ML12117A260

Revised Commitment for the Reactor Vessel Internals Aging Management Program for License Renewal and License Renewal Application Amendment #24

ML12117A260
Person / Time
Site:	Crystal River
Issue date:	04/23/2012
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0412-03, TAC ME0274
Download: ML12117A260 (18)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10CFR54 April 23, 2012 3F0412-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Revised Commitment for the Reactor Vessel Internals Aging Management Program for License Renewal (TAC NO. ME0274) and License Renewal Application Amendment #24

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 Regulatory Issue Summary 2011-07, "License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management,"

dated July 21, 2011 (NRC Accession No. ML111990086)

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). Reference 1 provided a list of License Renewal Commitments and included Commitments #1 and #4 that deal with Reactor Vessel Internals aging management activities.

NRC Regulatory Issue Summary 2011-07 (Reference 2) provided guidance regarding the schedule for submitting reactor vessel aging management programs. Enclosure 1 to this letter provides the current list of License Renewal Commitments revised in accordance with Reference 2. Enclosure 2 provides conforming changes to the License Renewal Application (LRA). In addition, the enclosures include an editorial change to Commitment #32 to document all applicable NRC Requests for Additional Information that apply and two PEF-identified editorial changes to the LRA description of the Structures Monitoring Program.

This submittal revises License Renewal Commitments #1 and #4; however, it contains no new regulatory commitments.

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.

Si erely, Jo A. Franke ice President rystal River Unit 3 JAF/dwh

Enclosures:

1. CR-3 License Renewal Commitments, Revision 6

2. Amendment #24 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. ,i4O Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0412-03 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 7 n, 7 ief.

Jon Franke VrePresident rystal River Nuclear Plant The foregoing document was acknowledged before me this __5 day of 2012, by Jon A. Franke.

Signature of Notary Public State of Florida

,,,, CAROLYN E.PORTMANN

' Commission # DD 937553 l Expires March 1,2014 BondedThu Toy FainInsurnc800.385.7019 (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 1 LICENSE NUMBER DPR - 72 ENCLOSURE 1 CR-3 LICENSE RENEWAL COMMITMENTS, REVISION 6

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 1 of 12 CR-3 LICENSE RENEWAL COMMITMENTS, REVISION 6 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 1 In accordance with the guidance of NUREG-1801, Rev. 1, A.1.1 As stated in the Reactor Vessel Internals regarding aging management of reactor vessel internals commitment Aging Management components, CR-3 will: (1) participate in the industry programs for Activities investigating and managing aging effects on reactor internals, (2) evaluate and implement the results of the industry programs as LRA Section A.1.1, applicable to the reactor internals, and (3) upon completion of RIS 2011-07 these programs, but not later than two years after issuance of the renewed license and not later than two years before entering the period of extended operation (whichever comes first), submit an aging management program/inspection plan for reactor internals in accordance with MRP-227-A to the NRC for review and approval.

2 In accordance with the guidance of NUREG-1801, Rev. 1, A.1.1 As stated in the Primary Water Stress regarding aging management of nickel alloy and nickel-clad commitment Corrosion Cracking of components susceptible to primary water stress corrosion Nickel Alloys cracking, CR-3 will comply with applicable NRC Orders and will implement applicable: (1) Bulletins and Generic Letters and LRA Section A.1.1 (2) staff-accepted industry guidelines.

3 The Program will be enhanced to select an alternate lubricant that A.1.1.3 Prior to the period of Reactor Head Closure is compatible with the fastener material and the contained fluid. extended operation Studs Program LRA Section B.2.3 4 The Thermal Aging and Neutron Irradiation Embrittlement of Cast A.1.1.6 As stated in the Thermal Aging and Austenitic Stainless Steel (CASS) Program is a new program to commitment Neutron Irradiation be implemented. Required actions that affect the aging Embrittlement of Cast management strategy for these components will be incorporated Austenitic Stainless into the program documents in accordance with Commitment #1 Steel (CASS) Program above.

