3F1210-05, License Amendment Request 310, Revision 0, Departure from a Method of Evaluation for Auxiliary Building Overhead Crane and Revisions to Associated Commitments

License Amendment Request 310, Revision 0, Departure from a Method of Evaluation for Auxiliary Building Overhead Crane and Revisions to Associated Commitments

ML103560837
Person / Time
Site:	Crystal River
Issue date:	12/20/2010
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1210-05
Download: ML103560837 (18)

Text

Progrs EnerY Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10CFR50.90 December 20, 2010 3F1210-05 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 License Amendment Request

1. 310, Revision 0 Departure from a Method of Evaluation for the Auxiliary Building Overhead Crane and Revisions to Associated Commitments

Dear Sir:

Pursuant to 10 CFR 50.90, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), hereby submits License Amendment Request (LAR) #310, Revision 0.

Crystal River Unit 3 (CR-3) will be constructing and operating an on-site Independent Spent Fuel Storage Installation (ISFSI) as a general licensee under the provisions of 10 CFR 72, Subpart K in order to maintain full-core offload capacity in the spent fuel pools. The spent fuel pools are located in the CR-3 Auxiliary Building (AB). In support of future dry shielded canister

/transfer cask loading operations, FPC is replacing the existing AB overhead crane with a new single failure proof crane.

This proposed LAR for CR-3 was the subject of a pre-application meeting with the NRC that was held on October 13, 2010. FPC proposes to perform analyses to qualify the new single failure proof AB overhead crane (FHCR-5) in accordance with ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)." FPC will also perform calculations to qualify the AB to Current Licensing Basis (CLB) using the applicable load cases in ASME NOG-1-2004 to account for the increased capacity of the new crane.

FPC requests NRC approval of the FPC method of analysis where differences exist between the CLB and ASME NOG-1-2004. In addition, as a result of improving the crane to a single failure proof classification, FPC desires to delete a commitment in the CR-3 Final Safety Analysis Report (FSAR) that is no longer applicable.

Neither the CR-3 Improved Technical Specifications nor the Facility Operating License are affected by this LAR.

New regulatory commitments are identified in Attachment 4.

FPC requests approval of this proposed LAR by December 1, 2011, with a 180 day implementation period. This time frame is required to perform all modification activities and preparations to commence fuel handling activities.

Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Powerline Street Crystal River, FL 34428

U. S. Nuclear Regulatory Commission 3F1210-05 Page 2 of 3 In accordance with 10 CFR 50.91, a copy of this application is being provided to the designated State of Florida Official.

The CR-3 Plant Nuclear Safety Committee has reviewed this request and recommended it for approval.

If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Superintendant, Licensing and Regulatory Programs at (352) 563-4796.

Vice President Crystal River Nuclear Plant JAF/rt/par Attachments: 1.

Background, Description of the Proposed License Amendment Request, Technical Analysis

2.

Regulatory Analysis (No Significant Hazards Consideration Determination, Applicable Regulatory Requirements, and Environmental Impact Evaluation) 3 Proposed Revised Final Safety Analysis Report Pages - Marked-Up Pages

4.

List of Regulatory Commitments cc:

NRR Project Manager Regional Administrator, Region II Senior Resident Inspector State Contact

U. S. Nuclear Regulatory Commission 3F1210-05 Page 3 of 3 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.

Jon A ranke V,e President 4

trystal River Nuclear Plant The foregoing document was acknowledged before me this ID Df.Wernber-

,2010, by Jon A. Franke.

day of Signature of Notary Public State of Florida aCfA ?&rbe\\

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

Personally Known A Produced

-OR-Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #310, REVISION 0 ATTACHMENT 1 Background, Description of the Proposed License Amendment Request, Technical Analysis

U. S. Nuclear Regulatory Commission 3F1210-05 Page 1 of 6 BACKGROUND, DESCRIPTION OF THE PROPOSED LICENSE AMENDMENT REQUEST, TECHNICAL ANALYSIS 1.0

Background

The purpose of the Crystal River Unit 3 (CR-3) Dry Fuel Storage project is to design, build and place into operation an Independent Spent Fuel Storage Installation (ISFSI). Florida Power Corporation (FPC) has selected the Transnuclear (TN) Standardized NUHOMS system as the dry spent fuel storage system for use at the CR-3 ISFSI under a 10 CFR 72, Subpart K, general license (Certificate Number 1004). The TN Standardized NUHOMS system provides for the horizontal storage of a Dry Shielded Canister (DSC) inside a ventilated, concrete horizontal storage module (HSM). Each DSC has a capacity to store up to 32 spent fuel assemblies. The ISFSI will be located within the CR-3 Protected Area and will be designed to provide storage capacity for a total of 80 HSMs.

