit 3 - Response Response to Request for Additional Information Information for the the Review Review of the Crystal River Unit 3, Nuclear Generating Generating Plant, License License Renewal Application (TAC NO. ME0274) - Structural and Electrical Electrical Aging Management Management Reviews Reviews and License License Renewal Application Application Amendment Amendment #7

References:

(1) CR-3 to NRC letter, 3F1208-01, December 16, 2008, "Crystal River 3F1208-01, dated December Unit Unit 3 - Application for Renewal Renewal of Operating License" (2)

(2) NRC to CR-3 letter, dated November 3, 2009, "Request for Additional Information for the Review Review of the Crystal River Unit 3, Nuclear Generating Generating Plant, License Renewal Application (TAC NO. ME0274)"

(3) CR-3 to NRC letter, 3F0909-06, dated September 30, 2009, "Crystal dated September "Crystal River Unit 3 - Response to Requests Requests for Additional Information Information for the the Review of the Crystal River Unit 3 Nuclear Nuclear Generating License Generating Plant, License Renewal Application (TAC NO. ME0274) and Amendment Amendment #4"

Dear Sir:

Sir:

On December December 16, 2008, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) to extend extend the term of its operating operating license an additional 20 years beyond the current expirationexpiration date (Reference 1). Subsequently, the Nuclear date (Reference Nuclear Regulatory Commission (NRC), by letter dated November 3, 2009, provided November provided a request for additional additional information (RAI) concerning information (RAI) concerning the CR-3 License Renewal Renewal Application (Reference (Reference 2). Enclosure 1 to this letter provides the response response toto Reference 2. In Reference In addition, Enclosure Enclosure 1 identifies an editorial editorial change applicable to the response response to RAI 2.4-1 previously submitted in Reference Reference 3. Enclosure Enclosure 2 provides Amendment Amendment #7 #7 to the the License Renewal Application.

Application.

commitments are contained No new regulatory commitments contained in this submittal.

If you have If have any questions regarding regarding this submittal, please please contact contact Mr. Mike Heath, Supervisor, License Renewal, at (910) 457-3487, e-mailatmike.heath@pgnmail.com.

e-mail at mike.heath@pgnmail.com.

Si cerely,

-"',. on FA. Frank Vice President Crystal River Unit 3 JAF/dwh

Enclosures:

1.

Enclosures:

Information Response to Request for Additional Information

2. Amendment Amendment #7, #7, Changes to the License Renewal Application License Renewal Application xc: NRC CR-3 Project Manager Manager NRC License NRC License Renewal Renewal Project Manager Project Manager I*4D Regional Administrator, Region NRC Regional Region"II Senior Resident Inspector Inspector

('

Progress Energy Florida, Inc. )

Progress Crystal River River Nuclear Nuclear Plant 15760 W. Power 15760 Power Line Street Street Crystal River, FL 34428

!"'.' "

U. S. Nuclear Regulatory Regulatory Commission Page 22 of 2 3F1209-03 3F1209-03 STATE OF FLORIDA COUNTY OF CITRUS COUNTY CITRUS Jon A. Franke Franke states that he is the Vice President, Crystal River River Nuclear Florida Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the Nuclear Regulatory the statements made attached hereto; and that all such statements information attached made and matters matters set forth therein are true and correct correct to the best of his knowledge, informatio*ndaelief.

informatiQQ;-a elief.

ocn A. Franke on A. Franke Vice President Crystal River River Nuclear Plant The foregoing document was acknowledged acknowledged before me this ~ day of December ,2009, by Jon A. Franke.

Public Signature of Notary Public State of Florida Florida MY COaM EaPkn Ju2n. 20131 (Print, type, or stamp Commissioned Commissioned Name of Notary Notary Public)

Personally ~ Produced Known . j -OR-Known ---'~t....-_ -OR- Identification Identification ---

PROGRESS ENERGY FLORIDA, INC.

PROGRESS CRYSTAL RIVER CRYSTAL RIVER UNIT 3 NUMBER 50 - 3021 DOCKET NUMBER 302 / LICENSE NUMBER NUMBER DPR - 72 72 ENCLOSURE I1 ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ADDITIONAL INFORMATION

U. S. Nuclear Regulatory U. Regulatory Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 1 of 26

RESPONSE

RESPONSE TO REQUEST FOR ADDITIONAL ADDITIONAL INFORMATION INFORMATION RAI 3.5.2.1 -1 3.5.2.1-1 Backqround

Background

The Generic Generic Aging Lessons Learned Learned (GALL) Report assigns assigns several aging effects effects to concrete concrete inin various environments, but makesmakes no mention of the aging effect "change in material material properties."

Issue License Renewal Renewal Application (LRA), (LRA), Section Section 3.5, lists the aging effect "change in material properties" for multiple concrete line items which reference license renewal reference license renewal Generic Generic Note A.

Request

1. Explain what the aging effect effect "change in material properties" includes and how the aging effect is managed.

2. Explain which recommended aging effects are covered by the aging effect "change in which GALL recommended in material properties" and how the LRA aging effect is equivalent equivalent to the GALL Report recommended aging effects which it replaces.

recommended

Response

Response 1.

1. For concrete, change For concrete, change in material material properties properties includes includes the agingaging effects for increase increase in porosity and permeability porosity permeability due to aggressive chemical attack; aggressive chemical poro~ity and increase in porosity attack; increase permeability and permeability and loss of strength strength due to leaching leaching of calcium calcium hydroxide; hydroxide; loss of bond due to corrosion corrosion of embedded steel; reduction of strength steel; reduction strength and modulus due to elevated temperature; temperature; and reduction reduction in foundation foundation strength strength due to erosion porous concrete erosion of porous concrete sub-sub-foundation. However, the aging foundation. However, reduction of strength aging effects of reduction strength and modulus due to elevated temperature elevated temperature andand reduction reduction in foundation foundation strength strength due to erosion erosion of porous concrete porous concrete sub-foundation determined to not be applicable sub-foundation were determined applicable at Crystal Crystal River Unit 3 (CR-3) in License Renewal Application Application (LRA) Table 3.5. 1. The applicable 3.5.1. aging effects covered applicable aging covered byby change change in material properties are material properties are the same as the NUREG-1801, NUREG-1801, "Generic"Generic Aging Lessons Learned (GALL) Report," Aging Management Learned (GALL) Management Program, Program, recommended recommended aging aging effects (increase in porosity (increase porosity and permeability aggressive chemical permeability due to aggressive attack; increase chemical attack; increase in porosity and porosity and permeability and loss of strength permeability and strength due to leaching leaching of calcium hydroxide; hydroxide; loss ofof bond due to corrosion corrosion of embedded steel). The concrete concrete aging aging effect of change change in material material properties is managed properties managed by the Structures Structures Monitoring Monitoring Program Program or or the ASME ASME Section Section X1, XI, Subsection IWL Program, Subsection Program, using using visual visual inspection methodology. Visual inspection inspection methodology. inspection attributes attributes include inspections include inspections forfor cracking; cracking; spalling; spalling; scaling; swelling; bulging; scaling; swelling; bulging; corrosion corrosion of rebar, rebar, anchorage components, anchorage components, or or liner,'

liner; groundwater seepage; water groundwater seepage; water stains; rust stains; stains; rust stains; efflorescence; and efflorescence; and chemical attack.

chemical attack.

2. The aging

2. covered by change aging effects covered change in material properties.in Response 1 material properties. I are are the same as the NUREG-1801 recommended aging NUREG-1801 recommended effects. CR-3 chose to use the aging effects. the. term "change "change in material properties" material properties" which envelopes the NUREG-1801 NUREG-1801 aging aging effects consistent consistent with the

U. S. Nuclear U. Regulatory Commission Nuclear Regulatory Commission Enclosure 1 Enclosure 3F1209-03 Page 2 of 26 Page 26 approach used for approach for previous previous Progress Progress Energy Energy LRAs (Robinson and LRAs (Robinson and Harris Nuclear Plants)

Harris Nuclear Plants) and several and other nuclear several other plants (e.g., Vogtle nuclearplants and Oyster Creek).

Vogt/e and Creek).

RAI 3.5.2.2-1

Background

Background Standard Review Plan Plan for License Renewal Applications of Nuclear Renewal Applications Nuclear Power Plants (SRP-LR),

Section 3.5.3.2.1.1, 3.5.3.2.1.1, discusses the evaluation evaluation of the acceptability acceptability of inaccessible inaccessible areas of concrete containments when conditions exist in accessible concrete containments accessible 'areas indicate the areas that could indicate the degradation to such inaccessible presence of or result in degradation presence inaccessible areas.

Issue LRA, Section 3.5.2.2.1.1, does not discuss the evaluation Section 3.5.2.2.1.1, acceptability of inaccessible evaluation of the acceptability inaccessible areas of concrete areas containments when conditions concrete containments conditions exist in accessible indicate the accessible areas that could indicate the presence presence of or result in degradation degradation to such inaccessible areas for inaccessible inaccessible areas inaccessible concrete areas Reactor Building structure.

of the Reactor Request Reguest Management Program (AMP) addresses Explain which Aging Management addresses the evaluation of the acceptability inaccessible areas of concrete of inaccessible conditions exist in accessible areas containments when conditions concrete containments areas that presence of or result in degradation could indicate the presence inaccessible areas and how it is degradation to such inaccessible being fulfilled.

Response

Response NUREG-1801, AMP XI.S2, ASME ASME Section XI, Subsection Subsection IWL Program Evaluation and Program Evaluation Technical Basis Technical Basis Element 1, "Scope 1, "Scope of Program", requires Program", requires the evaluation evaluation of the acceptability of acceptability of inaccessible areas of concrete inaccessible areas containments when conditions concrete containments conditions exist in accessible accessible areas areas that could indicate presence of or result indicate the presence degradation to such inaccessible result in degradation inaccessible areas.

areas. LRA, Appendix B, Subsection Subsection B.2.26, B.2.26, ASME ASME Section Xl, XI, Subsection IWL Program, Program, is an an existing consistent with NUREG-1801, program consistent program NUREG-1801, AMP XI.S2. This requirement has been incorporated requirement has incorporated ASME Section X1, into the ASME XI, Subsection IWElIWL Program Manual.

IWE/IWL Program Manual. The Program Program Manual Manual establishes establishes and and defines the administrative requirements required administrative requirements required to meet the CR-3 ASME ASME X1, Inservice Section XI, Inspection Program.

Inservice Inspection Program.

RAI 3.5.2.2.1.2-1

Background

Background recommends that cracks and distortion due to increased SRP-LR, Section 3.5.2.2.1.2, recommends increased stress stress settlement could occur in concrete and steel containments. Also, reduction of levels from settlement differential settlement due to erosion of porous concrete sub-foundation strength, cracking, and differential foundations could occur in all types of containments. SRP-LR, Section 3.5.2.2.1'.2, also states states that no further evaluation evaluation is necessary if applicant's if this activity is within the scope of the applicant's structures monitoring monitoring program.

U. Regulatory Commission U. S. Nuclear Regulatory Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 3 of 2626 Issue LRA, Section 3.5.2.2.1.2, 3.5.2.2.1.2, states that the aging effects caused by settlement settlement are managed managed by the the Structures Monitoring Program. Reactor Structures Reactor Building settlement analysis determined the upper analysis determined upper limit settlement settlement of about 0.875 in., and most of itit would have occurred during construction. The LRA LRA Section 3.5.2.2.1.2 also states that no cracking Section 3.5.2.2.1.2 cracking due to settlement has been observed. However, the procedure criteria for settlement monitoring are not stated in the LRA.

procedure and criteria Request:

1. Describe the procedure procedure for monitoring settlement under the Structures Structures Monitoring Program.

Program.

2. What inspection criteriacriteria are (or were) selected selected to identify if the cracking or other aging aging effect (if any) in concrete and steel components of the Crystal River Unit 3, Nuclear (if Nuclear Generating Generating containment were due to increased Plant (CR-3) containment increased stress levels levels from settlement.

Response

Response

1. The implementing

1. implementing procedure procedure for the Structures Structures Monitoring Monitoring Program Programis a common procedure procedure used for all of the Progress Progress Energy nuclearnuclear plants.

plants. The implementing implementing procedure monitors procedure monitors for concrete for cracking and concrete cracking and seismic seismic gapsgaps inin accordance accordance with the Structures Structures Monitoring Monitoring Program described Program described in LRA,LRA, Appendix B, Subsection Subsection B. B.2.30.

2. 30. The implementing procedure procedure performance performance standard cracks is the absence standard for cracks recent growth absence of recent growth or other other degradation degradation mechanism and mechanism and cracks cracks less than than a minimum gap gap size measured measured below any surface surface enhanced widening.

enhanced widening. Another performance standard performance standard is that that the gaps gaps at buildings buildings meet design requirements.

design requirements. Since settlement has has not manifested manifested itself via via cracked cracked walls walls or cracked foundations cracked foundations in 33 years years of operation, cracking due to settlement is not a significant operation, cracking significant aging effect at CR-3.

aging CR-3. However, However, the visual visual inspections inspections for concrete concrete cracking, cracking, andand any differential movement which would affect the gap differential gap design design between buildings, buildings, will continue continue in the period period of extended operation.

operation.

2. An inspection

2. inspection for concrete concrete cracking cracking is alsoalso included included forfor the Reactor Reactor Building Building (RB) in accordance with the ASME Section XI, Subsection IWL, Aging Management accordance Management Program, Program, described in LRA, described Subsection B.

LRA, Appendix B, Subsection B.2.26.

