ML110250183

Comments on the Safety Evaluation Report with Open Items Related to the License Renewal and Amendment # 18

ML110250183
Person / Time
Site:	Crystal River
Issue date:	01/21/2011
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0111-04, TAC ME0274
Download: ML110250183 (23)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10CFR54 January 21, 2011 3F01 11-04 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Comments on the Safety Evaluation Report with Open Items Related to the License Renewal of Crystal River Unit 3 Nuclear Generating Plant (TAC NO. ME0274) and Amendment #18

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 December 14, 2010, "Safety Evaluation Report with Open Items Related to the License Renewal of Crystal River Unit 3 Nuclear Generating Plant (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 December 14, 2010, provided a safety evaluation report (SER) with open items related to the license renewal of CR-3 (Reference 2). The NRC requested that CR-3 review the SER, verify its accuracy, and provide comments to the staff by January 21, 2011. Enclosure 1 to this letter provides comments on Reference 2 and information to resolve Open Item 01-3.0.3.1.19-1.

Enclosure 2 provides changes to the CR-3 License Renewal Application to resolve SER Confirmatory Item CI-4.3.4.2-1 and clarify previous commitments regarding the Fuel Oil Chemistry Program. Also, the CR-3 License Renewal Commitments, updated to reflect changes made during the NRC staffs review of the LRA, are included in Enclosure 3.

No new regulatory commitments are contained in this submittal; however, changes to commitments based on previous CR-3 letters to the NRC are included 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.

Sinc y Jon ,.Fran] e ViiePresident

,stal River Unit 3 "JAF/dwh

Enclosures:

1. Comments on the Crystal River Unit 3 Safety Evaluation Report

2. Amendment #18 Changes to the License Renewal Application

3. Crystal River Unit 3 License Renewal Commitments, Revision 4 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 L-l fL ,

crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 2 3F01 11-04 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, informt~o, andtJiefrý Viie President Crystal River Nuclear Plant The foregoing document was acknowledged before me this 9 / day of

• Aa&-r , 2011, by Jon A. Franke.

GawLý WWPqVVK--,

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 COMMENTS ON THE CRYSTAL RIVER UNIT 3 SAFETY EVALUATION REPORT

U. S. Nuclear Regulatory Commission Enclosure 1 3F01 11-04 Page 1 of 4 COMMENTS ON THE CRYSTAL RIVER UNIT 3 SAFETY EVALUATION REPORT Section Page Comment No. No.

1.5 1-7 The request for additional information (RAI) response to resolve Safety Evaluation Report (SER) Open Item (OI)-3.0.3.1.9-1 regarding the One-Time Inspection Program was provided in CR-3 letter, 3F1210-09, dated December 29, 2010.

1.5 1-8 The RAI response to resolve OI-3.0.3.1.10-1 regarding the Buried Piping and Tanks Inspection Program was provided in CR-3 letter, 3F1210-03, dated December 8, 2010 (ADAMS Accession No. ML103470140).

1.5 1-8 The RAI response to resolve 01-3.0.3.1.19-1 regarding the Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program was provided in CR-3 letter, 3F1110-02, dated November 12, 2010 (ADAMS Accession No. ML103200064). Further justification for the CR-3 manhole inspection schedule is provided below.

CR-3 has identified four manholes containing inaccessible in-scope power cables.

Of these, three are located on the plant berm, and one is located at the intake structure. The manhole located at the intake structure is equipped with a sump pump to remove any accumulating water. Of the three manholes located on the berm, one is located inside the Hot Machine Shop. This manhole is enclosed in a dry protected structure and is free from the effects of heavy rain events.

The remaining two manholes, E2 and E3, are located on the west side of the berm on a shelf that is approximately 18 feet above site elevation. The opening to the manholes is approximately 18 inches to 2 feet above the surrounding grade. The bottoms of these manholes are at elevation 104 ft.-6 in. and 105 ft.

respectively, which is approximately 14 feet above the water table at CR-3. A November 2010 inspection of manholes E2 and E3 found no standing water in manhole E3 and approximately 3 inches of water in manhole E2. The lowest cable tray in this manhole is 2 feet off the floor. The prior inspection was performed in August 2009. Due to the location of these manholes, i.e., well above the site elevation, flooding is not a concern.

