ML11242A151

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Nuclear Generating Plant - Audit of the Licensee'S Management of Regulatory Commitments
ML11242A151
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/31/2012
From: Farideh Saba
Plant Licensing Branch II
To: Franke J
Progress Energy Carolinas
Saba F
References
TAC ME5540
Download: ML11242A151 (24)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555*0001 January 31,2012 Mr. Jon A. Franke, Vice President Crystal River Nuclear Plant (NA2C)

ATrN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, Florida 34428-6708

SUBJECT:

CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME5540)

Dear Mr. Franke:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U. S. Nuclear Regulatory Commission (NRC) informed the licensees that the Nuclear Energy Institute (NEI) document, NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of the licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and regulatory commitments are being effectively implemented.

An audit of Crystal River Unit 3 Nuclear Generating Plant (CR-3) commitment management program was performed by the CR-3 project manager at the plant site during the period of June 29, 30 and 31, 2011. The Branch Chief of NRR's Division of Operating Reactor Licensing for Region II plants, which include CR-3, was also at the site during this period and participated in part of the discussions. During the audit, the NRC staff identified a missed implementation date for a regulatory commitment. The licensee's letter dated August 14, 2008, contained a regulatory commitment to revise the inservice inspection (lSI) plan regarding VT-3 examination of the reactor vessel support weld by September 30, 2008. However, the revision to the lSI plan was completed on December 15,2008 (overdue for 2.5 months) without a notification to the NRC and without a due date extension request. The licensee entered this missed implementation date in its PassPort© database and into its nuclear condition report. Notably, on February 2009, the licensee had created a business objects reports of the open commitments for the lead licensing engineer to ensure that regulatory commitments due dates are not missed.

J. Franke -2 Based on the audit, the NRC staff concluded that (1) CR-3 has generally, except as stated earlier, implemented NRC commitments on a timely basis, and (2) CR-3 has overall implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

Audit Report cc: Distribution via ListServ

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NOS. 50-302

1.0 INTRODUCTION AND BACKGROUND

In the Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitment are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

The document, NEI-99-04, defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (I.e. amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.).

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Crystal River Nuclear Plant, Unit 3 (CR-3) commitment management program was performed at the plant site during the period of June 29,30 and 31, 2011. This was the second audit performed at the plant. The previous audit was done in August 2008 and recorded in the audit report dated October 3, 2008. The second audit reviewed commitments made since the first audit. The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

Enclosure

- 2 2.1.1 Audit Scope The audit addressed most of the commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.), or licensing activities (bulletins, generic letters, etc.). Commitments made in licensee event reports or in response to notices of violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g.,

responding to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, technical specifications, and updated final safety analysis reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results Before the audit, the NRC staff searched the Agencywide Documents Access and Management System for the licensee's submittals that contained a list of regulatory commitments since the last audit. In addition, during the audit the NRC staff reviewed the status of regulatory commitments that were uin progress" during the last audit. Prior to the audit, the licensee also provided a list of regulatory commitments related to licensing actions from its commitment management system and the documentation to support the NRC staff's audit. The licensee's documentation included summary sheets providing the regulatory commitment action request and assignment number, the licensee's letter and date that contained the commitment, and the status of the commitment.

The licensee's commitment management program is described in the Progress Energy Corporation (PEC), Nuclear Generation Group, Standard Procedure REG-NGGC-011 0, Revision 3, "Regulatory Commitments." The PEC procedure is applicable to regulatory commitments made or modified after the effective date of this procedure.

The NRC staff reviewed the licensee's procedure, REG-NGGC-011 0, Revision 3, which is an updated version of the Revision 2 that was reviewed during the last audit. The NRC staff found that REG-NGGC-011 0, Revision 3 includes the following statements, which provide guidance to the licensee, is consistent with the intent of NEI 99-04, and ensures that CR-3 is appropriately implementing regulatory commitments.