2. 26. While minorminor cracking cracking of accessible accessible concrete has been identified, concrete identified, none of the aging aging mechanisms have been attributed attributed to settlement. An inspection settlement. inspection of the steelsteel surfaces performed in the ASME surfaces of the RB is performed ASME Section Xl, XI, Subsection IWE, Management Program.

I WE, Aging Management Program. Inspections Inspections are are made made for cracking, cracking, broken welds, broken bulging of the liner welds, bulging liner and and surface surface discontinuities, discontinuities,as as these could be indications indications of increased increasedstress stress levels from settlement.

settlement.

considerationof the recent In consideration recent discovery discovery of a gap in the concrete concrete of the outer outer radius CR-3 radius of the CR-3 containment structure, containment structure, which was the subjectsubject of NRC Event Notification Notification 45416, 45416, dated dated October 7, 2009, 7, 2009, and and NRC Special Special Inspection Inspection Team Press Press Release Release No. 1/-09-055, 11-09-055, dated dated October October 9, 2009, Progress Energy Florida, 2009, Progress Florida, Inc., (PEF)

(PEF) will evaluate evaluate the need to revise revise the technical technical response to this Request response Request for for Additional Additional Information Information (RAI) at a later date. This evaluation later date. evaluation will be completed following following the rootroot cause determination that cause determination that is currently currently in progress progress andand subsequent subsequent assessment assessment of any impact impact on the technical technical and and aging aging management management programs discussed in this programs discussed response.

response.

U. S. Nuclear Regulatory Regulatory Commission Enclosure 1 3F1209-03 3F1209-03 Page 4 of 26 RAI 3.5.2.2.1.4-1

Background

Background GALL GALL Report, Item II.A I.A1-1 1, states that corrosion is not significant 1-11, significant for inaccessible inaccessible areas of steel containments (embedded containment containments containment steel shell or liner) if if four conditions are satisfied. One of the conditions is the concrete is monitoredmonitored to ensure that it is free of penetrating penetrating cracks that provide aa path for water seepage to the surface surface of the containment shell or liner.

Issue LRA, Section Section 3.5.2.2.1.4, 3.5.2.2.1.4, does not discuss whether or not the concrete concrete is monitored monitored for penetrating cracks.

Request

1. Explain if if the concrete concrete i,sis monitored for penetrating penetrating cracks, and ifif so which which program program monitors the program.

program, plant-specific operating experience

2. Discuss plant-specific experience with cracks in the concrete concrete covering covering the the inaccessible areas inaccessible areas of the containment containment liner.

3. If If no program program exists to monitor monitor the concrete, please provide the further evaluation of this please provide this aging effect, as recommended by the GALL Report and SRP-LR, Section 3.5.2.2.1.4.

Response

Response

1. The RB reinforced

1. concrete is monitored reinforced concrete monitored to ensure ensure it is free of cracks cracks that that provide provide a path path for water seepage water seepage to the surfacesurface of the RB liner. liner. The ASME Section Xl, XI, Subsection Subsection IWLIWL Program, Program, performs a visual a visual examination examination of the accessible concrete for cracking accessible concrete for cracking on the RB dome, cylinder dome, walls, and foundation cylinder walls, foundation mat. Structures Monitoring mat. The Structures Monitoring Program Program performs a visual examination visual examination of the accessible accessible concrete concrete for cracking cracking on the RB basementbasement floor (Elevation 95 (Elevation 95 feet), which covers the floor liner plate.

liner plate.

2. As discussed

2. discussed in LRA, Appendix B, Subsection Subsection B.2.26, B. 2. 26, plant operating experience plant operating experience has identified minor cracks << 0.04 inches),

identified minor cracks (< 0. 04 inches), but all were dispositioned dispositioned as as minor in nature nature and not adversely adversely affecting the overall structural integrity of the RB. The Structures overall structural integrity Structures Monitoring Monitoring Program has Program has not identified cracking of the RB basement identified any cracking basement floor, floor, which covers covers the floor linerplate.

liner plate.

3. The ASME

3. ASME Section XI, Xl, Subsection Program, monitors Subsection IWL Program, monitors the concrete concrete as stated stated in the the response to Question response Question 1. 1. The Structures Structures Monitoring Program monitors Monitoring Program monitors for cracking cracking of of concrete as shown in LRA concrete LRA Aging Management Management Review (AMR) Table Table 3.5.2-1 forfor the commodity "Concrete:

"Concrete:Above Grade."

Above Grade."

Based on this response, response, a change change is required LRA Subsection required to LRA Subsection 3.5.2.2.1.4.

3.5.2.2.1.4. Refer to the LRA changes discussed changes discussed in Enclosure Enclosure 2. 2.

U. Regulatory Commission U. S. Nuclear Regulatory Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 5 of 26 RAI 3.5.2.2.2.1-1 3.5.2.2.2.1-1

Background

Background 3.5.2.2.2.1, recommends SRP-LR, Section 3.5.2.2.2.1, recommends that lock-up due to wear could occur Lubrite occur for Lubrite radial beam seats in boiling-water boiling-water reactor drywell, reactor pressurepressure vessel support shoes for pressurized water reactor reactor with nozzle nozzle supports, steam generator generator supports, and other sliding sliding support bearings and sliding support support surfaces. The existing program relies on the Structures Structures Monitoring Program or American Society of Mechanical Mechanical Engineers Engineers (ASME), Section Section XI,XI, Subsection IWF Program, to manage Subsection manage this aging effect. The GALL GALL Report recommends recommends further evaluation evaluation only for structure/aging structure/aging effect combinations that are not within the ASME Section XI, effect combinations XI, Subsection IWF Program or the Structures Monitoring Monitoring Program.

Issue:

LRA, Section 3.5.2.2.2.1, 3.5.2.2.2.1, states that lock-up due to wear is not applicableapplicable because CR-3 does does Lubrite in these applications.

not utilize Lubrite applications. However, the LRA has included lock-up as an aging effect effect in AMR Table 3.5.2-1 3.5.2-1 with a plant-specific plant-specific note 510. According According to the plant-specific note plant-specific note 510, the same aging effect used in the GALL Report, Items Items III.A4-6, III.A4-6, for Lubrite Lubrite plates (lock-up) is assigned Fluorogold slide bearing plates used for structural steel supports. In addition, assigned to Fluorogold determined change CR-3 determined change in material properties due to radiation is an applicable aging effect.

The Structures Monitoring Program Structures Monitoring Program is credited for inspecting inspecting the sliding bearing bearing plates which includes the Fluorogold plates.

LRA, Section 3.5.2.2.2.1 does does not include lock-up due to wear for the sliding bearing plates plates including the Fluorogold including Fluorogold plates which have been used used in CR-3 for the same application as application as Lubrite plates.

Lubrite Request

1. Discuss how the aging management management of Lubrite Lubrite plates is applicable applicable to Fluorogold plates plates and any other sliding bearing plates used in CR-3. Also describe what inspection criteria criteria are (or will be) followed for identification identification of change of material properties properties of these plates duedue to radiation. Indicate ifif any other aging effect is applicable applicable to the sliding bearing plates including the Fluorogold plates.

Describe how the criteria of the SRP-LR Section

2. Describe Section 3.5.2.2.2.1 3.5.2.2.2.1 on lock-up due to wearwear have have been met, and no further evaluation evaluation is required.

3. Discuss accumulation accumulation of debris debris which may resist sliding.

Response

Response

1. Fluorogold

1. Fluorogold and Lubrite are trade Lubrite are trade names names for reduced friction sliding reduced friction sliding surface bearing plate surface bearing plate materials materials typically used used with pipe supports or other applications, supports or other applications, and also associated also associated with support elements that support that experience experience thermal thermal growth.

growth. At CR-3, CR-3, Fluorogold Fluorogold slide slide bearing bearing plates were were used in applications supports and applications involving pipe supports and structural structural steel.

steel. For supports For pipe supports being age-managed age-managed by the ASME Section Section XI, Xl, IWF Program, Program, the aging aging effect of loss of of mechanical function mechanical function was selected selected' for Fluorogold Fluorogold since since Fluorogold Fluorogold waswas used used in the same application as Lubrite application Lubritematerial. Plant-Specific Notes 511 and material. Plant-Specific and 549 were usedused to provide

U. S. Nuclear Regulatory Commission U. Enclosure 11 3F1209-03 Page 6 of Page of 26 clarification. Loss of mechanical clarification. mechanical function function waswas determined determined to be be applicable applicable no matter matter the material type for material for slide slide bearing bearing plates.

plates. In areasareas of high radiation, radiation, e.g.,

e.g., the the RBRB and and the Auxiliary Building Auxiliary Building (AB), the aging aging effect of change in material properties change in material properties due to radiation was to radiation was selected for pipe selected pipe supports supports based based on vendorvendor literature.

literature. For For structural structural steel steel being being age-age-managed by the Structures managed Structures Monitoring Monitoring Program, Program,the the aging aging effect of lockup was was determined determined applicable since to be applicable since Fluorogold Fluorogold was was being being used in the same application application as as Lubrite Lubrite material. In an application material. application in in the RB, the slide slide bearing bearing plates plates are are in an an area area of high high radiation, so the radiation, the aging aging effect of changechange in in material material properties properties waswas determined determined to be applicablebased applicable based on vendor literature.

literature. Plant-Specific Plant-Specific Notes 510 510 for the RB and and 551 551 for the Cable Bridge Cable Bridge were used to provide clarification.

used to provide clarification.

The aging aging effect of change change in in material material properties properties due due to to radiation radiation could could affect the sliding sliding function of the Fluorogold, function Fluorogold, andand result result in in damage to the the steel steel members.

members. The Fluorogold Fluorogold bearing surfaces bearing surfaces are are inaccessible, inaccessible, except for for the edges.edges. Therefore, Therefore, the the Structures Structures Monitoring Program Monitoring applications perform Program applications perform visual visual inspections inspections for restricted restricted movement and damagedsteel members or damaged or connections connections (deformations, (deformations, tears, cracks, or tears, cracks, or broken broken welds).

welds). TheThe ASME Section Section XI, XI, Subsection Subsection IWF Program, Program,applications applications perform examinations examinations of supports supports including structural including structural degradation degradation of building building structure; structure; loosened, loosened, bent, bent, cracked cracked or or damaged damaged parts; cracked parts; cracked or degraded degraded welds; welds; obstructions obstructions to pipe movement, movement, misalignment misalignment and improper clearances; improper clearances; evidence of overload; scoring or overload; scoring or roughness roughness on sliding sliding surfaces; surfaces; and foreign material foreign materialaccumulation.

accumulation.

There areare no other other aging aging effects applicable applicableto the slidingsliding bearing bearing plates, plates, other other than than the three three identified identified in this response.

response.

2. Standard

2. Standard Review Plan-License Plan-License Renewal (SRP-LR), Section 3.5.2.2.2.1, 3.5.2.2.2. 1, was only applicable applicable to Lubrite material, as stated Lubrite material, stated in LRALRA Table Item 3.5.1-30.3.5. 1-30. Since Fluorogold Fluorogold was used, used, no further evaluation was provided further evaluation provided in LRA Subsection Subsection 3.5.2.2.2. 1.

3.5.2.2.2. 1. LRA, Subsection Subsection 3.5.2.2.2.1, did state, state, "Lock "Lock up due to wear wear for Lubrite Lubriteradial radial beam seats seats in BWR drywell, drywell, RPV support support shoes shoes for PWR with nozzle supports, supports, steam generator supports, and generator supports, and other other sliding support bearings and sliding support sliding support bearings and sliding support surfaces surfaces is not applicable because applicable because CR-3 does not utilize Lubrite Lubrite in these applications."

applications." The CR-3 methodology associated associatedthe Fluorogold Fluorogold slide bearing bearingplates plates with the applicable applicable commodities commodities either either "Steel "Steel Components:

Components: All Structural Structural Steel" and/or Steel" "Supportsfor ASME and/or "Supports ASME ClassClass 1, 2, 3 Piping 1, 2, Piping & & Components" Components"in LRA LRA Tables Tables 3.5.2-1, 3.5.2-2, 3.5.2-2, 3.5.2-5, 3.5.2-5, and 3.5.2-14 and and provided provided an explanation Plant-SpecificNotes explanation in Plant-Specific Notes 510, 510, 511, 549, 549, and 551.

3. The aging aging effect/mechanism of Loss of Mechanical Mechanical FunctionFunction due to corrosion, distortion, corrosion, distortion, dirt, overload, dirt, overload, fatigue fatigue due to vibratory vibratory and cyclic thermalthermal loads loads is applicable applicable andand considered considered inclusive of accumulation accumulation of debris debris which may resist resist sliding.

sliding.

RAI 3.5.2.2.2.1-2 3.5.2.2.2.1-2 Backqround

Background

SRP-LR, SRP-LR, Section Section 3.5.2.2.2.1, 3.5.2.2.2.1, and GALLGALL Report, GenericGeneric Item Item T-03, T-03, recommend recommend the Structures Structures Monitoring Program Monitoring Program to to manage manage cracking cracking duedue to expansion expansion and and reaction reaction with with aggregates aggregates in accessible accessible concrete concrete areas areas regardless regardless of how how the concreteconcrete was constructed constructed or how the the aggregates aggregates werewere tested.

U. S. Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 77 of 26 26 Issue LRA, Section 3.5.2.2.2.1, states that the aging effect is not applicable because of the tests done LRA, Section 3.5.2.2.2.1, states that the aging effect is not applicable because of the tests done aggregates and the method of construction.

on the aggregates Request Explain why the Structures Monitoring Program does not inspect accessible Monitoring Program accessible concrete concrete for thethe aging effect of cracking due to expansion and reaction reaction with aggregates, when the GALL Report recommends inspections of accessible recommends accessible areas regardless of the construction construction and testing methods.