CR-3 was originally designed and licensed for Spent Fuel shipping cask loading with two spent fuel pools separated by a removable gate, a cask loading pit and a cask decontamination pit located in the Auxiliary Building (AB). A 120-ton overhead crane (FHCR-5) was provided to lift and position fuel transportation casks in the AB and to deliver them to a transport vehicle through an elevated hatch to a grade level truck bay. FHCR-5 was designated as a Class I component but was not designed as single failure proof during initial plant design and licensing.

Auxiliar Building (AB) Design Basis The AB, with the exception of the steel roof support structure, is designated as a Class I structure as described in the CR-3 Final Safety Analysis Report (FSAR), Section 5.1, "Structural Design Classification." The concrete portion of the AB, which extends from the foundation mat to the 162 foot elevation at the top of the spent fuel pool, has been designed for the loads listed in FSAR Section 5.4.1.2, "Abnormal Loads (Protection of Safeguards)," which include seismic and tornado loads (including tornado generated missiles). The steel support structure (from the 162 foot to the 209 foot elevation) including the building siding and roof, is not a Class I structure.

As such, it is not designed or licensed to withstand tornado loads or to Class I seismic requirements. As the AB's steel structure is not classified as a Class I or II structure, it is by default Class III, in accordance with FSAR section 5.1.1.3. Based on a review of the original CR-3 design calculations, the steel support structure was designed to withstand Operational Basis Earthquake (OBE) loads based on Ground Response Spectra.

However, it was not designed to withstand Safe Shutdown Earthquake (SSE) loads.

FHCR-5 is supported by the AB steel roof/crane support structure. The crane rails are located at the 193 foot-7 inch elevation. The crane rails are supported on steel crane girders which are supported by vertical structural steel columns. The steel building columns are anchored to the concrete structure at the 143 foot and 162 foot elevations, and steel columns are also anchored at grade, 119 foot elevation.

The steel support structure (from the 162 foot to the 209 foot elevations) was designed for a wind load of 110 miles per hour (mph). CR-3 FSAR Section 5.1.2.4 states the following as the Class III design basis:

U. S. Nuclear Regulatory Commission 3F1210-05 Page 2 of 6 "Structures, components, and systems classified as Class III have been designed in accordance with applicable building code requirements."

A review of the CR-3 FSAR and design basis calculations indicate the following were used in design of the AB steel crane support structure, and represent the current licensing and design basis:

Wind/Hurricane Licensing Basis: Per applicable building code requirements (Ref.: FSAR 5.1.2.4).

Design Basis: 110 mph basic wind speed used in calculations.

Tornado Licensing Basis: Per applicable building code requirements (Ref.: FSAR 5.1.2.4). The Florida Building Code does not require structural design to include a tornado load case.

Design Basis: AB crane support structure is not designed for tornado wind or missile.

Seismic Licensing Basis: Per applicable building codes (Ref.: FSAR 5.1.2.4). The Florida Building Code does not require seismic design for this Class III structure.

Design Basis: The original plant design calculations included a seismic analysis for the crane support structure using an Operating Basis Earthquake (OBE) in response to ground acceleration of 0.05g horizontal and 0.033g vertical. This approach is consistent with FSAR Sections 5.1.2.3 and 5.1.2.9.a for the seismic design of Class II structures (see note below). Use of ground level OBE response spectra is the basis for the development of coefficients that were used to develop equivalent static seismic acceleration values at the various building elevations. Forces, based on these accelerations, were then used to design the various structural members of the AB crane support structure.

Note: The AB crane support structure was designed to withstand OBE level seismic loads, which exceeds the requirements for Class Ill structures, because Class III structures require no seismic design consideration per the Florida Building Code. The AB crane support structure is not designed for Safe Shutdown Earthquake (SSE) loads.

