ML093210167

Crystal River, Unit 3 - Response to Request for Additional Information for Review of License Renewal Application, Section 2.3

ML093210167
Person / Time
Site:	Crystal River
Issue date:	11/12/2009
From:	Franke J A Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1109-05, TAC ME0274
Download: ML093210167 (50)

Text

Progress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 November 12, 2009 3F1 109-05 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) -Section 2.3

References:

(1) CR-3 to NRC letter, 3F1208-01, dated December 16, 2008, "Crystal River Unit 3 -Application for Renewal of Operating License" (2) NRC to CR-3 letter, dated October 15, 2009, "Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)"

Dear Sir:

On December 16, 2008, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) to extend the term of its operating license an additional 20 years beyond the current expiration date (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by letter dated October 15, 2009, provided requests for additional information (RAI) concerning the CR-3 License Renewal Application (Reference 2). The Enclosure to this letter provides the response to Reference 2.No new regulatory commitments are contained in this submittal.

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.

Si ely, on A. Franke ice President Crystal River Unit 3 JAF/dwh

Enclosure:

Response to Request for Additional Information xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector Aoss Progress Energy Florida, Inc.Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 U. S. Nuclear Regulatory Commission 3F1 109-05 Page 2 of 2 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, informa xi'--tn elie ,n A. Franke Vice President Crystal River Nuclear Plant The foregoing document was acknowledged before me this J/0 day of L , 2009, by Jon A. Franke.Signature of Notary Public State of Florida (Print, type, or stamp Commissioned Name of Notary Public)Personally V/Known / -OR-Produced Identification PROGRESS ENERGY FLORIDA, INC.CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 -302 / LICENSE NUMBER DPR -72 ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION U. S. Nuclear Regulatory Commission F1 109-05 Page 1 of 47 REQUEST FOR ADDITIONAL INFORMATION RAI 2.3-01 General Items

Background:

Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal.Issue: Sections of the Crystal River Unit 3 Nuclear Generating Plant (CR-3) license renewal application (LRA) indicate that parts of various systems are in scope because they contain components that are relied upon during postulated fires per 10 CFR 54.4(a)(3).

Section 2.1 of the CR-3 LRA describes the process for selecting components that are in scope under 10 CFR 54.4(a)(3).

However, numerous systems identified with components that are included in scope under 10 CFR 54.4(a)(3) to operate during postulated fires contain no discussion of the (a)(3) components in the CR-3 LRA system description text, the CR-3 final safety analysis report (FSAR) discussion, or on the CR-3 LRA drawings provided.

It is not possible to identify components that are included in scope under 10 CFR 54.4(a)(3) for components that are relied upon during postulated fires without an understanding of the components that were selected by the process. Specific examples of systems with components that are not identified within scope under 10 CFR 54.4(a)(3) include:* 2.3.3.25 Circulating Water System* 2.3.3.28 Fuel Oil System 0 2.3.3.32 Demineralized Water System* 2.3.3.38 Instrument Air System* 2.3.3.42 Make Up and Purification System* 2.3.4.3 Condensate Chemical Treatment System* 2.3.4.4 Condensate System* 2.3.4.18 Secondary Plant System Request: Provide sufficient information to permit the staff to identify all portions of the systems within the license renewal boundary as specified in 10 CFR Section 54.4(a)(3).

Response: Consistent with the methodology utilized in previous Progress Energy License Renewal Applications (LRA), the CR-3 scoping process for 10 CFR 54.4(a)(3) was based on a review of component level data in the Passport Equipment Database (EDB), supplemented by topical reviews as necessary, to ensure a comprehensive result. CR-3 utilizes the EDB to maintain the licensing basis for regulated events by translating compliance requirements in plant design and licensing basis documents into component level parameters.

The EDB provides individual component parameters associated with compliance with Station Blackout (SBO), Fire Protection (FP), Anticipated Transients Without Scram (ATWS), and Environmental Qualification (EQ) requirements.

Fire Protection parameters can be further broken down into Appendix R and classical fire protection, and within classical fire protection, a separate EDB parameter is also assigned to credited fire barrier penetrations.

CR-3 considered U. S. Nuclear Regulatory Commission 3F17109-05 Enclosure Page 2 of 47 that components credited in the EDB for regulated events are in License Renewal scope.Likewise, systems containing credited components are in scope, with the associated system intended function being compliance with the applicable regulated event(s).The mechanical systems identified in Table 2.2-1 of the CR-3 LRA also include electrical and civil components that are credited in licensing evaluations for compliance with 54.4(a)(3) events.Since scoping was done on a system basis, these civil and electrical components are subject to scoping as part of the system they are assigned to in the EDB, and their scoping results are reflected in the resulting list of system intended functions presented in the LRA. A review of scoping results for the examples given in this RAI shows that 54.4(a)(3) scoping for each of these systems was coupled to electrical and civil components that do not appear on License Renewal boundary drawings, and that most of these systems have no mechanical components or mechanical intended function associated with 54.4(a)(3) scoping. For example, the Condensate Chemical Treatment, Condensate, Circulating Water, Demineralized Water, Instrument Air, and Makeup & Purification Systems all have fire barrier seals (a civil feature)associated with the 54.4(a)(3) system intended function for Fire Protection.

Generally, where 54.4(a)(3) scoping is associated with a mechanical intended function, the function is not unique to the regulated events involved, and is encompassed by the system descriptions provided in Section 2.3 of the CR-3 LRA. The following table addresses the 54.4(a)(3) scoping basis for the examples presented in this RAI.System Regulated 10 CFR 54.4(a)(3)

Scoping Basis 2.3.3.25 Cirul.n WFP Contains credited fire barrier penetration seals.Circulating Water Contains EQ Electrical/l&C components credited with fuel oil (FO) supply to the Emergency Diesel Generators.

Contains check valve credited in preventing backflow of FO, this valve is 2.3.3.28 FP on the credited fill line for Emergency Feedwater Pump FO tank DFT-4.Fuel Oil Credited in Appendix R/Safe Shutdown evaluations associated with FO supply to Emergency Diesel Generators.

Credited in SBO evaluations associated with FO supply to diesel-driven Emergency Feedwater Pump (EFP-3).2.3.3.32 EQ Contains EQ Electrical/l&C components associated with containment Demineralized Water isolation function.FP Contains credited fire barrier penetration seals.Contains credited fire barrier penetration seals.FP Contains diesel powered air compressor and air reservoirs credited in 2.3.3.38 Appendix R/Safe Shutdown evaluations.

Instrument Air Contains components credited in SBO evaluations associated with air SBO supply to Atmospheric Dump Valves and air reservoirs for Make Up System valves.EQ Contains Electrical/l&C components credited in EQ evaluations.

Contains credited fire barrier penetration seals.2.3.3.42 FP Credited with providing inventory control in Appendix R/Safe Shutdown Make Up & evaluations.

Purification Contains system containment isolation valves credited to close to maintain Reactor Coolant System inventory and direct current powered Make Up Pump lube oil auxiliary pumps credited with being secured in the event.2.3.4.3 Condensate FP Contains credited fire barrier penetration seals.Chemical Treatment U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 3 of 47 System Regulated 10 CFR 54.4(a)(3)

Scoping Basis Event 2.3.4.4 Contains credited fire barrier penetration seals.Condensate FP Contains the Condensate Storage Tank, and related level instrumentation, credited as a source of water for safe shutdown.A TWS Contains Electrical/l&C components credited in A TWS evaluations.

EQ Contains Electrical/l&C components credited in EQ evaluations.

2.3.4.18 FP Contains Electrical/l&C components credited in Appendix R/Safe Secondary Plant Shutdown evaluations.

SBO Contains Electrical/l&C components and instrument seals associated with steam generator level control.RAI 2.3-02 General Items

Background:

Issue: 10 CFR 54.21(a)(1) requires the applicant to provide a list of structures and components subject to an aging management review (AMR). The staff reviews the LRA, FSAR, and license renewal boundary drawings to verify that the list of components provided for each system is complete.The CR-3 LRA does not specify which version of the FSAR is to be used as a reference.

The last revision of the FSAR submitted to the NRC was Revision 30.Subsequently, a complete copy of Revision 31 of the CR-3 FSAR was provided following the June 2009 NRC site audit. As a result of the June 2009 NRC site audit, it was determined that most of the calculations for the CR-3 LRA were performed using CR-3 FSAR Revision 30.Request: Provide revisions to the FSAR that would affect any systems within the scope of license renewal since Revision 30.Response: The CR-3 LRA was submitted to the NRC by letter dated December 16, 2008. The Final Safety Analysis Report (FSAR) revision submitted to the NRC, and in effect at the time of the LRA submittal, was Revision 31. FSAR Revision 31 was submitted by CR-3 to NRC letter, 3F0508-13, dated May 28, 2008, "Crystal River Unit 3 -Final Safety Analysis Report, Revision 31 and 10 CFR 50.59 Report." Copies of FSAR Revision 31, on CD format, were provided during the June 2009 audit as an aid to the NRC auditors.Regardless of the FSAR revision that was in effect during preparation of the basis documents (i.e., the calculations) that support the LRA, the technical informnation supporting the LRA was reviewed and updated prior to submittal of the LRA. In addition, the basis documents supporting the LRA were updated as necessary to reflect the results of this review.The next revision of the FSAR will be submitted following the current refueling outage at CR-3 in accordance with 10 CFR 50.71(e).

Future changes to the Current Licensing Basis that materially affect the contents of the LRA will be provided to the NRC in accordance with 10 CFR 54.21(b).

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 4 of 47 RAI 2.3-03 Backqround:

Issue: General Items 10 CFR Section 54.21(a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.During the scoping and screening review process, the continuation from one drawing to another could not be established.

Drawing numbers and/or locations for continuations were not identified and could not be located where identified, the continuation drawing was not provided, and piping expected to be in scope based on one drawing led to a different conclusion on a connecting drawing.Given below is a table that indicates the systems identified with these drawing inconsistencies.

License Renewal Continuation Location / Issue Application (LRA)Section/Drawing Number 2.3.3.24 INDUSTRIAL COOLING SYSTEM Four feedwater (FW) system relief valves are shown at locations E-4 (connected to CIHE-2A and 2B), F-3 (near CIV-279), and G-3 (near CIV-280).

The relief LRA.302..762-LR, SH01 line from each of these valves is shown to be within scope of the license renewal. However, the lines from these four valves are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

2.3.3.26 EFP-3 DIESEL AIR STARTING SYSTEM Two lines connected to two solenoid operators in locations C-6 and E-6 are highlighted in scope for LRA-302-778-LR, SH01 license renewal. However they are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

The drawing depicts four lines to the building sump pump as included in scope of license renewal under 10 CFR 54.4(a)(1).

The connecting drawing is not noted. Therefore, it is not possible to evaluate the LRA-302-778-LR, SH01 interaction of the sump pump piping on the EFP-3 diesel air starting system. CR-3 LRA drawing 302-114-LR, SH02, depicts an EFP area sump, but it is not clear if this is the building sump referenced on CR-3 LRA drawing 302-778-LR, SH01.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 5 of 47 2.3.3.27 DECAY HEAT CLOSED CYCLE COOLING SYSTEM Relief valves are shown in structures that contain 10 CFR 54.4(a)(1)components.

The discharge path of these relief valves is not indicated.

An example of this on the referenced drawing occurs at locations LRA-302-631-LR, SH01 E-3, C-7, D-8, D-9, and B-10. However, similar relief valves appear in numerous system drawings.

Identify the relief path from the relief valves for all systems inside structures that contain 10 CFR 54.4(a)(1) components so that spatial interaction can be evaluated.