LRA Section B.2.6 RAI B.2.6-1 RIS 2011-07

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 2 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENTSOURCE LOCATION 5 Program administrative control documents will be enhanced to A.1.1.8 Prior to the period of Bolting Integrity Program include: (1) guidance for torquing and closure requirements based extended operation on the EPRI documents endorsed by NUREG-1 801, (2) LRA Section B.2.8, requirements to remove instances where molybdenum disulfide RAI B.2.8-2, lubricant is allowed for use in bolting applications in specific RAI B.2.8-3 procedures and to add a general prohibition against use of molybdenum disulfide lubricants for bolted connections, (3) guidance for torquing and closure requirements that include proper torquing of the bolts and checking for uniformity of gasket compression after assembly, (4) guidance for torquing and closure requirements based on the recommendations of EPRI NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants,"

(with exceptions noted in NUREG-1 339), EPRI TR-1 04213, "Bolted Joint Maintenance & Applications Guide," and EPRI 5067, "Good Bolting Practices, A Reference Manual for Nuclear Power Plant Personnel," Volumes I and II, (5) a centralized procedure based on EPRI NP-5769, EPRI TR-104213, and EPRI-5067 containing guidance regarding bolted joint leak tightness and pre-installation inspections consistent with the recommendations of those documents, (6) periodic examinations of a representative sample of bolting identified as potentially having yield strength

>150 ksi for SCC consisting of periodic in situ ultrasonic testing or, alternatively, surface examination or bolt replacement, with sample sizes based on EPRI TR-107514 methodology, (7) examination of NSSS support high strength bolting for SCC concurrent with examinations of the associated supports at least once per 10-year ISI period, and (8) acceptance standards for examination of high strength structural bolting consistent with the recommendations of EPRI NP-5769 or application specific structural analyses.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 3 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT ISCHEME SOURCE LOCATIONSCHEDULE SOURCE 6 The Program will be enhanced to: (1) include the Nuclear Services A.1.1.10 As stated in the Open-Cycle Cooling and Decay Heat Seawater System Pumps in a periodic inspection commitment Water System Program and/or rebuild program. This Program will be initiated during the current license period and inspect one or more pumps prior to the LRA Section B.2.10, period of extended operation, (2) subject the Nuclear Services and RAI B.2.10-1, Decay Heat Seawater System Discharge Conduits to inspection RAI B.2.10-2, and evaluation subsequent to the SG replacement project, but RAI B.2.10-3 prior to the period of extended operation, in order to determine the extent of activities required during the period of extended operation to support the intended function of these components, (3) incorporate hardness/scratch testing for selective leaching into the examinations of susceptible pumps and valves and, if evidence of degradation is detected, of seawater heat exchanger tubesheet cladding, (4) incorporate Nuclear Services and Decay Heat Seawater System Intake Conduit inspections for degraded or missing concrete lining. Affected areas will be monitored to assure no loss of intended function until such time as the lining can be repaired, (5) incorporate acceptance criteria into procedures for inspections for biofouling and maintenance of protective linings, and (6) establish periodic maintenance activities for Nuclear Services and Decay Heat Seawater System expansion ioints Drior to the period of extended operation.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 4 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 7 Administrative controls for the Program will be enhanced to: (1) A.1.1.12 Prior to the period of Inspection of Overhead include in the Program all cranes within the scope of License extended operation Heavy Load and Light Renewal, (2) require the responsible engineer to be notified of Load Handling Systems unsatisfactory crane inspection results involving loss of material, Program (3) specify the frequency of inspections for the cranes within the scope of License Renewal to be every refueling outage for cranes LRA Section B.2.12 in the Reactor Building and every two years for cranes outside the Reactor Building, and (4) clarify that crane rails are to be inspected for abnormal wear and that members to be inspected for cracking include welds.