2.0 Description of Chanaes and Proposed License Amendment Request To support the safe movement of the DSC and transfer cask (TC) within the CR-3 AB during cask loading operations, the AB overhead crane (FHCR-5) is being replaced with a new single failure proof crane that meets the criteria specified in ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder)." FHCR-5 will be a Type I crane as defined in ASME NOG-1-2004, Section 1150. This new crane will be used to move a loaded or unloaded TC between the cask loading pit, the decontamination pit, and the transfer trailer in the truck bay. The new FHCR-5 overhead crane has an upgraded main hook design rated load of 130 tons, a 10-ton increase over the original FHCR-5 capacity.

Portions of the AB, which serve as crane support structure, are being analyzed and upgraded to meet the seismic demand requirements of a SSE as specified in ASME NOG-1-2004, and to account for the increased crane capacity.

ASME NOG-1-2004 is used as the design code for the new single failure proof crane. The AB crane support structure must continue to meet the requirements of the Current Licensing Basis (CLB). However, there are areas where ASME NOG-1-2004 and the CLB differ (e.g., load combinations). FPC has reviewed the load combinations specified in ASME NOG-1-2004 and

U. S. Nuclear Regulatory Commission 3F1210-05 Page 3 of 6 the load cases used in the original CR-3 design basis calculations.

To assure compatibility between the building and crane design, FPC is using the following load cases:

Load Combinations Used to Structurally Qualify Auxiliary Building Steel Structure Load Combination Allowable Stress Increase i

D+L+Lc D+L+L,+Iv D+L+L,+ IT D+L+L,+IL D+L+W D + L + L+ E D+L+Lc+E' D + L + L+

Iv +W D + L + Lc + IT + Wo D + L + L+ IL +Wo D+ L + Lc + E + Wo D + L +L

+ E' D + L + E + W, D + L + E'+ W, None None None None 1.33 1.33 Elastic Limit 1.33 1.33 1.33 1.33 Elastic Limit 1.33 Elastic Limit L = Lf + Lr D

=

Dead Load Including Crane Members Lf

=

Floor Live Load Lr

=

Roof Live Load Lc

=

Crane Live Load W

=

Wind Load, 110 miles per hour (mph)

Wo=

Operating Wind Load, 39 mph E

=

Earthquake Load (OBE)

E

=

Earthquake Load (MHE) (Note: This is same as SSE)

IV,T,L =

Crane Impact Load (vertical, transverse, longitudinal)

Key areas of differences in the load cases above, and the load cases specified in ASME NOG 2004 and/or the original design basis calculations are as follows:

1. There is no tornado load case in the load cases shown above that will be used to qualify the AB for the upgraded FHCR-5 crane. Tornado loads will not be applied to the crane because this loading condition is outside the design basis of this portion of the building. ASME NOG-1-2004, Section 4140, includes a load case for tornado wind. Section 4134(c) specifies that tornado wind and tornado generated missiles be considered. An exception to ASME NOG-1-2004 is being requested, and administrative controls, as committed in Attachment 4, are proposed to minimize the likelihood that FHCR-5 will be handling a spent fuel cask during a tornado.

U. S. Nuclear Regulatory Commission 3F1210-05 Page 4 of 6

2. SSE seismic loads are included in the table above. SSE loads were not considered in the original CR-3 design basis calculations for the crane support structure. FPC is adding these SSE loads to the analysis of AB structural members that serve as the crane support structure, and FPC will perform building modifications as a result of the new analyses. In addition, there are no CR-3 FSAR requirements on damping coefficients for Class III structures.

Therefore, the ASME NOG-1-2004 damping coefficients (4% for OBE and 7% for SSE) are being applied to the crane and crane support structure in the new seismic analysis. FPC is performing a coupled seismic analysis of the new crane and the AB steel support structure in accordance with ASME NOG-1-2004.

All applicable ASME NOG-1-2004, Section 4140, load cases will be applied to the crane and crane support structure, except the tornado load case (ASME NOG-1-2004, Section 4140, load case Pc14). The crane is an indoor crane and no wind load is applicable to the crane design. Wind loads are only applied to the AB crane support structure. Operating wind loads in these load cases will be combined with seismic loads to ensure that the building and crane are analyzed in a consistent manner.