CR-3 annually receives approximately 52 inches of rain, and the recent manhole inspections show no significant accumulation of water in manholes E2 and E3.

These manholes have no drainage system, so any accumulated water must be removed by pumping. The work instructions for these manholes require that they are left properly sealed, precluding significant water ingress during rain events.

Should an accumulation of water be found during the annual inspection, an evaluation will be performed to determine the cause of the in-leakage and appropriate action taken through the CR-3 Corrective Action Program.

Based on the above, inspections following event .driven occurrences such as flooding or heavy rains are not required for in-scope electrical manholes at CR-3.

The manholes are equipped with sump pumps, protected from the elements, or maintained in a manner that precludes accumulation of water of sufficient depth to cover the cables.

1.5 1-8 The RAI response to resolve 01-3.0.3.2.10-1 regarding the Selective Leaching of Materials Program was provided in CR-3 letter, 3F1210-09, dated December 29, 2010.

1.5 1-8 The RAI response to resolve 01-3.0.3.2.13-1 regarding the Masonry Wall Program was provided in CR-3 letter, 3F1210-09, dated December 29, 2010.

U. S. Nuclear Regulatory Commission Enclosure 1 3F0111-04 Page 2 .of 4 Section Page Comment No. No.

1.5 1-9 The RAI response to resolve 01-3.0.3.2.14-1 regarding the Structures Monitoring Program was provided in CR-3 letter, 3F1210-09, dated December 29, 2010.

1.5 1-9 The RAI response to resolve 01-3.3.2.2.4.1-1 regarding aging management of letdown heat exchangers was provided in CR-3 letter, 3F1210-06, dated December 16, 2010.

1.5 1-9 The additional information to resolve 01-3.5-1 regarding Reactor Building concrete delamination has been submitted in several CR-3 letters as summarized in the supplemental response to RAI B.2.26-1 in letter 3F1210-09, dated December 29, 2010. Also, the discussion of this 01 includes a list of SER sections that discuss the issue. Section 3.0.3.1.16 should be added to the list.

1-5 1-10 The RAI response to resolve 01-4.3.3-1 regarding environmentally-assisted fatigue was provided in CR-3 letter, 3F1210-09, dated December 29, 2010.

1.6 1-10 Confirmatory Item (CI)-4.3.4.2-1 refers to a teleconference wherein CR-3 stated that a disposition would be provided for reactor coolant pump (RCP) casings and nozzles under 10 CFR 54.21(c)(1)(ii). The subject disposition is provided as a License Renewal Application (LRA) amendment in Enclosure 2 to this letter.

2.1.3 2-3 The list of systems that were the subject of an NRC scoping and screening audit includes a system named "complex chilled water". The correct system name is "Control Complex Chilled Water". This comment applies to several places where this list of systems is included in the SER, ref., page 2-9, page 2-21, page 2-22, page 2-26, and page 2-27.

2.3.2.5.1 2-51 In the second paragraph, it is stated that the screening results for each system are described elsewhere in LRA Section 2.3.2.5. This should be revised to refer to Section 2.3 of the LRA instead of 2.3.2.5. The screening results for systems with containment isolation valves are not in Section 2.3.2.5.

2.3.3.3.2 2-58 The penultimate paragraph should refer to "containment isolation piping and components".

2.4.2.1.1 2-143 The 2 nd paragraph refers to a 120-ton fuel handling area crane. The title of the crane was changed to "Auxiliary Building Overhead Crane" in Enclosure 2, page 7, of letter, 3F0110-04, dated January 27, 2010 (ADAMS Accession No.

ML100290366).

Table 3-8 The Buried Piping and Tanks Inspection Program should indicate that the 3.0.3-1 program is consistent with exception.

Table 3-9 The Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 3.0.3-1 Environmental Qualification Requirements Program should indicate that the program is consistent with exception as described in CR-3 letter, 3F1 110-02, dated November 12, 2010 (ADAMS Accession No. ML103200064).

Table 3-9 Add the new program X.S1, Concrete Containment Prestress Program.