Response

Response Structures Monitoring The Structures Monitoring Program Program examines CR-3 accessible accessible concrete concrete for for the aging aging effect of of

~ cracking regardless cracking aging mechanism.

regardless of the aging mechanism. The License Renewal basis basis document document for for the Structures Monitoring Structures Programonly identifies Monitoring Program identifies the aging aging effects such asas cracking cracking with no specific specific aging mechanisms aging mechanisms identified.

identified. cracking envelopes any aging The cracking aging mechanism, mechanism, including NUREG-1801, NUREG-1801, Generic Generic Item T-03.

T-03.

However, CR-3 did provide However, further evaluation provide furlher evaluation why cracking cracking due due to expansion expansion and reaction reaction with aggregates was not applicable aggregates applicable in LRA Subsection 3.5.2.2.2.

LRA Subsection 3.5.2.2.2.1.2. LRA Subsection 1.2. LRA Subsection 3.5.2.2.2.

3.5.2.2.2.1.2 1.2 states that CR-3 fine and coarse states coarse aggregates aggregateswere testedtested with each each brand brandof cement for possible possible alkali reaction alkali reaction in accordance accordance with American Society for for Testing and Materials Materials (ASTM) C227, C227, "Test for Potential "Test PotentialAlkali Reactivity of Cement-Aggregate Cement-Aggregate Combinations, Combinations, (Mortar Bar Method),"

(Morlar Bar and aggregates and aggregatesdid did not react react within the reinforced reinforced concrete.

concrete. American Concrete Concrete Institute (ACI)

Institute (ACI) 201.2R indicates indicates ASTM ASTM C227C227 is generally generally relied indicate potential relied on to indicate potential alkali alkali reactivity.

reactivity. In addition, the License Renewal basis addition, basis document provides provides additional details why the aging additional details mechanism of expansion mechanism expansion and and reaction aggregates was determined reaction with aggregates determined to not be applicable.

applicable.

Based on ACI 201.2R, Based chemical reaction 201.2R, chemical reaction of aggregates concrete is aggregates in concrete is typically typically associated associated with aggregates from Kansas, aggregates Kansas, Nebraska Nebraska and easterneastern Wyoming. CR-3 used coarse coarse aggregate aggregate and aggregatesfrom local fine aggregates local pits located located in Florida.

Florida.

addition, NUREG-1557, In addition, NUREG-1557, "Summary "Summary of Technical Technical Information Information and Agreements from Nuclear Management and Resources Management Resources Council Council Industry Industry Reporls Reports Addressing Addressing License Renewal," Table B3, states, "Reactions states, "Reactions with aggregates aggregates are are non-significant non-significant for concrete concrete containment structures containment structures constructed from aggregate constructed aggregate taken from geographic regions other geographic regions than those known to yield other than aggregates suspected aggregates suspected of or known to cause cause alkali-aggregate alkali-aggregatereactions; reactions; or from aggregate aggregate that that was investigated, investigated, tested, & subject tested, & subject to petrographic petrographic exam conducted conducted in accordance accordance with ASTM C295, or ASTM C295, ASTM C227, C227, which showed that that the aggregate aggregate isis non-reactive."

non-reactive."

There has There has been no specific plant operating operating experience associatedwith concrete experience associated concrete cracking cracking duedue to expansion expansion and reaction reaction with aggregates.

aggregates.

U. S. Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 88 of 26 3.5.2.2.2.2-1 RAI 3.5.2.2.2.2-1

Background

Background The GALL necessary for inaccessible management is not necessary GALL Report states that aging management concrete inaccessible concrete cracking due to expansion cracking expansion and reaction with aggregate aggregate ifif ASTM C227 or C295 were used to to demonstrate that the aggregates demonstrate aggregates do not react within the concrete.

Issue accordance with ASTM C227; however, the aggregates were tested in accordance The LRA states that the aggregates the unable to verify this in the Final Safety Analysis Report staff was unable Report (FSAR).

Request Provide documentation showing the aggregates documentation showing accordance with ASTM aggregates are not reactive in accordance C227 or C295, or explain how the standards documented in the FSAR standards documented FSAR meet or exceed the the requirements requirements of ASTM C227 or C295.

Response

Response The CR-3 Final (FSAR) does not specifically Final Safety Analysis Report (FSAR) specifically list ASTM C227 or ASTM C227 or C295.

C295.

However, "Concr~te," states However, FSAR Section 5.2.2.1, "Concrete," states that that concrete concrete aggregates aggregatesconform to ASTM C33-67.

C33-67. ASTM C33, ASTM C33, Appendix XI, lists methods for evaluating X1, lists potential reactivity evaluating potential reactivity ofof aggregates. ASTM aggregates. C227 is ASTM C227 is listed as as one of the proposed evaluating potential proposed methods for evaluating potential aggregate. In addition, reactivity of aggregate.

reactivity addition, as stated stated in response response to RAlRAI 3.5.2.2.2.1-2, 3.5.2.2.2.1-2, ACI 201.2R indicates ASTM indicates ASTM C227 is generally relied on to indicate generally relied potential alkali indicate potential alkali reactivity, and acceptance reactivity, and acceptance criteriaare criteria are given by ASTM ASTM C33 for evaluating these test results.

evaluating these results. Fine and coarse Fine and aggregatesat coarse aggregates CR-3 were tested with each each brand possible alkali brand of cement for possible alkali reaction reaction in accordance accordance with ASTM ASTM C227. information was provided This information C227. This provided to the NRC in in Appendix A (PageA-2) of the Final A (Page Final Report - Reactor Building Report Reactor Building Dome Delamination transmitted Delamination transmitted by CR-3 letter dated December letter dated December 10, 10, 1976 (Accession (Accession No. ML4006001187).

ML4006001187).

3.5.2.2.2.2-2 RAI 3.5.2.2.2.2-2

Background

Background The GALL Report states that aging management necessary for increase management is not necessary increase in porosity porosity and permeability and loss of strength due to leaching permeability leaching in inaccessible concrete ifif the concrete was inaccessible concrete was constructed in accordance constructed recommendations in ACI 201.2R-77. However, further accordance with the recommendations evaluation is necessary ifif the concrete is not constructed evaluation accordance with the constructed in accordance the recommendations in ACI 201.2R-77.

Issue The LRA states that CR-3 concrete was constructed in accordance accordance with ACI 301-66, which provides guidance similar recommendations in ACI 201.2R-77.

similar to the recommendations

U. S. Nuclear Regulatory Commission U. Commission Enclosure 1 3F1209-03 3F1209-03 Page Page 9 of 2626 Request Clearly explain explain how ACI 301-66301-66 meets the intentintent of ACI 201.2R-77. Include important concrete important concrete design parameters water-cement ratio, air entrainment, etc.)

parameters (e.g. water-cement demonstrate CR-3 etc.) which demonstrate CR-3 concrete meets concrete meets the recommendations recommendations in ACI 201.2R-77.

201.2R-77.

Response

Response Concrete for Concrete for CR-3 structures structures conformed to applicable applicable versions versions of ACI 301, with supplemental supplemental requirements added by site specifications.

requirements specifications. While generalgeneral recommendations recommendations are are in ACI 301, supplemental requirements supplemental requirements for for concrete concrete design design parameters parameterswere were provided provided in the CR-3 concrete concrete specifications.

specifications. A review of the CR-3 concrete specifications concrete specifications and a comparison comparison to ACI 201.2R recommendationsis recommendations is provided below:

provided below:

concrete specifications:

CR-3 concrete specifications:

content Air content

• • 3-6% for 1 13Y2 inch aggregate aggregate size and and 3/4% inch aggregate aggregate size for for original originalconstruction construction

• • 3-6% for Emergency Emergency Feedwater Feedwater (EFW)(EFW) Tank Enclosure Enclosure Building

• • 1.5% (approximately)

(approximately)for EFW Pump Pump Building Maximum Water Water cement ratio ratio (w/c)

(wlc)

• • 3000 psi mix - 6 gallons gallons of water waterper per sack of cement (0. 53) for (0.53) for original originalconstruction construction

• • 5000 psi mix - 5 gallons gallons of water waterper per sack of cement (0. 44) for (0.44) for original originalconstruction construction

• • 4000 psi mix - 0.43 0. 43 - 0.47 (approximately)

(approximately)for EFW Pump Building

• 5000 5000 psi mix - S;5 0.50 for EFW Tank EnclosureEnclosure Building

• • 6000 6000 psi mix - 0. 38 actual 0.38 actual mix design design used used on RB dome MaterialsStandards Materials Standards

• • Cement Cement - ASTMASTM C150 Type 1/ II (Type I oror II 1/ for EFW Pump Pump Building)

Building)

• • Aggregate Aggregate - ASTMASTM C33

• • Chemical Chemical Admixture - ASTM-494 ASTM-494

• • Air Entraining EntrainingAdmixture - ASTM ASTM C260 comparison of the CR-3 ACI 301-66 design A comparison design parameters parameters usedused along along with the CR-3 concrete concrete specificationsto ACI 201.2R-77 is summarized specifications summarized below:

below:

For For air air content, content, ACI 201.2R, 201.2R, Table 1.4.3 recommends recommends an averageaverage air air content content of 4Y2 4Y2 % +/- 1Y21Y %

(3-6%) for 111/24 inch aggregate Y2 inch aggregate and and 5% +/- 11/24%

1Y2% (331/2-61/2 (3Y2-6Y2 %9)

%) for % aggregate for a moderate Y inch aggregate moderate exposure.

exposure. The CR-3 concrete concrete specifications specifications required range of 3-6% except for the EFW required a range Pump Building. concrete batch Building. Actual concrete batch tickets showed the air air content at approximately approximately 1.5% for the EFW Pump Building.Building. However, However, ACIACI 201.2R concrete concrete air content is air content is based based on moderate moderate exposure, whereas exposure, whereas CR-3 is locatedlocated in a negligible weathering region.

negligible weathering region. Since therethere is not an air air content specified content specified in ACI 201.2R for a negligible negligible weathering weathering region, region, the lower value for for the EFW Pump Building Building is considered considered acceptable.

acceptable.

For w/c, ACI 201.2R, For wlc, Section 1.4.2, 201.2R, Section 1.4.2, recommends recommends not exceedingexceeding a wlc w/c of 0.50 for frost resistant resistant regular weight concrete regular concrete for the category category of "All"All other other structures" structures" which would apply at CR-3. CR-3.

A Cl 201.2R, Table ACI201.2R, Table 2.2.3, 2.2.3, recommends recommends a wlc w/c not exceeding 0.50 for concreteconcrete subject subject to sulfate

U. S. Nuclear Regulatory U. Regulatory Commission Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 10 of 26 26 attack (such attack (such as in seawater),

seawater), but refers refers to Section 4.5.1.1 for lower w/c ratios ratios which may be necessary to prevent necessary corrosion of embedded steel.

prevent corrosion steel. ACI201.2R, ACI 201.2R, Section 4.5.1.1 recommends,recommends, where corrosion where corrosion may be a problem,problem, a wlc 0. 45 to provide w/c of 0.45 provide good protection against corrosion.

protection against corrosion.

It also states a w/c of 0.40 performs also states performs significantly better and significantly better and recommends the wlc wic should should not exceed exceed 0.40 for for concrete concrete exposed to seawater.

seawater. It also provides provides an an allowance allowance to increase increase the w/c to 0.45 increased by Yz

0. 45 if the cover over any metal is increased 1/2 inch.

inch. It also also states states above the sea sea and range, the w/c should spray range, spray should not exceed 0.50. 0.50. AC!ACI 201.2R, 201.2R, Section 4.5.2, recommends 3 inches 4.5.2, recommends minimum concrete concrete cover on reinforcing reinforcingsteel for concrete concrete near near the waterline waterline or or in in other other locations exposed to a combination combination of seawater seawaterand and atmospheric atmospheric oxygen in marine marine construction.

construction.

Based on a comparison, structures constructed comparison, the structures constructed with 3000 psi psi concrete seawater concrete subject to seawater are are above the maximum w/c ratio range of ACI ratio range ACI 201.2R (0.53(0.53 versus versus 0.45). This would include the Circulating Water Intake Structure, Circulating Water Structure, Circulating Water Discharge Circulating Water Structure, the Nuclear Discharge Structure, Nuclear Service Sea Water Water Discharge Discharge Structure, Structure, and the Raw Water Water PitsPits of the AB. However,However, the the concrete concrete cover over the reinforcing reinforcing steel has been specified specified on the design drawings design drawings as as 4 inches at the Circulating Circulating Water Water Intake Structure Structure and the Nuclear Nuclear Service Sea Water Water Discharge Discharge Structure and Structure and 3 inches inches at the Circulating Circulating Water Water Discharge Discharge Structure Structure andand the Raw Water Pits, Pits, which meets or exceeds the recommendations recommendations in ACI ACI 201.2R, 201.2R, Section 4.5.2 for for additional additional corrosion protection.

corrosion protection. The remaining structures constructed remaining structures constructed with 3000 psi concrete concrete are are slightly slightly above the maximum wlc w/c ratio ratio range range of ACI 201.2R (0.53 versus versus 0.50). For For these structures, structures, this minimal this minimal difference difference is considered negligible.

considered negligible.