- 3

  • In the case where a third party (e.g., NEI, an owners group, or another organization) has been authorized to make regulatory commitments on behalf of the licensee, the affected licensee shall ensure that statements represented as regulatory commitments are appropriately documented and are subsequently managed in accordance with REG-NGGC-0110.
  • Docketed correspondence containing action items shall also contain an explicit statement concerning the existence of any regulatory commitment.
  • Each regulatory commitment shall be captured in a PassPort© Action Request (AR).
  • The responsible licensing supervisor, or designee, shall confirm the accuracy of any implicit or explicit restatement of a regulatory commitment in docketed correspondence received from the NRC to ensure that written or oral communication has not been misconstrued.
  • Except for "discretionary enforcement" situations, advise the NRC that an oral statement to take a certain action represents the intention to make a regulatory commitment but does not constitute a regulatory commitment until submitted by the licensee in writing on the docket.
  • An assignment associated with a regulatory commitment must include appropriate reference to implementing documentation to provide traceability for the regulatory commitment.
  • If a regulatory commitment is not implemented as described by the due date or if noncompliance with regulatory commitment occurs, the responsible licensing supervisor, or designee, shall initiate a nuclear condition report and, if necessary, notify the NRC.
  • If a regulatory commitment has yet to be implemented and implementation plans change, the revised commitment can be implemented, however, the NRC should be notified of the change as soon as practicable after approval by appropriate management, and before any committed completion date. Notification should be accomplished by supplementing or revising the docketed correspondence containing the original commitment.

The licensee enters commitments made to the NRC into a commitment database called "PassPort©." The PassPort© database handles the commitments that are open or active. This database is used to track all commitments, including commitments to state and other agencies, and also tracks other plant activities. Each regulatory commitment should be captured in a PassPort© AR, a Nuclear Task Management (NTM) should be initiated, and appropriate actions to implement the regulatory commitment should be captured in a PassPort© Action Tracking Assignment. The assignment type is usually entered as "COMM" and is owned by the

-4 REGCOMM group. Also, entered are due dates and the names of individuals responsible for meeting the commitment.

In addition to REG-NGGC-011 0, a site-specific procedure, CP-252, "Commitment Management," Revision 8, is also being utilized at the CR-3 site. The procedure defines a process for identifying, managing, and changing ongoing regulatory commitments. An ongoing commitment is defined in this procedure as a commitment requiring ongoing and continuous implementation, whereas a one-time commitment is a commitment that is to be completed once by a specific date, event, or milestone and has no future or ongoing action. This procedure also defines the process for creating, maintaining, and changing active nuclear operations commitment system (NOCS) database entries for the ongoing regulatory commitments. A computer report from the NOCS database cross-references commitments to CR-3 implementation.

The NRC staff reviewed documentation generated by the licensee related to items listed in the attached table that are identified as regulatory commitments in response to different types of actions or communications (Category) with the NRC, in order to assess the implementation of each regulatory commitment, including the completion status. For the commitments selected for the audit, the NRC staff found that the licensee had adequately captured all of the regulatory commitments in their PassPort© system, which is a data management and tracking tool. For the on the ongoing commitments, the NRC staff verified that they have been correctly entered into the NOCS database, which is a commitment management tool.

During the audit, the NRC staff reviewed plant procedures that have been revised as a result of commitments made by the licensee to the NRC. The NRC staff noted that the procedures that are affected by a regulatory commitment are identified in the PassPort© database under the AR assigned for that commitment. As such, the licensee's procedure owner will be advised to refer to all the regulatory commitments associated with each procedure, prior to making any changes to the procedure. The review of the sample commitments in the above database reflected their status consistent with the commitment program. The attached audit summary table provides details of the audit and its results.

The NRC staff reviewed the status of the implementation of the regulatory commitments that were made since the last audit and the commitments that were in progress at that time. During the audit the NRC staff identified a missed implementation date for a regulatory commitment.

