ML110760016

Response to Request for Additional Information for Review of License Renewal Application (TAC No. ME0274) and Amendment #19

ML110760016
Person / Time
Site:	Crystal River
Issue date:	03/15/2011
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0311-01, TAC ME0274
Download: ML110760016 (9)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 March 15, 2011 3F031 1-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Response to Request for Additional Information for the Review of the Crystal River Unit 3, Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274) and Amendment #19

References:

(1) CR-3 to NRC letter, dated December 16, 2008, "Crystal River Unit 3 -

Application for Renewal of Operating License" (2) NRC to CR-3 letter, dated November 30, 2010, "Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)"

(3) CR-3 to NRC letter, dated December 29, 2010, "Response to Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274) and Amendment #17" (4) NRC to CR-3 letter, dated December 14, 2010, "Safety Evaluation Report with Open Items Related to the License Renewal of Crystal River Unit 3 Nuclear Generating Plant (TAC NO. ME0274)"

Dear Sir:

On December 16, 2008, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) to extend the term of its operating license an additional 20 years beyond the current expiration date (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by letter dated November 30, 2010, provided a request for additional information (RAI) concerning the CR-3 License Renewal Application (Reference 2). Enclosure 1 to this letter provides a revised response to the previously-submitted RAI 4.3.3-6 response (Reference 3). The response was revised based on recent discussions with the NRC staff. Enclosure 2 to this letter contains Amendment #19 to the License Renewal Application and includes a new CR-3 License Renewal Commitment.

The NRC Safety Evaluation Report with Open Items Related to the License Renewal of CR-3 (Reference 4) has identified the resolution of RAI 4.3.3-6 as Open Item (Ol)-4.3.3-1. Therefore, this revised response to RAI 4.3.3-6 is intended to close that Open Item.

If you have any questions regarding this submittal, please contact Mr. Mike Heath, Supervisor, License Renewal, at (910) 457-3487, e-mail at mike.heath@pgnmail.com.

Jon .rn V. President rystal River Unit 3 JAF/dwh 140 Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street h Crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 3 3F031 1-01

Enclosures:

1. Revised Response to Request for Additional Information

2. Amendment #19 Changes to the License Renewal Application xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector

U. S. Nuclear Regulatory Commission Page 3 of 3 3F031 1-01 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. Franke Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this /. day of 2011, by Jon A. Franke.

Signature of Notary Public State of Florida

.- :'. CAROLYN CommissionE. # PORTMANN DD 937553 iJ -. PBonded Expires March 1,2014 ThruTroyFaininuanw 8"0.385.7019 (Print, type, or stamp Commissioned Name of Notary Public)

Personally V Produced Known -OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 1 REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

U. S. Nuclear Regulatory Commission Enclosure 1 3F031 1-01 Page 1 of 2 REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI 4.3.3-6

Background

In LRA Section 4.3.3, the applicant discussed the methodology to determine the locations that require environmentally assisted fatigue analyses consistent with NUREG/CR-6260 "Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear power Plant Components."

The staff noted that, in LRA Table 4.3-3, there are ten plant-specific locations listed based on the six generic components identified in NUREG/CR-6260.

Issue GALL Report AMP X.M1, "Metal Fatigue of Reactor Coolant Pressure Boundary," states that the impact of the reactor coolant environment on a sample of critical components should include the locations identified in NUREG/CR-6260 as a minimum, and that additional locations may be needed. The LRA is unclear whether the applicant verified that the plant-specific locations listed in the LRA Table 4.3-3 per NUREG/CR-6260 were bounding for the generic NUREG/CR-6260 components. Furthermore, the staff noted that the applicant's plant-specific configuration may contain locations that should be analyzed for the effects of the reactor coolant environment other than those identified in NUREG/CR-6260. This may include locations that are limiting or bounding for a particular plant-specific configuration, or that have calculated cumulative usage factor (CUF) values that are greater when compared to the locations identified in NUREG/CR-6260.

Request a) Confirm and justify that the plant-specific locations listed in LRA Table 4.3-3 are bounding for the generic NUREG/CR-6260 components.

b) Confirm and justify that the locations selected for environmentally-assisted fatigue analyses in LRA Table 4.3-3 consists of the most limiting locations for Crystal River Unit 3 Nuclear Generating Plant (beyond the generic components identified in the NUREG/CR-6260 guidance). If these locations are not bounding, clarify the locations that require an environmentally-assisted fatigue analysis and the actions that will be taken for these additional locations. If the limiting location identified consists of nickel alloy, state whether the methodology used to perform the environmentally-assisted fatigue calculation for nickel alloy is consistent with NUREG/CR-6909. If not, justify the method chosen.