For suitable For suitable materials, materials, ACI 201.2R, Section 1.4.4, 201.2R, Section 1.4.4, recommends materials include recommends materials include cement conforming to ASTM conforming ASTM C150, C150, aggregates conforming to ASTM aggregates conforming ASTM C33, C33, air-entraining admixture air-entraining admixture conforming to ASTM conforming ASTM 260,260, and and chemical chemical admixtures admixtures conforming conforming to ASTM-494. ACI ACI 201.2R, 201.2R, Table 2.2.3 recommends Table recommends use of Type /III cement for concrete concrete in seawater.

seawater. CR-3 concrete concrete specificationsrequire specifications materials which conform to the same ASTM require materials standards. In addition, ASTM standards. addition, CR-3 used fine and and coarse coarse aggregates aggregates from local quarries and local quarries and tested tested cement for possible alkali possible alkali reaction in accordance reaction in accordance with ASTM ASTM C227,C227, as discussed discussed in ACI 201.2R, Chapter 5 (refer 201.2R, Chapter (refer to RAI response 3.5.2.2.2.1-2).

response 3.5.2.2.2.1-2).

In summary, comparison of the ACI 301 design summary, a comparison design parameters parameters and and the CR-3 concrete concrete specifications to ACI 201.2R-77 shows that specifications that the air air content and the materialmaterial standards standards are are comparable except for comparable for the EFW Pump Building Building which has a lower minimum air air content content than than shown in the air content table'in air content table'in ACI 201.2R, Table 1.4.3. However, However, CR-3 is is in a negligible negligible weatheringregion weathering and ACI region and ACI 201.2R rangesranges areare provided provided for moderate moderate exposures.

exposures. The wlc w/c ratios ratios for the structures for constructed with 3000 structures constructed 3000 psi concrete, concrete, andand in a seawater seawaterenvironment, environment, are are above the range range of ACI 201.2R, Section ACI 201.2R, Section 4.5.1.1.

4.5.1.1. However, However, the reinforcing reinforcing steel concrete concrete cover has been specified on the design drawings as 4 inches design drawings inches at the Circulating Circulating Water IntakeIntake Structure Structure and Nuclear Service Sea Water the Nuclear Water Discharge Discharge Structure Structure and 3 inchesinches at the Circulating Circulating Water Discharge Structure Discharge Structure and the Raw Water Water Pits, Pits, as recommended recommended in AC! ACI 201.2R, 201.2R, Section 4.5.2, 4.5.2, for additional corrosion protection.

additional corrosion protection. In addition, these structures addition, these structures in seawater, 'including the seawater, including submerged concrete, submerged concrete, are are visually visually inspected inspected with the StructuresStructures Monitoring Monitoring Program.

Program.

Submerged concrete concrete is considered considered accessible accessible with divers divers or or by draining draining the areas areas and performing performing the visual inspections.

inspections. The portions structure in soil/groundwater portions of the structure soillgroundwater will also also bebe inspected whenever they are inspected are made accessible accessible by excavation excavation for for any reason. conclusion, reason. In conclusion, design parameters while the design parameters are are not an exact match with ACI 201.2R, 201.2R, the methodology employed using ACI ACI 301-66 and and the CR-3 concrete concrete specifications specifications provided provided similar guidance for similar guidance producing producing a low permeability, dense, air entrained, permeability, dense, air entrained, low water-cement water-cement ratio concrete similar ratio concrete similar to ACI 201.2R.

ACI201.2R.

U. S. Nuclear U. Nuclear Regulatory Regulatory Commission Enclosure 1 3F1209-03 3F1209-03 Page 11 of 2626 Concerning Concerning the background background information above, related information above, related to increase increase in porosity porosity andand permeability permeability and loss of strength and strength due to leaching leaching of calcium calcium hydroxide for for inaccessible areas of concrete, inaccessible areas concrete, Subsection 3.5.2.2.2.2.5, LRA, Subsection 3.5.2.2.2.2.5, provides provides further evaluation discussion furtherevaluation discussion andand states:

states:

Concrete was constructed Concrete ACI 301-66, which provides constructed to AC1301-66, guidance similar provides guidance similar to ACI 201.2R for producing for producing high high density, permeability concrete density, low permeability concrete mix designs.

designs. However, However, an increase increase in porosity porosity and permeability permeability due to leaching leaching of calcium calcium hydroxide is conservatively considered conservatively considered to be an aging requiring aging management aging effect requiring aging management because because of of existence of minor the existence minor indications leaching in below-grade indicationsof leaching below-grade concrete concrete in the RB tendon tendon access gal/ery.

access Therefore, any below grade gallery. Therefore, concrete in the scope grade concrete scope of License Renewal examined whenever excavated will be examined excavated for any reasonreason in accordance accordance with the Structures Structures Monitoring Program.

Monitoring Program.

Therefore, Therefore, any concrete structure in concrete on any structure in the scope of License Renewal when made accessible excavation of backfill, during excavation accessible during backfill, will be inspected inspected in accordance accordance with the Structures Structures Monitoring Program.

Monitoring Program.

3.5.2.2.2.2-3 RAI 3.5.2.2.2.2-3

Background

Background 3.5.2.2.2.4.1, recommend further evaluation 3.5.2.2.2.2.4 and 3.5.2.2.2.4.1, SRP-LR, Sections 3.5.2.2.2.2.4 evaluation and aa plant-specific AMP for concrete concrete structural elements exposedexposed to aggressive groundwater.

to aggressive Issue Plant-Specific Note 543, states that the seawater LRA, Plant-Specific aggressive and that the seawater at CR-3 is aggressive the Structures Monitoring Monitoring Program will be used to manage the aging aging effects of the concrete concrete exposed to seawater.

Request

1. Explain why the Structures Monitoring Program, including inspection methods and including existing inspection frequencies, frequencies, is adequate to manage manage the aging effects of concrete exposed to an aggressive concrete exposed aggressive environment and why a plant-specific seawater environment plant-specific AMP is not necessary. Provide any further further evaluation that was performed performed to support this conclusion.

2. Explain howhow an aggressive environment affects the necessary aging management seawater environment aggressive seawater management inaccessible areas of inaccessible Groups 1-3, 5, and 7-9 structures and Group 6 structures as areas of Groups as discussed in LRA, Sections 3.5.2.2.2.2.4 3.5.2.2.2.2.4 and 3.5.2.2.2.4.1, 3.5.2.2.2.4.1, respectively.

Response

Response

1. The commodity "Concrete:

1. Submerged" was added "Concrete: Submerged" structures addressed added to the structures addressed in LRA LRA Tables 3.5.2-2, Tables 3.5.2-2, 3.5.2-5, and 3.5.2-9 for concrete 3.5.2-8, and 3.5.2-5, 3.5.2-8, aggressive seawater concrete exposed to aggressive seawater environment (i.e., Raw Water Water - Seawater).

Seawater). For For "Concrete:

"Concrete: Submerged," CR-3 aligned aligned with the applicable NUREG-1801, Table applicable NUREG-1801, Table III.A3-7 and III.A5-7, or III.A6-6"and III.A5-7, or III.A6-6 and III.A6-7 line items for "water-flowing" "water-flowing"for structures in LRA for each of the structures LRA Tables 3.5.2-2, 3.5.2-2, 3.5.2-5, 3.5.2-8, and 3.5.2-5, 3.5.2-8, 3.5.2-9. However, there is 3.5.2-9. However, is not a specific NUREG-1801, NUREG-1801, AMP III.A6, line item for a raw water Ill.A6, line

U.

U. S. Nuclear Regulatory Commission Commission Enclosure 1 Enclosure 3F17209-03 3F1209-03* Page 12 of 2626 or water-flowing water-flowing environment environment which discusses discusses the aggressive water criteria.

aggressive water criteria. Therefore, Therefore, CR-added a specific 3 added specific line item to each each of the water-control water-control structures structures to address reinforced address reinforced concrete concrete "Concrete: Submerged" in a Raw Water "Concrete: Submerged" Water - Seawater environment and Seawater environment and applied applied aging effects of loss of material, aging cracking, and change material, cracking, change in material material properties along with a properties along Plant-SpecificNote 543 that Plant-Specific that stated:

stated:

NUREG-1801 only addresses addresses "corrosion "corrosion of embedded steel" steel" oror "aggressive "aggressive chemical chemical attack" attack" for a groundground water/soil environment. In Group water/soil environment. Group 3 and and Group Group 6 structures, structures, NUREG-1801 does not address NUREG-1801 address "corrosion "corrosionof embedded embedded steel" "aggressivechemical steel" or "aggressive chemical attack" attack" in a Raw Water Water environment.

environment. CR-3 Group Group 3 and and Group Group 6 structures structures have concrete components in a Raw Water concrete components Water environment.

environment. Raw Water Water - Seawater Seawater is aggressive aggressive at CR-3 because because the sulfate content is greater greater thanthan 1500 ppm and and the chloride chloride content is greater greater than than 500 ppm. Concrete Concrete cracking, cracking, loss of material, material, and change in change in material material properties properties are are applicable aging effects for the submerged applicable aging submerged concrete.

concrete.

The Structures Structures Monitoring Program is Monitoring Program is used to managemanage aging aging effects of submerged concrete concrete for for loss of material, cracking, and material, cracking, and change change in material materialproperties.

properties.

Since there there was not a specific specific NUREG-1801, NUREG-1801, Table III.A6 Ill.A6 line line item, item, with raw water water or water-water-flowing environment environment which required plant-specific program, required a plant-specific program, a plant-specific program was plant-specific program was not provided.

provided. However, However, CR-3 uses the StructuresStructures Monitoring Monitoring Program Programto address address concrete concrete in an aggressive in aggressive Raw Water - Seawater Seawater environment environment for the extended period operation period of operation based based on the following:

following:

• " concrete is accessible The concrete accessible for visual inspection inspection by using divers divers oror by draining draining portions portions of the structure structure for inspection.

inspection.

• • The periodic periodic inspection inspection frequency is is five years years as specified specified in ACI 349.3R, 349.3R, Chapter Chapter 6, for 6, for continuous continuous fluid-exposed fluid-exposed structures.

structures.

• • The implementing implementing procedure requires a reassessment procedure requires inspection frequency reassessment of the inspection based results of the periodic based on the results periodic inspection inspection commensurate commensurate with its its condition.

condition.

• " Concrete Concrete structures constructed with high density, structures were constructed density, low permeability permeability mix designs as discussed as discussed in RAI Response 3.5.2.2.2.2-2.

3.5.2.2.2.2-2.

• • Plant operating experience Plant operating experience to date date has has identified identified no unacceptable unacceptable concrete aging concrete aging effects due to the aggressive aggressive seawater seawater environment.

environment. Thus, Thus, there there has has been no loss of the structures' intended functions.

structures' intended functions.

• • Progress Progress Energy's Robinson and Energy's Robinson and Brunswick plants plants (with aggressive aggressive water) water) are are currently using currently using the samesame common implementing implementing procedure procedure at theirtheir water-control water-control structuresand inspecting structures submerged concrete.

inspecting submerged concrete.

Based upon the above, Based above, the Structures Structures Monitoring Monitoring Program; Program, including including existing existing inspection inspection methods and frequencies, frequencies, is adequate to manage manage the aging concrete exposed aging effects of concrete exposed to an aggressive aggressive seawater seawater environment.

environment.

2. LRA

2. LRA Subsections Subsections 3.5.2.2.2.2.4 and 3.5.2.2.2.4.1 discussion discussion is basedbased on the Groups Groups 1-3, 1-3, 5, 5,

and 7-9 structures and structures andand Group Group 6 structures structures in a groundwater groundwater environment.

environment. At CR-3, the groundwater has groundwater has been determined determined to be non-aggressive non-aggressive as stated stated in LRALRA Subsections 3.5.2.2.2.2.4 and and 3.5.2.2.2.4.1.

3.5.2.2.2.4. 1. However, However, the LRA LRA included included the statements:

statements:

However, concrete However, concrete cracking, cracking, loss of material, material,and and change change in material materialproperties propertiesareare conservatively assumed conservatively assumed to be applicable applicable to CR-3 in the soil environment.

environment.

U.

U. S. Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 13 of 2626 Structures Monitoring The Structures Monitoring Program Programwill continue continue to monitor groundwateron a periodic monitor groundwater periodic basis including basis including consideration considerationof potential potential seasonal variations.

seasonalvariations. The Structures Monitoring Structures Monitoring Programwill also Program also continue to examine the exposed portions portions of the below grade concrete grade concrete excavated for any reason.

when excavated reason.

The aggressive aggressive seawater environment was seawater environment was applied applied to the commodity "Concrete: "Concrete:

Submerged" as discussed Submerged" discussed in in response Question 1 above and not to the structures response to Question structures in a soil environment.

environment. Therefore, Therefore, the aggressive aggressive seawater seawater environment environment has no affect on the portion structuresin a soil environment portion of the structures environment with non-aggressive non-aggressive groundwater.

groundwater.

RAI 3.5.2.3-1 3.5.2.3-1

Background

Background Several Table Table 2's in LRA, Section Section 3.5, list the aging effect and AMP as none none for carbon steel, stainless steel and galvanized steel anchorage and embedment component groups embedded in concrete. The plant-specific plant-specific note also compares the line items to mechanical mechanical piping piping components in the GALL Report with no aging aging effect listed for carbon and stainless embedded in concrete.

Issue The components components under consideration occur occur throughout thro~ghout the plant, including including areas where where present in the concrete. The GALL Report moisture may be present Report for items in which moist concrete concrete may occur identifies identifies an aging effect of cracking, loss of bond, and loss of material material (spalling, scaling)/corrosion of embedded scaling}/corrosion embedded steel managed managed by the Structures Structures Monitoring ProgramProgram (e.g.

generic item T-05). .