2.3.3.29 JACKET COOLING SYSTEM The drawing depicts a pipe line marked 300-1 (shown at D-9 on each drawing) as included in scope of LRA-302-283-LR, license renewal under 10 CFR 54.4(a)(1).

This pipe SH01A&302-has an unidentified continuation arrow. Without SH01 &02 ...further information on this interface, it is not possible to evaluate the interaction of the connected piping on the jacket coolant system.2.3.3.32 DEMINERALIZED WATER SYSTEM At F-8, the drawing identifies connected piping in the liquid waste disposal spent resin transfer system at the decant pump suction as included in scope of LRA-302-182-LR, SH01 license renewal under 10 CFR 54.4(a)(2).

The associated drawing, 302-681-LR, SH05 does not identify any piping in scope at the decant pump suction.At C-4, the drawing identifies connected piping in the liquid waste disposal reactor coolant subsystem at the deborating demineralizers as included in scope of license renewal under 10 CFR 54.4(a)(2).

The associated drawing, 302-681-LR, SH03 identifies this connection as the boundary to an area exclusion where spatial interaction concerns do not exist.Therefore, there is a conflict as to what the applicant is identifying as in scope and what is excluded.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 6 of 47 2.3.3.38 INSTRUMENT AIR SYSTEM LRA-302-271-LR, SH01 The drawing depicts the backup air system for automatic dump valves (ADVs) as in scope of license renewal under 10 CFR 54.4(a)(2).

Continuation arrows are depicted in the intermediate building to MSV-25 and MSV-26. However the various air piping to the ADVs is not depicted on any instrument air system drawing or on the main steam drawings.Without a more extensive discussion of the instrument air piping to MSV-25 and MSV-26, it is not possible to validate that all components associated with the backup air system have been included in scope and evaluated for inclusion in an aging management program (AMP).No connection is shown from the instrument air system to the backup air system. A connection through IAV-546 and IAV-548 was expected.The drawing depicts an unlabeled drawing continuation mark as in scope of license renewal under 10 CFR 54.4(a)(2) at drawing location E-2.The CR-3 FSAR, Rev 31, drawing shows this connection to the condensate demineralizer system.This reference is not included with the license renewal drawings.The drawing inconsistently depicts American Society of Mechanical EngineersSection III, Class 2 and Class 4 flags on either side of containment penetrations 111 and 112 at location C-9. The depicted labeling confuses the evaluation of the boundaries for 10 CFR 54.4(a)(1) and (a)(2) piping and piping components.

2.3.3.41 MISCELLANEOUS DRAINS SYSTEM The drawing depicts a pipe continuation to a drain as in scope of license renewal at drawing location H-4. It is not clear if this continuation depicts a pipe run or an opening to another drain sump. No boundary flag is depicted.

It is not possible to completely evaluate piping that may be in scope of license renewal for spatial interaction without further discussion.

U.'S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 7 of 47 2.3.3.49 NUCLEAR SERVICE AND DECAY HEAT SEA WATER SYSTEM The line leaving valve RWV-1 11 shown at location F-6 is shown to be within the scope of license LRA-302-611-LR, SH01 renewal. However, it is not continued on another CR-3 LRA drawing, nor is it terminated at another valve or structure.

The discharge lines from RWV-61 (at location E-3)and RWV-62 (at location E-4) are shown to be within the scope of license renewal. However, the lines from these two valves are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

2.3.3.50 STATION AIR SYSTEM The drawing depicts connections to fire service valves (FSV-1 145, FSV-1 146, and FSV-1 147) as in LRA-302-271-LR, SH09 scope for license renewal. No connecting piping is depicted for a continued scoping and spatial interaction evaluation.

2.3.3.52 STATION DRAINS SYSTEM The line coming into isolation valve SDV-133 at location G-7 is shown to be within the scope of LRA-302-113-LR, SH02 license renewal. However, it is not continued on another CR-3 LRA drawing, nor is it terminated at another valve or structure.

Instrument air supply to SDV-90 shown at location A-8 is shown to be within the scope of license LRA-302-163-LR, SH01 renewal. However, the line into this valve is not continued on another CR-3 LRA drawing, nor is it terminated at another valve or structure.

2.3.3.60 WASTE SAMPLING SYSTEM The air supply line to flow control, RM-A6-FC, at location G-5 is shown to be within the scope of LRA-302-693-LR, SH01 license renewal. However, it is not continued on another CR-3 LRA drawing, nor is it terminated at another valve or structure.

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U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 8 of 47 2.3.4.1 CONDENSER AIR REMOVAL SYSTEM At location G-3, the applicant shows a line that goes into valve ARV-164. The drawing indicates that this LRA-302-131-LR, SH01 line is within the scope of AMR, but it does not indicate where the line originates from or to what the line connects.2.3.4.4 CONDENSATE SYSTEM Locations B-4 and B-9 show an exhaust line from the main feedwater pumps turbines (FWTB-1A at location B-4, FWTB-1 B at location B-9) to an open area of the drawing. These exhaust lines are also labeled "By LRA-302-101-LR, SH01 Foster Wheeler Corp." However, it is not clear if the FWTB exhaust to the atmosphere within theturbine building or to some other component or heat sink.Also, these two lines show no visible means of support or anchor.2.3.4.10 MAIN FEEDWATER SYSTEM Four FW system relief valves are shown at locations B-1 (FWV-263), B-2 (FWV-262), D-2 (FWV-16), and D-3 (FWV-17).

The relief line from each of these LRA-302-081-LR SH02 valves is shown to be within scope of the license renewal. However, the lines from these four valves are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

Two FW system relief valves are shown at locations D-7 (FWV-4) and D-9 (FWV-3). However, the relief line from each of these valves (FWV-3 & -4) are not shown on the drawing. Also, the lines are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

Request: Provide sufficient information for the continuation issues identified above to permit the staff to review all portions of the systems within the license renewal boundary as specified in 10 CFR Section 54.21(a)(1).

Response: CR-3 flow diagrams often do not depict, in their entirety, all relief valve discharge piping, instrument air piping to point of use devices, sample piping/tubing and drain piping. These piping components are included in scope in Class I structures.

In addition, CR-3 has revised its methodology for spatial interaction scoping to be more inclusive than the original LRA submittal scope as discussed in the response to RAI 2.1-2 in CR-3 to NRC letter, 3F0909-04, "Crystal U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 9 of 47 River Unit 3 -Response to Requests for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)," dated September 18, 2009 (ML092650272).

A specific evaluation for each of the identified continuation issues is included in the following table.LRA Section!Dra w in Continuation Location / Issue Resolution Drawing NumberI 2.3.3.24 INDUSTRIAL COOLING SYSTEM Four feedwater (FW) system relief The unnamed relief valves connected to valves are shown at locations E-4 CIHE-2A and CIHE-2B were factory relief (connected to CIHE-2A and 2B), F- valves provided with these hot water 3 (near CIV-279), and G-3 (near heaters. The discharge flow path from CIV-280).

The relief line from each these relief valves is not depicted on plant of these valves is shown to be drawings, but as a matter of design is within scope of the license renewal. directed to an area, such as a hub drain, LRA-302-762-LR, However, the lines from these four where a discharge would not create a SH01 valves are not continued on another personnel safety hazard. CIHE-2A and CR-3 LRA drawing, nor do they CIHE-2B relief valve discharge piping terminate at another valve or located inside the Intermediate Building structure. (IB) is in the scope of License Renewal.Relief valves CIV-279 and CIV-280 do not have discharge piping, and discharge directly into the Reactor Building (RB).2.3.3.26 EFP-3 DIESEL AIR STARTING SYSTEM Two lines connected to two The two referenced lines are vents for the solenoid operators in locations C-6 solenoid valves. There is no continuation LRA-302-778-LR, and E-6 are highlighted in scope for on additional CR-3 drawings.SH01 license renewal. However they are not continued on another CR-3 LRA drawing, nor do they terminate at another valve or structure.

The drawing depicts four lines to The sump pump is depicted on drawing the building sump pump as included 302-271-LR, Sheet 9 (G-5) and is part of in scope of license renewal under the Station Drain System. In the case of 10 CFR 54.4(a)(1).

The connecting the drains from the air receiver tanks in drawing is not noted. Therefore, it the Emergency Feedwater Pump Diesel LRA-302-778-LR, is not possible to evaluate the Air Starting System, the lines are free-SH01 interaction of the sump pump piping ended and routed to an open trench that on the EFP-3 diesel air starting communicates with the building.system. CR-3 LRA drawing 302-114-LR, SH02, depicts an EFP area sump, but it is not clear if this is the building sump referenced on CR-3 LRA drawing 302-778-LR, SH01.2.3.3.27 DECAY HEAT CLOSED CYCLE COOLING SYSTEM Relief valves are shown in Thermal relief valves and heat exchanger structures that contain 10 CFR /vessel overpressure protection 54.4(a)(1)components.

The installation at CR-3 incorporates LRA-302-631-LR, discharge path of these relief valves discharge piping, as needed, to route flow SH01 is not indicated.

An example of this to a local area where it poses no hazard on the referenced drawing occurs at to equipment or personnel.

In low locations E-3, C-7, D-8, D-9, and B- pressure, cold water applications, the 10. However, similar relief valves valve discharge piping may consist of a U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 10 of 47 appear in numerous system single piping fitting, or no discharge piping drawings.

Identify the relief path at all. As a matter of design, discharge from the relief valves for all systems piping from these relief valves does not inside structures that contain 10 incorporate isolation valves which might CFR 54.4(a)(1) components so that block the flow path and defeat the safety spatial interaction can be evaluated, function of the valve. Relief valve piping inside Class I structures is in the scope of License Renewal.2.3.3.29 JACKET COOLING SYSTEM The drawing depicts a pipe line The referenced line was incorrectly marked 300-1 (shown at D-9 on highlighted.

The "300-1" refers to a piping each drawing) as included in scope line class break and does not depict a of license renewal under 10 CFR piping component.

LRA-302-283-LR, 54.4(a)(1).

This pipe has an unidentified continuation arrow.Without further information on this interface, it is not possible to evaluate the interaction of the connected piping on the jacket coolant system. 1 2.3.3.32 DEMINERALIZED WATER SYSTEM At F-8, the drawing identifies CR-3 has revised its methodology for connected piping in the liquid waste spatial interaction scoping to narrowly disposal spent resin transfer system permit exclusions only in areas where at the decant pump suction as there are no safety related components, included in scope of license renewal that are adequately protected and isolated under 10 CFR 54.4(a)(2).

The from other areas of the plant, and are LRA-302-182-LR, associated drawing, 302-681-LR, equipped with drain systems which are SH01 SH05 does not identify any piping in themselves in the scope of License scope at the decant pump suction. Renewal. (See RAI 2. 1-2 response in CR-3 letter to NRC 3F0909-04, dated September 18, 2009.) Based on these changes, the decant pump suction piping on 302-182-LR, SH01 and 302-681-LR, SH05 is in the scope of License Renewal.At C-4, the drawing identifies CR-3 has revised its methodology for connected piping in the liquid waste spatial interaction scoping to narrowly disposal reactor coolant subsystem permit exclusions only in areas where at the deborating demineralizers as there are no safety related components, included in scope of license renewal that are adequately protected and isolated under 10 CFR 54.4(a)(2).

The from other areas of the plant, and are LRA-302-182-LR, associated drawing, 302-681-LR, equipped with drain systems which are SH03 identifies this connection as themselves in the scope of License the boundary to an area exclusion Renewal. (See RAI 2.1-2 response in CR-where spatial interaction concerns 3 to NRC letter, 3F0909-04, dated do not exist. Therefore, there is a September 18, 2009.) Based on these conflict as to what the applicant is changes, connected piping in the liquid identifying as in scope and what is waste disposal reactor coolant subsystem excluded, at the deborating demineralizers is I included in the scope of License Renewal.2.3.3.38 INSTRUMENT AIR SYSTEM The drawing depicts the backup air The Instrument Air System supply piping LRA-302-271-LR, system for automatic dump valves to the Main Steam System Atmospheric SH01 (ADVs) as in scope of license Dump Valves (ADVs), MSV-25 and MSV-renewal under 10 CFR 54.4(a)(2).

