ML11335A034

Response to Request for Additional Information for the Review of the Crystal River Unit 3, Nuclear Generating Plant, License Renewal Application and Amendment #23

ML11335A034
Person / Time
Site:	Crystal River
Issue date:	11/29/2011
From:	Franke J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1111-02, TAC ME0274
Download: ML11335A034 (19)

Text

io Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 November 29, 2011 3F1111-02 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 #23

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 November 8, 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 November 8, 2011, provided a request for additional information (RAI) concerning the CR-3 License Renewal Application (Reference 2). Enclosure 1 to this letter provides the response to Reference 2. In addition, Enclosure 2 to this letter contains Amendment #23 to the License Renewal Application.

No new regulatory commitments are contained in this submittal; however, changes to the CR-3 License Renewal Commitments based on previous CR-3 letters to the NRC are included in for your information and use.

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.

JAF/dwh

Enclosures:

1. Response to Request for Additional Information

2. Amendment #23 Changes to the License Renewal Application

3. Crystal River Unit 3 License Renewal Commitments, Revision 5 xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector 41 4D 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 3F1111-02 STATE OF FLORIDA COUNTY OF CITRUS Jon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.

4on A. Franke Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this __ day of

-av U/*,N- , 2011, by Jon A. Franke.

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

Personally 7 Produced Known 4' -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 3F1111-02 Page 1 of 1 REQUEST FOR ADDITIONAL INFORMATION RAI B.2.22-3.1

Background

The December 8, 2010, response to request for additional information (RAI) B.2.22-3, stated that alternative methods would be used to examine the nuclear services and decay heat seawater system intake conduits due to their depth of installation and proximity to the intake canal. The response also stated that the alternative method of inspection will be based on proven technology and industry operating experience, and will be qualified subject to performance demonstration specific to the plant, including consideration for piping material, design, and service. The response further stated that the performance demonstration will verify the ability of the test methods, equipment, and personnel to detect loss of material with sufficient resolution to ensure no loss of intended function. The April 26, 2011, response to RAI B.2.22-4 revised license renewal application Section A.1.1.20 to include a statement that the intake conduit inspections will be performed by qualified methods.

Issue Given that there are no currently qualified methods to examine the nuclear services and decay heat seawater system intake conduits one will have to be developed and demonstrated.

Request If a qualified method has been developed for inspecting the nuclear services and decay heat seawater system intake conduits, state this method and provide sufficient information such that the staff can confirm that the method will adequately manage the effects of aging.

If an alternative qualified performance demonstrated method to inspect the nuclear services and decay heat seawater system intake conduits must be developed then the proposed final safety analysis report (FSAR) supplement should contain a summary description of activities for managing the effects of aging as required by 10 CFR 21(d). The FSAR supplement should include, for example, that the test method will be based on proven technology and test parameters, a performance demonstration will verify the ability of the test methods, equipment, and personnel, and the alternative method will be capable of detecting loss of material with sufficient resolution to ensure no loss of intended function, and will consider industry operating experience.

Response

The CR-3 License Renewal FSAR Supplement description of the CR-3 Buried Pipingand Tanks Inspection Program has been revised to provide additionaldetail regarding inspection activities associated with the Nuclear Services and Decay Heat Seawater System intake conduits. The revised description reflects that test activities will be based on proven technology and test parameters. Test methods will incorporatethe use of performance demonstration and qualified methods as necessary to assure the efficacy of test results. These results will be capable of detecting loss of material with sufficient resolution to ensure no loss of intended function, and will considerapplicable industry operating experience.

This response involves a change to the License Renewal Application; refer to the information in .

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 2 AMENDMENT #23 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S. Nuclear Regulatory Commission Enclosure 2 3F1111-02 Page 1 of 1 AMENDMENT #23 CHANGES TO THE LICENSE RENEWAL APPLICATION Source of License Renewal Application (LRA) Amendment 23 Changes Change RAI On LRA Page A-13, replace Subsection A.1.1.20 as amended by LRA Amendments 12, 15, B.2.22-3.1 and 20, with the following paragraphs:

The Buried Piping and Tanks Inspection Program is a new program that manages the aging effect of loss of material for the external surfaces of buried steel piping components, as well as cracking and degradation of material properties of concrete, in CR-3 systems within the scope of License Renewal. The Program includes preventive measures to mitigate corrosion by protecting the external surface of buried components through use of coating or wrapping. The Program also includes visual examination of buried piping components made accessible by excavation. Program administrative controls to be developed include ensuring an appropriate as-found pipe coating and material condition inspection is performed whenever buried piping within the scope of this Program is exposed; specifying that an inspection datasheet will be used; requiring inspection results to be documented; including precautions concerning excavation and use of backfill for License Renewal piping and tanks, including a requirement that buried pipe and tank coating inspection shall be performed, when excavated, by qualified personnel to assess its condition; and including a requirement that a coating engineer or other qualified individual should assist in evaluation of any pipe and tank coating damage or degradation found during the inspection.