Operating wind load is based on minimum sustained tropical storm force winds. Note that load cases combining wind and seismic exceed the current design basis of the building and that appropriate modifications will be performed to the building members that serve as the crane support structure. The building was previously analyzed only for OBE loads.

Load cases that include operation induced loads and abnormal loads are not applicable, since these loadings do not exist for CR-3. The construction load is calculated using the crane rated load.

License Amendment Request (LAR) #310, Revision 0, requests NRC approval of the following:

1. An exception to ASME NOG-1-2004 criteria pertaining to the application of tornado wind and tornado generated missile loading to the AB overhead crane and crane support structure.

This constitutes approval of a departure from one requirement of an approved method of evaluation used for the design and structural analysis of the new single failure proof AB overhead crane. To mitigate this change request, CR-3 will prohibit/suspend cask handling operations when high wind conditions such as tornadoes, hurricanes, and tropical storms are forecast. The proposed commitment is shown in Attachment 4.

2. Deletion of an FSAR commitment that was credited in the CR-3 Safety Evaluation Report, dated July 5, 1974. CR-3 FSAR, Section 9.6.3.1, "Spent Fuel Assembly Removal," currently states:

"When the Auxiliary Building Overhead Crane is operated in the cask removal mode, there is no spent fuel stored in spent fuel pool B and the gate between pools A and B is in place and sealed."

This FSAR commitment is no longer required or applicable with a single failure proof cask handling crane that will preclude a cask drop event by design.

U. S. Nuclear Regulatory Commission 3F1210-05 Page 5 of 6 Neither the CR-3 Improved Technical Specification nor the Facility Operating License are affected by this LAR.

3.0 TECHNICAL ANALYSIS

3.1 ASME NOG-1-2004 Exception FPC is using ASME NOG-1-2004 for the design of the new FHCR-5. ASME NOG-1-2004 has been endorsed by the NRC in Regulatory Issue Summary (RIS) 2005-25, Supplement 1, "Clarification of NRC Guidelines for Control of Heavy Loads," as an acceptable method for meeting the guidance in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants."

The new FHCR-5 will meet the criteria in ASME NOG-1-2004 for a Type I crane except for ASME NOG-1-2004, Section 4134(c), "Tornado Wind."

The new crane design does not consider tornado loads because the AB steel roof support structure, the walls, and the roof above the spent fuel pool that enclose the FHCR-5 support structure were not designed to withstand tornado loads. This approach departs from ASME NOG-1-2004. As an alternative to the design code requirement of ASME NOG-1-2004, Section 4134(c), a commitment is being made to not operate the crane for cask loading operations if an approaching or potential tropical storm, an approaching or potential hurricane, or a tornado watch or warning has been declared for the site in accordance with existing CR-3 plant procedures. The following new commitment is proposed:

Spent fuel loading activities using the Auxiliary Building overhead crane (FHCR-5) shall not commence if a an approaching or potential tropical storm, an approaching or potential hurricane, or a tornado watch or warning has been declared for the site in accordance with CR-3 site procedures.

If spent fuel loading activities with FHCR-5 are in progress when any of the above criteria are met, the load will be lowered to a safe location. Auxiliary Building overhead crane FHCR-5 will be moved to the south end of the Auxiliary Building, away from the spent fuel pools, and the crane secured.

CR-3 site procedures will be modified and implemented, and training will be conducted, as needed, in order to implement this commitment prior to designating FHCR-5 as a single failure proof crane.

During cask loading operations, if severe weather arises unexpectedly, the location for safe placement will be determined depending upon the activity under way when the weather condition occurs.

The following three safe locations are identified for placement of the suspended TC: (a) the cask loading pit; (b) the decontamination pit; and (c) the transfer trailer in the truck bay.

Probability of a Tornado Strike During FHCR-5 Operation At CR-3, the exceedance frequency for tornado strikes corresponding to Category F2 and above is estimated to be 2.25 x 10-' per year. Category F2 corresponds to a tornado with wind speeds between 113 mph and 157 mph, per the Fujita scale. During a spent fuel dry storage loading

U. S. Nuclear Regulatory Commission 3F1210-05 Page 6 of 6 campaign, the mission time for the use of FHCR-5 involving movement of heavy loads is estimated to be less than 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per year.