26, is not depicted on additional CR-3 U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 11 of 47 Continuation arrows are depicted in the intermediate building to MSV-25 and MSV-26. However the various air piping to the ADVs is not depicted on any instrument air system drawing or on the main steam drawings.

Without a more extensive discussion of the instrument air piping to MSV-25 and MSV-26, it is not possible to validate that all components associated with the backup air system have been included in scope and evaluated for inclusion in an aging management program (AMP).flow diagrams, other than the depiction on 302-271-LR, SHOI. LRA Section 2.3.3.38 for the Instrument Air System states, "The system also provides high pressure bottled air for backup operational capability of the Main Steam System Atmospheric Dump Valves to meet Station Blackout commitments." The instrument air piping components associated with both the backup air system and the normal air supply to MSV-25 and MSV-26 have been included in scope and evaluated for inclusion in an aging management program (AMP).These instrument air piping components include valves, piping, filter regulators, and tubing connecting to the valve operator and are included in LRA Tables 2.3.3-38 and 2.3.4-12 as "Piping, piping components, piping elements, and tanks." No connection is shown from the The Instrument Air System normal supply instrument air system to the backup piping connection with the backup air LRA-302-271-LR, air system. A connection through system for the Main Steam System ADVs IA V-546 and IA V-548 was is in the scope of License Renewal and is expected.

not depicted on additional CR-3 flow diagrams, other than the depiction on 302-271-LR, SH01 (see above response).

The drawing depicts an unlabeled The unlabeled continuation at scoping drawing continuation mark as in drawing location E-2 is a connection to scope of license renewal under 10 the Condensate Demineralizer System.CFR 54.4(a)(2) at drawing location FSAR Revision 31 identifies the E-2. The CR-3 FSAR, Rev 31, connection drawing as 302-161, SH03 drawing shows this connection to coming from 302-271, SH04. Flow the condensate demineralizer diagram 302-161, SH03 was not system. submitted as a flow diagram aid with the LRA-302-271-LR, LRA submittal since the scoping boundary SH04 This reference is not included with ends at the first valve in the Condensate the license renewal drawings.

Demineralizer System. Instrument Air System supply piping up to the Condensate Demineralizer system is in the scope of License Renewal. These instrument air piping components are included in LRA Table 2.3.3-38 as"Piping, piping components, piping elements, and tanks." The drawing inconsistently depicts The Inservice Inspection (ISI) Code Class American Society of Mechanical 2 and Class 4 flags at RB penetrations Engineers Section Il/, Class 2 and 111 and 112 identified at locations C-9 Class 4 flags on either side of and B-9 of 302-271-LR, SH04 are LRA-302-271-LR, containment penetrations 111 and incorrectly depicted.

ISI Code Class 2 SH04 112 at location C-9. The depicted should be identified on the RB boundary labeling confuses the evaluation of side of the drawing code class symbol.the boundaries for 10 CFR All of the subject piping is in the scope of 54.4(a)(1)and (a)(2) piping and License Renewal.p! piping components.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 12 of 47 2.3.3.41 MISCELLANEOUS DRAINS SYSTEM The drawing depicts a pipe The CR-3 drawing convention for flow continuation to a drain as in scope diagrams does not depict all drain piping.of license renewal at-drawing A plant piping drawing shows the location H-4. It is not clear if this discharge line from MDP- I connecting to continuation depicts a pipe run or a 6 in. drain pipe located in the same LRA-302-114-LR, an opening to another drain sump. area. All piping in the Miscellaneous SH02 No boundary flag is depicted.

It is Drains System located within the IB, not possible to completely evaluate where the MDSU-1 sump is located, is in piping that may be in scope of the scope of License Renewal for spatial license renewal for spatial interactions.

interaction without further discussion.

2.3.3.49 NUCLEAR SERVICE AND DECAY HEAT SEA WA TER SYSTEM The line leaving valve RWV-1 11 RWV- 111 is a local sample isolation valve shown at location F-6 is shown to for the Nuclear Service and Decay Heat be within the scope of license Seawater System, located within the renewal. However, it is not Seawater Room inside the Auxiliary LRA-302-61 1-LR, continued on another CR-3 LRA Building (AB). The typical design for local SH01 drawing, nor is it terminated at sample points is a sample isolation valve another valve or structure.

with a length of connected tubing routed to a suitable location for collecting the sample. The sample line connected to RWV-111 is located inside the AB and is in the scope of License Renewal.The discharge lines from RWV-61 Thermal relief valves and heat exchanger!(at location E-3) and RWV-62 (at vessel overpressure protection installation location E-4) are shown to be within at CR-3 incorporates discharge piping, as the scope of license renewal. needed, to route flow to a local area However, the lines from these two where it poses no hazard to equipment or valves are not continued on another personnel.

In low pressure, cold water CR-3 LRA drawing, nor do they applications, the valve discharge piping terminate at another valve or may consist of a single piping fitting, or no LRA-302-61 1-LR, structure.

discharge piping at all. As a matter of SH01 design, discharge piping from these relief valves does not incorporate isolation valves which might block the flow path and defeat the safety function of the valve. Relief valve piping inside Class I structures is in the scope of License Renewal, as is the case with these DCHE heat exchanger relief valves and I discharge piping.2.3.3.50 STATION AIR SYSTEM The drawing depicts connections to There are no additional supply piping con-fire service valves (FS V- 1145, FS V- nections identified on CR-3 flow diagrams 1146, and FSV-1147) as in scope for the Station Air System supply to FSV-for license renewal. No connecting 1145, FSV-1146, and FSV-1147.

The LRA-302-271-LR, piping is depicted for a continued Station Air System supplies supervisory SH09 scoping and spatial interaction air for the Emergency Feedwater Pump evaluation.

Building's pre-action sprinkler systems.The subject Station Air System piping components are in scope and included in LRA Table 2.3.3-50 as "Piping, piping components, piping elements, and tanks."

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 13 of 47 2.3.3.52 STATION DRAINS SYSTEM The line coming into isolation valve The CR-3 drawing convention for flow SDV-133 at location G-7 is shown diagrams does not depict all drain piping.LRA-302-113-LR, to be within the scope of license All piping in the Station Drains System SH02 renewal. However, it is not within the IB, including that depicted continued on another CR-3 LRA above the boundary flag on 302-113-LR, drawing, nor is it terminated at SH02, is in the scope of License another valve or structure.

Renewal.Instrument air supply to SD V-90 The CR-3 drawing convention for flow shown at location A-8 is shown to diagrams does not depict all instrument be within the scope of license air supply piping. The instrument air LRA-302-163-LR, renewal. However, the line into this supply piping to SDV-90, located in the SHOI valve is not continued on another AB, is included in the scope of License CR-3 LRA drawing, nor is it Renewal.terminated at another valve or structure.

2.3.3.60 WASTE SAMPLING SYSTEM The air supply line to flow control, The air supply piping for RM-A6-FC from RM-A6-FC, at location G-5 is shown the Instrument Air System to the radiation to be within the scope of license monitor flow control valve is not depicted LRA-302-693-LR, renewal. However, it is not on additional CR-3 flow diagrams.

This SH01 continued on another CR-3 LRA Instrument Air System supply line, located drawing, nor is it terminated at inside the AB, is in scope and included in another valve or structure.

LRA Table 2.3.3-38 as "Piping, piping I components, piping elements, and tanks." 2.3.4.1 CONDENSER AIR REMOVAL SYSTEM At location G-3, the applicant shows The referenced line is a dilution air inlet a line that goes into valve ARV-164. for vacuum pump ARP-1A, and originates The drawing indicates that this line locally at the vacuum pump skid. This LRA-302-131-LR, is within the scope of AMR, but it line is in the scope of License Renewal does not indicate where the line and is included in LRA Table 2.3.4-1 as originates from or to what the line "Piping, piping components, piping connects.

elements, and tanks." 2.3.4.4 CONDENSATE SYSTEM Locations B-4 and B-9 show an Foster-Wheeler Corp supplied the FWTB-exhaust line from the main 1A and 1B exhaust ducts which connect feedwater pumps turbines (FWTB- to the Main Condenser.

The subject 1A at location B-4, FWTB-1B at highlighted lines do not indicate location B-9) to an open area of the components.

Instead, the two referenced LRA-302-101-LR, drawing. These exhaust lines are drawing lines indicate the scope of work L 3- L also labeled "By Foster Wheeler to be completed by Foster Wheeler Corp Corp." However, it is not clear if the and should not have been highlighted.

FWTB exhaust to the atmosphere CR-3 flow diagrams do not identify within the turbine building or to supports or anchors.some other component or heat sink.Also, these two lines show no visible means of support or anchor.2.3.4.10 MAIN FEEDWA TER SYSTEM Four FW system relief valves are The relief line from each of these four shown at locations B-1 (FWV-263), Main Feedwater System relief valves is LRA-302-081-LR B-2 (FWV-262), D-2 (FWV-16), and not continued or identified on additional D-3 (FWV-17).

The relief line from CR-3 flow diagrams.

The subject Main each of these valves is shown to be Feedwater System piping components for within scope of the license renewal. these relief lines are located in the However, the lines from these four Turbine Building (TB), are in scope, and U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 14 of 47 valves are not continued on another are included in LRA Table 2.3.4-8 as CR-3 LRA drawing, nor do they "Piping, piping components, piping terminate at another valve or elements, and tanks." structure.

Two FW system relief valves are The relief line from each of these two shown at locations D-7 (FWV-4) Main Feedwater System relief valves is and D-9 (FWV-3). However, the not continued or identified on additional relief line from each of these valves CR-3 flow diagrams.

The subject Main (FWV-3 & -4) are not shown on the Feedwater System piping components for drawing. Also, the lines are not these relief lines are located in the TB, continued on another CR-3 LRA are in scope, and are included in LRA drawing, nor do they terminate at Table 2.3.4-8 as "Piping, piping another valve or structure.

components, piping elements, and tanks." RAI 2.3-04

Background:

Issue: General Items 10 CFR Section 54.21(a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.During the scoping and screening review process, several components were found highlighted on CR-3 LRA drawings as being in scope for license renewal, but were not found on the associated tables for mechanical systems in the Scoping and Screening Results-Mechanical Systems section of the CR-3 LRA.Given below is a table that indicates the systems identified with these table inconsistencies.

License Renewal Table Location / Issue Application (LRA)Section/Drawing Number 2.3.3.22 CONTROL COMPLEX CHILLED WATER SYSTEM The drawing depicts air eliminator and air purger components as included in scope of license renewal under 10 CFR 54.4(a)(1) at the inlet of chilled water pumps CHP-1A and CHP-1 B (shown at locations D-5 and E-5 on the drawing).Additionally, a di-electric coupling is shown in scope at B-9 on the drawing in the makeup water LRA-302-756-LR, SH01 supply line. The LRA uses the NUREG-1801,"Generic Aging Lessons Learned (GALL) Report," Revision 1 definition for piping, piping components and piping elements.

It is rhot clear that this definition covers these additional elements in this drawing. Air eliminator, air purger, and di-electric coupling components are not included on Table 2.3.3-22 or Table 3.3.2-22 with intended function U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 15 of 47 M-1, pressure boundary.LRA-302-756-LR, SH01 The drawing depicts the heat exchangers for the post accident sampling system cooler as included in scope of license renewal under 10 CFR 54.4(a)(1).