The licensee's letter dated August 14, 2008, contained a regulatory commitment to revise the inservice inspection (lSI) plan regarding the VT -3 examination of the reactor vessel support weld by September 30, 2008. However the lSI plan was revised on December 15, 2008 (overdue for 2.5 months) without notifying the NRC and requesting a due date extension. The licensee entered this missed implementation date in its PassPort© database AR No. 474202 and into its nuclear condition report (NCR) 20110630. Notably from February 2009 and looking forward, the licensee had created a business objects reports of the open commitments to ensure that regulatory commitments due dates are not missed. This report did not look backward, therefore it did not identify the previously missed due date.

- 5 2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at CR-3 is contained in the PEC's procedure, REG-NGGC-0110. This procedure along with the CR-3 procedure, CP-252, for managing ongoing regulatory commitments, are being used at CR-3 for tracking changes to regulatory commitments made to the NRC. The audit reviewed most of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results The NRC staff reviewed the licensee's procedure, REG-NGGC-0110 against NEI 99-04. The REG-NGGC-0110 provides guidance to the licensee that is consistent with the intent of NEI 99 04, and ensures that CR-3 is appropriately implementing regulatory commitment changes, as well as tracking changes to the commitments.

The NRC staff found that REG-NGGC-011 0 adequately conforms to the guidance and intent of NEI 99-04 for commitment tracking, the commitment change process, traceability of commitments, and reporting requirements. Regulatory commitment changes are processed and tracked by the responsible licensing supervisor, or designee. The evaluation of any commitment changes is to be done by filling the "Regulatory Commitment Change Evaluation" form in Attachment 3 of the procedure. The NRC staff reviewed this form and found it consistent with the intent of the "Commitment Evaluation" form in NEI 99-04.

During the audit, the NRC staff reviewed the licensee's letter dated May 25,2010, that includes a summary of the CR-3 regulatory commitment changes for the period of November 23, 2007 to January 5, 2010. This regulatory commitment changes report indicated that of the 15 regulatory commitments that were modified or inactivated, 7 met the NEI 99-04 criteria for NRC notification. During the audit, the NRC staff reviewed the Regulatory Commitment Change Evaluation forms for those changes that were reported to the NRC as well as for those that did not meet the NEI 99-04 criteria for reporting to the NRC. These changes were captured in the NOCS database and provided in a computer review package. A computer report from the NOCS database and the regulatory commitment change evaluations are created and maintained in a binder by the lead licensing engineer.

During the audit, the NRC staff reviewed a change to a regulatory commitment that was originated in the licensee's letter dated February 12, 2007, and was reported by the licensee in its letter dated May 25,2010. The NRC staff noticed this is not a regulatory commitment; rather, it is the licensee's response to an NRC security order. However, the CR-3 lead licensing engineer indicated that this is consistent with the NEI proposal, as captured in the a safety

- 6 evaluation attached to the NRC's letter dated August 23,2007, that states "the implementing details found to be acceptable means of meeting the license condition would be treated as commitments and managed in accordance with NEI 99-04." During the audit, the NRC staff found this approach acceptable, since it is endorsed by the NRC in the August 23,2007, safety evaluation. No deficiencies were identified during this review for those changes that were reported to the NRC.

The NRC staff also reviewed the regulatory commitment changes that were made by the licensee from January 5, 2010, which is reported in the licensee's letter dated May 25, 2010, to a week prior to the audit. These regulatory commitment changes were compiled by the lead licensing engineer in a specific binder for this period and were presented to the NRC staff during the audit.

During the audit, the NRC staff identified an improper regulatory commitment change regarding the licensee's response to Notice of Violation 89-23-01 in 1989. The licensee in its letter dated November 21, 1989, committed to revise RSP-11 0, "Control of Auxiliary Building Rollup Door, n to require closure of the sliding door in the green room in the Auxiliary building (AB) when not in use. RSP-110 was replaced by RSP-101 "Basic Radiological Safety Information and Instructions for Radiation Workers." A commitment change request, which was approved internally by the licensee on July 15, 2010, added a note to the NOCS for this commitment for including a contingency in OP-409, "Plant Ventilation System," Revision 82. Specifically, OP-409 was revised to state that OP-409 will include contingencies for maintaining negative pressure in the AB when the green room sliding door is open for reasons other than ingress and egress from the AB. Section 4.28.3 of this procedure provides steps for opening the AB Sliding green room doorto the environment, if AHF-11A, AHF-11B or AHF-10 are removed from service and a high differential pressure exists across any AB door. The procedure requires monitoring airflow though the AB to the environment two times per shift. Further, OP-409 states that if airflow at the room is out from the AB or AB differential pressure reads less than 0.0 inches of water gage, then close the AB green room door.