Request Explain the evaluation which concluded concluded these items could be compared compared to mechanical mechanical piping systems with no aging effects, as opposedopposed to steel and concrete concrete in an environment environment that may be be wet and require aging aging management. Include Include a discussion discussion of the environments environments the surrounding surrounding concrete is exposed to (i.e. seawater, aggressive aggressive groundwater, groundwater, contaminants, contaminants, etc.).

Response

Response "Anchorage/Embedment"commodity in The "Anchorage/Embedment" in LRA LRA Tables 3.5.2-1 through through 3.5.2-19 was addedadded at CR-3 because there was not a specific NUREG-1801, because there NUREG-1801, Chapter" ChapterII or or III, Ill, item for for anchorages anchoragesand embedment completely embedded in a reinforced reinforced concrete environment.

concrete environment. The The "Anchorage/Embedment"commodity uses "Anchorage/Embedment" uses concrete as the environment concrete as environment and and does not replace replace any of the wet environments environments that may surround surround concrete concrete as described described in NUREG-1801, NUREG-1801, Chapters II and III.

Chapters" Ill.

The methodology of using using AMR comparisons to NUREG-1801, AMR comparisons NUREG-1801, based based on the material material and environment regardless regardless of the NUREG-1801 Chapter Chapter to which the comparison comparison is made, made, has been previously usedused by Progress ProgressEnergy and other other utilities LRA submittals.

utilities in LRA submittals. In this example, example, Plant-SpecificNote 501 was used a Plant-Specific used to explain explain why there there were no agingaging effects. The note stated the CR-3 AMR AMR methodology concluded concluded there there were no aging aging effects when components components are are

U. S. Nuclear Regulatory Regulatory Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 14 of 26 encased in concrete.

completely encased concrete. Use Use of the mechanical mechanical commodity, commodity, for for steel embedded in concrete concrete to validate that there validate that there were no aging aging effects, was justified since the mechanical justified since mechanical NUREG-1801 NUREG-1801 table items had the same material material and environment.

environment. In this this example, example, the concrete considered to have a high alkalinity concrete is considered alkalinity (pH >12.5) and is not subject to an aggressive (pH >12.5) aggressive environment (such (such as seawater seawater or contaminants) contaminants) as defined in NUREG-1801, Chapter Chapter III.A3-4.

CR-3 does not have aggressive groundwateras aggressive groundwater as discussed discussed in LRALRA Subsection Subsection 3.5.2.2.2.4.1.

3.5.2.2.2.4. 1.

RAI 3.5.2.3-2 3.5.2.3-2

Background

Background Under item III.A6-9 II1.A6-9 (T-22), the GALL GALL Report specifies an aging effect requiring management management (AEM) as loss of material, loss of form/erosion, formlerosion, settlement, frost action, waves, currents, surface surface runoff, and seepage seepage for earth in flowing and standing water.

Issue In LRA, Table specified only loss of material Table 3.5.2-7, CR-3 has specified material and loss of form of earth in raw water (sea water) environment. The AEM erosion, settlement, frost action, waves, currents, surface runoff, and seepage seepage are not listed.

Request Provide justification for not addressing addressing the AEM erosion, settlement, frost action, waves, currents, surface runoff, and seepage. If If it is an oversight, describe describe how these aging effects will be managed managed by the Structures Monitoring Monitoring Program Program so that the structures will perform the the intended functions functions and maintained consistent with the current maintained consistent current licensing basis basis (CLB) during the the period of extended extended operation.

Response

Response LRA Table 3.5.2-7 provides provides the aging aging effects requiring requiringmanagement management and does not list the aging aging mechanisms. The aging mechanisms. aging effects of loss of material material and loss loss of form are provided for both the are provided the Water - Seawater Raw Water Seawater and and the Air - Outdoor Outdoor environments.

environments. LRA LRA Table 3.5.2-7 is is evaluated evaluated in LRA Table 3.5.1, Item 3.5.1-48.

3.5.1-48. The LRA Table 3.5.1, LRA Table 3.5. 1, Item 3.5.1-48, 3.5.1-48, discussion states that discussion states that CR-3 is is consistent consistent with NUREG-1801 for material, environment material, environment and aging effect.

aging effect. The specific aging aging mechanisms (erosion, mechanisms (erosion, settlement, settlement, sedimentation, sedimentation, frost action, waves, currents, action, waves, currents, surface surface runoff, runoff, and seepage) and seepage) are are included included in the License Renewal AMR AMR basis basis document.

document. The aging aging effects will be managed managed by the Structures Monitoring Program, Structures Monitoring Program,LRA Subsection B. 2.

LRA Subsection 2.30, as identified 30, as identified in the the enhancement:

enhancement:

Identify additional additionalcivil/structural civil/structuralcommodities commodities along with the associated associatedinspection inspection attributes attributes and performance and standard required performance standard License Renewal in the corporate required for License corporate procedure procedure for condition monitoring condition monitoring of structures.

structures.

U. S. Nuclear U. Regulatory Commission Nuclear Regulatory Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 15 of 2626 3.5.2.3-3 RAI 3.5.2.3-3

Background

Background In LRA, Table Table 3.5.2-12, CR-3 has credited the Structures MonitoringMonitoring Program for managing the the aging effect of loss of material material of carbon stainless steel in treated water. Also the carbon steel and stainless the applicant has added plant-specific plant-specific Notes 546 and 527. Note Note 546 states states that the CR-3 aging aging management management review (AMR) methodology methodology concluded that carbon carbon steel in aa treated treated water water environment has loss of material as aging effect. Note environment Note 527 states that the CR-3 methodology methodology concluded that stainless steel conduits and support steel located located in the dedicated dedicated EFW Tank Enclosure Building northwest northwest corner recessed area recessed area (similar to a a sump) will have the aging aging effect of loss of material. Also these two line items are assigned with Generic Note Note G which represents environment not in the GALL Report Report for this component component and material.

For similar material/environment/aging material/environment/aging effect effect combinations combinations involving stainless steel and steel, treated water, and loss of material, the GALL Report, Item VII.E3.15 (A-58) and VII.E3-18 (A35) management program described in GALL Report,Section XI.M2, "Water recommends the aging management recommends recommends that the AMP is to be augmented Chemistry." Also the GALL Report recommends augmented by verifying the effectiveness water chemistry effectiveness of water chemistry control. acceptable verification program is An acceptable recommended recommended in the GALL Report Chapter Chapter XI.M32, "One-Time Inspection."

Issue In LRA, Table 3.5.2-12, CR-3 has credited the Structures managing the Monitoring Program for managing Structures Monitoring the aging effect of loss of material material of carbon steel in treated treated water. However, for similar similar material/environment/aging effect material/environment/aging combinations the GALL Report recommends effect combinations recommends XI.M2, Xl.M2, "Water Chemistry", and XI.M32, "One-Time Inspection."

Request Program will monitor and manage the aging of stainless Describe how the Structures Monitoring Program stainless steel and steel in treated water environment.

environment.

Response

Response Structures Monitoring The Structures Programperforms visual inspections Monitoring Program stainless steel and steel inspections on the stainless components in the sump area components area of the EFW Tank Enclosure Bui/ding.

Enclosure Building. The visual inspections are visual inspections are performed during quarterly performed during quarterly walkdowns by the system engineer including inspections of the engineer including inspections the components in the sump.

components sump. Visual inspections inspections areare also performed by a structural also performed engineer on a structural engineer frequency not to exceed 10 years. Deficiencies are years. Deficiencies are identified Corrective Action identified in the CR-3 Corrective Program and Program and corrected corrected on a timely basis.

basis. As result of the system walkdown performed As a result performed in 2009, a work activity was February 2009, February was initiated initiated in the work management process to clean management process clean the the prepare the supports sump, prepare sump, supports and and sump for for coating restoration, and restore coating restoration, restore the coatings.

coatings. This demonstrates the Structures demonstrates Monitoring Program Structures Monitoring Program is managing managing the agingaging effect of loss of material.

material. Since these components are accessible are accessible for inspection, inspection, and are being are being inspected, inspected, no other aging other managementprogram aging management programis required.

required.

The sump areaarea in the EFW Tank Enclosure Building collects water Enclosure Building water from system leakage.

leakage. TheThe water collected in the sump varies water varies in depth depth and semi-annually. During and is pumped out semi-annually. During the the performed in February inspection performed inspection February 2009, water was 2009, no water was recorded recorded in the sump.

sump.

U.

U. S. Nuclear Nuclear Regulatory Regulatory Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 16 of 26 26 During this During this review, review, it was determined Plant-Specific Notes 527 and 546 identified determined Plant-Specific identified in LRA LRA Table 3.5.2-12 should 3.5.2-12 should be revised.

revised. Refer to the LRALRA changes provided in Enclosure changes provided Enclosure 2. 2.

RAI 3.5.2.3-4 RAJ

Background

Background In LRA, Table Table 3.5.2-2, CR-3 states that no AEM and therefore therefore no AMP is required for copper components in an environment including borated including borated water leakage. The LRA includesincludes plant-specific Note 525 with this AMR line item. Note 525 states that the CR-3 AMR AMR methodology methodology concluded that copper materials concluded materials in air-indoor air-indoor or borated water leakageleakage environments environments have no no aging effect. This applies applies only to straps for copper tubing. Also a Generic Generic Note JJ is assigned assigned to to this line item which represents that neither the component represents that component nor the material material and environment environment combination is evaluated combination evaluated in the GALL GALL Report.

material/environment/aging effect items, the GALL Report (Item V.E-11 (EP-38))

For similar material/environment/aging recommends recommends the Boric Acid Corrosion Corrosion Program for managing managing the aging effect of loss of material components in air with borated water leakage.

for copper alloy components Issue:

In LRA Table 3.5.2-2, CR-3 identifies an AEM of none and therefore therefore no AMP required for copper components in an environment environment of borated water leakage. The GALL Report identifies identifies loss of material material as an aging effect of concernconcern for copper copper components components in an environment environment including including borated water leakage leakage with the Boric Acid Corrosion Corrosion recommended recommended to managemanage the the aging effect of concern.

Request Justify why loss of material is not an aging effect effect of concern for copper components components in an environment that includes environment includes borated water leakage.

Response

Response In LRA LRA Table 3.5.2-2 for the AB, the commodity "Cable Tray, Conduit, "Cable Tray, Conduit, HVAC Ducts, Ducts, Tube Track" Track" for copper material copper material in a Borated Water Borated Water Leakage environment environment should have had an aging had effect of Loss of Material, Material, an an aging aging management management program program of Boric Acid Corrosion, Corrosion, a NUREG-180 1, Volume 2, Item of VII.

1801, VI1.1-12 1-12 (AP-66); Table I1 Item of 3.3.

(AP-66); a Table 1-88, and 3.3.1-88, and a Note C with no plant-plant-note.

specific note.

Plant-Specific Plant-Specific Note 525 should be changed changed to read:

read:

The CR-3 aging aging management management review methodology concluded concluded that copper copper materials materialsinin an an Air

- Indoor environment Indoor environment hashas no aging aging effects. This applies applies only to straps straps for copper tubing.

copper tubing.

These changes These changes to the LRA are addressed LRA are addressedfurther Enclosure 2.

further in Enclosure 2.

U. S.

U. S. Nuclear Regulatory Regulatory Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 17 of 26 RAI 3.5.2.3-5 RAI3.5.2.3-5

Background:

The GALL Report identifies aging effects of cracking, loss of bond, and loss of material scaling)/corrosion for embedded steel components. In (spalling, scaling}/corrosion In LRA, Tables 3.5.2-1 to 3.5.2-19, the corresponding aging effect is described as change in material 19, material properties.

The GALL Report identifies aging effects of loss of sealing/deterioration sealing/deterioration of seals, gaskets, and moisture barriers (caulking, flushing, and other sealants). In LRA, LRA, Tables 3.5.2-1 to 3.5.2-19, the corresponding aging effect is described as as cracking inin some places and change in material cases.

properties in other cases.

increase in porosity and permeability, cracking, loss The GALL Report identifies aging effects of increase loss of material scaling)/aggressive chemical attack. In material (spalling, scaling}/aggressive In LRA, Tables 3.5.2-1 to 3.5.2-19, corresponding aging effect is listed as loss of material.

corresponding Issue The aging effects listed in the LRA tables do not appear to be consistent with the GALL Report, Generic Note A has been assigned but Generic assigned to these AMR items which represents that these lines lines are consistent with the GALL Report.

Request Request Describe Describe how all the various aging effects described above will be managed effects described managed so that the the structures will be able to perform their intended functions consistent with the CLB during during the the period of extended operation.

Response

Response Crackinq, loss of bond, Cracking, bond, and and loss of material material {spalling, (spalling, scalinc)/corrosion scaling)/corrosion for for embedded steelsteel components stated in RAI As stated RAI response response 3.5.2.1-1, change change in material material properties properties is the aging effect effect used at CR-3 for loss of bond due to corrosion corrosion of embedded steel.steel. CR-3 used the term "change "change in material properties" material properties" to envelope the NUREG-1801 NUREG-1801 aging effect consistent with effect of loss of bond consistent the approach approach used for previous previous Progress Energy LRAs Progress Energy LRAs (Robinson (Robinson andand Harris Harris Nuclear Plants)

Nuclear Plants) and several other nuclear several other nuclearplants plants (e.g., Vogt/e Vogtle and Oyster Oyster Creek).