The post accident sampling system cooling coil components are not included on Table 2.3.3-22 or Table 3.3.2-22 with intended function M-1, pressure boundary, and the cooling coils are not included on Table 2.3.3-22 or Table 3.3.2-22 with intended function M-5, heat transfer.The cooling coil components and cooling coils of other air handling heat exchangers cooled by control complex chilled water are included in the AMR under the respective ventilation system.However, an AMR could not be identified for the post accident containment atmospheric sampling system post accident sampling system cooler.2.3.3.23 APPENDIX R CHILLED WATER SYSTEM LRA-302-756-LR, SH01 The drawing depicts the heat exchangers for the switchgear room air handling units (AHHE-1OA and AHHE-10B) as included in scope of license renewal under 10 CFR 54.4(a)(1).

These components are actually cooled by the appendix R chilled water system because of the blank flanges installed (F-4/5). The switchgear room cooling coil components are not included on Table 2.3.3-23 or Table 3.3.2-23 with intended function M-1, pressure boundary, and the cooling coils are not included on Table 2.3.3-23 or Table 3.3.2-23 with intended function M-5, heat transfer.The cooling coil components and cooling coils of other air handling heat exchangers cooled by appendix R chilled water are included in the AMR under the respective ventilation system. However, no AMR could be identified for the switchgear room heat exchangers under an associated ventilation system.2.3.3.24 INDUSTRIAL COOLING SYSTEM The drawing depicts the cooling tower heat exchanger, leak rate test air cooler, reactor cavity LRA-302-762-LR, SH01 cooling coils, and industrial cooler electric water heaters (CIHE-2A and CIHE-2B) as included in scope of license renewal under 10 CFR 54.4(a)(2).

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 16 of 47 The cooling coil components are not included on Table 2.3.3-24 or Table 3.3.2-24 with intended function M-1, pressure boundary, and the cooling coils are not included on Table 2.3.3-24 or Table 3.3.2-24 with intended function M-5, heat transfer.No AMR could be identified for these heat exchangers under an associated system.The drawing depicts expansion joints, industrial cooler pump casings, and reactor cavity pump casings as included in scope of license renewal under 10 CFR 54.4(a)(2).

These components are not included on Table 2.3.3-24 or Table 3.3.2-24 with intended function M-1, pressure boundary.Pump casings and expansion joints are listed separately on other system AMR tables such as the control complex chilled water system.The drawing highlights a heat exchanger (CIHE-10) in location C-7 of the drawing in scope LRA-302-762-LR, SH03 for license renewal, but it is not included on Table 2.3.3-24 or Table 3.3.2-24 with intended function M05, heat transfer.2.3.3.25 CIRCULATING WATER SYSTEM The drawing depicts manholes as included in scope of license renewal under 10 CFR 54.4(a)(2)(example shown at B-3 on the drawing).

The applicant uses the NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report," Revision 1 definition for piping, piping components and piping elements.

It is not clear that this definition covers manholes.

Manhole components are not included on Table .2.3.3-25 or Table 3.3.2-25 with intended function M-1, pressure boundary.2.3.3.27 DECAY HEAT CLOSED CYCLE COOLING SYSTEM The drawing depicts the heat exchangers for the decay heat closed cycle cooling pump motor air handling units (AHHE-30A and AHHE-30B) as included in scope of license renewal under LRA-302-631-LR, 10 CFR 54.4(a)(1).

The cooling coil components SH01 & 02 are not included on Table 2.3.3-27 or Table 3.3.2-27 with intended function M-1, pressure boundary, and the cooling coils are not included on Table 2.3.3-27 or Table 3.3.2-27 with intended function M-5, heat transfer.

No AMR could be U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 17 of 47 identified for the decay heat closed cycle cooling pump motor air handling unit heat exchangers under an associated ventilation system.2.3.3.28 FUEL OIL SYSTEM The drawing depicts the sump pumps (SDP-9A and SDP-9B) and the dirty fuel drain tank as included in scope of license renewal under 10 CFR 54.4(a)(2) and (a)(1), respectively.

Other system tanks are specifically identified as part of an AMR. These components are not included on Table 2.3.3-28 or Table 3.3.2-28 with intended function M-1, pressure boundary.The drawing depicts the vent cap, screen, and flame arrester for each emergency diesel generator (EDG) fuel storage tank as included in scope of license renewal under 10 CFR 54.4(a)(2).

These components are not specifically included on Table 2.3.3-28 nor Table 3.3.2-28, and the components do not meet the CR-3 definition for piping, piping components and piping elements.2.3.3.29 JACKET COOLING SYSTEM The drawing depicts diesel engine-driven pumps as included in scope of license renewal under 10 CFR 54.4(a)(1).

These components are not included on Table 2.3.3-29 or Table 3.3.2-29 with intended function M-1, pressure boundary.

The LRA-302-283-LR, "CPM" standby coolant pump casings on EDG 1A SH01 & 02; and 1B are specifically identified in an AMP.Engine-driven and motor-driven pump casings are LRA-302-284-LR, also depicted as in scope without a specific AMP SH01 & 02; on: LRA-302-777 LR, SH01

• CR-3 LRA drawing 302-285-LR, SH01 and SH02, EDG lube oil piping system schematic diagram* CR-3 LRA drawing 302-775-LR, SH01, EFP-3 lube oil piping system schematic diagram The drawing depicts electric standby heaters as included in scope of license renewal under LRA-302-283-LR, 10 CFR 54.4(a)(1).

These components are included on Table 2.3.3-29 or Table 3.3.2-29 with intended function M-1, pressure boundary.However, there is no consideration of intended function M-5, heat transfer.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 18 of 47 LRA-302-284-LR, SH01& 02;LRA-302-285-LR, SH01 & 02 The drawing depicts the heat exchangers for the EDG gearbox oil cooler (DLHE-5 and DLHE-6) as included in scope of license renewal under 10 CFR 54.4(a)(1).

The cooling coil components are not included on Table 2.3.3-29 or Table 3.3.2-29 with intended function M-1, pressure boundary, and the cooling coils are not included on Table 2.3.3-29 or Table 3.3.2-29 with intended function M-5, heat transfer.

An AMP for the EDG gearbox oil cooler is not included under the lube oil system, either. AMP are specifically identified for the EDG lube oil cooler and the EFP-3 gearbox lube oil cooler.The drawing depicts the air filter and turbo-charger for each EDG as included in scope of license renewal under 10 CFR 54.4(a)(1) (shown at location C-2 on each drawing).

Neither component LRA-302-284-LR, is specifically included on Table 2.3.3-29 nor Table SH01 & 02 3.3.2-29 with intended function M-1, pressure boundary.

The turbo-charger does not meet the CR-3 definition for piping, piping components and piping elements, and the air filter is not listed with intended function M-2, filtration.

2.3.3.30 DIESEL GENERATOR LUBE OIL SYSTEM The drawing depicts the EDG gearbox oil sump housing, the EDG and EFP-3 lube oil sump LRA-302-285-LR, housing, and the EFP-3 speed increaser housing SH01 & 02; as included in scope of license renewal under 10 CFR 54.4(a)(1).

These components are not LRA-302-775-LR, SH01 included on Table 2.3.3-30 or Table 3.3.2-30 with intended function M-1, pressure boundary.

Other system reservoirs are specifically identified.

2.3.3.42 MAKE UP AND PURIFICATION SYSTEM The drawing depicts thermal expansion chamber with rupture seal disc assemblies (MURS-1 at location C-5 on SH01 and MURS-2 at location C-4 on SH02) as in scope of license renewal. These LRA-302-661-LR, components are not included on Table 2.3.3-42 or SH01 & 02 Table 3.3.2-42 with intended function M-1, pressure boundary.

These components do not appear to meet the CR-3 definition for piping, piping components and piping elements.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 19 of 47 The drawing depicts a cabinet shown at location G-2 on the drawing as outside the scope of license LRA-302-661-LR, SH01 renewal. It appears that this component should be included on Table 2.3.3-42 or Table 3.3.2-42 with intended function M-1, pressure boundary.2.3.3.50 STATION AIR SYSTEM The drawing depicts station air dryers and filter regulators as in scope for license renewal. These LRA-302-271-LR, SH09 components are not included on Table 2.3.3-50 or Table 3.3.2-50 with intended function M-1, pressure boundary.

Similar air dryers in the instrument air system are specifically identified as part of an AMP.2.3.3.51 SECONDARY SERVICES CLOSED COOLING WATER SYSTEM Secondary cycle primary sample cooling water LRA-302-221-LR, SH01 pump, SCP-4, shown at location A-2, is not specifically included in Tables 2.3.3-51 or 3.3.2-51.Turbine lubricating oil coolers, TBHE-7A, TBHE-7B, shown at locations C-3 and D-3, respectively, are not specifically included in Tables 2.3.3-51 or 3.3.2-51.Feedwater pump turbine lubricating oil coolers, 3A and 3B, shown at locations F-4 and F-6, respectively, are not specifically included in Tables 2.3.3-51 or 3.3.2-51.Feedwater booster pump lubricating oil coolers, LOHE'-6A and LOHE-6B, shown at locations G-2 and G-1, respectively, are not specifically included in Tables 2.3.3-51 or 3.3.2-51.Electro-hydraulic fluid coolers, EHHE-1A and EHHE-1B, shown at locations B-8 and B-9, respectively, are not specifically included in Tables 2.3.3-51 or 3.3.2-51.Sample chiller condenser, SSHE-1, shown at location E-3, is not specifically included in Tables 2.3.3-51 or 3.3.2-51.Generation hydrogen coolers, TBHE-4A through LRA-302-221-L-R, SH02 4D, shown at locations E-4, E-5, E-6, and E-7, respectively, are not specifically included in Tables 2.3.3-51 or 3.3.2-51.2.3.3.52 STATION DRAINS U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 20 of 47 SYSTEM Filter regulator lubricator SA-144-FR shown at LRA-302-115-LR, SH01 location G-6 is not specifically included in Tables 2.3.3-52 or 3.3.2-52.The diesel pump room floor shown at location H-4 and the diesel pump room wall shown at location G-4 do not identify which diesel they are associated with.2.3.3.53 SPENT FUEL COOLING SYSTEM Spent fuel pool coolant filters 3A (SFFL-1A at location D-5) and 3B (SFFL-1 B at location D-6) are LRA-302-11 5-LR, SH01 shown to be included in the scope of license renewal. Filter regulator lubricator SA-144-FR shown at location G-6 is not specifically included in Tables 2.3.3-53 or 3.3.2-53.2.3.3.54 NUCLEAR SERVICES CLOSED CYCLE COOLING SYSTEM Nuclear service closed cycle chemical feed pump and feed tank, SWT-2, at location D-10 is shown to LRA-302-601-LR, SH03 be included in the scope of license renewal.However, the tank is not specifically included in Tables 2.3.3-54 or 3.3.2-54.SW demineralizer, SWDM-1, at location E-5 is shown to be included in the scope of license renewal. However, the demineralizer is not specifically included in Tables 2.3.3-54 or 3.3.2-54.2.3.4.1 CONDENSER AIR REMOVAL SYSTEM Tables 2.3.4-1 and 3.4.2-1 of the CR-3 LRA list the condenser vacuum pump heat exchanger and heat transfer surfaces as being included in the AMR.LRA-302-131-LR SH01 Specific components ART-2 and ART-3, shown at locations G-5 and G-7, are indicated to be within the scope of an AMR. However, components ART-2 and ART-3 are not listed in CR-3 LRA Tables 2.3.4-1 or 3.4.2-1.At location C-4, component ARWT-1 is indicated as being in scope of an AMR. However, ARWT-1 is LRA-302-131-LR SH01 not included in CR-3 LRA Tables 2.3.4-1 or 3.4.2-1, nor is the component specifically identified (i.e., type, function, etc.).