8 The Program administrative controls will be enhanced to: (1) A.1.1.13 Prior to the period of Fire Protection Program include specific guidance for periodic inspection of fire barrier extended operation walls, ceilings, and floors including a requirement to notify Fire LRA Section B.2.13, Protection of any deficiencies having the potential to adversely RAI B.2.13-2.1 affect the fire barrier function, (2) include additional inspection criteria as described in NUREG-1801 for penetration seals, (3) include additional inspection criteria for corrosion of fire doors, (4) specify minimum qualification requirements for personnel performing visual inspections of penetrations seals and fire doors, and (5) specify inspections of fire barrier walls, ceilings, and floors on a frequency of at least once every five years.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 5 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL FIALSFEYPROGRAM SAFETY LICENSE RENEWAL ITEM NO. COMMITMENT ANALYSIS REPORT PROGRAM FSA) SUPLEENTIMPLEMENTATION LICENSE REEAL APPLICATION (LRA)

NO. COMMITMENTL(FSAR)TSUPPLEMENT SCHEDULE LOCATION SOURCE 9 The Program will be enhanced to: (1) incorporate a requirement to A.1.1.14 Prior to the period of Fire Water System perform one or a combination of the following two activities: extended operation Program (a) Implement periodic flow testing consistent with the intent of NFPA 25, or LRA Section B.2.14, (b) Perform wall thickness evaluations to verify piping is not RAI B.2.14-1 impaired by pipe scale, corrosion products, or other foreign material. For sprinkler systems, this may be done by flushing, internal inspection by removing one or more sprinkler heads, or by other obstruction investigation methods, (such as technically proven ultrasonic and X-ray examination) that have been evaluated as being capable of detecting obstructions. (These inspections will be performed before the end of the current operating term. The results from the initial inspections will be used to determine inspection intervals thereafter during the period of extended operation.),

(2) Perform internal inspections of system piping at representative locations as required to verify that loss of material due to corrosion has not impaired system intended function. Alternately, non-intrusive inspections (e.g., ultrasonic testing) can be used to verify piping integrity. (These inspections will be performed before the end of the current operating term. The results from the initial inspections will be used to determine inspection intervals thereafter during the period of extended operation.), (3)

Incorporate a requirement to perform a visual inspection of yard fire hydrants annually consistent with the intent of NFPA 25 to ensure timely detection of signs of degradation, such as corrosion, and (4) consistent with the intent of NFPA 25, either replace the sprinkler heads prior to reaching their 50-year service life or revise site procedures to perform field service testing, by a recognized testing laboratory, of representative samples from one or more sample areas. (Subsequent testing will be performed on a representative sample at an interval of 10 years after the initial field service testing.)

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 6 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR)LOCATION SUPPLEMENT LOAINSCHEDULESCEUEORE SOURCE 10 The Aboveground Steel Tanks Program is a new program to be A.1.1.15 Prior to the period of Aboveground Steel implemented. extended operation Tanks Program LRA Section B.2.15 11 The Program will be enhanced to: (1) adjust the inspection A.1.1.16 Prior to the period of Fuel Oil Chemistry frequency for the Diesel-Driven Emergency Feedwater Pump Fuel extended operation Program Oil Storage Tank to ensure an inspection is performed prior to the period of extended operation, (2) inspect the internal surfaces of LRA Section B.2.16 the Diesel-Driven Fire Pump Fuel Oil Storage Tanks. Based on RAI B.2.16-1.1 the results of the inspection, the tanks will be cleaned and flushed as necessary. These inspections will be performed every 2 years, unless trending indicates an appropriate change in frequency is warranted, and (3) perform UT inspections of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks prior to the period of extended operation, and at intervals not to exceed 10 years.

12 The Program will be enhanced to: (1) ensure that neutron A.1.1.17 Prior to the period of Reactor Vessel exposure conditions of the reactor vessel remain bounded by extended operation Surveillance Program those used to project the effects of embrittlement to the end of the 60-year extended license period and (2) establish formalized LRA Section B.2.17 controls for the storage of archived specimens to ensure availability for future use by maintaining the identity, traceability, and recovery of the archived specimens throughout the storage period.