Creek). CR-3 considered considered the use of of change change in material materialproperties properties as equivalent equivalent to loss of bond, bond, consistent consistent with NUREG-1801 NUREG-1801 and assigned assigned the applicable Generic Note A. For applicable Generic For the RB, the concrete aging aging effect of change change in material properties, due to corrosion material properties, corrosion of embedded steel, steel, is managed managed by the Structures Monitoring Monitoring Program, Program, or the ASME ASME Section Xl, XI, Subsection IWL Program Program as shown in LRA LRA Table 3.5.2-1, using using visual inspections.

inspections. For For the remaining structures, remaining structures, the concrete aging effect of concrete aging of change change in material material properties, properties, due to corrosion corrosion of embedded steel, steel, is managed managed by the the Structures Monitoring Structures Monitoring Program Program as shown in LRA LRA Tables 3.5.2-2 throughthrough Table 3.5.2-19.

3.5.2-19.

Cracking and Cracking and loss of material, material, due to corrosion corrosion of embedded steel, steel, are all managed managed by the Structures Monitoring Structures Monitoring Program Progra(T1 as shown in LRALRA Tables 3.5.2-1 through through 3.5.2-19 using visual inspections.

inspections.

U. S. Nuclear U. Nuclear Regulatory Commission Regulatory Commission Enclosure Enclosure 1 3F1209-03 Page 18 26 18 of 26 applicable line items which align The applicable align with change change in material materialproperties, cracking, and loss properties, cracking, loss of of material in combination material combination due to corrosion corrosion of embedded steel in in LRA Tables 3.5.2-1 through LRA Tables through 3.5.2-19, are 3.5.2-19, identified in the column "Table are identified "Table 1 I Item" as as 3.5.1-01 3.5. 1-01 (C-05 (C-05 is the corresponding corresponding NUREG-1801, NUREG-1801, Volume 2, related generic 2, related generic Item, for example),

for example), 3.5.1-23 (T-04), 3.5.1-31 (T-05); (T-05),

and 3.5.1-34 (T-18). Line items using and using Plant-Specific Plant-Specific Note 543 for for the commodity "Concrete:

"Concrete:

Submerged" Submerged" were added to the applicable applicable LRA LRA Tables through 3.5.2-19 because Tables 3.5.2-1 through because the aging effects of change aging change in material material properties, properties, cracking, cracking, and and loss of material material due to corrosion corrosion of embedded steel were applicableapplicable to concrete concrete in in a Raw Water - Seawater Seawater environment.

environment. In addition, the applicable addition, applicable line items assigned assigned loss of material material due to corrosion corrosion of embedded embedded steel Tables 3.5.2-1 through in LRA Tables through 3.5.2-19 are are identified identified in the column 'Table "Table 1 Item" as Item 3.3.1-3.3. 1-67 (A-91 or A-93) and managed managed by the combination combination of the Fire Fire Protection Program and Protection Program and the Structures Structures Monitoring Program,or managed Monitoring Program, managedby the ASME ASME Section XI, X1, Subsection IWL IWL Program.

Program.

summary, the aging In summary, aging effects of change change in material material properties properties (loss bond), cracking

(/oss of bond), cracking and and loss of material material due to corrosion corrosion of embedded steel will continue continue to be managed managed by the Structures Monitoring Monitoring Program Program or the ASME Section XI, X1, Subsection Subsection IWL Program Program during period of during the period extended operation.

operation. In addition, addition, the aging aging effect of loss of material material due to corrosion corrosion of of embedded steel will continue continue to be managed managed by the Fire Fire Protection Program and Protection Program and Structures Monitoring Monitoring Program Programor or the ASME ASME Section X1, XI, Subsection Subsection IWL Program.

Program.

sealing/deteriorationof seals.

Loss of sealing/deterioration seals, gaskets.

gaskets, andand moisture moisture barriers barriers (caulking.

(caulking, flashing.

flashing, and other sealants) other sealants)

NUREG-1801, AMP III.A6-12 NUREG-1801, II.A6-12 (TP-7), component "Seals, "Seals, gaskets, gaskets, and and moisture moisture barriers barriers (caulking, flashing, (caulking, flashing, and and other sealants)" identifies sealants)" identifies an aging effect aging loss of sealing effect of loss sealing due to deterioration seals, gaskets, deterioration of seals, gaskets, andand moisture barriers barriers (caulking, (caulking, flashing, flashing, and and other other sealants).

sealants).

NUREG-1801, AMP II.A3-7 (C-18), component NUREG-1801, component "Seals, "Seals,gaskets, gaskets, andand moisture moisture barriers barriers(caulking, (caulking, flashing, and other flashing, other sealants)"

sealants)" identifies identifies an aging aging effect of loss of sealing and leakage sealing and leakage through through containment due to deterioration containment deterioration of seals, seals, gaskets, gaskets, and moisture moisture barriers barriers (caulking, flashing, (caulking, flashing, and other and other sealants).

sealants). CR-3 considered considered loss of sealing sealing a result change in material result of change materialproperties properties and cracking and cracking of elastomeric elastomeric type materials.

materials. Also, CR-3 used the term "change "change in material material properties" properties" to envelope the NUREG-1801 NUREG-1801 aging aging effect of loss of sealing consistent sealing consistent with the approach used approach used forfor previous Progress Energy LRAs previous Progress LRAs (Robinson, Brunswick, Harris (Robinson, Brunswick, Harris Nuclear Plants)and several Plants) several other nuclearplants other nuclear Millstone and Cooper).

plants (e.g., Millstone Cooper). CR-3 considered considered the use change in material of change materialproperties properties as equivalent equivalent to loss of sealing, sealing, consistent consistent with NUREG-1801 NUREG-1801 and assigned and assigned the applicable Generic Note A. CR-3 utilized applicable Generic utilized two commodities commodities groups groups for "Seals, "Seals, gaskets, and moisture barriers."

gaskets, barriers." One commodity was "Seals, gaskets, and moisture "Seals, gaskets, moisture barriers."

barriers."

This was used This used only in LRA LRA Table 3.5.2-1 for the RB seals seals on the RB pressure pressure boundary boundary or at the interface interface of the RB vertical vertical liner plate with the concrete liner plate concrete basemat basemat covercover slab.

slab. The other identified as "Seals commodity was identified "Seals andand gaskets."

gaskets." "Seals "Seals and gaskets" gaskets" was used in in all other locations.

locations.

For "Seals, gaskets, For "Seals, gaskets, and moisture moisture barriers" barriers" in LRA TableTable 3.5.2-1 (RB),(RB), cracking cracking and changechange in material properties are identified material properties are identified as aging effects and LRA and LRA TableTable 3.5.1, Item 3.5.1-16, states in 3.5.1-16, states the discussion discussion that that the aging aging effects of cracking and change in material properties cracking and change material properties result in loss result of sealing sealing and leakage leakage through through the RB due to deterioration deterioration ofjoint seals,seals, gaskets; gaskets; and moisture moisture barrier. For "Seals, barrier. For "Seals, gaskets, gaskets, and moisture moisture barriers,"

barriers, " the aging aging effects of cracking cracking andand change change in material propertiesare material properties are managed managed by the ASME ASME Section XI, X1, Subsection Subsection IWE and 10 CFR Part Part50, 50, Appendix J Programs.

Programs. For "Seals and For "Seals and gaskets" gaskets" in LRALRA Tables Tables 3.5.2-1 to 3.5.2-19, 3.5.2-19, cracking cracking and change change in material material properties properties areare identified identified as aging aging effects; and and LRALRA Table 3.5.1, Item 3.5. 1-3.5.1-

U.

U. S. Nuclear Nuclear Regulatory Regulatory Commission Enclosure 1 3F1209-03 Page 19 19 of 26 26 44, 44, states states in the discussion discussion that the agingaging effects of cracking cracking and change change in material properties materialproperties result in loss of sealing.

result sealing. Also, the assignedassigned Plant-Specific Plant-Specific Note 509 509 states, states, "Cracking "Cracking and change in material change material properties properties for elastomers results in loss elastomers results loss of sealing sealing and and is considered considered an equivalent aging effect." For "Seals equivalent aging effect." For "Seals and and gaskets," the aging effects aging effects of cracking cracking andand change change in material properties are materialproperties are managed managed by the Structures Monitoring Program.

Structures Monitoring Program.

aging effects of cracking The aging cracking and changechange in material properties, which envelopes loss material properties, loss ofof sealing/deteriorationof seals, sealing/deterioration seals, gaskets, gaskets, and moisture moisture barriers barriers (caulking, flashing, and other (caulking, flashing, sealants) for seals, sealants) seals, gaskets, gaskets, andand moisture moisture barriers barriers will continue managed by either continue to be managed either the the ASME ASME Section XI, X1, Subsection IWE and 10 CFR CFR 50,50, Appendix J Programs Structures Programs or the Structures Monitoring Program, Monitoring Program, as as applicable.

applicable.

Increase in norosity Increase and permeability, porosity and permeability, cracking, cracking, loss of material material (spalling, (spalling, scaling)/aggressive scaling)/aggressive chemical attack chemical attack stated in RAI response As stated response 3.5.2. 1-1, change 3.5.2.1-1, change in material material properties properties is the aging aging effect effect used at CR-3 for increase increase in porosity porosity andand permeability permeability due to aggressive aggressive chemical attack. CR-3 used chemical attack.

the term "change "changein material materialproperties" properties" to envelope the NUREG-1801 NUREG-1801 aging aging effect of increase increase in porosity porosity andand permeability consistent with the approach permeability consistent approach used for for previous previous Progress Progress Energy Energy LRAs (Robinson LRAs (Robinson and and Harris Nuclear Plants)

Harris Nuclear Plants) and several other nuclear several other nuclearplants Vogtle and plants (e.g., VogtJe Oyster Creek). CR-3 considered Oyster considered the use of change change in material material properties properties as as equivalent equivalent to increase in porosity increase porosity and permeability, permeability, consistent consistent with NUREG-1801 NUREG-1801 and and assigned assigned the applicable applicable Generic Note A.

Generic For For the RB, the concreteconcrete aging aging effect of change change in material material properties, properties, due to aggressive aggressive chemical attack, is chemical attack, is managed managed by the Structures Monitoring Program Structures Monitoring Program or the ASME ASME Section Section Xl,XI, Subsection IWL Program, Subsection Program, as shown in in LRA LRA Table Table 3.5.2-1, usingusing visual visual inspections.

inspections. For For the remaining structures, remaining structures, the concrete aging effect of change concrete aging change in in material material properties, properties, due to aggressive chemical attack, aggressive chemical managed by the Structures attack, is managed Monitoring Program Structures Monitoring Programas as shown in LRA Tables 3.5.2-2 through Tables through Table Table 3.5.2-19.

3.5.2-19. Cracking Cracking and and loss of material, material, due to aggressive aggressive chemical attack, chemical attack, are are all managed managed by the Structures Monitoring Structures Monitoring Program Program as shown in LRA Tables Tables 3.5.2-1 through through 3.5.2-19 using using visual visual inspections.

inspections.

applicable line The applicable line items assigned change in material assigned change properties,cracking, material properties, cracking, andand loss of material material in combination, combination, due due to aggressive aggressive chemical chemical attack, LRA Tables attack, in LRA Tables 3.5.2-1 through through 3.5.2-19 and are are identified in the column "Table identified in "Table 1 Item" as 3.5.1-01 (C-03 (C-03 is the corresponding corresponding NUREG-1801 NUREG-1801 Volume 2 related generic Item, for example),

related generic example), 3.5.1-24 (T-06), 3.5.1-31 (T-07), and 3.5.1-34 (T-19). Line items using Plant-Specific Plant-SpecificNote 543 for the "Concrete:

"Concrete:Submerged" Submerged" were added added to the applicable LRA applicable LRA Tables 3.5.2-1 through 3.5.2-19, because through 3.5.2-19, because the aging aging effects of change change in material material properties,cracking, properties, cracking, andand loss of material, material, due to aggressive aggressive chemical chemical attack, attack, were applicable applicable to concrete in a Raw Water concrete Water - Seawater Seawater environment.

environment. In addition, addition, the applicable applicable lineline items assignedloss assigned loss of material materialandand cracking, cracking, due to aggressive aggressive chemical chemical attack, attack, in LRA Tables 3.5.2-LRA Tables through 3.5.2-19 are 1 through are correlated correlated in the column "Table "Table 1 I Item" to Item 3.3.1-66 3.3. 1-66 (A-92)

(A-92) and managed managed by either either the Fire Protection Program Fire Protection Program and Structures Structures Monitoring Monitoring Program Program or or the ASME ASME Section X1, Subsection XI, Subsection IWL Program.

Program.

aging effects of change The aging change in material material properties (increase in porosity properties* (increase porosity and and permeability),

permeability),

cracking, and cracking, and loss of material, material, due to aggressive chemical attack, aggressive chemical continue to be managed attack, will continue Structures Monitoring by the Structures Programor the ASME Section XI, Monitoring Program X1, Subsection Subsection IWL IWL Program during Program during the period operation. In addition, period of extended operation. addition, the aging aging effect of loss of material material andand cracking, cracking,

U. S.

U. S. Nuclear Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 Page 20 20 of 26 due due toto aggressive aggressive chemical chemical attack, attack, will continue to be will continue be managed managed by the Fire Fire Protection ProtectionProgram Program and Structures and StructuresMonitoring MonitoringProgram, Program,or or the the ASME Section Section XI, X1, Subsection Subsection IWL Program.

Program.