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 21 of 47 2.3.4.2 AUXILIARY STEAM SYSTEM The drawing depicts steam traps as in scope of license renewal in numerous drawing locations.

These components are not included on Table LRA-302-114-LR, SH03 2.3.4-2 or Table 3.4.2-2 with intended function M-1, pressure boundary.

The applicant should identify steam traps in all systems and verify that they are included in an AMP.Request: Confirm that the above passive, long-lived components are subject to an AMR, and indicate in which component group they are included.

If they are not subject to an AMR, justify their exclusion.

Response: A specific evaluation has been provided for each of the items in the table.LRA Section/ Table Location / Issue Resolution Drawing Number 2.3.3.22 CONTROL COMPLEX CHILLED WATER SYSTEM The drawing depicts air eliminator and Air Purger, CHAP- 1, is an inline air purger components as included in piping component with an upper semi-scope of license renewal under 10 CFR spherical region that provides a high 54.4(a)(1) at the inlet of chilled water point for air collection and removal.pumps CHP-1A and CHP-1B (shown at Air Eliminator, CHAE-1, is a simple locations D-5 and E-5 on the drawing).

float operated device that receives air Additionally, a di-electric coupling is from the air purger and expels it when shown in scope at B-9 on the drawing in sufficient volume has been collected.

the makeup water supply line. The Both the Purger and Eliminator are LRA-302-756-applicant uses the NUREG-1801, piping system components with only LR, SHO0 "Generic Aging Lessons Learned the M-1, Pressure-Boundary, (GALL) Report," Revision I definition for intended function, and are included in piping, piping components and piping Table 2.3.3-22 as "Piping, piping elements.

It is not clear that this components, and piping elements." definition covers these additional Di-electric couplings, much like elements in this drawing. Air eliminator, corrosion resistant coatings, are a air purger, and di-electric coupling design feature intended to prevent components are not included on Table corrosion.

They do not perform an 2.3.3-22 or Table 3.3.2-22 with intended intended function and are not in the function M-1, pressure boundary, scope of License Renewal.The drawing depicts the heat The Post Accident Sampling System exchangers for the post accident SW Cooler, SWHE-2, is a plate frame sampling system cooler as included in heat exchanger, and has no shell or scope of license renewal under 10 CFR tubes, per se. This heat exchanger is LRA-302-756-54.4(a)(1).

The post accident sampling cooled by the Nuclear Services LR, SHO1 system cooling coil components are not Closed Cycle Cooling (NSCCC)included on Table 2.3.3-22 or Table Water System, and is included in 3.3.2-22 with intended function M-1, Table 2.3.3-54 as "PASS NSCCC pressure boundary, and the cooling Plate Heat Exchanger" (M-1 function), coils are not included on'Table 2.3.3-22 and "PASS NSCCC Plate Heat U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 22 of 47 or Table 3.3.2-22 with intended function M-5, heat transfer.The cooling coil components and cooling coils of other air handling heat exchangers cooled by control complex chilled water are included in the AMR under the respective ventilation system.However, an AMR could not be identified for the post accident containment atmospheric sampling system post accident sampling system cooler.Exchanger Plates" (M-5 function).

2.3.3.23 APPENDIX R CHILLED WATER SYSTEM The drawing depicts the heat Cooling the Turbine Building exchangers for the switchgear room air Switchgear is not a License Renewal handling units (AHHE-IOA and AHHE- intended function.

These cooling 1 OB) as included in scope of license coils are part of the Control Complex renewal under 10 CFR 54.4(a)(1).

Chilled Water System and not the These components are actually cooled Appendix R Chilled Water System by the appendix R chilled water system and are included in Table 2.3.3-22 as because of the blank flanges installed "Piping, piping components, and (F-4/5). The switchgear room cooling piping elements." These components coil components are not included on can be further identified by the AMR Table 2.3.3-23 or Table 3.3.2-23 with lines for copper and copper alloys in LRA302.756 intended function M-1, pressure Table 3.3.2-22 on page 3.3-196.LR, SH01 boundary, and the cooling coils are not included on Table 2.3.3-23 or Table 3.3.2-23 with intended function M-5, heat transfer.The cooling coil components and cooling coils of other air handling heat exchangers cooled by appendix R chilled water are included in the AMR under the respective ventilation system.However, no AMR could be identified for the switchgear room heat exchangers under an associated ventilation system.2.3.3.24 INDUSTRIAL COOLING SYSTEM The drawing depicts the cooling tower The Industrial Cooling System heat exchanger, leak rate test air cooler, Cooling Towers (shown on plant reactor cavity cooling coils, and drawing 302-762, Sheet 2) are not industrial cooler electric water heaters within the scope of License Renewal.(CIHE-2A and CIHE-2B) as included in The Leak Rate Test Air Cooler is scope of license renewal under 10 CFR evaluated as part of the Leak Rate 54.4(a)(2).

The cooling coil components Test System and is depicted on LRA-302-762-are not included on Table 2.3.3-24 or drawing 302-722-LR, Sheet 1. This LR, SH01 Table 3.3.2-24 with intended function M- cooler is within the scope of License 1, pressure boundary, and the cooling Renewal for spatial interaction coils are not included on Table 2.3.3-24 concerns only and is included in or Table 3.3.2-24 with intended function Table 2.3.3-40 as "Piping, piping M-5, heat transfer.

No AMR could be components, and piping elements" identified for these heat exchangers with only an M-1 Pressure-Boundary under an associated system. intended function.

The Reactor I_ I Building Cavity Cooling Coils are not U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 23 of 47 required to function following a Loss of Coolant Accident or Main Steam Line Break, but are required to maintain their pressure boundary during an earthquake to assure containment isolation.

The coils are included in Table 2.3.3-24 as"Containment isolation piping and components" with an M- I Pressure-Boundary intended function.

The Industrial Cooler Electric Water Heaters are within the scope of License Renewal for spatial interaction concerns only. The heaters are included in Table 2.3.3-24 as "Piping, piping components, piping elements, and tanks" with only an M-1 Pressure-Boundary intended function.The drawing depicts expansion joints, The industrial cooler pump casings, industrial cooler pump casings, and reactor cavity pump casings, and reactor cavity pump casings as included expansion joints depicted as in scope in scope of license renewal under 10 are included in Table 2.3.3-24 as CFR 54.4(a)(2).

These components are "Piping, piping components, piping not included on Table 2.3.3-24 or Table elements, and tanks." The expansion LR, SHOl 3.3.2-24 with intended function M-1, joints are further identified by the pressure boundary.

Pump casings and "Elastomers" material designation on expansion joints are listed separately on page 3.3-209 of Table 3.3.2-24.other system AMR tables such as the control complex chilled water system.The drawing highlights a heat The Plate Heat Exchanger, CIHE-l O, exchanger (CIHE-lO) in location C-7 of is within the scope of License the drawing in scope for license Renewal for spatial interaction LRA-302-762-renewal, but it is not included on Table concerns only. The heat exchanger is LR, SH03 2.3.3-24 or Table 3.3.2-24 with intended included in Table 2.3.3-24 as "Piping, function M05, heat transfer.

piping components, piping elements, and tanks" with only an M-1 Pressure-Boundary intended function.2.3.3.25 CIRCULATING WATER SYSTEM The drawing depicts manholes as There are two types of manholes included in scope of license renewal depicted on drawing 302-201-LR, under 10 CFR 54.4(a)(2) (example Sheet 1. There are those at shown at B-3 on the drawing).

The coordinates A-3, A-4, A-6, and A-7 applicant uses the NUREG-1801, that depict flanged connections to the"Generic Aging Lessons Learned Circulating Water System piping.(GALL) Report," Revision I definition for These flanges and their associated LRA-302-201-piping, piping components and piping bolting are included in Table 2.3.3-25 LR, SH01 elements.

It is not clear that this as "Piping, piping components, piping definition covers manholes.

Manhole elements, and tanks." The other components are not included on Table manholes at coordinates B-3, B-4, B-2.3.3-25 or Table 3.3.2-25 with intended 6, and B-7 provide access to a piping function M-1, pressure boundary.

tunnel housing Circulating Water System piping. These manholes are not part of the Circulating Water System, but are civil features addressed in Section 2.4.2.7 of the U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 24 of 47 CR-3 LRA.2.3.3.27 DECAY HEAT CLOSED CYCLE COOLING SYSTEM The drawing depicts the heat The heat exchangers are evaluated in exchangers for the decay heat closed the Decay Heat Closed Cycle Pump cycle cooling pump motor air handling Cooling System and not the Decay units (AHHE-30A and AHHE-30B) as Heat Closed Cycle Cooling System, included in scope of license renewal and are depicted on drawing 302-751, under 10 CFR 54.4(a)(1).

The cooling Sheet I (Coordinates G-7 and H-7).coil components are not included on The heat exchangers are included in LRA-302-631-Table 2.3.3-27 or Table 3.3.2-27 with Table 2.3.3-7 as "Decay Heat Closed LR, intended function M-1, pressure Cycle Pump Air Supply Cooling Coil SH01 & 02 boundary, and the cooling coils are not Tubes" with an M-5 Heat Transfer'included on Table 2.3.3-27 or Table intended function and "Decay Heat 3.3.2-27 with intended function M-5, Closed Cycle Pump Air Supply heat transfer.

No AMR could be Cooling Coil Components" with an identified for the decay heat closed M- I Pressure-Boundary intended cycle cooling pump motor air handling function.unit heat exchangers under an associated ventilation system.2.3.3.28 FUEL OIL SYSTEM The drawing depicts the sump pumps The referenced components are (SDP-9A and SDP-9B) and the dirty fuel included in Table 2.3.3-28 as "Piping, drain tank as included in scope of piping components, piping elements, license renewal under 10 CFR and tanks." LRA-302-281-54.4(a)(2) and (a)(1), respectively.

LR, SH01 Other system tanks are specifically identified as part of an AMR. These components are not included on Table 2.3.3-28 or Table 3.3.2-28 with intended function M-1, pressure boundary.The drawing depicts the vent cap, The vent cap, screen, and flame screen, and flame arrester for each arrester are included in Table 2.3.3-emergency diesel generator (EDG) fuel 28 as "Piping, piping components, storage tank as included in scope of piping elements, and tanks." license renewal under 10 CFR LR, SH01 54.4(a)(2)..

These components are not specifically included on Table 2.3.3-28 nor Table 3.3.2-28, and the components do not meet the CR-3 definition for piping, piping components and piping elements.2.3.3.29 JACKET COOLING SYSTEM The drawing depicts diesel engine- The pumps, depicted on drawings LRA-302-283-driven pumps as included in scope of 302-285-LR, Sheets I and 2, and license renewal under 10 CFR 302-775-LR, Sheet 1, are associated LR, 54.4(a)(1).

These components are not with the Diesel Generator Lube Oil SH01 & 02, included on Table 2.3.3-29 or Table System. These pumps are included LRA302284 3.3.2-29 with intended function M-I, in Table 2.3.3-30 as "Piping, piping LR, pressure boundary.

