ML11203A516

Response to Request for Additional Information for the Review of License Renewal Application (TAC No. ME0274) and Amendment #22

ML11203A516
Person / Time
Site:	Crystal River
Issue date:	07/20/2011
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0711-10
Download: ML11203A516 (9)

Text

Cl Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 July 20, 2011 3F071 1-10 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River 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 #22

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 June 30, 2011, "Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)"

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 letter dated June 30, 2011, provided a request for additional information (RAI) concerning the CR-3 License Renewal Application (Reference 2). Enclosure I to this letter provides the response to Reference 2. Enclosure 2 to this letter contains Amendment #22 changes to the License Renewal Application.

No new regulatory commitments are included in this letter.

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.

ice President Crystal River Unit 3 JAF/dwh

Enclosures:

1. Response to Request for Additional Information

2. Amendment #22 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 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 3F071 1-10 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, infor ation,.and belief J*on A. Franke Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this ___-_ day of

,J4 ,2011, by Jon A. Franke.

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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

U. S. Nuclear Regulatory Commission Enclosure 1 3F071 1-10 Page 1 of 4 REQUEST FOR ADDITIONAL INFORMATION RAI B.1.4-1

Background

Pursuant to Title 10 of the Code of FederalRegulations (10 CFR) 54.21 (a)(3), a license renewal applicant is required to demonstrate that the effects of aging on structures and components subject to an aging management review are adequately managed so that their intended functions will be maintained consistent with the current licensing basis for the period of extended operation. Section 3.0.1 of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," Revision 2 (SRP-LR), defines an aging management review as the identification of the materials, environments, aging effects, and aging management programs (AMPs) credited for managing the aging effects. In turn, SRP-LR Section A. 1.2.3 defines an acceptable AMP as consisting of ten elements. Element 10, "Operating Experience," in part, is described in SRP-LR Section A.1.2.3.10, paragraph 1, as follows:

Consideration of future plant-specific and industry operating experience relating to aging management programs should be discussed. Reviews of operating experience by the applicant in the future may identify areas where aging management programs should be enhanced or new programs developed. An applicant should commit to a future review of plant-specific and industry operating experience to confirm the effectiveness of its aging management programs or indicate a need to develop new aging management programs (emphasis added). This information should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.

In addition, 10 CFR 54.21(d) requires the application to contain a final safety analysis report (FSAR) supplement. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation.

Based on its review of the Crystal River Unit 3 Nuclear Generating Plant license renewal application (LRA), the U.S. Nuclear Regulatory Commission (NRC or the staff) determined that Section B.1.4 provides a general description of how Florida Power Corporation (the applicant) gathered and considered operating experience in preparing its LRA, and Sections B.2.1 through B.2.38, B.3.1, and B.3.2 summarize the specific operating experience considered for each AMP.

Issue:

Although LRA Sections B.1.4, B.2.1 through B.2.38, B.3.1, and B.3.2 describe how the applicant incorporated operating experience into its AMPs, they do not fully describe how the applicant will use future operating experience to ensure that the AMPs will remain effective for managing the aging effects during the period of extended operation. Many of the program descriptions contain statements indicating that future operating experience will be used to adjust the programs as appropriate; however, the details of this process are not fully described. Also,

U. S. Nuclear Regulatory Commission Enclosure 1 3F071 1-10 Page 2 of 4 some program descriptions contain no such statements and, for these AMPs, it is not clear whether the applicant currently has or intends to implement actions to monitor operating experience on an ongoing basis and use it to ensure the continued effectiveness of the AMPs.

In addition, the LRA does not state whether new AMPs will be developed, as necessary.

Further, none of the AMP descriptions provide the staff reasonable assurance that ongoing operating experience reviews will continue to inform AMP updates for license renewal.

Request:

Describe the programmatic activities that will be used to continually identify aging issues, evaluate them, and, as necessary, enhance the AMPs or develop new AMPs for license renewal. In this description, address the following:

Describe the sources of plant-specific and industry operating experience that are monitored on an ongoing basis to identify potential aging issues. Indicate whether these plant-specific sources require monitoring: corrective action program, system health reports, licensee event reports (LERs), and the results of inspections performed under the AMPs. Similarly, indicate whether these industry sources require monitoring: vendor recommendations, revisions to industry standards on which the AMPs are based, LERs from other plants, NRC Bulletins, Generic Letters, Regulatory Issue Summaries, Information Notices, Regulatory Guides, License Renewal Interim Staff Guidance, and revisions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report." Describe the criteria used to classify a particular piece of information as aging related and outline the training provided to plant personnel so that they can adequately make such classifications.

Describe how the identified aging issues are further evaluated to determine their potential impact on the plant aging management activities. Indicate whether the affected structures and components and their materials, environments, aging effects, aging mechanisms, and AMPs are identified and documented consistent with the methods used to prepare the LRA.

Describe how the results of AMP inspections are considered to adjust the frequency of future inspections, establish new inspections, and ensure an adequate depth and breadth of component, material, environment, and aging effect combinations. Describe the records of these evaluations and indicate whether they are maintained in an auditable and retrievable form.

Describe the process and criteria used to ensure that the identified enhancements are implemented in a timely manner.

• Describe the administrative controls over these programmatic activities.

Provide a summary description of these activities for the FSAR supplement required by 10 CFR 54.21(d). If enhancements for license renewal are necessary, also provide the updates for the FSAR supplement.

If such an operating experience program is determined to be unnecessary, provide a detailed explanation of the bases for this determination.