The exceedance frequency for strikes corresponding to Category F2 and above tornadoes during FHCR-5 operation is therefore estimated to be 5.13 x 10- per year (2.25 x 10-6 x 200/8760). This represents a low probability of occurrence, and therefore is considered to be a very small threat to the safe conduct of the CR-3 ISFSI loading operations. In addition, a commitment is made not to operate the crane if an approaching tropical storm or hurricane, or tornado related watch or warning has been declared for the site. Since these conditions are the most likely to spawn tornados, the probability of a tornado strike when FHCR-5 is being operated to move casks will be significantly lower than that calculated above.

3.2 Deletion of FSAR Commitment CR-3 FSAR, Section 9.6.3.1, "Spent Fuel Assembly Removal," states:

"When the Auxiliary Building Overhead Crane is operated in the cask removal mode, there is no spent fuel stored in spent fuel pool B and the gate between pools A and B is in place and sealed."

This requirement will prevent FPC from performing cask loading operations because it is not currently possible to remove all spent fuel from pool B. This FSAR commitment was made during initial CR-3 licensing prior to any spent fuel being loaded into pool B and is credited in the CR-3 Safety Evaluation Report, Section 9.1.2, "Spent Fuel Storage," dated July 5, 1974.

Industry expectations regarding spent fuel storage and offsite shipping options at that time were different from today's expectations.

This FSAR commitment is being deleted because spent fuel transfer cask handling with FHCR-5 will be conducted using a single failure proof lifting system, comprised of the new FHCR-5, along with lifting devices and interfacing lift points meeting the guidance in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6. With a single failure proof lifting system, including the new FHCR-5, a load drop accident will be an extremely low probability event below the threshold requiring consideration.

Thus, the cask drop event described in the CR-3 Safety Evaluation Report, Section 9.1.2 (dated July 5, 1974), involving a dropped cask striking the edge of the pool deck and rolling or tumbling into the adjacent spent fuel pool causing damage to stored fuel is not considered credible. Similarly, there is also no need to install and seal the gate between the two spent fuel pools during cask transfer operations because a cask drop that could damage pool B and drain both pools, is no longer considered a credible event. Crane operation will be procedurally controlled. Therefore, this commitment, intended to protect the fuel and pool inventory, is no longer required.

See Attachment 3 for proposed FSAR mark-up.

Conforming changes will also be made to the FSAR based on deletion of this commitment and installation of the single failure proof crane under 10 CFR 50.59.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #310, REVISION 0 ATTACHMENT 2 Regulatory Analysis No Significant Hazards Consideration Determination, Applicable Regulatory Requirements and Environmental Impact Evaluation

U. S. Nuclear Regulatory Commission 3F1210-05 Page 1 of 3 No Significant Hazards Consideration Determination Proposed License Amendment Request (LAR) #310, Revision 0, seeks NRC approval of the method of analysis used in the qualification of new fuel handling crane, FHCR-5, and portions of the Auxiliary Building (AB) that serve as the crane support structure. LAR #310 also requests NRC approval to delete a commitment in the Crystal River Unit 3 (CR-3) Final Safety Analysis Report (FSAR) related to use of the existing FHCR-5 for cask handling. This commitment is no longer required as a result of replacing crane FHCR-5 with a single failure proof design meeting the guidance in ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes, (Top Running Bridge, Multiple Girder)." Specifically, FPC requests the following:

a) Approval for a departure from the requirements of an approved method of evaluation used for the design and structural analysis of the new single failure proof AB overhead crane pertaining to tornado loads.

b) Approval to delete an FSAR commitment related to the use of the existing FHCR-5 for cask handling.

1. Does not involve a significant increase in the probability or consequences of an accident previously evaluated The proposed LAR does not involve plant equipment used to operate or shutdown the reactor or in the mitigation of accidents described in Chapter 14 of the FSAR.