The "CPM" standby components, and piping elements." SHOI & 02;~ coolant pump casings on EDG 1A and SB are specifically identified in an AMP. Tag Drawing LRA-302-777 LR, Engine-driven and motor-driven pump DLP-I 302-285-LR, Sheet I SH01 casings are also depicted as in scope DLP-2 302-285-LR, Sheet 2 without a specific AMP on: DLP-3 302-285-LR, Sheet I I I DLP-4 302-285-LR, Sheet 2 U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 25 of 47* CR-3 LRA drawing 302-285-LR, SHOI and SH02, EDG lube oil piping system schematic diagram* CR-3 LRA drawing 302-775-LR, SHOI, EFP-3 lube oil piping system schematic diagram DLP-5 DLP-6 DLP-7 DLP-8 DLP-9 DLP-10 DLP-11 DLP-12 DLP-13 DLP-14 DLP-15 DLP-16 DLP- 17 DLP-18 302-285-LR, Sheet I 302-285-LR, Sheet 2 302-285-LR, Sheet 1 302-285-LR, Sheet 2 302-285-LR, Sheet 1 302-285-LR, Sheet 2 302-775-LR, Sheet I 302-775-LR, Sheet I 302-775-LR, Sheet 1 302-775-LR, Sheet I 302-775-LR, Sheet 1 302-775-LR, Sheet 1 302-775-LR, Sheet I 302-775-LR.

Sheet I The drawing depicts electric standby DJHE-1 and DJHE-2 consist of tanks heaters as included in scope of license with separate electric heaters. The renewal under 10 CFR 54.4(a)(1).

electric heaters are used to transfer LRA-302-283-These components are included on heat to the fluid. Electrical/l&C LR, Table 2.3.3-29 or Table 3.3.2-29 with component/commodity groups are SH01& 02 intended function M-1, pressure evaluated in Section 2.5 of the LRA.boundary.

However, there is no consideration of intended function M-5, heat transfer.The drawing depicts the heat The EDG Gearbox Oil Coolers exchangers for the EDG gearbox oil depicted on 302-285-LR, Sheets I cooler (DLHE-5 and DLHE-6) as and 2, (DLHE-5 and DLHE-6, included in scope of license renewal respectively) are included in Table under 10 CFR 54.4(a)(1).

The cooling 2.3.3-30 as "EDG Lube Oil Cooler LRA-302-284-coil components are not included on Components" and "EDG Lube Oil LR, Table 2.3.3-29 or Table 3.3.2-29 with Cooler Tubes" that are part of the SHOI & 02; intended function M-1, pressure Diesel Generator Lube Oil System.boundary, and the cooling coils are not These commodities also include LRA-302-285-included on Table 2.3.3-29 or Table DLHE-IA, IB, 2A, and 2B (EDG Lube LR, 3.3.2-29 with intended function M-5, Oil Coolers shown on 302-285-LR, SHOI & 02 heat transfer.

An AMP for the EDG Sheets 1 and 2, respectively).

gearbox oil cooler is not included under the lube oil System, either. AMP are specifically identified for the EDG lube oil cooler and the EFP-3 gearbox lube oil cooler.The drawing depicts the air filter and The air filters (AHFL-22A and AHFL-turbo-charger for each EDG as included 22B) are shown on drawings 302-in scope of license renewal under 10 284-LR, Sheets 1 and 2, respectively.

CFR 54.4(a)(1) (shown at location C-2 These filters are evaluated as part of on each drawing).

Neither component is the Emergency Diesel Generator Air specifically included on Table 2.3.3-29 Handling System in Section 2.3.3.12 LRA-302-284-nor Table 3.3.2-29 with intended of the LRA. These filters are included LR, function M-1, pressure boundary.

The in Table 2.3.3-12 as "EDG Air SH01 & 02 turbo-charger does not meet the CR-3 Handling Filter Housings." The filter definition for piping, piping components media are screened as replaced.

As and piping elements, and the air filter is stated on page 2.1-25 of the LRA: not listed with intended function M-2, "Commodity group components that filtration.

are replaced based on qualified life or specified time period (i.e., short-lived components) are not subject to AMR."

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 26 of 47 The turbochargers do not require AMR since they are part of a complex assembly and screened as active. A discussion of complex assemblies is provided in the LRA on page 2.1-20.2.3.3.30 DIESEL GENERA TOR LUBE OIL SYSTEM The drawing depicts the EDG gearbox The sumps shown on drawings 302-oil sump housing, the EDG and EFP-3 285-LR, Sheets 1 and 2, are part of lube oil sump housing, and the EFP-3 the diesel engine. The sumps do not LR, speed increaser housing as included in require AMR since they are part of a SH01 & 02; scope of license renewal under 10 CFR complex assembly and screened as 54.4(a)(1).

These components are not active. A discussion of complex included on Table 2.3.3-30 or Table assemblies is provided in the LRA on LRA-301- 3.3.2-30 with intended function M-1, page 2.1-20. The speed increaser LR, SHO1 pressure boundary.

Other system housing shown on 302-775-LR, Sheet reservoirs are specifically identified.

I has been evaluated in the same I manner.2.3.3.42 MAKE UP AND PURIFICATION SYSTEM The drawing depicts thermal expansion The Rupture Disk Assemblies chamber with rupture seal disc (expansion chamber and flange), assemblies (MURS-1 at location C-5 on MURS-1 and MURS-2 are included in SH01 and MURS-2 at location C-4 on Table 2.3.3-42 as "Piping, piping LRA-302-661-SH02) as in scope of license renewal. components, piping elements, and These components are not included on tanks." LR, Table 2.3.3-42 or Table 3.3.2-42 with SHOI & 02 intended function M-1, pressure boundary.

These components do not appear to meet the CR-3 definition for piping, piping components and piping elements.The drawing depicts a cabinet shown at The component designated as "LC" at location G-2 on the drawing as outside coordinate G-2 on drawing the scope of license renewal. It appears 302-661-LR, Sheet I is a "local LRA 02-61 that this component should be included container." It is a portable container LR, SH01 on Table 2.3.3-42 or Table 3.3.2-42 with used to collect fluid when draining intended function M-1, pressure liquid radiation monitor RM-L1.boundary.2.3.3.50 STATION AIR SYSTEM The drawing depicts station air dryers The air dryers (SADR-4, -5, and -6)and filter regulators as in scope for are within the scope of License license renewal. These components are Renewal for spatial interaction not included on Table 2.3.3-50 or Table concerns only. The dryers are 3.3.2-50 with intended function M-1, included in Table 2.3.3-50 as "Piping, pressure boundary.

Similar air dryers in piping components, piping elements, the instrument air system are and tanks." The filter regulators (SA-LRA-302-271-specifically identified as part of an AMP. 134-FR through SA-136-FR and SA-LR, SH09 141-FR through SA-144-FR) are considered minor components that are within the scope of License Renewal for spatial interaction concerns only. The filter regulators are included in Table 2.3.3-50 as"Piping, piping components, piping elements, and tanks."

U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 27 of 47 2.3.3.51 SECONDARY SERVICES CLOSED COOLING WATER SYSTEM Secondary cycle primary sample cooling The Secondary Cycle Primary LRA-302-221-water pump, SCP-4, shown at location Sample Cooling Water Pump, SCP-4, LR, SH01 A-2, is not specifically included in is included in Table 2.3.3-51 as Tables 2.3.3-5 1 or 3.3.2-5 1. "Piping, piping components, piping elements, and tanks." Turbine lubricating oil coolers, TBHE- The Turbine Lubricating Oil Coolers, 7A, TBHE-7B, shown at locations C-3 TBHE-7A/7B, are not credited with a LRA-302-221-and D-3, respectively, are not heat transfer intended function and LR, SHOI specifically included in Tables 2.3.3-51 are included in Table 2.3.3-51 as or 3.3.2-51. "Piping, piping components, piping elements, and tanks." Feedwater pump turbine lubricating oil These Main Feedwater Turbine Lube coolers, 3A and 3B, shown at locations Oil Coolers, LOHE-2/3/4/5, are F-4 and F-6, respectively, are not evaluated in the Main Feedwater specifically included in Tables 2.3.3-51 Turbine Lube Oil System. They are or 3.3.2-51.

included in Table 2.3.4-11 as "Main LRA-302-221-Feedwater Pump Turbine and LR, SH01 Booster Pump Lube Oil Cooler Components" and "Main Feedwater Pump Turbine and Booster Pump Lube Oil Cooler Tubes" with the M-1 Pressure-Boundary and M-5 Heat Transfer intended functions, respectively.

Feedwater booster pump lubricating oil These components are evaluated in coolers, LOHE-6A and LOHE-6B, the Main Feedwater Turbine Lube Oil shown at locations G-2 and G-1, System. They are included in Table respectively, are not specifically 2.3.4-11 as "Main Feedwater Pump LRA-302-221-included in Tables 2.3.3-51 or 3.3.2-51.

Turbine and Booster Pump Lube Oil LR, SHOI Cooler Components" and "Main Feedwater Pump Turbine and Booster Pump Lube Oil Cooler Tubes" with the M-1 Pressure-Boundary and M-5 Heat Transfer intended functions, respectively.

Electro-hydraulic fluid coolers, EHHE- The Electro-Hydraulic Fluid Coolers, 1A and EHHE-1B, shown at locations B- EHHE-1A/lB, are not credited with a LRA-302-221-8 and B-9, respectively, are not heat transfer intended function and LR, SHO0 specifically included in Tables 2.3.3-51 are included in Table 2.3.3-51 as or 3.3.2-51. "Piping, piping components, piping elements, and tanks." Sample chiller condenser, SSHE-1, The Sample Chiller Condenser, shown at location E-3, is not specifically SSHE-1, is not credited with a heat LRA-302-221-included in Tables 2.3.3-51 or 3.3.2-51.

transfer intended function and is LR, SH01 included in Table 2.3.3-51 as "Piping, piping components, piping elements, and tanks." Generation hydrogen coolers, TBHE-4A The Turbine Generator Hydrogen through 4D, shown at locations E-4, E- Coolers, TBHE-4A/4B/4C/4D, are not LRA-302-221-5, E-6, and E-7, respectively, are not credited with a heat transfer intended LR, SH02 specifically included in Tables 2.3.3-51 function and are included in Table or 3.3.2-51.

2.3.3-51 as "Piping, piping components, piping elements, and tanks."

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 28 of 47 2.3.3.52 STATION DRAINS SYSTEM Filter regulator lubricator SA-144-FR The filter regulator, SA-144-FR, is shown at location G-6 is not specifically considered a minor component that is included in Tables 2.3.3-52 or 3.3.2-52.

within the scope of License Renewal LRA-302-115-for spatial interaction concerns only.LR, SH01 The filter regulator is included in Table 2.3.3-50 as "Piping, piping components, piping elements, and tanks." The diesel pump room floor shown at EFPB Sump Pump, SDP-12, is 115- location H-4 and the diesel pump room located in the Emergency Feedwater LRA -302 wall shown at location G-4 do not Pump Building structure which identify which diesel they are associated houses Emergency Feedwater Pump with. 3.2.3.3.53 SPENT FUEL COOLING SYSTEM Spent fuel pool coolant filters 3A (SFFL- The Spent Fuel Coolant Filters, SFFL-1A at location D-5) and 3B (SFFL-IB at 1A/1B, are shown on drawing 302-location D-6) are shown to be included 621-LR, Sheet 2. Their filter media in the scope of license renewal. Filter have been screened as replaced.regulator lubricator SA- 144-FR shown at The filter housings are included in location G-6 is not specifically included Table 2.3.3-53 as "Piping, piping in Tables 2.3.3-53 or 3.3.2-53.

components, and piping elements." LRA-302-115-LR, SH01 The filter regulator, SA-144-FR, is considered a minor component that is within the scope of License Renewal for spatial interaction concerns only.The filter regulator is included in Table 2.3.3-50 as "Piping, piping components, piping elements, and I tanks." 2.3.3.54 NUCLEAR SERVICES CLOSED CYCLE COOLING SYSTEM Nuclear service closed cycle chemical The Nuclear Service Closed Cycle feed pump and feed tank, SWT-2, at Chemical Feed Tank, SWT-2, is LRA-302-601-location D-10 is shown to be included in included in Table 2.3.3-54 as "Piping, LR, SH03 the scope of license renewal. However, piping components, piping elements, the tank is not specifically included in and tanks." Tables 2.3.3-54 or 3.3.2-54.SW demineralizer, SWDM-1, at location The Nuclear Service Closed Cycle E-5 is shown to be included in the scope Cooling Demineralizer, SWDM-1, is LRA-H32 of license renewal. However, the included in Table 2.3.3-54 as "Piping, demineralizer is not specifically included piping components, piping elements, in Tables 2.3.3-54 or 3.3.2-54.