3.0.3-1 3.0.3.1.10 3-39 The first bullet in operating experience (OE) discussion refers to incidence of corrosion at the Condensate Storage Tank (CST) piping ground/air interface as being a leak. There was never any leakage or unacceptable loss of material associated with this event. This was clarified in the response to RAI B.2.22-3, in CR-3 letter, 3F1210-03, dated December 8, 2010 (ADAMS Accession No.

ML103470140).

3.0.3.1.10 3-39 The sixth bullet regarding the Diesel Generator Fuel Oil (DG FO) storage tank inspections; CR-3 periodically inspects the lower heads and shells, not heads and lower shells.

U. S. Nuclear Regulatory Commission Enclosure 1 3F01 11-04 Page 3 of 4 Section Page Comment No. No.

3.0.3.1.10 3-39 The eighth bullet states that most of the Nuclear Service and Decay Heat Seawater System is 20 feet below sea level. This description only pertains to the intake conduits, not the entire system. Suggest stating: "The nuclear service and decay heat sea water system intake conduits were constructed underwater and are approximately 20 feet below mean sea level".

3.0.3.1.13 3-48 The 2 nd paragraph last sentence should be corrected to state, "...the work orders generated to perform IWE examinations will contain a task..." not "...the work orders generated to examinations will contain a task...".

3.0.3.2.2 3-89 The description of what CR-3 will consider as high-strength bolting reads, "(i.e.,

bolting with 120 less than Sy less than 150 ksi) and above, will be assumed to be high-strength bolting"., This should read "i.e., bolting with Sy greater than 120 ksi will be assumed to be high-strength bolting".

3.0.3.2.4 3-98 The penultimate paragraph should state that "... flow rate is not relevant to the industrial cooling system pump's intended function". Likewise, the same paragraph relating to the heat exchanger on page 3-99-should state "... heat transfer is not relevant to the industrial cooling system heat exchanger's intended function."

3.0.3.2.4 3-99 The conclusion of the first paragraph on this page should be related to heat exchangers, not pumps.

3.0.3.2.4 3-101 The conclusion paragraph to this section states that, "Also, the staff reviewed the enhancements and confirmed that its implementation through Commitment No.

29 prior to the period of extended operation would make the existing AMP consistent with the GALL Report AMP to which it was compared." To the contrary, as noted in the preceding discussion, this AMP has several exceptions to GALL.

3.0.3.2.8 3-120 The discussion of commitments (1), (2), and (3) on page 3-120 should be revised to agree with the response to RAI B.2.16-1-1 in CR-3 letter 3F0110-04, dated January 27, 2010 (ADAMS Accession No. ML100290366). Specifically commitment (2) should be revised in accordance with the following wording:

(2) inspect the internal surfaces of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks, unless trending indicates an appropriate change in frequency is warranted, and, Also, it would appear that the LRA and CR-3 License Renewal commitments were not updated to reflect the response to RAI B.2.16-1.1 and should be revised as indicated in Enclosures 2 and 3.

3.0.3.3.1 3-153 The description of the program at the bottom of the page (and elsewhere in the program description) could be interpreted as having a staggered test schedule for both Boral and Carborundum panels. In fact, the staggered test schedule only pertains to Carborundum, where attenuation testing and weight testing will alternate on a five year frequency. For Boral, testing will be limited to attenuation testing on a ten year frequency.

3.1.2.2.5 3-201 In the second paragraph, regarding a time-limited aging analysis (TLAA), it states:

In LRA Table 3.1.1, the applicant identified item 3.1.1-21 as a TLAA item for reactor vessel shell fabricated of SA208-CI 2 forgings clad with stainless steel using a high-heat input welding...

SA208-CI 2 should be SA508-CI 2 to agree with LRA, Table 3.1.1, page 3.1-16, Item 3.1.1-21.

U. S. Nuclear Regulatory Commission Enclosure 1 3F01 11-04 Page 4 of 4 Section Page Comment No. No.

3.1.2.2.7 3-204 The discussion of a destructive examination being performed in lieu of volumetric examinations was not accepted by the staff, and has been superseded.

3.1.2.3.1 3-216 There is an incorrect reference to the section where the One-Time Inspection AMP is evaluated. Instead of 3.0.3.1.11, this should read 3.0.3.1.9.