Upon reviewing the revised OP-409, the NRC staff determined that the administrative controls added to the revised procedure are not adequate to ensure continuous negative pressure in the AB. Therefore, the original adverse condition identified in the notice of violation was restored by this change to the commitment. The licensee entered this inadequacy in the CR-3 operating procedure in its PassPort©database AR No. 474433 and into NCR 20110701.

Discussions with CR-3 staff confirmed that changes to regulatory commitments are generally being handled in accordance with the guidance contained in NEI 99-04. In addition, the NRC staff reviewed documentation from the licensee related to the items that involved changes to the commitments. The NRC staff found that, except for the commitment in the licensee's letter dated November 21, 1989, the licensee properly addressed each regulatory commitment change reviewed during this audit and has implemented an effective program to manage commitment changes.

-7 2.3 Audit Observations and Suggestions During the audit, the NRC staff noticed that:

(1) PassPort© database is used for all plant activities. Therefore, unless specific information (such as an AR number) is available, PassPort© is not a friendly tool for searching and identifying regulatory commitments applicable to the NRC.

(2) In preparation for the audit, the PEC lead licensing engineer requested that a business objects report be run on PassPort© to identify all assignments that were created since last audit. The lead licensing engineer only kept those assignments that in their attribute notes referred to a letter originated by the CR-3 licensing to the NRC, which its numbering started by "3F," e.g., 3F1008-05. Although, this report captured the majority of the regulatory commitments, it did not include those commitments made by other organizations, such as the licensee's corporate office.

This report also did not include commitments made in the amendment requests submittals and were considered completed upon issuance of the amendments.

(3) No AR number was assigned to the regulatory commitments prior to the use of the PassPort© database. The responsible licensing engineer generated an AR number if the commitment required a change or an update in its status (not a regulatory commitment change).

(4) Review of regulatory commitment changes that were not reported to the NRC shows that some of these commitments (usually, old commitments) should not have been identified as regulatory commitments because they were either codified requirements, commitments not related to the NRC, updated submittal schedules, or related to an inspection activity. As an example, the inadequacy that is discussed in Section 2.2.1 of this report is not a regulatory commitment; rather, it is a corrective action to restore compliance.

During the audit, the NRC staff and the CR-3licensing engineer discussed ways to improve efficiency and traceability of the regulatory commitments in both the Passport© and NOCS databases, and to ensure that a regulatory commitment due date is not missed. As a result, the following items were suggested:

(1) When creating an assignment to capture a regulatory commitment, a reference to both the letter number in which the regulatory commitment is contained and the letter date should be included.

(2) Check the status of open regulatory commitments at least every two weeks to ensure that the regulatory commitment due date is not missed.

3.0 CONCLUSION

The NRC staff concludes that based on the above audit: (1) CR-3 has generally implemented NRC commitments on a timely basis, and (2) CR-3 has implemented an effective program for managing NRC commitment changes.

- 8 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Dennis Herrin, Lead Engineer- Licensing and Regulatory Programs Dan Westcott, Supervisor - licensing and Regulatory Programs Principal Contributor: Farideh E. Saba

Attachment:

Audit Summary

AUDIT

SUMMARY

IMPLEMENTATION OF COMMITMENTS:

No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No.* Method Assignment No.

1 Relief Request March 12,2008 Provide a report of the weld overlay 14 days after 00269743-06 Attachment 2 of Letter 3F0208-04 examination results including a listing engineering 3F0308-07 dated of indications detected. The recording acceptance of the 03/26/08 criteria of the ultrasonic examination ultrasonic procedure to be used for the examination examination of the overlays requires results.

that all indications, regardless of amplitude, be investigated to the extent necessary to provide accurate characterization, identity, and location.

