ML102230030

Response to Requests for Additional Information for the Review of the License Renewal Application and Amendment #12

ML102230030
Person / Time
Site:	Crystal River
Issue date:	08/09/2010
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0810-01, TAC ME0274
Download: ML102230030 (15)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 August 9, 2010 3F081 0-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Response to Requests for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274) and Amendment #12

References:

(1) CR-3 to NRC letter, 3F1208-01, dated December 16, 2008, "Crystal River Unit 3 - Application for Renewal of Operating License" (2) NRC to CR-3 letter, dated July 8, 2010, "Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)" - Small Bore Piping and Erosion of Orifice (3) NRC to CR-3 letter, dated July 8, 2010, "Request for Additional.

Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)" - Buried Piping

Dear Sir:

On 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 the term of its operating license an additional 20 years beyond the current expiration date (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by two (2) letters dated July 8, 2010, provided requests for additional information (RAIs) concerning the CR-3 License Renewal Application (References 2 and 3). Enclosure 1 to this letter provides the response to Reference 2. Enclosure 2 to this letter provides the response to Reference 3. to this letter contains Amendment #12 to the License Renewal Application. In addition, the RAI responses contained in this submittal resulted in a change to License Renewal Commitment #16; the change is described in Enclosure 3.

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

2incerel n A. Franke Vice President Crystal River Unit 3 JAF/dwh

Enclosures:

1. Response to Request for Additional Information (Reference 2)

2. Response to Request for Additional Information (Reference 3)

3. Amendment 12 Changes to the License Renewal Application xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector A71 4C)

Progress Energy Florida, Inc.

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

U. S. Nuclear Regulatory Commission Page 2 of 2 3F081 0-01 STATE OF FLORIDA COUNTY OF CITRUS Jon A. Franke states that he is the Vice President, Crystal River 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 information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

CstA. Rranke a n ViePresident Crystal River Nuclear Plant The foregoing document was acknowledged before me this day of 9, 2010, by Jon A. Franke.

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Signature of Notary Public State of Florida (Print, type, or stamp Commissioned Name of Notary Public)

Personally Produced Known -OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (REFERENCE 2)

U. S. Nuclear Regulatory Commission Enclosure 1 3F081 0-01 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (REFERENCE 2)

RAI 3.2.2.2.6-1 Backqround:

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), Section 3.2.2.2.6, Loss of Material Due to Erosion, discusses stainless steel orifice plates in the High Pressure Safety Injection minimum flow lines. The referenced document in the GALL Report discusses the excessive flow rate due, in part, to erosion of the orifice plate, causing potential cavitation concerns for the centrifugal charging pumps. License renewal application (LRA) Section 3.2.2.2.6 states that CR-3 manages this aging effect with the "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program."

According to the associated aging management program (AMP), in LRA Section B.2.23, this program will be implemented using existing "preventive maintenance, surveillance testing and periodic testing work order tasks that provide opportunities for the visual inspection of internal surfaces of piping and ducting components."

Issue:

SRP-LR states that the acceptance criteria for this item are described in Branch Technical Position RSLB-1 in Appendix A.1. Section A.1.2.2.2, states, in part, that all activities that are credited for managing a certain aging effect for a specific component should be described.

Based on the information in LRA Section 3.2.2.2.6 and Section B.2.23, it is unclear what specific activities are credited for managing the loss of material due to erosion for the orifice plates in question.

Request:

Describe the existing preventive maintenance, surveillance testing or periodic testing work order task(s) that provide the opportunity to perform a visual inspection, such that material loss due to erosion will be adequately managed for the HPI Make Up (charging) pump miniflow recirculation orifices.

Response

The CR-3 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program uses, but is not strictly limited to, existing preventive maintenance, surveillance testing, and periodic testing work order tasks that provide opportunities for the visual inspection of internal surfaces of piping and ducting components. Where no existing activity can be identified that adequately manages the effects of aging, additional activities will be specified as necessary to satisfy program requirements. It is noted that the program description in NUREG-1801, Volume 2, Section Xl.M38, makes no regards as to whether a program activity is new or existing, hence this clarificationhas no bearing on programconsistency with NUREG-1801.