During this During this review, review, itit was was determined determined thatthat the discussion in LRA discussion in LRA Table Table 3.3.1, Line Line Item 3.3.1-67, 3.3.1-67, should should bebe revised revised to be consistent 3.3.1-66. Refer to the LRA changes consistent with Line Item 3.3.1-66. changes provided in Enclosure

'in Enclosure 2.2.

RAI 3.6-1 RAI3.6-1

Background

Background In the discussion column in In in LRA, Table 3.6.1, Metal-Enclosed Bus 3.6.1, the LRA stated that the Metal-Enclosed Bus (MEB) Inspection Program is credited for the aging management management of elastomer elastomer seals associated enclosure assemblies. The LRA further states that the MEB program will perform an with MEB enclosure enclosure assembly for cracks, corrosion, foreign debris, excessive inspection of the enclosure internal inspection excessive evidence of moisture intrusion which may indicate degradation of the dust buildup, and evidence the elastomer seal. The AMR results line that points to Table 3.6.1, 3.6.1, Item 3.6.1-10, includes a reference to Note E.

reference The AMR result lines referenced referenced to Note E means that the component type, material, environment, and aging effect are consistent consistent with the corresponding line of the GALL Report; however, where the GALL GALL Report recommends AMP XI.S6, "Structures Monitoring Report recommends Monitoring Program,"

Metal-Enclosed Bus Inspection Program. The LRA stated that itit proposed the Metal-Enclosed the LRA has proposed proposed proposed to perform internal enclosure assembly internal inspection of the enclosure assembly for foreign excessive foreign debris, excessive bus buildup, and evidence evidence of moisture evidence of elastomer degradation.

moisture intrusion as an evidence degradation. The The applicant stated in LRA, Section B.2.34, that the MEB program applicant program is consistent with GALL AMP AMP exception or enhancement. The staff audited this program and verified that itit was XI.E4 with no exception was consistent with GALL AMP XI.E4. The LRA did not discuss the inspection inspection aspects of elastomers as an enhancement elastomers enhancement to MEB program. However, the LRA proposed to use the Metal Enclosed Bus Program to take credit Enclosed credit for elastomer inspection.

elastomer inspection.

Issue Inspecting internals of the MEB alone may not detect elastomer Inspecting the internals elastomer aging because elastomers because elastomers installed outside between the transformer may be installed and transformer and bus duct. In addition, there In addition, there is no direct relationship between moisture intrusion and degradation relationship between degradation of the elastomer. Moisture intrusionintrusion oror dust buildup buildup may may not mean elastomer is degraded. It mean that the elastomer It could be from another another source source such as missing missing seal at the panel below or above the bus duct.

panel below Request Request Explain Explain how how the internal internal inspection inspection of MEBsMEBs alone alone will detect detect elastomer elastomer degradation.

degradation.

Response

Response The inspections inspections required required by AMP X1. XI. S6, "Structures "Structures Monitoring Program,"

Monitoring Program, " will be integrated integrated into the overall Metal Enclosed Enclosed Bus Inspection Program.

Inspection Program. Prior Prior to entering entering the bus, gaskets on bus bus duct covers are inspected are inspected for crumbling, cracking crumbling, cracking or hardening hardening which could permit water to enter the bus.

bus. Once inside, internal inspection inside, an internal inspection of areas sealant/caulking has been areas where sealant/caulking

U. S. Nuclear Regulatory Commission U. Enclosure 11 3F1209-03 Page 21 of Page of 26 26 utilized will be performed utilized performed andand resealed resealed as as necessary.

necessary. These inspections inspections comply with with the requirements of the NUREG-1801-recommended requirements NUREG- 1801-recommendedAMP XI. S6, "Structures Xl. S6, Monitoring Program,"

"StructuresMonitoring Program,"

as well as as as the the requirements requirementsof of the the Metal Metal Enclosed Enclosed Bus Inspection Inspection Program.

Program.

RAI 3.6-2 RAI3.6-2

Background

Background In LRA, Section 3.6.2.2.3, the LRA stated that loss of transmission conductor strength due to corrosion is an applicable aging effect but ample design margin ensures that itit is not not significant enough to cause a loss of intended function. The LRA stated that the National National Electrical Safety Code (NESC) requires that tension on installed conductors be be a maximum maximum of 60% of the ultimate conductor strength. The NESC also sets the maximum conductor must be maximum tension a conductor be designed to withstand under heavy load requirements, which includes consideration consideration of ice, wind, and temperature. The LRA further stated that tests performed by Ontario Hydroelectric Hydroelectric showed a 30% loss of composite conductor strength of an 80-year-old transmission conductor composite conductor due to corrosion. The LRA used a typical 954 MCM ACSR transmission conductor conductor in the the switchyard to illustrate how the transmission conductor aging due to corrosion is insignificant.

switchyard The LRA stated that the ultimate strength of a 954 MCM (24/7 strand) ACSR conductor is lbs. and the maximum design tension for this conductor is 15,000 Ibs.

33,500 Ibs. lbs. The LRA also also stated that the margin between the maximum design tension and the ultimate strength 18,500 strength is 18,500 lbs. The LRA further stated that there is a 55.2% ultimate strength margin. With the loss 30%

Ibs.

conductor strength due to corrosion, the applicant applicant stated that there would would still 25.2% ultimate ultimate strength margin between what is required by the NESC and the actual conductor strength conductor strength in an 80-year old conductor.

The staff reviewed the LRA calculation. conductor strength calculation. The staff noted that aa loss of conductor strength of 30%

on 954 MCM ACSR transmission conductors conductors would mean that the conductor strength strength would be be 22,450 22,450 Ibs. lbs. x 0.7). The ratio between lbs. (33,500 Ibs. between heavy heavy loading conductor loading and the ultimate conductor approximately 67% by the staff's calculation.

strength would be approximately tension on an installed calculation. The tension installed conductor exceed conductor may exceed the maximum of 60% the ultimate conductor strength conductor strength of NESC.

Issue tension (heavy load)

The tension load) of a typical typical transmission conductor illustrated by the LRA would conductor as illustrated would exceed requirement exceed the NESC maximum requirement of 60% of the ultimate conductor strength during the ultimate conductor strength during the period of extended extended operation.

Request:

loss of conductor Explain why loss conductor strength due to corrosion significant aging effect corrosion is not a significant effect requiring management at CR-3 during the extended management extended period period of operation.

Response

Response The 30% reduction reduction in conductor conductor strength analysis is for an 80-year old conductor.

strength used in the analysis conductor.

Renewal, the installed For License Renewal, For installed time frame for the conductor actually only 60 years.

conductor is actually years. By By simple ratio ratio (30/80 (30/80 = = x/60) xl60) a 22.5% reduction reduction in conductor strength is more appropriately conductor strength appropriately established for License Renewal.

established Renewal. The loss of conductor conductor strength of 22.5% on 954 MCM ACSR strength of ACSR

U. S. Nuclear U. Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 22 of 26 transmission conductors transmission conductors then becomes 25,962.5 Ibs. lbs. (33,500 lbs. x 0.775).

(33,500 Ibs. 0. 775). The ratio ratio between heavy loading loading and and the ultimate ultimate conductor conductorstrength strength would be approximately approximately 58% 58% andand is bounded by the NESC requirement.

requirement.

RAI3.6-3 RAI 3.6-3

Background

Background In LRA, Table 3.6.2-1, 3.6.2-1, under under Non-EQ Electrical/l&C Penetration Assemblies, the LRA indicated Non-EO Electricalll&C indicated that there is no aging effect which will require management management for non-EQ non-EO electrical/l&C electrical/l&C penetration assemblies penetration assemblies (XLPO, SR, Kapton, CSPE, EPR, Kynar material) material) installed in an adverse localize localize environment environment caused by heat, radiation, or moisture. The LRA included Note Note J and plant-specific plant-specific Note 604. Plant-specific Plant-specific Note 604 stated that evaluation evaluation has shown shown that the the insulation materials materials for this commodity group are aptly suited for their service condition and acceptable for the period acceptable period of extended extended operation.

operation.

Issue Various organic polymers (etc., XLPO, SR, Kapton, CSPE, CSPE, EPR, Kynar) material used in in Non-EQ electrical/l&C Non-EO electrical/l&C penetration penetration assemblies assemblies could degrade degrade in an adverse localized adverse localized environment due to heat, radiation, or moisture. The LRA did not provide a technical environment justification justification to demonstrate that the insulation material of non-EO non-EQ electrical/l&C electrical/I&C penetration penetration assemblies are not subject to aging degradation.

degradation.

Request Explain why the insulation materials of non-EO non-EQ electricalll&C electrical/I&C penetration penetration installed installed in adverse adverse localized environment environment are not subjectsubject to aging effect requiring management.

Response

Response penetrations' primary The penetrations' insulation materials primary insulation materials are essentially cable are essentially cable conductor conductor insulation insulation materials. The primary materials. insulation materials primary insulation materials for the non-EQ penetration assemblies, subject to penetration assemblies, A-MR, are AMR, are identical identical to the penetration penetration assemblies assemblies in the EQ EQ Program Program in both composition composition and function.

function. All penetration assemblies penetration assemblies subject subject to AMR are AMR are located located in the Intermediate Intermediate and ReactorBuildings.

Reactor Buildings. All penetration penetration assemblies assemblies in EQ Program Program areare qualified qualified by test for the worst-worst-case design case design basis basis event (DBE) conditions in the Intermediate (OBE) conditions Intermediate and Reactor Reactor Buildings.

Buildings. The non-EQ penetration EQ assemblies subject to AMR penetration assemblies AMR are are not required required to remain remain functional during or functional during following a design following design basis accident. The penetration basis accident. penetration assemblies assemblies in the EQ Program Programare are qualified for post-accident for post-accident operation and the EQ test operation and test profiles profiles envelope the (non-accident)

(non-accident) temperature temperature and radiation environments and radiation environments in both the Intermediate Intermediate and Reactor Buildings. Therefore, since Reactor Buildings. Therefore, the non-EQ penetration penetration assemblies assemblies are are not required remain functional required to remain functional during during oror following following a design basis accident, and design basis accident, and their their insulation insulation materials materials have been tested tested to the worst-case worst-case OBE DBE conditions in the Intermediate conditions Intermediate and Reactor Reactor Buildings, Buildings, the insulation materials for the non-EQ insulation materials non-EQ penetration penetration assemblies assemblies are acceptable for 60-year are acceptable 60-year service. Penetration assembly pigtails service. Penetration pigtails available for visual available visual inspection inspection areare covered underunder the NUREG-1801, NUREG-1801, AMP XI.EI XI.E1 Program, Program, Electrical Cables Electrical Cables and Connections Connections Not Subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements.

Requirements.

U. S. Nuclear Regulatory Commission U. Commission Enclosure 11 3F1209-03 Page Page 23 of 26 RAI B.2.36-1 RAJ

Background

Background GALL AMP XI.E6, under Program Description, states that cable connections within the scope of renewal should be tested to provide an indication license renewal indication of the integrity of the cable connections. GALL AMP XI.E6 uses a sampling method to select cable connections to be be tested. Among the factors considered in in connection selection are high, medium, and low low voltages. GALL AMP XI.E6 Parameters Parameters Monitored/Inspected Monitored/Inspected also references references high, medium, and low voltages as being a factor consideredconsidered in the sampling method. ISG LR-ISG-2007-02 LR-ISG-2007-02 removed high voltage connections from GALL AMP XI.E6.

Issue The AMP B.2.36 program descriptiondescription states that the program does not include include high-voltage high-voltage

(>35KV) switchyard connections. The second paragraph of the program description of AMP AMP B.2.36 states that factors considered for sample selection selection are application (high, medium and low low voltage). AMP B.2.36 does not take exception to GALL GALL AMP XI.E6 with regard to voltage voltage LR-ISG-2007-02.

selection or reference ISG LR-ISG-2007-02.

Request Reconcile the sample program voltage selection of AMP B2.36 and the AMP basis document, ifif required, consistent with GALL AMP XI.E6 or ISG LR-ISG-2007-02LR-ISG-2007-02 with a documented documented basis as as applicable.

Response

Response NUREG-1801, NUREG-1801, Rev. 1, 1, AMP XI.E6 states that the following states that following factors factors are are to be considered considered for sampling:

sampling: application (high, medium and low voltage),

application (high, voltage), circuit loading, and circuit loading, and location location (high(high temperature, temperature, high humidity, humidity, vibration, vibration, etc.). However, consistent with the sampling However, consistent sampling criteria criteria provided in proposed provided LR-ISG-2007-02, dated proposed LR-ISG-2007-02,* dated August 29, 29, 2007, 2007, CR-3 shall consider consider the the following factors factors for sampling:

sampling: voltage level (medium and low voltage), voltage), circuit circuit loading loading (high(high load), and load), and location location (high temperature,high humidity, (high temperature, humidity, vibration, vibration, etc.).

response requires This response requires changes changes to the LRA; refer to Enclosure LRA; refer Enclosure 2.