and tanks." 2.3.4.1 CONDENSER AIR REMOVAL SYSTEM Tables 2.3.4-1 and 3.4.2-1 of the CR-3 The Air Removal Tanks, ART-2/3, are LRA list the condenser vacuum pump included in LRA Table 2.3.4-1 as heat exchanger and heat transfer "Piping, piping components, piping surfaces as being included in the AMR. elements, and tanks." LRA-302-131-LR Specific components ART-2 and ART-3, SH01 shown at locations G-5 and G-7, are indicated to be within the scope of an AMR. However, components ART-2 and ART-3 are not listed in CR-3 LRA I Tables 2.3.4-1 or 3.4.2-1.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 29 of 47 At location C-4, component ARWT-1 is The RM-A12 Water Trap, ARWT-1, is indicated as being in scope of an AMR. included in LRA Table 2.3.4-1 as LRA-302-131-LR However, ARWT-1 is not included in "Piping, piping components, piping SH01 CR-3 LRA Tables 2.3.4-1 or 3.4.2-1, nor elements, and tanks." is the component specifically identified (i.e., type, function, etc.).2.3.4.2 AUXILIARY STEAM SYSTEM The drawing depicts steam traps as in The Main Steam System steam traps scope of license renewal in numerous are within the scope of License drawing locations.

These components Renewal and are included in Table are not included on Table 2.3.4-2 or 2.3.4-12 as "Piping, piping Table 3.4.2-2 with intended function M- components, piping elements, and LRA-302-114-1, pressure boundary.

The applicant tanks." The Auxiliary Steam System should identify steam traps in all steam traps are within the scope of systems and verify that they are License Renewal and are included in included in an AMP. Table 2.3.4-2 as "Piping, piping components, piping elements, and tanks." See Tables 3.4.2-12 and 3.4.2-2, respectively, for the aging L__ Imanagement review results.RAI 2.3-05 General Items

Background:

Issue: 10 CFR Section 54.21 (a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.During the scoping and screening review process, several structures were found on the CR-3 LRA drawings that were not included within the scope of license renewal. These structures were sumps, waste collectors, canals, pits, etc. In the table below it is indicated which systems are associated with these structures.

License Renewal Sump Location / Issue Application (LRA)Section / Drawing Number 2.3.3.34 FLOOR DRAINS SYSTEM LRA-302-683-L-R, SH01 Two auxiliary building sumps, WDP-4A and WDP-4B, are shown at location H-4 on the drawing.Eight sumps are shown on the drawing: (a) reactor building sumps WDP-2A and WDP-2B (location F-3), (b) tendon access gallery sumps SDP-3A and LRA-302-683-LR, SH02 SDP-3B (location H-4), (c) nuclear service area sumps SDP-2A and SDP-2B (location F-6), and (d)decay heat pit sumps WDP-3A and WDP-3B (location H-7).

U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 30 of 47 2.3.3.49+NUCLEAR SERVICE AND DECAY HEAT SEA WATER SYSTEM Two nuclear service cooler area sumps are shown LRA-302-61 1-LR, SH02 on the drawing: 3A SDP-2A at location D-1 and 3B SDP-2B at location E-1.2.3.3.52 STATION DRAINS SYSTEM A sump associated with the air operated sump LRA-302-115-LR, SH01 pump, SDP-12, is shown at location H-5 on the drawing.A sump, SDP-9B, associated with the EDG fuel LRA-302-281-LR, SH01 transfer pumps, 3B (AC motor driven) and 3D (DC motor driven) is shown at location F-6 on the drawing.LRA-302-281-LR, SH01 The drawing indicates at location F-3 an unidentified structure that is assumed to be a sump associated with the EDG fuel transfer pumps 3A (AC motor driven) and 3C (DC motor driven).2.3.3.53 SPENT FUEL COOLING SYSTEM The drawing shows two structures at location B-i, the incore instrument pit and the fuel transfer canal, that are not included in the scope of license renewal.Request: Provide justification of the exclusion of the structures identified above from the scope of license renewal and any SSCs inside the sumps or structures.

Response: As reflected by the response comments for each item listed in the table below, the sumps, pits, and canals in question are located within the following structures:

Reactor Building (RB), Auxiliary Building (AB), Intermediate Building (IB), Diesel Generator Building, and Emergency Feedwater Pump Building (EFPB). These structures are within the scope of License Renewal.Sumps, pits, and canals are formed by concrete in each building.

As such, the sumps, pits, and canals are included in the "Concrete

-Above Grade" commodity listed in LRA Section 2.4, Tables 2.4.1-1, 2.4.2-1, 2.4.2-9, 2.4.2-10 and 2.4.2-13 for the applicable structures.

The liner plate for the incore instrument pit and the fuel transfer canal in the RB are included with the"Steel Components:

Fuel Pool Liner" Component/Commodity group in LRA Table 2.4.1-1.Sump liners are included in the "Platforms, Pipe Whip Restraints, Jet Impingement Shields, Masonry Wall Supports, and Other Miscellaneous Structures Commodity," listed in LRA Tables 2.4.1-1 and 2.4.2-1.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 31 of 47 CR-3 has revised its methodology for spatial interaction scoping to narrowly permit exclusions only in areas where there are not safety related components, that are adequately protected and isolated from other areas of the plant, and are equipped with drain systems which are themselves in the scope of License Renewal. (See the response to RAI 2.1-2 in CR-3 to NRC letter, 3F0909-04, "Crystal River Unit 3 -Response to Requests for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)," dated September 18, 2009 (ML092650272)).

Based on this, all drain system piping and associated components located in the RB, AB, IB, Diesel Generator Building and EFPB have been included in the scope of License Renewal.LRA Section Sump Location / Issue Response Comments Drawing NumberII 2.3.3.34 FLOOR DRAINS SYSTEM LRA-302-683-Two auxiliary building sumps, WDP-4A The two components listed, WDP-4A LR, SHOI and WDP-4B, are shown at location H-4 and WDP-4B, are pumps located in on the drawing. the AB sump, WDSU-2.Eight sumps are shown on the drawing: The eight components listed, WDP-(a) reactor building sumps WDP-2A and 2A, WDP-2B, SDP-3A, SDP-3B, WDP-2B (location F-3), (b) tendon SDP-2A, SDP-2B, WDP-3A, and LRA-302-683-access gallery sumps SDP-3A and SDP- WDP-3B, are pumps located within LR, SH02 3B (location H-4), (c) nuclear service the four specified sumps. These area sumps SDP-2A and SDP-2B sumps are located in the RB (RB (location F-6), and (d) decay heat pit sump), the IB (tendon access gallery sumps WDP-3A and WDP-3B (location sump), and the AB (nuclear services H-7). area sump, decay heat pit sump).2.3.3.49 NUCLEAR SERVICE AND DECAY HEAT SEA WATER SYSTEM Two nuclear service cooler area sumps The two components listed, SDP-2A LRA-302-61 1- are shown on the drawing: 3A SDP-2A at and SDP-2B, are pumps located in LR, SH02 location D-1 and 3B SDP-2B at location sump SDSU-2. Sump SDSU-2 is E-1. located in the AB.2.3.3.52 STATION DRAINS SYSTEM LRA-302-115-A sump associated with the air operated The sump pump listed, SDP-12, is LR, SH01 sump pump, SDP-12, is shown at located in sump MDSU-1. Sump location H-5 on the drawing. MDSU-I is located in the EFPB.LRA-302-281-A sump, SDP-9B, associated with the The component listed, SDP-9B, is a EDG fuel transfer pumps, 3B (AC motor pump located in a sump in the floor driven) and 3D (DC motor driven) is of the Diesel Generator Building.shown at location F-6 on the drawing.The drawing indicates at location F-3 an The pump, SDP-9A, is located in the unidentified structure that is assumed to Diesel Generator Building.

The LRA30221 be a sump associated with the EDG fuel sump for this pump, shown on transfer pumps 3A (AC motor driven) drawing LRA-302-281-LR SH01, at and 3C (DC motor driven), location F-3, is located in the floor of Diesel Generator Building, elevation 111 ft. 2in.2.3.3.53 SPENT FUEL COOLING SYSTEM The drawing shows two structures at These are untagged features of the LRA-302-621-location B- 1, the incore instrument pit RB.LR, SH01 and the fuel transfer canal, that are not included in the scope of license renewal.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 32 of 47 RAI 2.3-06 General Items

Background:

Issue: 10 CFR Section 54.21 (a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.The applicant used a definition for piping, piping components, and piping elements that are based on Section IX of NUREG-1801, Volume 2. The CR-3 definition of "Piping, piping components, and piping elements" replaces various combinations of the following:

piping, fittings, tubing, flow elements/indicators,-filter/demineralizer housings, nozzles, orifices, flex hoses, expansion joints, pump casing and bowl, safe ends, sight glasses, spray head body, strainer housings, thermowells, valve body and bonnet, and closure bolting. However, in the LRA, components such as expansion joints, filters, strainers, and flexible connections are specifically identified in the AMR for one or more mechanical systems, but not the associated, tables for other similar mechanical systems.Also, components that have an intended function in addition to M-1, pressure boundary, such as M-2, filtration, and M-5, heat transfer, are frequently not listed separately with the additional intended function.

Rather, these components are frequently only listed under piping components with an M-1 function.Furthermore, some systems list tanks with piping and some systems list tanks separately.

The staff is unable to discern a consistent CR-3 methodology for identifying components on the mechanical system AMR tables in the Scoping and Screening Results-Mechanical Systems section of the CR-3 LRA.Consequently, the staff is unable to verify that all components subject to an AMR are adequately represented in the AMR tables. Given below is a table with examples of systems identified with these table inconsistencies.

License Renewal Component Listing / Issue Application (LRA)Section / Drawing Number 2.3.3.22 CONTROL COMPLEX CHILLED WATER SYSTEM The drawing depicts temporary strainer components as included in scope of license renewal under 10 CFR 54.4(a)(1) at the inlet of chilled water pumps CHP-1A and CHP-1 B (shown at locations C-6 and E-6 on the drawing).

These components are not included on Table 2.3.3-22 or LRA-302-756-LR, SH01 Table 3.3.2-22 with intended function M-1, pressure boundary, or M-2, filtration.

Temporary strainers are also depicted as in scope on:* CR-3 LRA drawing 302-762-LR, SH01, industrial cooler water (shown at locations U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 33 of 47 C-2 and D-2 on the drawing)CR-3 LRA drawing 302-631-LR, SH01 and SH02, decay heat closed cycle cooling (shown at location F-1 on'SH01 and location E-2 on SH02)2.3.3.24 INDUSTRIAL COOLING SYSTEM The drawing depicts expansion joints, industrial cooler pump casings, and reactor cavity pump casings as included in scope of license renewal under 10 CFR 54.4(a)(2).