13 The One-Time Inspection Program is a new program to be A.1.1.18 Prior to the period of One-Time Inspection implemented. extended operation Program LRA Section B.2.18 14 The Selective Leaching of Materials Program is a new program to A.1.1.19 Prior to the period of Selective Leaching of be implemented. extended operation Materials Program LRA Section B.2.19

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 7 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR)LOCATION SUPPLEMENT LOAINSCHEDULESCEUEORE SOURCE 15 The Buried Piping and Tanks Inspection Program is a new A.1.1.20 Prior to the period of Buried Piping and Tanks program to be implemented. extended operation Inspection Program LRA Section B.2.20 16 Program administrative controls will be revised to incorporate A.1.1.1 Prior to the period of ASME Section XI periodic volumetric examinations of ASME Code Class 1 small- extended operation Inservice Inspection, bore socket welds. A volumetric examination technique will be Subsections IWB, IWC, developed capable of detecting cracking in Class 1 socket welds. and IWD Program The total number of socket welds selected for examination will be at least 10% of the total population per inservice inspection (ISI) LRA Section B.2.1, interval. Prior to the period of extended operation, CR-3 will RAI B.2.21-3 perform a baseline inspection equivalent to one third of those RAI B.2.21-5 inspections required for an interval. The regular inspection schedule is to commence in the third period of the fourth ISI interval.

17 The Program will be enhanced to: (1) incorporate measures to A.1.1.22 Prior to the period of External Surfaces assure the integrity of surfaces that are inaccessible or not readily extended operation Monitoring Program visible during both plant operations and refueling outages, and (2) incorporate inspection attributes for degradation of coatings. LRA Section B.2.22, RAI B.2.22-1 18 The Inspection of Internal Surfaces in Miscellaneous Piping and A.1.1.23 Prior to the period of Inspection of Internal Ducting Components Program is a new program to be extended operation Surfaces in implemented. Miscellaneous Piping and Ducting Components Program LRA Section B.2.23 19 Program administrative controls will be enhanced to (1) identify A.1.1.29 Prior to the period of Masonry Wall Program the structures that have masonry walls in the scope of License extended operation Renewal, (2) include inspection of the masonry walls in the LRA Section B.2.29 Machine Shop in a periodic engineering activity (PMID), and

3) require periodic inspection of masonry walls every five years. RAI 2.2-06

_RAI B.2.29-1

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 8 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENTSOURCE LOCATION 20 Program will be enhanced by revising the administrative controls A.1.1.30 Prior to the period of Structures Monitoring that implement the Program to: (1) identify all License Renewal extended operation Program structures and systems that credit the Program for aging management in the corporate procedure for condition monitoring LRA Section B.2.30, of structures, (2) require notification of the responsible engineer when below grade concrete including concrete pipe is exposed so RAI B.2.13-2.1 an inspection may be performed prior to backfilling, (3) require RAI B.2.30-6 periodic groundwater chemistry monitoring including consideration for potential seasonal variations, (4) require periodic inspections of the water control structures, i.e., Circulating Water Intake Structure, Circulating Water Discharge Structure, Nuclear Service Sea Water Discharge Structure, Intake Canal, and Raw Water Pits, on a frequency not to exceed five years, (5) require periodic inspections of the Circulating Water Intake Structure submerged portions on a frequency not to exceed five years, (6) identify additional civil/structural commodities and associated inspection attributes and performance standard required for License Renewal in the corporate procedure for condition monitoring of structures, (7) identify additional inspection criteria for structural commodities in the site system walkdown checklist, (8) add inspection of corrosion to the inspection criteria for the bar racks at the Circulating Water Intake Structure as a periodic maintenance activity, (9) add an inspection of the earth for loss of form and loss of material for the Wave Embankment Protection Structure as a periodic maintenance activity, (10) include additional in-scope structures and specific civil/structural commodities in periodic engineering activities, (11) require periodic inspections of the Fluorogold slide bearing plates used in structural steel platform applications in the Reactor Building., (12) require periodic inspection of structures on a frequency of at least once every five years, and (13) include the quantitative acceptance criteria of ACI 349.3R, Chapter 5, and (14) perform a baseline inspection using the quantitative acceptance criteria of ACI 349.3R prior to the period of extended operation.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 9 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCEUEORE LOAINSCHEDULE SOURCE LOCATION 21 The Electrical Cables and Connections Not Subject to 10 CFR A.1.1.31 Prior to the period of Electrical Cables and 50.49 Environmental Qualification Requirements Program is a extended operation Connections Not Subject new program to be implemented. to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.31 22 The Electrical Cables and Connections Not Subject to 10 CFR A.1.1.32 Prior to the period of Electrical Cables and 50.49 Environmental Qualification Requirements Used in extended operation Connections Not Subject Instrumentation Circuits Program is a new program to be to 10 CFR 50.49 implemented. Environmental Qualification Requirements Used in Instrumentation Circuits Program LRA Section B.2.32 23 The Inaccessible Medium Voltage Cables Not Subject to 10 CFR A.1.1.33 Prior to the period of Inaccessible Medium 50.49 Environmental Qualification Requirements Program is a extended operation Voltage Cables Not new program to be implemented. Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.33 24 The Metal Enclosed Bus Program is a new program to be A.1.1.34 Prior to the period of Metal Enclosed Bus implemented. extended operation Program LRA Section B.2.34 25 The Fuse Holder Program is a new program to be implemented. A.1.1.35 Prior to the period of Fuse Holder Program extended operation LRA Section B.2.35