The Buried Piping and Tanks Inspection Program activities for the element Detection of Aging Effects are performed consistent with the requirements of NUREG-1801, Revision 2, except that CR-3 will use alternative methods, such as Broadband Electromagnetic (BEM) scanning, to examine the Nuclear Services and Decay Heat Seawater System intake conduit piping from the inside to determine the condition of its external surfaces.

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

This examination will be performed on at least 50% of the length of one of the two intake conduits, such that at least 25% of the piping length of both conduits will be inspected.

Qualification of the test methods will be established based on proven technology and test parameters, consideration of operating experience at other facilities, and will be validated with a performance demonstration specific to CR-3. The performance demonstration will incorporate piping material, design and service conditions, and will verify the ability of the test methods, equipment, and personnel to detect loss of material with sufficient resolution to ensure no loss of intended function. Initial testing will be performed prior to the period of extended operation, and will be repeated at intervals based on test results to ensure no loss of intended function prior to the next test performance. Test qualifications, including performance demonstration results, will be documented with the results of the initial testing.

The following table outlines the minimum inspection schedule prescribed for the Buried Piping and Tanks Inspection Program. (Note that the table of inspections was provided in LRA Amendment #20 via PEF letter to the NRC 3F0411-05, dated April 26, 2011.)

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 5

U. S. Nuclear Regulatory Commission Enclosure 3 3F1111-02 Page 1 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 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 cracking, Nickel Alloys CR-3 will comply with applicable NRC Orders and will implement applicable: (1) Bulletins and Generic Letters and (2) staff-accepted LRA Section A. 1.1 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 be extended operation Neutron Irradiation implemented. When a Safety Evaluation Report is issued for MRP- Embrittlement of Cast 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 3F1111-02 Page 2 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 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 disulfide LRA Section B.2.8, lubricant is allowed for use in bolting applications in specific RAI B.2.8-2, procedures and to add a general prohibition against use of RAI B.2.8-3 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 3F1111-02 Page 3 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT IMPLEDULEN O A ON(RC 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 prior RAI B.2.10-3 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 3F1111-02 Page 4 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL FIALSFEYPROGRAM SAFETY LICENSE RENEWAL ITEM NO. COMMITMENT ANALYSIS (FSAR) REPORT SUPPLEMENT PROGRAM IMPLEMENTATION LICENSE REEAL APPLICATION (LRA)

LOCATION SCHEDULE SOURCE LOCATION 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 3F1111-02 Page 5 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR)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 testincl.)

U. S. Nuclear Regulatory Commission Enclosure 3 3F1111-02 Page 6 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEM E LOAINSCHEDULE SOURC SOURCEE LOCATION 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 the RAI B.2.16-1.1 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 exposure A.1.1.17 Prior to the period of Reactor Vessel conditions of the reactor vessel remain bounded by those used to extended operation Surveillance Program project the effects of embrittlement to the end of the 60-year extended license period and (2) establish formalized controls for LRA Section B.2.17 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 3F1111-02 Page 7 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE SOURCE LOCATION 15 The Buried Piping and Tanks Inspection Program is a new program A.1.1.20 Prior to the period of Buried Piping and Tanks 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 the A.1.1.29 Prior to the period of Masonry Wall Program 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

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NO.SCHEDULE SOURCE 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 of LRA Section B.2.30, structures, (2) require notification of the responsible engineer when below grade concrete including concrete pipe is exposed so an RAI B.2.13-2.1 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 3 3F1111-02 Page 9 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. (FSAR) SUPPLEMENT SCHEDULE 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 new extended operation Connections Not 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 new extended operation Voltage Cables Not 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 3F1111-02 Page 10 of 12 CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5 FINAL SAFETY PROGRAM LICENSE RENEWAL ITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)

NO. _____________________________ (FSAR) SUPPLEMENT LOATONSCHEDULE SCHEM E SOURC SOURCEE LOCATION 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 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 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 A.1.1.38 Prior to the period of High-Voltage Insulators new program to be implemented. extended operation in the 230KV Switchyard Program LRA Section B.2.38

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NO. (FSAR) SUPPLEMENT SCHEM LOAINSCHEDULE E SOURC E 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 the RAI B.2.11-2 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.

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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 (AMP) prior to the period of Tendon Prestress 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 surveillance data, performing the regression analyses and log-linear trend plots, and a schedule for performing the tendon 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.