In the example of the High Pressure Injection Make Up (charging)pump miniflow recirculation orifices, there are currently no existing activities that can be credited for managing loss of material due to erosion. Therefore, a new periodic inspection activity will be implemented to

U. S. Nuclear Regulatory Commission Enclosure 1 3F081 0-01 Page 2 of 3 ensure the intended function of these components is maintained through the period of extended operation.

RAI B.2.21-4 Back-ground:

The GALL Report,Section XI.M35 recommends the use of the One-Time Inspection of ASME Code Class 1 Small-Bore Piping only for those plants that have not experienced cracking of ASME Code Class 1 small-bore piping resulting from stress corrosion or thermal and mechanical loading. For those plants that have experienced cracking, the GALL Report recommends periodic inspection of the subject piping to be managed by a plant-specific AMP.

The GALL Report also recommends the use of volumetric technique in the examination of ASME Code Class 1 small bore piping.

Issue:

By letter dated September 11, 2009, the staff issued RAI B.2.21-2 requesting information regarding the examination technique on Class 1 socket welds. In its response on October 13, 2009, and as supplemented on March 3, 2010, the applicant stated that it will perform periodic volumetric examinations of Class 1 socket welds. The applicant further stated that the examination "will begin at such a time as an acceptable nuclear industry methodology for nondestructive socket weld examination becomes available." However, the applicant did not clearly identify when "such a time" ,would be, nor did the applicant describe the details of "an acceptable nuclear industry methodology."

Request:

Provide detailed information on the committed inspection schedule and methodology of volumetric examinations on socket welds.

Response

The response to RAI B.2.21-3 stated:

In addition, CR-3 will perform periodic volumetric examinations of ASME Code Class I small-bore socket welds during the period of extended operation.

These inspections will commence prior to the end of the 5 th Inservice Inspection (ISI) Interval and will recur in the 6 th ISI Interval.

The response to RAI B.2.21-3 also stated:

The examinations will detect and size discontinuities within the specified examination volume...

In the context of the ASME Section X1 Inservice Inspection, Subsections IWB, IWC, and IWD Program this would entail implementing Appendix VIII, "Performance Demonstration for

U. S. Nuclear Regulatory Commission Enclosure 1 3F081 0-01 Page 3 of 3 UltrasonicExamination Systems", of the Code of Record. Appendix VIII requires qualificationof the procedures,personnel, and equipment used to detect and size flaws.

As also stated in the response to RAI B.2.21-3, a destructive examination on an opportunistic basis may be performed in lieu of the specified nondestructive examinations.

In the event a fully qualified technique for nondestructive examination is not available and an opportunistic inspection cannot be completed prior to the end of the 5 th ISI Interval, CR-3 will develop a plant-specific volumetric examination procedure and perform an inspection prior to the end of the 5th ISI Interval.

A License Renewal Application amendment is required to address the above response; refer to .

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (REFERENCE 3)

U. S. Nuclear Regulatory Commission Enclosure 2 3F081 0-01 Page 1 of 5 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (REFERENCE 3)

RAI B.2.22-2 Backqround:

The license renewal application (LRA) states that aging management program (AMP) B.2.20, Buried Piping and Tanks Inspection Program, is a new program with no exceptions or enhancements and is consistent with the program elements in GALL AMP XI.M34. This AMP addresses buried piping, (i.e., piping in direct contact with soil). The LRA also states that AMP B.2.22, External Surfaces Monitoring Program, is an existing program with no exceptions and five enhancements and is consistent with the program elements in GALL AMP XI.M36. This AMP addresses aging management of the external surfaces of piping exposed to air, which would normally include underground inaccessible piping (i.e., piping not in direct contact with soil, but located below grade in a vault, pipe chase, or other structure where it is exposed to air and where access is limited).

There have been a number of recent industry events involving leakage from buried and underground piping and tanks.

Issue:

In light of this recent industry operating experience (OE), the staff is concerned about the continued susceptibility to failure of buried and/or underground piping and tanks that are within the scope of 10 CFR 54.4 and subject to aging management for license renewal. In reviewing the AMPs cited above along with the applicable aging management review (AMR) items associated with them, the staff is not clear whether: (1) the components addressed by these AMPs clearly include both buried and underground piping (piping which is below grade and contained in a vault or other structure where it is exposed to air and where access is limited);

and (2) whether such programs are being updated to incorporate lessons learned from recent industry events as well as any OE from Crystal River Unit 3 Nuclear Generating Plant's (CR-3's) history.