3.2.2.2.6 3-241 The discussion at the bottom of the page discusses the implementation of a new visual examination activity to detect erosion on the inside of the High Pressure Injection (HPI) mini-flow orifices. However, the CR-3 response to RAI 3.2.2.2.6-1 in letter, 3F0810-01, dated August 9, 2010 (ADAMS Accession No.

ML102230030), does not say this will be a visual exam, and due to the configuration, a visual of internal surfaces is not feasible. It will likely necessitate a radiographic test.

3.3.2.3.15 3-311 In the discussion on the effectiveness of the Selective Leaching Program, this section states, "... as documented in LRA Section B.2.10, the applicant discussed plant-specific operating experience in which multiple instances of selective leaching of components in the nuclear services and decay heat sea water system have been detected and corrected by this program." While CR-3 has identified instances of selective leaching, the Selective Leaching Program is a NEW, sample based program, and was not involved in this OE.

3.3.2.3.18 3-315 The discussion of inspection of buried components in the middle of the third paragraph has been superseded. This text discusses that inspections will be implemented consistent with the recommendation of GALL AMP XI.M34. The inspection requirements of GALL, Rev. 1, were later determined to be insufficient, and in the response to RAI B.2.22-3 CR-3 agreed to an inspection schedule based on the requirements of the GALL, Rev. 2, Buried Piping Program, AMP XI.M41.

3.3.2.3.20 3-319 The first paragraph should refer to LRA Table 3.3.2-20 (not 2.3.2-20).

3.5.3.2.16 3-476 There is an incorrect reference to the section where the One-Time Inspection Program is evaluated. Instead of 3.0.3.1.11, this should read 3.0.3.1.9.

3.6.2.1.1 3-484 In the discussion of Metal Enclosed Bus on this page, an NRC letter dated September 30, 2009 and a CR-3 letter dated December 30, 2009 are cited. The dates of these letters should be November 3, 2009 and December 3, 2009.

4.3.3.2 4-42 In the fourth paragraph, revise NUREG/CR-6909 to NUREG/CR-5704 to agree with the response provided to RAI 4.3.3-2, Part 5, contained in letter, 3F1009-07, dated October 13, 2009 (ADAMS Accession No. ML092890155).

4.7.4 4-63 The final sentence in this section refers to the UFSAR Supplement. For CR-3, this should be the FSAR Supplement.

Commit #1 A-2 The implementation schedule should be, "As stated in the Commitment."

Commit A-4 Refer to the comment on SER Section 3.0.3.2.8, page 3-120, regarding updating

1. 11 the commitments for the Fuel Oil Chemistry Program. Also see the revised Commitment #11 in Enclosure 3.

Commit A-5 Refer to the revised commitment in Enclosure 3 which is based on the information

1. 19 provided in the response to RAI B.2.29-1 submitted in letter, 3F1210-09, dated December 29, 2010.

Commit A-6 Refer to the revised commitment in Enclosure 3 which is based on the information

1. 20 provided in the response to RAI B.2.30-6 submitted in letter, 3F1210-09, dated December 29, 2010.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 2 AMENDMENT #18 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S. Nuclear Regulatory Commission Enclosure 2 3F01 11-04 Page 1 of 3 Amendment 18 Changes to the License Renewal Application Source Source of oLicense Change I Renewal Application Amendment 18 Changes RAI Revise LRA Table 4.1-1 on Page 4.1-4 to change entry under the column entitled "10 CFR 4.3.4-1 54.21(c)(1) Paragraph" for the RCS Loop Piping Leak-Before-Break Analysis from (i) to (ii).

Revised Response Make the following changes to LRA Section 4.3.4 on Page 4.3-13:

Revise the Summary Description on Page 4.3-13 by deleting the last sentence and combining sentences 3 and 4 to read:

The TLAA in report BAW-1847, Revision 1, addresses fatigue flaw growth and an assessment of thermal aging of cast austenitic stainless steel (CASS) RCP inlet and exit nozzles.

Revise the second paragraph of the Fatigue Flaw Growth analysis at the top of LRA Page 4.3-14 by deleting the last sentence.