Additionally, the procedure requires that all indications, regardless of amplitude, that cannot be clearly attributed to the geometry of the overlay configuration be considered

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flaw indications. -_. -

Attachment

-2 No. Category Letter Datel Commitment Scheduled Date Action Completion Date*

No. Request No. - Method Assignment

-

No.

2 Relief Request March 12, 2008 Provide a report documenting the 14 days after 00269743-07 Letter 3F0308*07 3F0208*04 disposition of indications using the engineering dated 03/26/08.

standards of America Society of acceptance of the There were no Mechanical Engineers (ASME) Section ultrasonic suspected flaw XI, IWB-3514-2 and/or IWB-3514-3 examination indications observed criteria and, if possible, the type and results. during the nature of the indications. The examinations. No ultrasonic examination procedure disposition was requires that all suspected flaw necessary.

indications are to be plotted on a cross-sectional drawing of the weld and that the plots should accurately identify the specific origin of the reflector.

3 Relief Request March 12, 2008 Provide a report discussing any repairs 14 days after 00269743-08 Letter 3F0308-07 to the weld overlay material andlor engineering dated 03126/08.

base metal and the reason for the acceptance of the There were no repairs repairs.4 ultrasonic necessary to the weld examination overlay material or results. base metal.

- 3 No. Category Letter Datel Commitment Scheduled Date Action Completion Date*

No. Request No.* Method Assignment

-------- --------

No. ----

4 Relief Request March 12, 2008 Provide a report documenting a stress 60 days after 00269743-09 Attachment to Letter analysis summary demonstrating that entry into Mode 4 3F0508-12 dated the subject piping will perform its start-up. 05/15/08 intended design functions after the weld overlay installation. The stress analysis report will include results showing that the requirements of NB-3 200 and NB-3 600 of the ASME Code,Section III, are satisfied. The stress analysis will also include results showing that the requirements of IWB 3000 of the ASME Code,Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles will not adversely affect the integrity of the overlaid

welds. ---- ----

5 Generic Letter May 8,2008 Complete the detailed walk-downs and Currently 00263132-04 This commItment was (GL) 2008-01 3F0508-07 ultrasonic examinations of inaccessible scheduled for completed on 10/8/10.

piping at locations potentially 12119/2009. All GL-2008-01 susceptible to gas accumulation for activities were closed systems within the scope of the GL by the NRC letter prior to startup from the next refueling dated 6/24/2011.

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outage.

-4 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. Method Assignment

--

No.

6 GL 2008-01 May 8,2008 Submit supplemental response to the 90 days following 00263132-05 This commitment was 3F0508-07 NRC within 90 days following completion of completed on completion of Refueling Outage 16, Refueling Outage 14/044/10. All which will describe any changes to the 16. GL-2008-01 activities 9-month GL 2008-01 response were closed by the resulting from walkdowns and NRC letter dated ultrasonic examination of inaccessible 6/24/2011.

-

piping.

7 License October 6, 2008 Removal of the plant-specific technical This commitment 00288262-23 One TS page was Amendment PE&RAS-08-037 specifications (TSs) requirements will will be completed updated on 06/25/09.

Request be performed concurrently with the no later than implementation of the Title 10 of the October 1,2009.

Code of Federal Regulations (10 CFR), Part 26, Subpart I requirements.

- 5 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. - Method Assignment

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No.

8 GL 2008-01 October 13, 2008 Quarterly monitoring will be developed 1/31/2009 00263132-08 Assignment 08 was 3F1008-05 and implemented to ensure that the 00263132-12 completed on emergency core cooling system 00263132-13 01/27109 by (ECCS), decay heat removal (DH), and establishing containment spray system (BS) suction procedures for and discharge piping will be quarterly UT maintained sufficiently full of water to examinations.

ensure that the systems can reliably perform their intended functions. Assignment 12 was completed on The inspections will include a 02/02/09 by issuing requirement for periodic verification CP-1130.

