ML11335A034

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 and Amendment #23

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

Text

io Progress EnergyCrystal River Nuclear PlantDocket No. 50-302Operating License No. DPR-72Ref: 10 CFR 54November 29, 20113F1111-02U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001Subject:Crystal River Unit 3 -Response to Request for Additional Information for theReview of the Crystal River Unit 3, Nuclear Generating Plant, License RenewalApplication (TAC NO. ME0274) and Amendment #23References:(1)CR-3 to NRC letter, 3F1208-01, dated December 16, 2008, "Crystal RiverUnit 3 -Application for Renewal of Operating License"(2) NRC to CR-3 letter, dated November 8, 2011, "Request for AdditionalInformation for the Review of the Crystal River Unit 3 Nuclear GeneratingPlant, License Renewal Application (TAC NO. ME0274)"Dear Sir:On December 16, 2008, Florida Power Corporation (FPC), doing business as Progress EnergyFlorida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) toextend the term of its operating license an additional 20 years beyond the current expirationdate (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by letter datedNovember 8, 2011, provided a request for additional information (RAI) concerning the CR-3License Renewal Application (Reference 2). Enclosure 1 to this letter provides the response toReference 2. In addition, Enclosure 2 to this letter contains Amendment #23 to the LicenseRenewal Application.No new regulatory commitments are contained in this submittal; however, changes to the CR-3License Renewal Commitments based on previous CR-3 letters to the NRC are included inEnclosure 3 for your information and use.If you have any questions regarding this submittal, please contact Mr. Mike Heath,License Renewal, at (910) 457-3487, e-mail at mike.heath@pgnmail.com.Supervisor,JAF/dwhEnclosures:1.2.3.Response to Request for Additional InformationAmendment #23 Changes to the License Renewal ApplicationCrystal River Unit 3 License Renewal Commitments, Revision 5xc: NRC CR-3 Project ManagerNRC License Renewal Project ManagerNRC Regional Administrator, Region IISenior Resident InspectorProgress Energy Florida, Inc.Crystal River Nuclear Plant15760 W. Power Line StreetCrystal River, FL 34428414D U. S. Nuclear Regulatory Commission3F1111-02Page 2 of 2STATE OF FLORIDACOUNTY OF CITRUSJon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for FloridaPower Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized onthe part of said company to sign and file with the Nuclear Regulatory Commission theinformation attached hereto; and that all such statements made and matters set forth therein aretrue and correct to the best of his knowledge, information and belief.4on A. FrankeVice PresidentCrystal River Nuclear PlantThe foregoing document was acknowledged before me this __-av , 2011, by Jon A. Franke.day ofJ~64qL~ &~'J77';~pv7~Signature of Notary PublicState of Florida(Print, type, or stamp CommissionedName of Notary Public)Personally 7Known 4' -OR-ProducedIdentification PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72ENCLOSURE 1RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION U. S. Nuclear Regulatory Commission Enclosure 13F1111-02 Page 1 of 1REQUEST FOR ADDITIONAL INFORMATIONRAI B.2.22-3.1BackgroundThe December 8, 2010, response to request for additional information (RAI) B.2.22-3, statedthat alternative methods would be used to examine the nuclear services and decay heatseawater system intake conduits due to their depth of installation and proximity to the intakecanal. The response also stated that the alternative method of inspection will be based onproven technology and industry operating experience, and will be qualified subject toperformance demonstration specific to the plant, including consideration for piping material,design, and service. The response further stated that the performance demonstration will verifythe ability of the test methods, equipment, and personnel to detect loss of material with sufficientresolution to ensure no loss of intended function. The April 26, 2011, response to RAI B.2.22-4revised license renewal application Section A.1.1.20 to include a statement that the intakeconduit inspections will be performed by qualified methods.IssueGiven that there are no currently qualified methods to examine the nuclear services and decayheat seawater system intake conduits one will have to be developed and demonstrated.RequestIf a qualified method has been developed for inspecting the nuclear services and decay heatseawater system intake conduits, state this method and provide sufficient information such thatthe 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 anddecay heat seawater system intake conduits must be developed then the proposed final safetyanalysis report (FSAR) supplement should contain a summary description of activities formanaging the effects of aging as required by 10 CFR 21(d). The FSAR supplement shouldinclude, for example, that the test method will be based on proven technology and testparameters, 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 withsufficient resolution to ensure no loss of intended function, and will consider industry operatingexperience.ResponseThe CR-3 License Renewal FSAR Supplement description of the CR-3 Buried Piping and TanksInspection Program has been revised to provide additional detail regarding inspection activitiesassociated with the Nuclear Services and Decay Heat Seawater System intake conduits. Therevised description reflects that test activities will be based on proven technology and testparameters. Test methods will incorporate the use of performance demonstration and qualifiedmethods as necessary to assure the efficacy of test results. These results will be capable ofdetecting loss of material with sufficient resolution to ensure no loss of intended function, andwill consider applicable industry operating experience.This response involves a change to the License Renewal Application; refer to the information inEnclosure 2.

PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72ENCLOSURE 2AMENDMENT #23 CHANGES TO THE LICENSE RENEWALAPPLICATION U. S. Nuclear Regulatory Commission Enclosure 23F1111-02 Page 1 of 1AMENDMENT #23 CHANGES TO THE LICENSE RENEWAL APPLICATIONSource of License Renewal Application (LRA) Amendment 23 ChangesChangeRAI 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 theaging effect of loss of material for the external surfaces of buried steel pipingcomponents, as well as cracking and degradation of material properties of concrete, inCR-3 systems within the scope of License Renewal. The Program includes preventivemeasures to mitigate corrosion by protecting the external surface of buried componentsthrough use of coating or wrapping. The Program also includes visual examination ofburied piping components made accessible by excavation. Program administrativecontrols to be developed include ensuring an appropriate as-found pipe coating andmaterial condition inspection is performed whenever buried piping within the scope of thisProgram is exposed; specifying that an inspection datasheet will be used; requiringinspection results to be documented; including precautions concerning excavation anduse of backfill for License Renewal piping and tanks, including a requirement that buriedpipe and tank coating inspection shall be performed, when excavated, by qualifiedpersonnel to assess its condition; and including a requirement that a coating engineer orother qualified individual should assist in evaluation of any pipe and tank coating damageor degradation found during the inspection.The Buried Piping and Tanks Inspection Program activities for the element Detection ofAging Effects are performed consistent with the requirements of NUREG-1801, Revision2, except that CR-3 will use alternative methods, such as Broadband Electromagnetic(BEM) scanning, to examine the Nuclear Services and Decay Heat Seawater Systemintake conduit piping from the inside to determine the condition of its external surfaces.These examinations will be performed using qualified methods subject to performancedemonstration 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 intakeconduits, 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 testparameters, consideration of operating experience at other facilities, and will be validatedwith a performance demonstration specific to CR-3. The performance demonstration willincorporate piping material, design and service conditions, and will verify the ability of thetest methods, equipment, and personnel to detect loss of material with sufficientresolution to ensure no loss of intended function. Initial testing will be performed prior tothe period of extended operation, and will be repeated at intervals based on test results toensure no loss of intended function prior to the next test performance. Test qualifications,including performance demonstration results, will be documented with the results of theinitial testing.The following table outlines the minimum inspection schedule prescribed for the BuriedPiping and Tanks Inspection Program. (Note that the table of inspections was provided inLRA Amendment #20 via PEF letter to the NRC 3F0411-05, dated April 26, 2011.)

PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72ENCLOSURE 3CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS,REVISION 5 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 1 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEDULE SOURCELOCATION1 In accordance with the guidance of NUREG-1801, Rev. 1, A.1.1 As stated in the Reactor Vessel Internalsregarding aging management of reactor vessel internals commitment Aging Managementcomponents, CR-3 will: (1) participate in the industry programs for Activitiesinvestigating and managing aging effects on reactor internals,(2) evaluate and implement the results of the industry programs as LRA Section A. 1.1applicable to the reactor internals, and (3) upon completion ofthese programs, but not less than 24 months before entering theperiod of extended operation, submit an inspection plan for reactorinternals 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 Stressregarding aging management of nickel alloy and nickel-clad commitment Corrosion Cracking ofcomponents susceptible to primary water stress corrosion cracking, Nickel AlloysCR-3 will comply with applicable NRC Orders and will implementapplicable: (1) Bulletins and Generic Letters and (2) staff-accepted LRA Section A. 1.1industry guidelines.3 The Program will be enhanced to select an alternate lubricant that A.1.1.3 Prior to the period of Reactor Head Closureis compatible with the fastener material and the contained fluid. extended operation Studs ProgramLRA Section B.2.34 The Thermal Aging and Neutron Irradiation Embrittlement of Cast A.1.1.6 Prior to the period of Thermal Aging andAustenitic Stainless Steel (CASS) Program is a new program to be extended operation Neutron Irradiationimplemented. When a Safety Evaluation Report is issued for MRP- Embrittlement of Cast227, any required actions that affect the aging management Austenitic Stainlessstrategy for these components will be incorporated into the Steel (CASS) Programprogram documents.LRA Section B.2.6RAI B.2.6-1 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 2 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEDULE SOURCELOCATION5Program administrative control documents will be enhanced toinclude: (1) guidance for torquing and closure requirements basedon the EPRI documents endorsed by NUREG-1801,(2) requirements to remove instances where molybdenum disulfidelubricant is allowed for use in bolting applications in specificprocedures and to add a general prohibition against use ofmolybdenum disulfide lubricants for bolted connections,(3) guidance for torquing and closure requirements that includeproper torquing of the bolts and checking for uniformity of gasketcompression after assembly, (4) guidance for torquing and closurerequirements based on the recommendations of EPRI NP-5769,"Degradation and Failure of Bolting in Nuclear Power Plants," (withexceptions noted in NUREG-1339), EPRI TR-104213, "Bolted JointMaintenance & Applications Guide," and EPRI 5067, "Good BoltingPractices, A Reference Manual for Nuclear Power PlantPersonnel," Volumes I and II, (5) a centralized procedure based onEPRI NP-5769, EPRI TR-104213, and EPRI-5067 containingguidance regarding bolted joint leak tightness and pre-installationinspections consistent with the recommendations of thosedocuments, (6) periodic examinations of a representative sample ofbolting identified as potentially having yield strength >150 ksi forSCC consisting of periodic in situ ultrasonic testing or, alternatively,surface examination or bolt replacement, with sample sizes basedon EPRI TR-107514 methodology, (7) examination of NSSSsupport high strength bolting for SCC concurrent with examinationsof the associated supports at least once per 10-year ISI period, and(8) acceptance standards for examination of high strengthstructural bolting consistent with the recommendations of EPRI NP-5769 or application specific structural analyses.A.1.1.8Prior to the period ofextended operationBolting IntegrityProgramLRA Section B.2.8,RAI B.2.8-2,RAI B.2.8-3 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 3 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT IMPLEDULEN O A ON(RCLOCATIONSCHEDULE SOURCE6The Program will be enhanced to: (1) include the Nuclear Servicesand Decay Heat Seawater System Pumps in a periodic inspectionand/or rebuild program. This Program will be initiated during thecurrent license period and inspect one or more pumps prior to theperiod of extended operation, (2) subject the Nuclear Services andDecay Heat Seawater System Discharge Conduits to inspectionand evaluation subsequent to the SG replacement project, but priorto the period of extended operation, in order to determine theextent of activities required during the period of extended operationto support the intended function of these components, (3)incorporate hardness/scratch testing for selective leaching into theexaminations of susceptible pumps and valves and, if evidence ofdegradation is detected, of seawater heat exchanger tubesheetcladding, (4) incorporate Nuclear Services and Decay HeatSeawater System Intake Conduit inspections for degraded ormissing concrete lining. Affected areas will be monitored to assureno loss of intended function until such time as the lining can berepaired, (5) incorporate acceptance criteria into procedures forinspections for biofouling and maintenance of protective linings,and (6) establish periodic maintenance activities for NuclearServices and Decay Heat Seawater System expansion joints priorto the period of extended operation.A.1.1.10As stated in thecommitmentOpen-Cycle CoolingWater System ProgramLRA Section B.2.10,RAI B.2.10-1,RAI B.2.10-2,RAI B.2.10-3 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 4 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETYFIALSFEYPROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT PROGRAM LICENSE REEALNO. (FSAR) SUPPLEMENT IMPLEMENTATION APPLICATION (LRA)LOCATION SCHEDULE SOURCELOCATION7 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 LightRenewal, (2) require the responsible engineer to be notified of Load Handling Systemsunsatisfactory crane inspection results involving loss of material, Program(3) specify the frequency of inspections for the cranes within thescope of License Renewal to be every refueling outage for cranes LRA Section B.2.12in the Reactor Building and every two years for cranes outside theReactor Building, and (4) clarify that crane rails are to be inspectedfor abnormal wear and that members to be inspected for crackinginclude 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 operationwalls, 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.2.13-2.1affect the fire barrier function, (2) include additional inspectioncriteria as described in NUREG-1801 for penetration seals, (3)include additional inspection criteria for corrosion of fire doors,(4) specify minimum qualification requirements for personnelperforming visual inspections of penetrations seals and fire doors,and (5) specify inspections of fire barrier walls, ceilings, and floorson a frequency of at least once every five years.