Request:

1. Provide a list and brief summary of any leaks or adverse conditions discovered during inspections (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within six inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried or underground piping or tanks at CR-3 in the past five years that were entered in your corrective action program but are not included in your LRA. Describe how your current AMPs or proposed changes to the AMPs address these issues.

2. Provide a discussion of how the AMPs used in managing the aging of buried, underground, and limited access piping and tanks within the scope of license renewal will address recent industry OE as well as any OE from CR-3's history.

U. S. Nuclear Regulatory Commission Enclosure 2 3F081 0-01 Page 2 of 5 Response to Request 1:

CR-3 performed a review of site OE in conjunction with development of its Buried Piping and Tanks Inspection Program. This OE review identified one case of corrosion at the ground to air interface, and one instance where a Polyvinyl Chloride (PVC) piping failed under heavy equipment traffic. The OE review identified no corrosion related degradation of buried piping.

There was one instance noted where a buried pipe in close proximity to one being inspected was damaged during the excavation process. Recent buried piping inspections being performed as part of the CR-3 response to the industry's ongoing Buried Piping Integrity Initiative (Reference NEI 09-14); and opportunistic inspections of the Fire Water System have found CR-3 piping and coatings to be in good condition. A single incidence of leakage was noted in a buried pipe adjacent to a focused inspection candidate, resulting from damage incurredduring the excavation performed to facilitate the inspection.

In addition to the buried piping managed by the Buried Piping and Tanks Inspection Program, CR-3 has a limited quantity of buried PrestressedConcrete Cylinder Pipe (PCCP)where the concrete external surface is managed by the Structures Monitoring Program. The piping falling into this category includes the large diameter Circulating Water System piping, and the Nuclear Services and Decay Heat Seawater System discharge conduits. Of these, the Nuclear Services and Decay Heat Seawater System discharge conduits have been subject to Remote Field Transformer Coupling (RFTC) testing to verify the integrity of the reinforcing wire in the piping spools. These conduits will be subject to additionalinspection and evaluation prior to the period of extended operation as part the Open-Cycle Cooling Water System Program commitment.

CR-3 CE does include areas of degradation,primarily in the form of spalled concrete, on interior surfaces of the Circulating Water System piping, where the Inspection of Interior Surfaces of Miscellaneous Ducting and Piping Components Program has been specified for aging management. These areas are currently being resurfaced using a system of internal EPDM flexible joint seals and AL6XN stainless steel expanders to provide a leak tight seal and prevent further degradation. The Inspection of Interior Surfaces of Miscellaneous Ducting and Piping Components Program uses periodic inspections to verify the integrity of piping components, including polymeric and stainless steel components in the Circulating Water System PCCP piping.

CR-3 also has limited undergroundpiping (i.e., not direct buried, but inaccessible,below grade) as described in this RAI. The Condensate System and Emergency Feedwater System each have a vault containing a system valve and attached piping, managed by the External Surfaces Monitoring Program. The piping inside these vaults is not in contact with the soil, and the vaults, located at grade elevation at the top of the berm, are equipped with drainage to prevent accumulation of water. The External Surfaces Monitoring Program incorporates periodic inspections of piping components inside the valve vaults coincident with Structures Monitoring Programinspections of the vault. Inspections performed in January 2010 identified no corrosion or degradation of the piping components within these vaults. As modified by the response to RAI B.2.22-1, the External Surfaces Monitoring Program is an existing program that takes exceptions to NUREG-1801 in that it addresses materials and aging effects that are not describedin GALL Section XI. M36.

Regarding the CR-3 soil environment and excavation backfill, CR-3 buried components are exposed to non-aggressive soil conditions as defined in NUREG-1801, Volume 2, based on groundwater chemical analysis. Additionally, the CR-3 power block was constructed on an elevated berm, approximately 20 feet above original site grade, to address hurricane and

U. S. Nuclear Regulatory Commission Enclosure 2 3F081 0-01 Page 3 of 5 flooding concerns. With the exception of the Circulating Water and Nuclear Services Decay Heat Seawater Systems, essentially all buried piping in the scope of license renewal is situated well above the water table at the site. Site construction specifications directed the use of limerock or dolomite crushed to a suitable sieve size for excavation backfill. These mitigating factors support the conclusion that buried piping at CR-3 is not in an environment that would be considered aggressive with regardto the initiation of corrosion. The site OE review findings are consistent with this result, and identified no instances where leakage or degradation to external coatings was attributedto adverse soil conditions or improper backfill.