(every 92 days) that the ECCS, DH, and BS piping will be maintained ' Assignment 13 was sufficiently full of water by a completed on combination of ultrasonic testing (UT), 01/29/09 by Rev 19 of and venting as deemed necessary, of OPS-NGGC-130, locations identified to be potentially Equipment Clearance.

susceptible to gas intrusion. (high to low pressure interfaces) The licensee created NOCS 100549 and Additionally, should any maintenance NOCS1 00550 for activities breach the ECCS, DH, or BS these ongoing RC.

system boundary, a UT will be performed as deemed necessary to verify the respective system{s) are sufficiently full prior to return to service. --

- 6 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. - Method Assignment No.

9 GL 2008-01 October 13, 2008 Procedures will be enhanced to Procedure 00263132-09 This commitment was 3F1008-0S provide additional detail where needed revisions will be completed on concerning venting sequence, venting completed by 12/23/09 through duration, dynamic venting, etc., and to 12/31/2009. completion of OP-402, UT appropriate piping locations OP-404 and OP*40S.

following fill and vent as deemed necessary, to ensure piping is The licensee created sufficiently full prior to return to service. NOCS 1OOSS1for this

ongoing RC.

10 GL 2008-01 October 13, 2008 Florida Power Corporation (FPC) is 9 months after 00263132*06 Holding until approval 3F1008-0S continuing to support the industry and NRC approval of of TSTF S23, which Nuclear Energy Institute (NEI) Gas the TSTF. was submitted to the Accumulation Management Team NRC on June 29, activities regarding resolution of 2010, and is under generic improved technical review by the NRC specifications (ITS) changes via the staff.

Technical Specification Task Force (TSTF) Traveler process. Within 9 months after NRC approval of the TSTF Traveler, FPC wi" evaluate its applicability to Crystal River Unit 3 Nuclear Generating Plant (CR-3), and evaluate adopting the TSTF Traveler to supplement the current ITS requirements.

-7

~

No. Category Letter Datel Commitment Scheduled Date Action Completion Date-No. Request No. - Method Assignment No.

11 GL 2008-01 October 13, 2008 FPC will develop an acceptance 12/31/09 00263132-10 This commitment is 3F1008-0S criterion for the maximum allowable completed on void volume that will not challenge 12/23/09 by ECCS, DH, or BS System operability. Calculation M09-0049, Revision 1 and M09-00S1, Revision 1.

12 GL 2008-01 October 13, 2008 FPC will install the new vent valves Installation will be 00263132-11 All on-line and outage 3F1008-0S and relocate existing vent valves as completed prior to vent valves installed discussed in the design evaluation breaker closure by 12/29/09.

section of this response. following Refueling Outage 16.

13 Relief Request October 29, 2008 The details surrounding the design This vendor- 00282980-03 The analysis was 3F1008-03 analysis for the structural weld overlay supplied analysis completed by are bein~ developed to support the will be available 09/2S/09 and will be CR-3 16t refueling outage. for NRC review at available at the site for the beginnin~ of NRC's review at the the CR-3 16t beginning of the 16th refueling outage. iefueling.

14 Relief Request October 29, 2008 After completion of the ultrasonic Within 60 days of 00282980-06 The ultrasonic 3F1008-03 examination of the weld overlays, a completion of the examination results report containing the ultrasonic ultrasonic were submitted to the examination results, a discussion of examination of the NRC by letter 3F011 0 any repairs to the weld overlay weld overlays OS dated 01/13/2011.

material andlor base metal, and performed during reason the repair will be submitted to Refueling Outage the NRC. 16.

-8 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. - Method Assignment No.

15 Relief Request October 29,2008 The NRC will be notified as soon as Prior to Mode 4 00282980-13 See relief request 3F1008-03 practical, but no later than Mode 4 during restart from dated March 12, 2009.

during restart, if any cracks are the CR-3 16th detected that exceed the preservice refueling outage, if examination acceptance standards in required.