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 10 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL FIALSFEYPROGRAM SAFETY LICENSE RENEWAL ITEM COMTETANALYSIS REPORT PRGALIESRNWL NO. COMMITMENT(FSAR) SUPPLEMENT IMPLEMENTATION APPLICATION (LRA)

LOCATION SCHEDULE LOCATION SOURCE 26 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A.1.1.36 Prior to the period of Electrical Cable Environmental Qualification Requirements Program is a new extended operation Connections Not Subject program to be implemented. to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.36 27 Administrative controls for the Program will be enhanced to: (1) A.1.1.37 Prior to the period of Fuel Pool Rack Neutron include provisions to monitor and trend data for incorporation in extended operation Absorber Monitoring test procedures to ensure the projection meets the acceptance Program criteria, (2) incorporate acceptance criteria tables for accumulated weight losses of monitored Carborundum samples, and (3) LRA Section B.2.37, implement periodic Boron-10 Areal Density Gauge for Evaluating RAI 3.3.2.2.6-2, Racks (BADGER) testing or comparable neutron attenuation RAI B.2.37-2 testing for racks in Pools A and B to ensure that the neutron absorption intended function is maintained, and that technical specification criticality requirements are continually met.

28 The High-Voltage Insulators in the 230KV Switchyard Program is A.1.1.38 Prior to the period of High-Voltage Insulators a new program to be implemented. extended operation in the 230KV Switchyard Program LRA Section B.2.38

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NO. (FSAR)LOCATION SUPPLEMENT LOAINSCHEDULESCEUEORE SOURCE 29 Administrative controls for the Program will be revised to: (1) A.1.1.11 Prior to the period of Closed-Cycle Cooling enhance procedures and activities credited for performance of extended operation Water System Program physical inspections to reflect that inspections of components exposed to closed-cycle cooling water will be performed as made LRA Section B.2.11, available on an opportunistic basis, (2) flag procedures and RAI B.2.11-1, activities credited with performance monitoring of parameters in RAI B.2.11-2 the Instrument Air and Secondary Services Closed Cycle Cooling Water Systems to assure pump and heat exchanger performance are identified as license renewal activities, and (3) flag procedures associated with closed cycle cooling water chemistry controls to identify chemistry controls associated for in-scope systems as License Renewal activities.

30 Implementing procedures for the Program will be enhanced to A.1.9 Prior to the period of Steam Generator Tube ensure compliance with the requirements in NUREG-1801, extended operation Integrity Program Revision 1,Section XI.M19.