The CR-3 Cathodic Protection System includes operating cathodic protection installed on the buried Emergency Diesel Fuel Oil Storage Tanks, as well as buried piping in the Condensate System and Emergency Feedwater System. A review of operating history was performed to review the effectiveness of this portion of the CR-3 cathodic protection over the last 5 years.

This review found that cathodic protection system for the Emergency Fuel Oil Storage Tanks has generally been effectively operating within specifications. The review identified a period beginning 2004 and lasting about 4 years when cathodic protection for Condensate System and Emergency Feedwater System buried piping was not being regularly monitored and maintained.

Since that time, monitoring activities have been resumed and troubleshooting is ongoing to restore this part of the Cathodic Protection System to operation within specifications. Recent inspections of this piping have identified no degradation of the piping or protective coatings (see discussion of Emergency Feedwater/CondensateSystem inspections, below).

Response to Request 2:

The following discussion describes how the AMPs used in managing the aging of buried and underground piping and tanks at CR-3 will ensure their intended functions are maintained through the period of extended operation:

Buried Piping and Tanks Managed by the Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Programis specified to manage aging of buried piping in the scope of License Renewal, with the exception of a limited quantity of PCCPpiping in the Circulating Water System and the Nuclear Services and Decay Heat Seawater System. In addition to the use of design features such as protective coatings, the program will incorporate periodic visual inspections, or in the case of the Nuclear Services and Decay Heat Seawater System inlet conduits, periodic nondestructive examinations using qualified methods. These inspections and nondestructive examinations will inspect a sufficient quantity of piping for each system to adequately characterize the condition of buried piping, including protective coatings and wrappings, in the scope of the program and assure the intended function is maintained.

These investigations will be initially performed prior to the period of extended operation, and recurat a frequency of at least once every 10 years.

Emergency Feedwater/CondensateSystem - Piping managed by the Buried Piping and Tanks Inspection Program consists of the buried piping from the Condensate Storage Tank to Emergency Feedwater Pump suction piping, from the Condensate Storage Tank to the Emergency Feedwater Tank, and buried portions of the Emergency Feedwater Pump suction and recirculation lines to and from the Emergency Feedwater Tank. Additionally there is a short length of piping (approximately20 feet) from the Condensate Storage Tank to the Turbine Building. There is a total of approximately 1,600 feet of buried piping, predominantly carbon steel, but including some stainless steel, associated with the

U. S. Nuclear Regulatory Commission Enclosure 2 3F081 0-01 Page 4 of 5 interfacingpiping in these systems. Excavation and inspection of a representativeportion of this piping will be performed prior to the period of extended operation, and repeated periodically through the period of extended operation at a frequency of at least once every 10 years. A recent guided wave ultrasonic(G-scan) inspection performed on an Emergency Feedwater System suction line identified one area recommended for further investigation.

An excavation was done at this location, and it was determined that the protective wrap was in good condition and no corrosion was present. The Condensate supply line to the Emergency Feedwater Pumps, the Condensate fill line to the Emergency Feedwater Tank, the Emergency Feedwater Pump suction piping and recirculation lines, and the Emergency Feedwater Tank fill line are protectedby a cathodic protection system.

• Fuel Oil System - Piping managed by the Buried Piping and Tanks Inspection Program consists of the piping from the Main Fuel Oil Storage Tanks (DFT-1A and DFT-1B) into the Diesel GeneratorBuilding. There is a total of approximately 220 feet of buried Carbon Steel piping in this system. Excavation and direct inspection of a representative portion of this piping will be performed prior to the period of extended operation, and repeated periodically through the period of extended operation at a frequency of at least once every 10 years.

The Main Fuel Oil Storage Tanks themselves are also in the scope of the program, and are periodically subject to ultrasonic test surveys of the tank heads and lower shell. The most recent inspections, performed in 2007, identified no external corrosion and concluded there was no evidence to suspect breakdown of the external protective coating. The Main Fuel Oil Storage Tanks are provided with a cathodicprotection system.