ASME Code,Section XI, Table IW8-3514-2. --

16 Relief Request March 12, 2009 1 NRC will be notified as soon as Prior to Mode 4 00282980-13 The NRC was notified 3F0309-03 practical if any cracks are detected that during restart from by letter 3F1209-01 exceed the preservice examination Refueling Outage dated 12/15/09.4 acceptance standards in ASME Code 16, scheduled for Section X1, Table IW8-3514-2, in fall 2009, if accordance with Attachment 5 of the necessary.

CR- 3 letter to NRC dated October 29, 2008 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML083080296).  !

17 Relief Request March 12, 2009 Submit preliminary analysis of the Prior to Mode 4 00282980-10 Final analysis of the 3F0309-03 residual stresses and flaw growth of during restart from residual stresses and repaired weldment, including crack Refueling Outage . flaw growth was growth calculations. 16, scheduled for submitted to the NRC fall 2009. by letter 3F1209-02

--

dated 12/17/09.

1 Also, see NRC's letter dated July 18, 2009.

- 9

-- --------,

No. Category Letter Date/ Commitment Scheduled Date Action Completion Date-No. Request No. - Method Assignment

---

No. ----

18 Relief Request March 12, 2009 After completion of the ultrasonic 60 days after 00282980-06 T e ultrasonic 3F0309-03 examination of the weld overlays completion of the e amination results performed in Refueling Outage 16, ultrasonic were submitted to the submit to the NRC the ultrasonic examination of the NRC by letter 3F011 0 examination results of the weld weld overlays 0 dated 01/13/2011.

overlays and a discussion of any performed in repairs to the overlay material andlor Refueling Outage base metal and reason for the repair, 16, scheduled for in accordance with Attachment 5 of the fall 2009.

CR-3 letter to NRC dated October 29, 2008 (ADAMS Accession No.

ML083080296). -

19 Relief Request March 12, 2009 Submit analysis of the residual 60 days after plant 00282980-12 Crack growth 3F0309-03 stresses and flaw growth of repaired restart (output caleulations were weldment, including crack growth breaker closure) su bmitted to the NRC calculations. from Refueling by letter 3F1209-02 Outage 16, dated 12/17/09.

scheduled for fall 2009.

20 License August4,2009 Proposed TS limits for frequency and Procedures are in 00288450 O~ 125/2010 Amendment 3F0809-01 voltage will be administratively place and will be (NTM PI ocedures SP-354A Request enforced until the license amendment maintained 2888450) ar d SP-354B were is implemented. amendment is in place and until the license maintained prior to implemented. af proval (12/10/2009) ar d implementation of

-- ~-.- ........... , the

-- amendment.

--

- 10 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. Method Assignment No.

21 National Fire November 25, CR-3 will submit a license amendment 6 months after the 00453160-03 This AR is completed Protection 2009 request for transitioning to NFPA 805. date of NRC's by the licensee's letter Association 3F1109-01 The license amendment request will safety evaluation dated June 29, 2011 (NFPA) 805 include a plant-wide assessment to report issuing the (six months after identify fire areas and fire hazards and license approval of the 2 nd evaluate compliance with the existing amendment to the pilot plant) requesting CR-3 fire protection licensing basis. second NFPA 805 an extension to July 1, This assessment will be performed in pilot plant. 2014. This request accordance with NEI 04-02, "Guidance was accepted by the for Implementing a Risk-Informed, NRC's letter dated Performance-Based Fire Protection August 8, 2011. The Program under 10 CFR 50.48(c)." licensee opens a new AR to track the new due date.

22 Exemption July 13, 2010 CR-3 will ensure that the affected For a minimum of The licensee withdrew 3F071 0-03 individuals will not work excessive 8 weeks this request on April overtime during the period immediately preceding 11,2011.

preceding the implementation of the implementation of exemption to 10 CFR 26.205(d)(3). the exemption.

Specifically, CR-3 will ensure covered personnel, including those temporarily assigned to outages at other units, do not work greater than an average of 54 hours2.25 days <br />0.321 weeks <br />0.074 months <br /> per week.