LRA Section A.1.9 RAI B.2.9-2.1 31 CR-3 will perform a review of design basis ASME Code Class 1 A.1.2.2.10 Prior to the period of Environmentally -

fatigue evaluations to determine whether the NUREG/CR-6260 extended operation Assisted Fatigue Review based locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting RAI 4.3.3-6 locations for the CR-3 plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage. If any of the limiting locations consist of nickel alloy, NUREG/CR-6909 methodology for nickel alloy will be used in the evaluation.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0412-03 Page 12 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 6 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 32 CR-3 will develop and submit a plant-specific Concrete A.1.1.41 At least one year Concrete Containment Containment Tendon Prestress aging management program prior to the period of Tendon Prestress (AMP) to address plant operating experience from the concrete extended operation Program delaminations; include any revised Minimum Required Values and plans and schedules for revising the plant-specific program basis RAI B.3.3-1 and implementation documents; include details for collecting RAI B.3.3-2, surveillance data, performing the regression analyses and log- RAI B.3.3-3, linear trend plots, and a schedule for performing the tendon RAI B.3.3-4 surveillances; provide a discussion of tendon surveillances, including re-stressed tendons and any remaining undisturbed tendons; and provide a discussion of tendon surveillances, including use of common tendons during the period of extended operation. The AMP will follow the criteria of NUREG-1 800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2, and will ensure aging effects are adequately managed during the period of extended operation.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 1 LICENSE NUMBER DPR - 72 ENCLOSURE 2 AMENDMENT #24 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S, Nuclear Regulatory Commission Enclosure 2 3F0412-03 Page 1 of 2 AMENDMENT #24 CHANGES TO THE LICENSE RENEWAL APPLICATION Source of License Renewal Application (LRA) Amendment 24 Changes Change NRC Revise the third paragraph of Subsection A.1.1 on LRA Page A-5 to read:

Regulatory Information In accordance with the guidance of NUREG-1 801, "Generic Aging Lessons Learned Summary (GALL)," Rev. 1, U.S. Nuclear Regulatory Commission, September 2005, regarding 2011-07 aging management of reactor vessel internals components for aging mechanisms, such as embrittlement and void swelling, CR-3 will: (1) participate in the industry programs for investigating and managing aging effects on reactor internals, (2) evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not later than two years after issuance of the renewed license and not later than two years before entering the period of extended operation (whichever comes first), submit an aging management program/inspection plan for reactor internals in accordance with MRP-227-A to the NRC for review and approval.

Revise Subsection A.1.1.6, previously revised by PEF Letter to the NRC 3F1009-07, dated October 13, 2009, on LRA Page A-7 to read:

The Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program is a new program that will manage loss of fracture toughness due to thermal aging and/or neutron irradiation embrittlement of CASS reactor vessel internals. Required actions that affect the aging management strategy for these components will be incorporated into the program documents in accordance with the reactor vessel internals aging management commitment in Subsection A.1.1 above. The Program will effectively manage the aging effect to prevent loss of intended function.

PEF- Make the following editorial corrections to Subsection A.1.1.30 on LRA Page A-16 for the Identified Structures Monitoring Program:

Editorial Changes 0 Revise the second sentence to replace report number "NEI 93-01" with "NUMARC 93-01 ". The title of the report remains unchanged.

0 Revise the title of report NEI 96-03 in the last sentence on page A-16 to read:

"Guidelines for Monitoring the Condition of Structures at Nuclear Power Plants". (In other words, add the word "Power" to the title of the report.)

NRC Revise the third and fourth sentences of the first paragraph of Program Description in Regulatory Subsection B.2.6, on LRA Page B-26, previously revised by PEF Letter to the NRC Information 3F1009-07, dated October 13, 2009, to read:

Summary 2011-07 The augmented inspections for the CASS reactor vessel internals components will conform to the guidance of MRP-227-A, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines," and required actions that affect the aging management strategy for these components will be incorporated into the program documents in accordance with the License Renewal commitments regarding reactor vessel internals aging management.

U. S. Nuclear Regulatory Commission Enclosure 2 3F0412-03 Page 2 of 2 Source of License Renewal Application (LRA) Amendment 24 Changes Change PEF- Make the following editorial corrections on LRA Page B-89 for the Structures Monitoring Identified Program:

Editorial Changes 0 Revise the second sentence of the Program Description to change the report number for "Nuclear Energy Institute (NEI) 93-01" to "NUMARC 93-01" a Revise the title of report NEI 96-03 in the third sentence of the Program Description to read: "Guidelines for Monitoring the Condition of Structures at Nuclear Power Plants". (In other words, add the word "Power" to the title of the report.)