U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 5 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR)SCHEDULE SOURCELOCATION9The Program will be enhanced to: (1) incorporate a requirement toperform one or a combination of the following two activities:(a) Implement periodic flow testing consistent with the intent ofNFPA 25, or(b) Perform wall thickness evaluations to verify piping is notimpaired by pipe scale, corrosion products, or other foreignmaterial. For sprinkler systems, this may be done by flushing,internal inspection by removing one or more sprinkler heads, orby other obstruction investigation methods, (such as technicallyproven ultrasonic and X-ray examination) that have beenevaluated as being capable of detecting obstructions. (Theseinspections will be performed before the end of the currentoperating term. The results from the initial inspections will beused to determine inspection intervals thereafter during the periodof extended operation.),(2) perform internal inspections of system piping at representativelocations as required to verify that loss of material due to corrosionhas not impaired system intended function. Alternately, non-intrusive inspections (e.g., ultrasonic testing) can be used to verifypiping integrity. (These inspections will be performed before theend of the current operating term. The results from the initialinspections will be used to determine inspection intervals thereafterduring the period of extended operation.), (3) incorporate arequirement to perform a visual inspection of yard fire hydrantsannually consistent with the intent of NFPA 25 to ensure timelydetection of signs of degradation, such as corrosion, and (4)consistent with the intent of NFPA 25, either replace the sprinklerheads prior to reaching their 50-year service life or revise siteprocedures to perform field service testing, by a recognized testinglaboratory, of representative samples from one or more sampleareas. (Subsequent testing will be performed on a representativesample at an interval of 10 years after the initial field servicetestincl.)A. 1. 1. 14Prior to the period ofextended operationFire Water SystemProgramLRA Section B.2.14,RAI B.2.14-1 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 6 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEM E SOURC ELOAINSCHEDULE SOURCELOCATION10 The Aboveground Steel Tanks Program is a new program to be A.1.1.15 Prior to the period of Aboveground Steelimplemented. extended operation Tanks ProgramLRA Section B.2.1511 The Program will be enhanced to: (1) adjust the inspection A.1.1.16 Prior to the period of Fuel Oil Chemistryfrequency for the Diesel-Driven Emergency Feedwater Pump Fuel extended operation ProgramOil Storage Tank to ensure an inspection is performed prior to theperiod of extended operation, (2) inspect the internal surfaces of LRA Section B.2.16the Diesel-Driven Fire Pump Fuel Oil Storage Tanks. Based on the RAI B.2.16-1.1results of the inspection, the tanks will be cleaned and flushed asnecessary. These inspections will be performed every 2 years,unless trending indicates an appropriate change in frequency iswarranted, and (3) perform UT inspections of the Diesel-Driven FirePump Fuel Oil Storage Tanks prior to the period of extendedoperation, 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 Vesselconditions of the reactor vessel remain bounded by those used to extended operation Surveillance Programproject the effects of embrittlement to the end of the 60-yearextended license period and (2) establish formalized controls for LRA Section B.2.17the storage of archived specimens to ensure availability for futureuse by maintaining the identity, traceability, and recovery of thearchived 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 Inspectionimplemented. extended operation ProgramLRA Section B.2.1814 The Selective Leaching of Materials Program is a new program to A.1.1.19 Prior to the period of Selective Leaching ofbe implemented. extended operation Materials ProgramLRA Section B.2.19 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 7 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEDULE SOURCELOCATION15 The Buried Piping and Tanks Inspection Program is a new program A.1.1.20 Prior to the period of Buried Piping and Tanksto be implemented. extended operation Inspection ProgramLRA Section B.2.2016 Program administrative controls will be revised to incorporate A.1.1.1 Prior to the period of ASME Section XIperiodic 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 ProgramThe total number of socket welds