- 11 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. - Method Assignment No. I 23 License December 20, Spent fuel loading activities using the Procedures will be 00438875-02 In progress, this Amendment 20102 auxiliary building (AS) overhead crane modified and submittal was Request 3F1210-05 (FHCR-5) shall not commence if an implemented, and replaced by the letter approaching or potential tropical storm, training dated July 20, 2011.

an approaching or potential hurricane, conducted, as or a tornado watch or warning has needed, prior to been declared for the site in designating accordance with CR-3 site procedures. FHCR-5 as a If spent fuel loading activities with single failure proof FHCR-5 are in progress when any of crane.

the above criteria are met, the load will be lowered to a safe location. AS overhead crane FHCR-5 will be moved to the south end of the AS, away from the spent fuel pools, and the crane secured. I 24 License February 25, 2011 Proposed TS limits for the DFT-4 fuel Procedures are in 00448253-06 Procedures SP-306 Amendment 3F0211-01 oil supply tank level will be place and will be (NTM448253) and SP-249C and Request administratively maintained until the maintained until calculation M98-0118 license amendment is implemented. the license amendment is

-

implemented.

2 This amendment was supplemented by letter dated 20,2011.

- 12 No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. Method Assignment No.

  • 25 Exemption March 3, 2011 All workers beginning restart work will CR-3 will return to This exemption 3F0311-02 have a minimum 34-hour break within normal, online request is a the 9 days that precedes the day on work hour controls supplement to th July which the worker begins work at CR-3, within 60 days or 13, 2010 request. The and will not exceed the maximum work when the outage licensee withdrew this hour rules. activities are request on April 11, completed, 2011.

whichever is less.

26 Relief Request August14,2008 CR-3 will revise the Inservice 09/30/2008 NOCS During the audit the 3F0808-03 Inspection (lSI) Plan to assure that the 100547 NRC staff noticed that performance of a VT -3 examination of lSI plan is completed the reactor vessel support skirt weld, to on 12/14/2009, which the extent practical, will occur when is 2.5 months later maintenance or other activities remove than the commitment the insulation covering the support skirt due date without weld. reporting to the NRC.

The licensee created Action Request No.

00281127 to follow up

this issue.

27 GL 2004-02 February 26, 2009 FPC will respond to Request for Within 90 days of 00196070-07 In progress, 3F0209-02 Additional #7, and how the in-vessel issuance of the completion of this item downstream effects are addressed for final NRC staff. is linked to the NRC's CR-3. safety evaluation. approval of WCAP

~----.-

16793.

~ 13 ~

No. Category Letter Datel Commitment Scheduled Date Action Completion Date No. Request No. - Method Assignment No.

28 Topical August 25, 2009 CR-3 will provide the structural limit 180 days after the 00344602-03 In progress, due date Report, SAW 3F0809~02 associated with the most limiting large initial entry into is unknown due to 2374 break loss-of-coolant accident for the Mode 4 following extended refueling replacement steam generators as part completion of the outage of 2009.

of the next once-through steam steam generator generator tube inspection report tube inspections (required by the TSs) following in the fall 2011 completion of the next inspection of the refueling outage.

tubes in the replacement steam generators.

29 Cyber Security November 19, Enclosure 2 to request for approval of Varies 00367940-02 Withdrawn and 2009 the Crystal River Unit 3 Cyber Security 00367940-03 replaced by the 3F1 109-08 Plan. corporate letter dated July 8, 2010, which was approved by the NRC on July 29,2011.

J. Franke -2 Based on the audit, the NRC staff concluded that (1) CR-3 has generally, except as stated earlier, implemented NRC commitments on a timely basis, and (2) CR-3 has overall implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely, IRA!

Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

Audit Report cc: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL 2-2 R/F RidsNrrDor1LPL2-2 RidsNrrLACSola RidsNrrPMCrystalRiver RidsOgcRp RidsAcrsAcnw_MailCTR RidsRgn2MailCenter SMeighan, NRR ADAMS ACCESSION NO.: ML11242A151 o LPL2-2/LA LPL2-2/PM NAME FSaba CSoia FSaba DATE 09/06111 09/02/11 1131112 FFICIAL RECORD COpy

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