Revise the Summary paragraph on LRA Page 4.3-15 to read:

In summary, it has been demonstrated that the fatigue flaw growth analysis reported in BAW-1847, Revision 1, remains valid since the number of NSSS design transients will not be revised for License Renewal. Reduction of fracture toughness of the RCP nozzles was determined to be acceptable by projection to the end of the period of extended operation through the flaw stability analysis described above. The Alloy 82/182 welds within the scope of BAW-1847, Revision 1, are the welds that connect the 28 in. stainless steel carbon steel cold leg piping to the stainless safe pump transition pieces. Based on the above, the analysis has been projected to the end of the period of extended operation.

Revise the Disposition statement on LRA Page 4.3-15 to read:

10 CFR 54.21(c)(1)(ii) -The RCS loop LBB analysis has been projected to the end of the period of extended operation.

Make the following changes to LRA Section A.1.2.2.11 on Pages A-35 through A-37:

Revise the first paragraph on Page A-35 and the top of Page A-36 by deleting the last sentence and combining sentences 2 and 3 to read:

The TLAA in BAW-1847, Revision 1, addresses flaw growth and an assessment of thermal aging of cast austenitic stainless steel (CASS) RCP inlet and outlet nozzles.

Revise the first full paragraph on Page A-36 by deleting the last sentence, i.e., the sentence beginning with: "Therefore, the flaw growth evaluation reported in BAW-1 847..."

Revise the final paragraph on Page A-37 to read:

Therefore, it has been demonstrated that the fatigue flaw growth analysis reported in BAW-1847, Revision 1, remains valid since the number of NSSS design transients will (continued)/

U. S. Nuclear Regulatory Commission Enclosure 2 3F0111-04 Page 2 of 3 Source of License Renewal Application Amendment 18 Changes Change RAI not be revised for License Renewal. Reduction of fracture toughness of the RCP 4.3.4-1 nozzles was determined to be acceptable by projection to the end of the period of Revised extended operation through the flaw stability analysis described above. The Alloy Response 82/182 welds within the scope of BAW-1 847, Revision 1, are the welds that connect the (continued) 28 in. stainless steel carbon steel cold leg piping to the stainless safe pump transition pieces. Based on the above, the analysis has been projected to the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii).

RAI Revise the second paragraph of LRA Subsection A.1.1.16 on Page A-12, as follows:

B.2.16-1.1 from CR-3 Prior to the period of extended operation, the Program will be enhanced to: (1) adjust letter the inspection frequency for the Diesel-Driven Emergency Feedwater Pump Fuel Oil 3F01 10-04 Storage Tank to ensure an inspection is performed prior to the period of extended operation, (2) inspect the internal surfaces of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks. Based on 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.

Revise Exception (3) to Program Element Detection of Aging Effects, in LRA Subsection B.2.16, on Page B-55, as follows:

• Detection of Aging Effects

3) With the exception of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks which are subject to periodic ultrasonic thickness (UT) measurements, UT examinations would only be performed if visual inspection reveals significant internal damage due to loss of material. This exception is justified because if visible damage on the internal surface is not identified, then there is no compelling reason to perform UT measurements. Prior to the period of extended operation, all of the subject tanks will have had an inspection of internal surfaces. With the exception of the Emergency Diesel Generator Fuel Oil Storage, these are above ground tanks located inside protected structures; and their external surfaces will be periodically monitored during the period of extended operation in accordance with the License Renewal External Surfaces Monitoring Program. For the in-scope above ground tanks, if there is no significant corrosion identified in internal and external inspections, then additional UT inspections are not warranted. Based on the above, this exception is justified.

Revise Enhancements (2) and (3) to Program Elements Preventive Actions and Detection of Aging Effects, in LRA Subsection B.2.16, on Page B-55 and B-56, as follows:

• Preventive Actions

2) Inspect the internal surfaces of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks. Based on 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

U. S. Nuclear Regulatory Commission Enclosure 2 3F0111-04 Page 3 of 3 Source of License Renewal Application Amendment 18 Changes Change (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.