The change provides justification for an exception to a Code requirement pertaining to the design and qualification of the new single failure proof crane in the AB. The new crane will meet the design specifications in ASME NOG-1-2004, with the exception of Section 4134 (c). The change also includes a commitment not to operate the crane if an approaching or potential tropical storm, an approaching or potential hurricane, or a tornado watch or warning has been declared for the site.

With the replacement of the crane, the occurrence of a cask load drop accident is considered not credible. As a result, the proposed change does not increase the probability or consequences of a load drop accident previously evaluated that could impact stored fuel and/or pool structural integrity.

Therefore, the proposed change does not involve significant increase in the probability or consequences of an accident previously evaluated.

2. Does not create the possibility of a new or different kind of accident from any accident previously evaluated The power generation portion of the plant is unaffected by the proposed change, which is limited to the design and analysis of a new overhead crane in the AB. The location and design functions of the AB overhead crane remain as they are currently described in the CR-3 FSAR. Overall, the design of the crane is being enhanced to single failure. proof in order to reduce the likelihood of an uncontrolled lowering of the load due to an unforeseen malfunction or subcomponent failure.

Portions of the design and analysis of the crane require NRC approval because they deviate from the NRC-endorsed design code for single failure proof cranes and the CR-3 licensing basis. The new single failure proof crane will be used to move a loaded or unloaded transfer cask between

U. S. Nuclear Regulatory Commission 3F1210-05 Page 2 of 3 the cask loading pit, the decontamination pit, and the transfer trailer in the truck bay. Any credible event involving the fuel handling evolutions are bounded by existing FSAR analyses.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does not involve a significant reduction in the margin of safety.

This proposed LAR involves the replacement of the existing non-single failure proof AB overhead crane with a new single failure proof crane. The new crane will meet the design specifications found in ASME NOG-1-2004, with the exception of Section 4134 (c). ASME NOG-1-2004 has been endorsed by the NRC in Regulatory Issue Summary (RIS) 2005-25, Supplement 1, "Clarification of NRC Guidelines for Control of Heavy Loads," as an acceptable means of meeting the criteria in NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants." The ASME NOG-1-2004 design code has been found by the NRC to provide adequate protection and safety margin against the uncontrolled lowering of the lifted load. The occurrence of a cask load drop accident is considered not credible when the load is lifted with a single failure proof lifting system meeting the guidance in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," Section 5.1.6, "Single Failure Proof Handling Systems." As a result, the proposed change has no adverse impact on new fuel, stored spent fuel, cooling capacity of the pool, or structural integrity of the pool. Similarly, the margin of safety for the operation and safe shutdown of the plant will not be affected by the proposed change.

Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above, Florida Power Corporation (FPC) concludes that the proposed license amendment request presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

Applicable Regulatory Requirements The proposed change is not a risk-informed change. The operation of the AB crane will be the same as is currently described in the CR-3 FSAR. The NRC has endorsed ASME NOG-1-2004 for licensees to use in the design and analysis of single failure proof cranes at nuclear power plants. Because FPC is deviating from that design code, NRC approval of that deviation is being requested.

FPC has evaluated the regulatory requirements and criteria applicable to the proposed LAR.

Heavy loads must be handled in a manner that does not jeopardize the ability of the plant to operate safely, to be shut down and maintained in a safe shutdown condition, and to mitigate potential accidents and other design basis operational events. FPC has determined that the new overhead crane is consistent with the following applicable regulatory requirements, guidance or criteria, except as noted in this LAR:

U. S. Nuclear Regulatory Commission 3F1210-05 Page 3 of 3

1. NRC Regulatory Issue Summary 2005-25, Supplement 1, "Clarification of NRC Guidelines for Control of Heavy Loads," dated May 29, 2007

2. ASME NOG-1-2004, "Rules for Construction of Overhead and Gantry Cranes, (Top Running Bridge, Multiple Girder)"

Environmental Impact Evaluation 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment, if operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant hazards consideration, (ii) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) results in a significant increase in individual or cumulative occupational radiation exposure.