" Fire Protection System - Piping managed by the Buried Piping and Tanks Inspection Program consists of the yard loop that encircles the plant and underground lines that feed the outlying structures. There is a total of more than 3,300 feet of buried cast/ductile iron piping in the system. The system has been subject to recent inspection as a result of plant maintenance and modification activities, which found external surfaces of buriedpiping and components to be in good condition. The system will continue to be subject to inspections during the period of extended operation under the Buried Piping and Tanks Inspection Program,with a minimum of one inspection performed every 10 years.

" Nuclear Service and Decay Heat Sea Water System - Piping managed by the Buried Piping and Tanks Inspection Program consists of the inlet flumes from the Intake Structure to the Nuclear Services and Decay Heat SeawaterPump sump in the Auxiliary Building, a total of approximately 600 feet of piping. The inlet flumes are cast iron bell and spigot piping with cement lining inside, and protective coal tar coating externally. The lines are on the suction side of the Nuclear Services and Decay Heat Seawater Pumps, and under static hydraulic pressure associatedwith sea level. The inlet flumes originate approximately 30 feet below grade at the Intake Structure, and slope downward towards the Nuclear Services and Decay Heat SeawaterPump sump underneath the Auxiliary Building, where they are nearly 60 feet below grade elevation atop the plant berm. They are over 20 feet below mean sea level throughout their length, and the construction specification reflects that the conduits were constructed underwater in a common trench using divers.. Given the difficulty associated with performing direct inspection via excavation, examination will be performed using nondestructive methods from the inside of the pipe to determine the condition of the piping.

These examinations will be performed using qualified methods subject to performance demonstration to verify the efficacy of the examination techniques and inspection results.

U. S. Nuclear Regulatory Commission Enclosure 2 3F081 0-01 Page 5 of 5 Initial testing will be performed prior to the period of extended operation, with subsequent inspections during the period of extended operationnot to exceed 10 years.

Buried Piping and Tanks Managed by the Structures Monitoring Program The Structures Monitoring Programis used to manage external surfaces of buried PCCPpiping in the Circulating Water System and the Nuclear Services and Decay Heat Seawater System.

The Structures Monitoring Program utilizes opportunistic inspections to detect degradation of below grade concrete structures, including concrete piping.

Additionally, Circulating Water System PCCPpiping will be subject to RFTC testing prior to the period of extended operation under the Inspection of Internal Surfaces of Miscellaneous Ducting and Piping Components Program which is specified for the aging management of inside surfaces, with subsequent inspections during the period of extended operation based on inspection results. The Nuclear Services and Decay Heat Seawater discharge conduits have recently been subject to RFTC testing, determined to be in good condition, and will be subject to additional RFTC testing prior to the period of extended operation as part the existing Open-Cycle Cooling Water System Program commitment.

UndergroundPiping Managed by the External Surfaces Monitoring Program The External Surfaces Monitoring Program is specified for aging management of external surfaces of underground components installed inside valve vaults in the Condensate System and Emergency Feedwater System. The External Surfaces Monitoring Program includes measures to ensure that surfaces that are inaccessible or not readily visible during both plant operations and refueling outages are inspected at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation. Relative to undergroundpiping in the Condensate System and Emergency Feedwater System valve vaults, access for inspections of external surfaces of piping components is facilitated by Structures Monitoring Programperiodic inspections of the vaults themselves. As modified by the response to RAI B.2.22-1, the External Surfaces Monitoring Program is an existing program that takes exceptions to NUREG-1801 in that it addresses materials and aging effects that are not describedin GALL Section XI. M36.

A License Renewal Application amendment is required to address the above response; refer to .

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 3 AMENDMENT 12 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S. Nuclear Regulatory Commission Enclosure 3 3F081 0-01 Page 1 of 2 Amendment 12 Changes to the License Renewal Application Source of License Renewal Application Amendment 12 Changes Change RAI B.2.21-4 Revise LRA Appendices A and B by inserting the following statement immediately after the sentence "A destructive examination may be performed on an opportunisticbasis in lieu of the socket weld volumetric examinations"in the description of the A SME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program in Subsection A. 1. 1.1 on Page A-5 and in the ProgramDescriptionin Subsection B.2. 1, on Page B-12:

In the event a fully qualified technique for nondestructiveexamination is not available and an opportunisticinspection cannot be completed priorto the end of the 5 th ISI Interval, CR-3 will develop a plant-specific volumetric examination procedure and perform an inspection priorto the end of the 5th ISI Interval.