Revised Response:

The following response replaces the response to this Request for Additional Information (RAI) provided in Crystal River Unit 3 (CR-3) to NRC letter, 3F1210-09, dated December 29, 2010, "Response to Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274) and Amendment

1. 17" (NRC Accession No. ML110030015).

U. S. Nuclear Regulatory Commission Enclosure 1 3F031 1-01 Page 2 of 2 CR-3 will perform a review of design basis ASME Code Class 1 fatigue evaluations to determine whether the NUREG/CR-6260 based locations that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting locations for the CR-3 plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactor coolant environment on fatigue usage. If any of the limiting locations consist of nickel alloy, NUREG/CR-6909 methodology for nickel alloy will be used in the evaluation.

This response has resulted in the changes to the LRA and development of a new License Renewal Commitment #31. These are documented in Enclosure 2.

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE 2 AMENDMENT #19 CHANGES TO THE LICENSE RENEWAL APPLICATION

U. S. Nuclear Regulatory Commission Enclosure 2 3F031 1-01 Page 1 of 2 Amendment #19 Changes to the License Renewal Application Source of License Renewal Application Amendment 19 Changes Change RAI Revise Section 4.3.3 of the LRA as follows. On page 4.3-12, insert the following paragraph 4.3.3-6 prior to the last paragraphin the section:

CR-3 will perform a review of design basis ASME Code Class I fatigue evaluations to determine whether the NUREG/CR-6260 based locations that have been evaluated for the effects of the reactorcoolant environment on fatigue usage are the limiting locations for the CR-3 plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactorcoolant environment on fatigue usage. If any of the limiting locations consist of nickel alloy, NUREG/CR-6909 methodology for nickel alloy will be used in the evaluation.

On page 4.3-13, revise the last paragraphin the section as follows:

Based on the results of this evaluation, the commitment to perform a review to determine whether the NUREG/CR-6260 based locations are limiting, and in accordancewith 10 CFR 54.21(c)(1)(iii), the effects of aging on the intended function(s) will be adequately managed for the period of extended operation using the CR-3 RCPB Fatigue Monitoring Program.

Revise Section A. 1.2.2.10 of the LRA as follows. On page A-35, insert the following paragraphpriorto the last paragraphin the section:

CR-3 will perform a review of design basis ASME Code Class 1 fatigue evaluationsto determine whether the NUREG/CR-6260 based locations that have been evaluated for the effects of the reactorcoolant environment on fatigue usage are the limiting locations for the CR-3 plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactorcoolant environment on fatigue usage. If any of the limiting locations consist of nickel alloy, NUREG/CR-6909 methodology for nickel alloy will be used in the evaluation.

The above change requires a revision to the CR-3 License Renewal Commitments to add new Commitment #31 as follows:

31 CR-3 will perform a review of design basis A.1.2.2.10 Prior to Environmentally 4SME Code Class I fatigue evaluations to the -Assisted determine whether the NUREG/CR-6260 based period of Fatigue Review locations that have been evaluated for the extended effects of the reactor coolant environment on operation RAI 4.3.3-6 fatigue usage are the limiting locations for the CR-3 plant configuration. If more limiting locations are identified, the most limiting location will be evaluated for the effects of the reactorcoolant environment on fatigue usage.

If any of the limiting locations consist of nickel alloy, NUREG/CR-6909 methodology for nickel alloy will be used in the evaluation.

(continued)

U. S. Nuclear Regulatory Commission Enclosure 2 3F031 1-01 Page 2 of 2 Source of License Renewal Application Amendment 19 Changes Change RAI On page A-35, revise the last paragraphas follows:

4.3.3-6 (continued) Based on the results of this evaluation and the commitment to perform a review to determine whether the NUREG/CR-6260 based locations are limiting, the effects of aging on the intended function(s) will be adequately managed for the period of extended operation using the CR-3 RCPB Fatigue Monitoring Programin accordance with 10 CFR 54.21(c)(1)(iii).