Detection of Aging Effects

2) Inspect the internal surfaces of the Diesel-Driven Fire Pump Fuel Oil Storage Tanks. Based on 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.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302/ LICENSE NUMBER DPR - 72 ENCLOSURE 3 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4

U. S. Nuclear Regulatory Commission Enclosure 3 3F01 11-04 Page 1 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 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 these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals 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 Prior to the period of Thermal Aging and Austenitic Stainless Steel (CASS) Program is a new program to extended operation Neutron Irradiation be implemented. When a Safety Evaluation Report is issued for Embrittlement of Cast MRP-227, any required actions that affect the aging management Austenitic Stainless strategy for these components will be incorporated into the Steel (CASS) Program program documents.

LRA Section B.2.6 RAI B.2.6-1

U. S. Nuclear Regulatory Commission Enclosure 3 3F01 11-04 Page 2 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 1E FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM '

• COMMITMENT_ ANALYSISREPORT IMPLEMENTATION, APPLICATION (LRA)

NO.... (FSAR) SUPPLEMENT E,,- - SOURCE___

___II LOCATION S 5 Program administrative control documents will be enhanced to A.1.1.8 Prior to the period of Bolting Integrity include: (1) guidance for torquing and closure requirements based extended operation Program on the EPRI documents endorsed by NUREG-1801, (2) requirements to remove instances where molybdenum LRA Section B.2.8, disulfide lubricant is allowed for use in bolting applications in RAI B.2.8-2, specific procedures and to add a general prohibition against use RAI B.2.8-3 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-1339), EPRI TR-104213, "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 3 3F01 11-04 Page 3 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4' FINAL SAFETY ITEM CM E ANALYSSFET PROGRAM LICENSE RENEWAL NO.COMMITMENT (FSAR) suppLEMENT IMPLEMENTATION APPLICATION (LRA)

-___ _________:_______..............__"___ ._-_ - LOCATION ' SCHEDULE- '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 joints prior to the period of extended operation.

U. S. Nuclear Regulatory Commission Enclosure 3 3F01 11-04 Page 4 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. __LOAINSCHEDULE (PSAR)LOCATION SUPPLEMENT SCEUEORE "SOURCE 7 Administrative controls for the Program will be enhanced to: A.1.1.12 Prior to the period of Inspection of Overhead (1) 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: A.1.1.13 Prior to the period of Fire Protection Program (1) 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 3 3F0111-04 Page 5 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 ITEM COMTETANALYSIS FINAL SAFETY REPORT PROGRAM PORM LICENSE LCNERNWL RENEWAL COMMITMENT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 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 3 3F01 11-04 Page 6 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDE SOURC E LOCATION SCHEDULE 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 3 3F01 11-04 Page 7 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM ANALYSIS REPORT A L NO. COMMITMENT (FSAR) SUPPLEMENT IMPLEMENTATION APPLICATION (LRA)

LOCATION SCHEDULE 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 Xl 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 3 3F01 11-04 Page 8 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT LOCATION SCHEDULE SOURCE 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 neriod of extended oDeration.

U. S. Nuclear Regulatory Commission Enclosure 3 3F01 11-04 Page 9 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. __LOAINSCHEDULE (FSAR)LOCATION SUPPLEMENT SCEUEORE SOURCE 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 new program to be implemented. Subject 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 Instrumentation Circuits Program is a new program to be Subject 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 3 3F01 11-04 Page 10 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMIMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT LOCATION LOCAIONSCHEDULE 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 program to be implemented. Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.36 27 Administrative controls for the Program will be enhanced to: A.1.1.37 Prior to the period of Fuel Pool Rack Neutron (1) include provisions to monitor and trend data for incorporation extended operation Absorber Monitoring in 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 LRA Section B.2.37, (3) implement periodic Boron-10 Areal Density Gauge for RAI 3.3.2.2.6-2, Evaluating Racks (BADGER) testing or comparable neutron RAI B.2.37-2 attenuation 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

U. S. Nuclear Regulatory Commission Enclosure 3 3F01 11-04 Page 11 of 11 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 4 FINAL SAFETY PROGRAM' LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 29 Administrative controls for the Program will be revised to: A.1.1.11 Prior to the period of Closed-Cycle Cooling (1) 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-1 801, extended operation Integrity Program Revision 1,Section XI.M19.

LRA Section A. 1.9 IRAI B.2.9-2.1