selected for examination will beat 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.2.21-3perform a baseline inspection equivalent to one third of those RAI B.2.21-5inspections required for an interval. The regular inspectionschedule is to commence in the third period of the fourth ISIinterval.17 The Program will be enhanced to: (1) incorporate measures to A.1.1.22 Prior to the period of External Surfacesassure the integrity of surfaces that are inaccessible or not readily extended operation Monitoring Programvisible during both plant operations and refueling outages, and (2)incorporate inspection attributes for degradation of coatings. LRA Section B.2.22,RAI B.2.22-118 The Inspection of Internal Surfaces in Miscellaneous Piping and A.1.1.23 Prior to the period of Inspection of InternalDucting Components Program is a new program to be extended operation Surfaces inimplemented. Miscellaneous Pipingand DuctingComponents ProgramLRA Section B.2.2319 Program administrative controls will be enhanced to (1) identify the A.1.1.29 Prior to the period of Masonry Wall Programstructures that have masonry walls in the scope of License extended operationRenewal, (2) include inspection of the masonry walls in the LRA Section B.2.29Machine Shop in a periodic engineering activity (PMID), and3) require periodic inspection of masonry walls every five years. RAI 2.2-06RAI B.2.29-1 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 8 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO.SCHEDULE SOURCELOCATION20Program will be enhanced by revising the administrative controlsthat implement the Program to: (1) identify all License Renewalstructures and systems that credit the Program for agingmanagement in the corporate procedure for condition monitoring ofstructures, (2) require notification of the responsible engineer whenbelow grade concrete including concrete pipe is exposed so aninspection may be performed prior to backfilling, (3) requireperiodic groundwater chemistry monitoring including considerationfor potential seasonal variations, (4) require periodic inspections ofthe water control structures, i.e., Circulating Water Intake Structure,Circulating Water Discharge Structure, Nuclear Service Sea WaterDischarge Structure, Intake Canal, and Raw Water Pits, on afrequency not to exceed five years, (5) require periodic inspectionsof the Circulating Water Intake Structure submerged portions on afrequency not to exceed five years, (6) identify additionalcivil/structural commodities and associated inspection attributesand performance standard required for License Renewal in thecorporate procedure for condition monitoring of structures, (7)identify additional inspection criteria for structural commodities inthe site system walkdown checklist, (8) add inspection of corrosionto the inspection criteria for the bar racks at the Circulating WaterIntake Structure as a periodic maintenance activity, (9) add aninspection of the earth for loss of form and loss of material for theWave Embankment Protection Structure as a periodic maintenanceactivity, (10) include additional in-scope structures and specificcivil/structural commodities in periodic engineering activities,(11) require periodic inspections of the Fluorogold slide bearingplates used in structural steel platform applications in the ReactorBuilding., (12) require periodic inspection of structures on afrequency of at least once every five years, and (13) include thequantitative acceptance criteria of ACI 349.3R, Chapter 5, and (14)perform a baseline inspection using the quantitative acceptancecriteria of ACI 349.3R prior to the period of extended operation.A.1.1.30Prior to the period ofextended operationStructures MonitoringProgramLRA Section B.2.30,RAI B.2.13-2.1RAI B.2.30-6 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 9 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEDULE SOURCELOCATION21 The Electrical Cables and Connections Not Subject to 10 CFR A.1.1.31 Prior to the period of Electrical Cables and50.49 Environmental Qualification Requirements Program is a new extended operation Connections Notprogram to be implemented. Subject to 10 CFR 50.49EnvironmentalQualificationRequirements ProgramLRA Section B.2.3122 The Electrical Cables and Connections Not Subject to 10 CFR A.1.1.32 Prior to the period of Electrical Cables and50.49 Environmental Qualification Requirements Used in extended operation Connections NotInstrumentation Circuits Program is a new program to be Subject to 10 CFR 50.49implemented. EnvironmentalQualificationRequirements Used inInstrumentation