Florida Power Corporation (FPC) has reviewed this License Amendment Request (LAR) and has determined that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22, no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the proposed license amendment request.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #310, REVISION 0 ATTACHMENT 3 Proposed Revised Final Safety Analysis Report Pages -

Marked-Up Pages

Revision:

32 Florida Power FINAL SAFETY ANALYSIS REPORT A Progress Energy Company AUXILIARY & EMERGENCY SYSTEMS Chapter:

9 Page:

45 of 80 9.6.3 CAPABILITY FOR ONSITE STORAGE OR OFFSITE DISPOSAL CR3 is licensed for storage of 1474 fuel assemblies. Before that limit is reached, it will be necessary for CR3 to consider additional onsite storage capacity or offsite disposal. The original CR3 design assumed that spent fuel would not be stored in Spent Fuel Pool B. That pool area was to have been used for cask loading. Therefore, rearrangement of Spent Fuel Pool B will be required prior to implementing spent fuel cask operations.

The following discussion is general information to describe the provisions that have been made in the design of CR3 to accommodate transfer of spent fuel either onsite or offsite.

However, the handling of heavy loads for cask movement will be subject to review by FPC and the NRC in accordance with the requirements of Bulletin 96-02, "Movement of Heavy Loads Over Spent Fuel, Over Fuel In The Reactor Core, Or Over Safety-Related Equipment."

9.6.3.1 Spent Fuel Assembly Removal Following a decay period, the spent fuel assemblies will be removed from storage and loaded into the spent fuel shipping cask underwater for removal from the site. The Auxiliary Building Overhead Crane (FHCR-5) will be used to handle the casks.

heen the Auxiliary Building OVerhead Crane is operated in the cask r.emoval mode, there is nie spent fuel stored in spent fuel peal B and the gate between pools A and B is in place and sealed.

The spent fuel cask will not be moved over any stored spent fuel. The movement of the cask will be limited to the cask storage area in the pool (near column line K, Figure 1-1 1), to the adjacent decontamination pit (on column line M l), then through the hatch between column lines QI and SI to a truck.

The handling of the spent fuel cask into and out of the cask loading area will be performed with a minimum of water (approximately 6,000 gallons) contained in the loading area.

Should the spent fuel cask be dropped during this operation and rupture the cask loading area floor, the 6,000 gallons of water could flow onto floor elevation 95 feet 0 inches. Floor drains are positioned in respective equipment cubicles throughout elevation 95 feet 0 inches to dissipate this volume of water to the Auxiliary Building sump, thus precluding any damage to major safety related equipment. Should any leakage develop related to Spent Fuel Pool B, the sump pumps which are located below elevation 95 feet 0 inches have the capacity to transfer the anticipated volume to the miscellaneous waste storage tank.

Prior to the actual handling of the spent fuel cask, the crane and associated systems will be thoroughly tested for any possible defects or inadequacies.

A check-off list and stringent administratively controlled operating procedures will be strictly adhered to during all spent fuel cask handling operations.

A decontamination area where the outside surfaces of the casks can be decontaminated prior to shipment will be provided.

9.6.4 CONTROL OF HEAVY LOADS PROGRAM DESCRIPTION 9.6.4.1 Introduction/Licensing Background In 1978 the NRC had concerns with the increased frequency in the handling of spent fuel casks over the spent fuel pools and near spent fuel. These concerns prompted Generic Technical Activity A-36 (Reference 14). The purpose of this task was to recommend necessary changes to assure the safe handling of heavy loads.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #310, REVISION 0 ATTACHMENT 4 List of Regulatory Commitments

U. S. Nuclear Regulatory Commission 3F1210-05 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Florida Power Corporation (FPC) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please notify the Superintendent, Licensing and Regulatory Programs of any questions regarding this document or any associated regulatory commitments.

Regulatory Commitments Due Date/Event

-I-Spent fuel loading activities using the Auxiliary Building overhead crane (FHCR-5) shall not commence if an approaching or potential tropical storm, an approaching or potential hurricane, or a tornado watch or warning has been declared for the site in accordance with CR-3 site procedures. If spent fuel loading activities with FHCR-5 are in progress when any of the above criteria are met, the load will be lowered to a safe location. Auxiliary Building overhead crane FHCR-5 will be moved to the south end of the Auxiliary Building, away from the spent fuel pools, and the crane secured.

Procedures will be modified and implemented, and training conducted, as needed, prior to designating FHCR-5 as a single failure proof crane.