RAI B.3.38-1 RAJ B.3.38-1

Background

Background The "Detection of Aging Aging Effects" program program element element criterion criterion in SRP-LR, Appendix Appendix A.1.2.3.4, states that that the parameters parameters to be monitored monitored oror inspected inspected should be appropriate appropriate to ensure ensure that the structures structures and components components intended intended function(s) function(s) will be adequately adequately maintained maintained for license license renewal under under all CLB design design conditions. This includes includes aspects aspects such such asas method method or technique technique (eg., visual, (e.g., visual, volumetric, surface surface inspection),

inspection), frequency frequency and timing of of inspection inspection to ensure ensure timely timely detection detection of aging effects. In In LRA, Section Section B.3.38, under under the same program element, same program element, the LRA LRA states states that that the high-voltage high-voltage insulators insulators within within the scope scope of this program program areare to be inspected at be inspected

U. S.

U. S. Nuclear Regulatory Commission Enclosure 11 .

3F1209-03 3F1209-03 Page 24 of 26 least once every four years. The first inspection for license renewal is to be completed prior to least once every four years. The first inspection for license renewal is to be completed prior to extended operation.

the period of extended Issue The LRA's "Detection of Aging Effect" program element did not identify the method or technique technique of inspection. The appropriate method or technique should be identified to ensure that high-intended functions for license renewal under all CLB design voltage insulators will perform their intended conditions.

Request:

Identify the inspection technique for detecting degradation degradation of insulator quality due to salt deposit.

Response

Response Operatingexperience Operating experience hashas shown thatthat surface surface contamination contaminationon CR-3 high-voltage high-voltage insulators insulators is an applicable aging an applicable mechanism that aging mechanism that requires requires management.

management. As the result result of the flashover flashover events at at CR-3 due to salt salt spray, spray, a silicon coating has silicon coating has been applied applied to the insulators.

insulators. The The silicon coating silicon coating isis reapplied years. A reapplied every ten years. visual inspection A visual inspection will be performed performed to verify that the silicon the silicon coating coating has has not degraded degraded as as well asas to assure there has assure there has been no accumulation accumulation of salt salt deposits or other deposits airbornedeposits, other airborne deposits, such as as dust and and industrial effluents, that industrial effluents, that could contaminate contaminate the insulator insulator surface and and lead lead to tracking.

tracking. The siliconsilicon coating coating prevents prevents the salt salt spray spray from adhering adhering to the insulators under insulators under high wind, wind, no rainrain environmental environmental conditions.

conditions. Normally, Normally, rainwater rainwater will wash residual residualsalt salt from the insulators.

insulators. The silicon silicon coating coating has an an expected life of of greater than ten years; greater than therefore, a four year years; therefore, year inspection inspection frequency is sufficient to assure assure the coating remains coating remains intact.

intact.

RAI 8.3.38-2 B.3.38-2

Background

Background The "Acceptance Criteria" program element element criterion criterion in SRP-LR, Appendix A.1.2.3.6, states states that the acceptance acceptance criteria for the program and and its basis should be described.

described. The acceptance acceptance

criteria, criteria, against against which which the need need for corrective corrective actions will be evaluated, evaluated, should should ensure that the the structure structure and component component intended function(s) are maintained are maintained under all CLB design conditions conditions during the period of extended extended operation. In LRA, Section B.3.38, under the same same program program element, the LRA LRA states inspection results are to be within states that inspection within, the acceptance acceptance criteria criteria to ensure ensure component component intended function(s) are maintained maintained underunder all CLB design design conditions conditions during the the period of extended extended operation. Acceptance Acceptance criteria criteria will be delineated delineated in the applicable applicable inspection procedure.

Issue The LRA's LRA's "Acceptance Criteria" program program element element did not not describe describe the acceptance criteria the acceptance criteria to to ensure ensure that insulator's function(s) function(s) are are maintained maintained underunder CLB design condition.

condition.

U. S. Nuclear Regulatory Regulatory Commission Enclosure Enclosure 1 3F1209-03 3F1209-03 Page 25 of 26 Request Describe the acceptance acceptance criteria criteria for inspecting inspecting surface contamination of high-voltage high-voltage insulators due to salt deposit.

Response

Operatingexperience Operating experience has has shown thatthat surface contamination on CR-3 high-voltage surface contamination insulatorsis high-voltage insulators an applicable aging an applicable mechanism that aging mechanism that requires management. As requires management. result of the flashover As the result flashover events at CR-3 due to salt spray, spray, a silicon coating has silicon coating applied to the insulators.

has been applied insulators. The The silicon coating silicon coating is reapplied every ten years.

is reapplied years. A A visual visual inspection inspection will be performed to verify that the silicon silicon coating coating has degraded as well as has not degraded assure there has as to assure has been no accumulation accumulation of salt salt deposits deposits oror other other airborne deposits, such as dust airbornedeposits, dust and industrial industrialeffluents, effluents, that that could contaminate contaminate the insulator insulator surface surface and lead to tracking.

and lead tracking. The silicon silicon coating coating prevents prevents the salt spray from salt spray adhering adhering to the insulators under insulators under high wind, wind, no rain environmental conditions.

rain environmental conditions. Normally,Normally, rainwater willwash rainwater will 'wash residual insulators. The silicon salt from the insulators.

residual salt coating has an expected life of silicon coating of greater than ten years; greater than therefore, a four year years; therefore, year inspection frequency is sufficient to assure inspection frequency assure the coating remains coating remains intact.

intact.

RAI 8.3.38-3 B.3.38-3

Background

Background The "Detection of Aging Effects" program element criterion in SRP-LR, Appendix Appendix A.1.2.3.4, states that the frequency frequency (of inspection) inspection) should be linked plant-specific operating linked to plant-specific operating experience.

experience.

experienced a loss of the 230 kV switchyard On March 17, 1993, CR-3 experienced switchyard (normal off-site power power to safety-related busses) when aa light rain safety-related caused arcing across salt-laden 230 kV insulators and insulators switchyard. During tropical storm Frances opened breakers in the switchyard. Frances on September September 6, 2004, CR-3CR-3 experienced phase-to-ground experienced concurrently on a 230KV phase-to-ground faults concurrently transmission line and aa 230KV 230KV transmission switchyard south bus breaker. The transmission line fault was caused by mechanical switchyard mechanical failure of vertical string of insulators due to high wind conditions. The breaker aa carbon steel pin in aa vertical breaker fault was caused by flashover due to contamination contamination from wind and salt spray.

Issue Section B.3.38 of the LRA proposed proposed a four-year inspection interval and justified the four-year four-year inspection frequency based on a slow aging process. However, itit appears appears that aa four-year four-year inspection frequency may not be adequate experience and the plant-specific operating experience adequate given the plant-specific the location of the plant which is in the vicinity of salt water bodies.

Request additional justification technical basis for how a four-year inspection Provide additional Provide inspection frequency frequency is insulator quality due to salt deposit.

degradation of insulator adequate to detect degradation

Nuclear Regulatory U. S. Nuclear U. Regulatory Commission Enclosure 1 Enclosure 3F1209-03 3F1209-03 Page 26 of 26 26

Response

Response Operating Operating experience experience has has shown that that surface surface contamination contamination on CR-3 high-voltage insulatorsis high-voltage insulators an applicable aging an applicable aging mechanism mechanism that that requires management. As requires management. As the result result of the flashover events at CR-3 due to salt spray, a silicon salt spray, silicon coating coating hashas been applied applied to the insulators.

insulators. The silicon coating is reapplied silicon coating reappliedevery ten years. A visual inspection years. A visual inspection will be performed to verify that the silicon coating has silicon coating degraded as well as has not degraded as to assure accumulation of salt assure there has been no accumulation salt deposits or other airborne deposits airbornedeposits, deposits, such as industrial effluents, as dust and industrial effluents, that could contaminate contaminate the insulator insulator surface surface andand lead tracking. The silicon lead to tracking. silicon coating coating prevents prevents the saltsalt spray from spray from adhering adhering to the insulators insulators under under high wind, wind, no rainrain environmental environmental conditions.

conditions. Normally, Normally, rainwater rainwaterwill wash residual residualsalt insulators. The silicon salt from the insulators. coating has an expected life of silicon coating of greater greater than than ten years; years; therefore, therefore, a fourfour year frequency is inspection frequency year inspection assure the is sufficient to assure coating coating remains intact.

remains intact.

Editorial Correction to the Response to RAI 2.4-1 Revise the first sentence of first sentence the first ofthe first bullet bullet in the response submitted by CR-3 to response to RAI 2.4-1, submitted letter, 3F0909-06, NRC letter, 3F0909-06, dateddated September 30, 2009: "Crystal 30, 2009: "Crystal River UnitUnit 3 - Response to Requests for Additional Information for the Review of the Crystal Additional Information Crystal River Unit 3 Nuclear Generating Generating Plant, Application (TAC NO.

Plant, License Renewal Application NO. ME0274)

ME0274) and Amendment #4,"

and Amendment #4," by deleting deleting the word word "door" as shown below.

"door" as below.

identified in Table As identified Table 2.4.1-1, 2.4.1-1, there are no fire doors, there are barrier--eFe penetration doors, fire barrier-fieeF seals penetration seals interiorfire hose stations or interior or stationsin the Reactor ReactorBuilding.

Building.

PROGRESS ENERGY FLORIDA, INC.

PROGRESS CRYSTAL RIVER UNIT 3 CRYSTAL DOCKET NUMBER NUMBER 50 - 302! NUMBER DPR - 72 302 I LICENSE NUMBER 72 ENCLOSURE 2 ENCLOSURE AMENDMENT AMENDMENT #7 CHANGES TO THE CHANGES RENEWAL APPLICATION THE LICENSE RENEWAL APPLICATION

U.

U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission Enclosure Enclosure 2 3F1209-03 3F1209-03 Page Page 1 of 2 Amendment #7, #7, Changes Changes to the License Renewal Application Application Source of License Renewal Application Amendment #7 Changes License Renewal Application Amendment #7 Changes Change Change 3.5.2.2.1.4-1 RAI 3.5.2.2.1.4-1 Replace Replace Item 2 in LRA Subsection 3.5.2.2.1.43.5.2.2.1.4 on page 3.5-23 with the following:

2. Concrete Concrete is monitored to ensure it is free of penetrating penetrating cracks that provide provide a path for water seepage seepage to the surface of the Reactor Reactor Building liner.

RAI 3.5.2.3-3 3.5.2.3-3 Revise Plant-Specific Plant-Specific Note 527 on LRA Page 3.5-153 to state:

The CR-3 aging management management review methodology concluded concluded that stainless steel steel support support steel for piping and conduit located in the Dedicated Dedicated EFW Tank Enclosure Tank Enclosure northwest corner recessed area (similar to a sump) has the aging effect Building northwest effect of Loss of Material.

Revise Plant-Specific Plant-Specific Note 546 on LRA Page 3.5-155 3.5-155 to state:

The CR-3 aging management management review methodology methodology concluded concluded that carbon steel steel supports Dedicated EFW Tank Enclosure supports located in the Dedicated Enclosure Building northwest northwest corner corner recessed area (similar to a sump) has the aging effect of Loss of Material.

RAI 3.5.2.3-4 3.5.2.3-4 On LRA Page 3.5-69, revise the Table Table 3.5.2-2 3.5.2-2 line item for Copper Cable Tray, Conduit, HVAC Ducts, Tube Track in Borated Borated Water Leakage Leakage environment, as follows:

NUREG-1801 Aging Effect Requiring Requiring Aging Management Aging Management NUREG-1801 Table Table 1 Notes Volume tVolume22 Item Notes Noe Management Management

_ __

____

Loss of Material Material

___

_ __

_______

__

____

_

___

_

Program Program

_

____

_

___

_ _

____

Boric Acid Corrosion

_Item

_ j Item VII. 1-12 VII.I-12 (AP-66 (AP-66)

_

Item 3.3.1-88 3.3.1-88

_ _

C (AP-66)

Revise Plant-Specific Plant-Specific Note 525 to read:

The CR-3 aging management management review methodology methodology concluded that copper materials in copper materials an Air - Indoor environment have no aging effects. This applies only to straps straps for for copper copper tubing.

RAI 3.5.2.3-5 3.5.2.3-5 Revise the Discussion columncolumn of LRA Table 3.3.1, 3.3.1, item 3.3.1-67 3.3.1-67 on page 3.3-88 to read:

CR-3 manages the aging effect effect for structures components outside of containment structures and components containment with aa combination combination of the Fire Protection Protection Program and the Structures Monitoring Monitoring Program. For the RB cylindercylinder wall, CR-3 manages the aging effect with the ASME ASME Section Section Xl, XI, Subsection IWL IWL Program as stated in 3.3.1-66 above.

U. S. Nuclear Nuclear Regulatory Regulatory Commission Enclosure Enclosure 2 3F1209-03 3F1209-03 Page 2 of 2 Source Source of License License Renewal Application Application Amendment Amendment #7 Changes

1. 7 Changes Change Change RAI B.2.36-1 Replace the fourth sentence Subsection A.1.1.36, on page A-19, and the first sentence sentence of Subsection of paragraph two of the Program Program Description in in Subsection Subsection B.2.36, on page B-104, with the following:

The factors considered considered for sample sample selection selection are application (medium (medium and lowlow voltage),

voltage), circuit circuit loading (high loading), and location location (high temperature, high humidity, vibration, etc.) in both indoor and outdoor environments.

environments.

Incorporate the following exception:

Proaram Elements Affected Program

• Parameters Monitoried/lnspe~ted Parameters Monitoried/Inspected NUREG-1801, Rev. 1, NUREG-1801, 1, AMP XI.E6 XI.E6 states that the following factors are to be be considered considered for sampling: application (high, medium medium and low voltage), circuit circuit loading, and location (high temperature, high humidity, vibration, etc.). However, consistent consistent with the sampling provided in proposed LR-ISG-2007-02, sampling criteria provided LR-ISG-2007-02, dated August 29, 2007, CR-3 shall consider the following factors for sampling:

29,2007, voltage sampling: voltage level (medium and low voltage), circuit loading (high load), and location location (high (high temperature, high humidity, vibration, etc.).

etc.).