CircuitsProgramLRA Section B.2.3223 The Inaccessible Medium Voltage Cables Not Subject to 10 CFR A.1.1.33 Prior to the period of Inaccessible Medium50.49 Environmental Qualification Requirements Program is a new extended operation Voltage Cables Notprogram to be implemented. Subject to 10 CFR 50.49EnvironmentalQualificationRequirements ProgramLRA Section B.2.3324 The Metal Enclosed Bus Program is a new program to be A.1.1.34 Prior to the period of Metal Enclosed Busimplemented. extended operation ProgramLRA Section B.2.3425 The Fuse Holder Program is a new program to be implemented. A.1.1.35 Prior to the period of Fuse Holder Programextended operationLRA Section B.2.35 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 10 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEM E SOURC E_____________________________ LOATONSCHEDULE SOURCELOCATION26 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A.1.1.36 Prior to the period of Electrical CableEnvironmental Qualification Requirements Program is a new extended operation Connections Notprogram to be implemented. Subject to 10 CFR 50.49EnvironmentalQualificationRequirements ProgramLRA Section B.2.3627 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 Monitoringtest procedures to ensure the projection meets the acceptance Programcriteria, (2) incorporate acceptance criteria tables for accumulatedweight 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.2.37-2attenuation testing for racks in Pools A and B to ensure that theneutron absorption intended function is maintained, and thattechnical 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 Insulatorsnew program to be implemented. extended operation in the 230KV SwitchyardProgramLRA Section B.2.38 U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 11 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEM E SOURC ELOAINSCHEDULE SOURCELOCATION29 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 Programphysical inspections to reflect that inspections of componentsexposed 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.2.11-2Instrument Air and Secondary Services Closed Cycle CoolingWater Systems to assure pump and heat exchanger performanceare identified as license renewal activities, and (3) flag proceduresassociated with closed cycle cooling water chemistry controls toidentify chemistry controls associated for in-scope systems asLicense Renewal activities.30 Implementing procedures for the Program will be enhanced to A.1.9 Prior to the period of Steam Generator Tubeensure compliance with the requirements in NUREG-1801, extended operation Integrity ProgramRevision 1,Section XI.M19.LRA Section A.1.9RAI B.2.9-2.131 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 Reviewbased locations that have been evaluated for the effects of thereactor coolant environment on fatigue usage are the limiting RAI 4.3.3-6locations for the CR-3 plant configuration. If more limiting locationsare identified, the most limiting location will be evaluated for theeffects of the reactor coolant environment on fatigue usage. If anyof the limiting locations consist of nickel alloy, NUREG/CR-6909methodology for nickel alloy will be used in the evaluation.

U. S. Nuclear Regulatory Commission3F1111-02Enclosure 3Page 12 of 12CRYSTAL RIVER UNIT 3 LICENSE RENEWAL COMMITMENTS, REVISION 5FINAL SAFETY PROGRAM LICENSE RENEWALITEM COMMITMENT ANALYSIS REPORT IMPLEMENTATION APPLICATION (LRA)NO. (FSAR) SUPPLEMENT SCHEDULE SOURCELOCATION32 CR-3 will develop and submit a plant-specific Concrete A. 1.1.41 At least one year Concrete ContainmentContainment Tendon Prestress aging management program (AMP) prior to the period of Tendon Prestressto address plant operating experience from the concrete extended operation Programdelaminations; include any revised Minimum Required Values andplans and schedules for revising the plant-specific program basis RAI B.3.3-1and implementation documents; include details for collectingsurveillance data, performing the regression analyses and log-linear trend plots, and a schedule for performing the tendonsurveillances; provide a discussion of tendon surveillances,including re-stressed tendons and any remaining undisturbedtendons; and provide a discussion of tendon surveillances,including use of common tendons during the period of extendedoperation. The AMP will follow the criteria of NUREG-1 800,Standard Review Plan for Review of License Renewal Applicationsfor Nuclear Power Plants, Revision 2, and will ensure aging effectsare adequately managed during the period of extended operation.