Note that the sentence "A destructive examination may be performed on an opportunistic basis in lieu of the socket weld volumetric examinations"had previously been added in accordancewith the response to RAI B.2.21-3 in CR-3 letter to the NRC 3F0310-01, dated March 3, 2010, "CrystalRiver Unit 3-- Response to Request for Additional Information for the Review of the Crystal River Unit 3, Nuclear Generating Plant,License Renewal Application (TAC NO. ME0274) and Amendment #10".

Based on this change, License Renewal Commitment #16 has been revised to read:

Program administrativecontrols will be revised to incorporateperiodic volumetric examinations of ASME Code Class I small-bore socket welds. The total number of socket welds selected for examination will be at least 10% of the total population per interval. The examinations will detect and size discontinuitieswithin the specified examination volume, and will begin at such time as an acceptable nuclear industry methodology for nondestructive socket weld examination becomes available. A destructive examination may be performed on an opportunisticbasis in lieu of the socket weld volumetric examinations. In the event a fully qualified technique for nondestructive examination is not available and an opportunisticinspection cannot be completed priorto the end of the procedure and5h ISI Interval, perform CR-3 will an inspection develop prior to theaend plant-specific volumetric of the 5th ISI Interval.examination RAI B.2.22-2 Add the folowing discussion to the text of LRA Subsection A. 1.1.20 on Page A-14:

For the Nuclear Services and Decay Heat Seawater System inlet conduits, where excavation for direct visual inspection is not feasible, the effectiveness of protective coatings and wrappings in protecting the piping will be assessed by periodic monitoring of the materialcondition of the piping itself Monitoring of the Nuclear Services and Decay Heat Seawater System inlet conduits will utilize qualified methods subject to performance demonstrationto verify the efficacy of the examination techniques and inspection results.

In addition, in Subsection B.2.20, on LRA Page B-67, revise the NUREG-1801 Consistency statement to read:

The Buried Piping and Tanks Inspection Program is a new program consistent with NUREG-1801,Section XI. M34, with an exception.

(continued)

I

U. S. Nuclear Regulatory Commission Enclosure 3 3F081 0-01 Page 2 of 2 Source of Chanue License Renewal Application Amendment 12 Changes

- i.

RAI B.2.22-2 Add an exception to LRA Subsection B. 2.20 by replacingthe word "None"with the following:

(continued)

ProaramElements Affected ParametersMonitored/Inspected Coatings and wrappings are inspected by visual techniques, with the exception of the Nuclear Services and Decay Heat Seawater System inlet conduits, where excavation and inspection is not feasible. In these instances, the effectiveness of coatings and wrappings in protecting the piping will be assessed by monitoring the materialcondition of the piping itself, utilizing qualified methods subject to performance demonstrationto verify the efficacy of the examination techniques and inspection results.

Update the NUREG-1801 Comparisonfor the Buried Piping and Tanks Inspection Program on LRA Table B-I, to state:

New program consistent with NUREG- 1801 with exception In the AMR Tables in LRA Sections 3.3 and 3.4, for each line item that credits the Buried Piping and Tanks Inspection Program, change each Generic Note A to Note B and each Generic Note C to Note D to account for the identified exception to NUREG-1801.

Various as Update the NUREG-1801 Comparison statements on LRA Table B-I, for the CR-3 Programs Noted to agree with previously submitted changes to Appendix B as noted in the following table:

CR-3 Program NUREG-1801 Comparison Source of Change ASME Section XI Inservice Existing program consistent CR-3 letter to NRC Inspection, Subsections IWB, with NUREG-1801 with 3F0310-01, dated IWC, and IWD Program exception March 3, 2010 Closed-Cycle Cooling Water Existing program consistent CR-3 letter to NRC System Program with NUREG- 1801 with 3F1009-07, dated exceptions and enhancement October 13, 2009 External Surfaces Monitoring Existing program consistent CR-3 letter to NRC Program with NUREG-1801 with 3F1009-07, dated exceptions and enhancement October 13, 2009 Inspection of Internal Surfaces New program consistent with CR-3 letter to NRC in Miscellaneous Piping and NUREG-1801 with exception 3F1209-12, dated Ducting Components Program December 30, 2009