U. S. Nuclear Regulatory Commission Enclosure 1 3F071 1-10 Page 3 of 4

Response

The operating experience (OE) review process at Crystal River Unit 3 (CR-3) is directed through the use of a Progress Energy fleet-level procedure. This procedure provides direction for the receipt, screening, processing, evaluation, implementation, and distribution of OE information to prevent or mitigate the consequences of similar events reported by both external (industry OE) and internal (Progress Energy Nuclear fleet) sources. As required by CR-3's current operating license, this procedure for feedback of OE is maintainedpursuant to NUREG-0737, Item I. C. 5, "Procedurefor Feedback of OperatingExperience to Plant Staff" All personnel are directed to include OE information in day-to-day and emergent activities where its use can be expected to increase personnel safety, plant safety, and reliability. Personnel utilize OE tools, or designated personnel, to find appropriate internal and external OE information in an effort to minimize preventable events. When undesired conditions are identified during review or evaluation of an OE item, Nuclear Condition Reports (NCRs) are generatedin the ProgressEnergy Corrective Action Program(CAP). Personnelacting as points of contact for industry group participation (i.e., Electric Power Research Institute (EPRI),

Nuclear Energy Institute (NEI), Institute for Nuclear Power Operations (INPO), Pressurized Water Reactor Owners Group (PWROG) and Boiling Water Reactor Owners Group (BWROG),

etc.) ensure associated correspondence, and documents potentially requiring action by Progress Energy, are entered into appropriate programs and formal tracking systems.

Screening of potential OE items is performed by the Operating Experience Screening Committee, made up of representativesfrom each ProgressEnergy nuclearplant and corporate personnel. The screening results of OE Items are captured in Action Tracking (includes CAP).

Action Tracking will also capture the results of OE Item evaluations and associatedactions.

Sources of Internal OE include INPO Areas for Improvement (AFIs) for Progress Energy Facilities,NRC Violations for Progress Energy Facilities,Root Cause Evaluations, and Licensee Event Reports (LERs). Additional sources of Internal OE include searches of CAP, pre-job or lessons learned databases, lessons learned captured in work orders during their last performance, Engineering's System Notebooks, and personnel experiences, including good practices.

Sources of External OE include INPO Event Reports, Nuclear Network OE, INPO Significant Operating Experience Reports, INPO Significant Event Reports, INPO Significant Event Notifications, INPO Topical Reports, NRC Documents (Information Notices, Regulatory Issue Summary, Bulletins, Miscellaneous NRC Memorandums and/or Information), 10 CFR Part 21 Notifications, Nuclear Safety Advisory Letters, Technical Bulletins, and EPRI Owners Group Information.

The use of OE imbues Progress Energy processes. For example, the Maintenance Rule Program procedure directs system engineers to consider applicable OE. The Equipment Reliability Process Guideline procedure states that equipment reliability analyses should be reviewed and updated based on the evaluation of OE. The Preventive Maintenance and Surveillance Testing Administration procedure directs system engineers to review OE for possible impact to the equipment in their systems.

The CAP complements the OE Program to monitor aging-related issues. It includes in its evaluation of degraded conditions items related to aging, erosion, corrosion, wear, pitting,

U. S. Nuclear Regulatory Commission Enclosure 1 3F071 1-10 Page 4 of 4 expansion, shrinkage, yielding, fracture, moisture, blockage, etc. Attributes of the CAP are described in Section B. 1.3 of the License Renewal Application (LRA). The CAP provides a process to ensure that a broad range of issues or conditions can be documented and coded to enable trending for the purpose of addressing broaderprogrammatic or process weaknesses.

Conditions adverse to quality are identified, classified regarding significance, reported to the appropriatelevel of management, and subsequently corrected. The cause of the condition is determined and corrective actions are taken to preclude recurrence. The CAP implements the requirements of 10 CFR 50, Appendix B, CriterionXVI. As such, the CAP is used to monitor plant-specific OE and industry OE that is relevant to CR-3.

Regulatory Guides, License Renewal Interim Staff Guidance and License Renewal NUREGs are not reviewed, as they are not considered sources of OE. These documents may, at best, be lagging indicators based on other OE documents previously discussed.

The OE review process is part of the current licensing basis. The current licensing basis will be maintained during the period of extended operation, which includes ongoing review and incorporationof OE, as appropriate. License Renewal programs, as part of the licensing basis after the renewed license is issued, are subject to the OE review process described above.

An LRA amendment is required to add a description of the ongoing process OE reviews to Section B. 1.4. Refer to the specific changes documented in Enclosure 2.

Since the OE review process exists under the current licensing basis and will be maintained through the period of extended operation, consistent with the methods used to prepare the LRA, a separate discussion of the OE program is not requiredin the FSAR supplement.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 2 AMENDMENT #22 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S. Nuclear Regulatory Commission Enclosure 2 3F071 1-10 Page 1 of 1 AMENDMENT #22 CHANGES TO THE LICENSE RENEWAL APPLICATION Source of License Renewal Application Amendment #22 Changes Change RAI B.1.4-1 In Section B.1.4 of the License Renewal Application, on page B-6, add the following new paragraph after the second paragraph:

Existing ProgressEnergy processes require reviews of relevant site and industry operating experience and periodic benchmarking to ensure programenhancements are identified and implemented. Such ongoing reviews identify potential needs for aging management programrevisions to ensure their effectiveness throughout the period of extended operation.