These components are LRA-302-762-LR, SH01 not included on Table 2.3.3-24 or Table 3.3.2-24 with intended function M-1, pressure boundary.Pump casings and expansion joints are listed separately on other system AMP tables such as the control complex chilled water system.2.3.3.26 ERP-3 DIESEL AIR STARTING SYSTEM The drawing depicts expansion joints as included in scope of license renewal under 10 CFR 54.4(a)(1) on the diesel exhaust line. These components are not included on Table 2.3.3-26 or Table 3.3.2-26 with intended function M-1, pressure boundary.LRA-302-778-LR, SH01 Expansion joints are included as separate component entries in other system tables such as the control complex chilled water system. The applicant should identify expansion joints in all systems and verify that they are included in an AMP.The drawing depicts flexible connections as included in scope of license renewal under 10 CFR 54.4(a)(1) on the diesel air start line. These components are not included on Table 2.3.3-26 or Table 3.3.2-26 with intended function M-1, pressure boundary.

Flexible connections are included as separate component entries in other system tables such as the reactor building recirculation system.The applicant should identify flexible connections in all systems and verify that they are included in an AMP.2.3.3.28 FUEL OIL SYSTEM The drawing depicts flexible connections in the LRA-302-776-LR, SH01 drawing as included in scope of license renewal under 10 CFR 54.4(a)(1) on the DDEFW pump U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 34 of 47 diesel fuel storage tank. These components are not included on Table 2.3.3-28 or Table 3.3.2-28 with intended function M-1, pressure boundary.2.3.3.29 JACKET COOLING SYSTEM LRA-302-283-LR, The drawing depicts expansion tanks as included in SH01& 02; scope of license renewal under 10 CFR 54.4(a)(1).

These components are not included on Table 2.3.3-LRA-302-284-LR, 29 or Table 3.3.2-29 with intended function M-1, SH01 & 02; pressure boundary.

Other systems specifically identify major system tanks as part of an AMP.LRA-302-777-LR, SH01 2.3.3.32 DEMINERALIZED WATER SYSTEM The drawing depicts the auxiliary building condensate and demineralized water storage tank as included in scope of license renewal under 10 CFR 54.4(a)(2) (shown at B-3 on the drawing).This tank is a significant system component and the tank is not specifically included on Table 2.3.3-32 or Table 3.3.2-32 with intended function M-1, pressure boundary.

Other systems, such as the fuel oil system, identify significant system tanks that are subject to an AMP separately.

The drawing depicts the post treatment filter as included in scope of license renewal under 10 CFR 54.4(a)(2) at the discharge of demineralized water pumps DWP-1A and DWP-1 B (shown at D-7 on the drawing).

The filter is not included on Table 2.3.3-32 or Table 3.3.2-32 with intended function M-2, filtration.

2.3.3.33 EMERGENCY DIESEL GENERATOR SYSTEM Filters are depicted as included in scope of license renewal under 10 CFR 54.4(a)(1) in numerous system drawings.

An example of this on the referenced drawing occurs at locations D-1 and D-8. However, similar filters appear in numerous LRA-302-282-LR, SH01 system drawings, and the filters are not specifically included on Table 2.3.3-33 nor Table 3.3.2-33 with intended function M-1, pressure boundary or M-2, filtration.

Filters do not appear to meet the CR-3 definition for piping, piping components and piping elements.

U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 35 of 47 The drawing depicts flexible connections in the drawing as included in scope of license renewal under 10 CFR 54.4(a)(1) at locations E-1 (near EGV-35) and E-8 (near EGV-39). These components are not included on Table 2.3.3-33 or Table 3.3.2,33 with intended function M-1, pressure boundary.2.3.3.41 MISCELLANEOUS DRAINS SYSTEM The drawing depicts a flash tank as in scope of license renewal at drawing location H-3. Typically, a pressure and temperature change allows entrained steam in the drains to change state to LRA-302-114-LR, SH02 liquid and cool in the flash tank. Table 2.3.3-41 and Table 3.3.2-41 in the LRA only identify components with an intended function of pressure-boundary (M-1). The flash tank is not identified with an intended function of heat transfer (M-5).2.3.3.42 MAKE UP AND PURIFICATION SYSTEM The drawing depicts Y-strainers as in scope of license renewal at drawing locations E-3 and E-7.These components are not included on Table 2.3.3-42 or Table 3.3.2-42 with intended function LRA-302-661-LR, SH01 M-2, filtration.

Strainers are identified in other systems such as the nuclear services closed cycle cooling system. The applicant should identify Y-strainers in all systems and verify that they are included in an AMP.2.3.3.49 NUCLEAR SERVICE AND DECAY HEAT SEA WATER SYSTEM Expansion joint encapsulation sleeves, RWEJ-1 through RWEJ-10, shown at locations F-2, D-2, LRA-302-611-LR, SH01 F-10, D-9, E-9, D-8, E-8, D-7, E-7 and D-6, respectively, are not specifically included in Tables 2.3.3-49 or 3.3.2-49.Request: Explain the CR-3 methodology for identifying components on the mechanical system aging management program tables in the scoping and screening results-mechanical systems section of the CR-3 LRA. Justify the exclusion of the listed components with a specific intended function from an AMR. Evaluate all systems for similar excluded components.

U. S. Nuclear Regulatory Commission F1 109-05 Page 36 of 47 Response: NEI 95-10, Section 4.1, discusses that it may be beneficial to create commodity groups of like structures or components to disposition the entire group with a single aging management review. The basis for group structures or components can be such characteristics as similar design, similar materials of construction, similar aging management practices and similar environments.

The Structure and Component Screening process described in Section 2.1.2 of the CR-3 LRA states: During the screening process, some SCs were incorporated into commodity groups based on similarity of their design or materials of construction.

Use of commodity groups made it possible to address an entire group of SCs with a single evaluation.

This approach is consistent with the changes made in Revision 1 of NUREG-1801, "Generic Aging Lessons Learned (GALL) Report" to enhance. its applicability to future plant License Renewal applications.

One of these revisions was the simplification and generalization of terms used to make the component/commodity line items more generic and less prescriptive.

As an example based on the definitions in Section IX of NUREG-1801, Volume 2, the CR-3 definition of "Piping, piping components, and piping elements" replaces various combinations of the following:

piping, fittings, tubing, flow elements/indicators, filter/demineralizer housings, nozzles, orifices, flex hoses, expansion joints, pump casing and bowl, safe ends, sight glasses, spray head body, strainer housings, thermowells, valve body and bonnet, and closure bolting.As with the definition in GALL, Volume 2,Section IX, the list of component types associated with the definition of "piping, piping components, and piping elements" in Section 2.1.2 of the CR-3 LRA was not intended to be prescriptive.

Consistent with the methodology recently used and accepted in the Harris Nuclear Plant License Renewal Application, CR-3 utilizes this term to generically address piping system components whose sole component intended function is to provide a pressure boundary.

In some cases, components are included that potentially have multiple intended functions, but for the application at hand, have only the "M-1" pressure boundary function.

Common examples are found in systems that are only in scope for potential spatial interaction with safety related components.

The intended function for components in these systems would be to maintain their pressure boundary so as not to leak; and component level functions for straining/filtration, heat transfer, and flow restriction would not apply. Under this circumstance, the line item "Piping, piping components, and piping elements" would be expanded to include strainer/flow element housings and heat exchanger shells, as applicable.

Deference was given to systems having small miscellaneous tanks (expansion chambers, accumulators, etc.) to use the GALL variant "Piping, piping components, piping elements and tanks" to reflect the presence of these components.

It is important to note that the term "Piping, piping components, and piping elements" was only used to generically represent piping components having the M-1 intended function.Components/commodities having other component intended functions were broken out into separate line items and associated with the applicable component intended function(s).

CR-3 did provide separate listings of major system components to improve in accounting during the review process. The intent was to account for system components consistent with the extent reflected in NUREG-1801 Volume 1 and Volume 2 AMR tables, with additional consideration given to providing line items identifying major system pumps, tanks, and heat exchangers as an aid to reviewers.

The following table resolves scoping results for the individual examples provided in this RAI:

U. S. Nuclear Regulatory Commission 3F17109-05 Enclosure Page 37 of 47 LRA Section /Drawing Number Component Listing Issue Resolution 2.3.3.22 CONTROL COMPLEX CHILLED WATER SYSTEM The drawing depicts temporary strainer The locations identified depict components as included in scope of license flanged connections provided renewal under 10 CFR 54.4(a)(1) at the to facilitate the installation of inlet of chilled water pumps CHP- 1A and temporary strainers for startup CHP-IB (shown at locations C-6 and E-6 on and /or system maintenance the drawing).

These components are not activities.

To the extent that included on Table 2.3.3-22 or Table 3.3.2- temporary strainers may, at 22 with intended function M-1, pressure some time, be installed at boundary, or M-2, filtration.

Temporary these locations, they are not LRA-302-756-LR, strainers are also depicted as in scope on: considered permanent plant SH01 equipment, are not long-lived," CR-3 LRA drawing 302-762-LR, and therefore not subject to SHOI, industrial cooler water License Renewal (shown at locations C-2 and D-2 on requirements.

the drawing)" CR-3 LRA drawing 302-631-LR, SHO0 and SH02, decay heat closed cycle cooling (shown at location F-I on SHOI and location E-2 on SH02)2.3.3.24 INDUSTRIAL COOLING SYSTEM The drawing depicts expansion joints, The industrial cooler pump industrial cooler pump casings, and reactor casings, reactor cavity pump cavity pump casings as included in scope of casings, and expansion joints license renewal under 10 CFR 54.4(a)(2).

depicted as in scope are These components are not included on included as "Piping, piping LRA-302-762-LR, Table 2.3.3-24 or Table 3.3.2-24 with components, piping elements, SHO1 intended function M-1, pressure boundary.

and tanks" in Table 2.3.3-24.Pump casings and expansion joints are The expansion joints are listed separately on other system AMP further identified by the tables such as the control complex chilled "Elastomers" material water system. designation in aging management review Table 3.3.2-24.2.3.3.26 EFP-3 DIESEL AIR STARTING SYSTEM The drawing depicts expansion joints as AHEJ-1 is part of the Air included in scope of license renewal under Handling Ventilation and 10 CFR 54.4(a)(1) on the diesel exhaust Cooling System described in line. These components are not included Subsection 2.3.3.1 of the LRA.on Table 2.3.3-26 or Table 3.3.2-26 with AHEJ-1 is included as "EFP-3 intended function M-1, pressure boundary.

Diesel Engine Exhaust Expansion joints are included as separate Expansion Joints and LRA-302-778-LR, component entries in other system tables Silencers" in Table 2.3.3-1.SHO1 such as the control complex chilled water AHEJ-2 and AHEJ-3 are part system. The applicant should identify of the Emergency Feedwater expansion joints in all systems and verify Pump Building Ventilation that they are included in an AMP. System described in Subsection 2.3.3.18 of the LRA. AHEJ-2 and AHEJ-3 are included as "Expansion Joints" in Table 2.3.3-18.

U. S. Nuclear Regulatory Commission 3F1109-05 Enclosure Page 38 of 47 The drawing depicts flexible connections as The flexible connections included in scope of license renewal under shown on drawing 302-778-10 CFR 54.4(a)(1) on the diesel air start LR, Sheet I are braided hoses line. These components are not included and are included as "Piping, on Table 2.3.3-26 or Table 3.3.2-26 with piping components, and piping LRA-302-778-LR, intended function M-1, pressure boundary.

elements" in Table 2.3.3-26 of SH01 Flexible connections are included as the LRA.separate component entries in other system tables such as the reactor building recirculation system. The applicant should identify flexible connections in all systems and verify that they are included in an AMP.2.3.3.28 FUEL OIL SYSTEM The drawing depicts flexible connections in The flexible connections the drawing as included in scope of license shown on drawing 302-776-renewal under 10 CFR 54.4(a)(1) on the LR, Sheet 1 are braided stain-SH021 DDEFW pump diesel fuel storage tank. less steel hoses and included These components are not included on as "Piping, piping components, Table 2.3.3-28 or Table 3.3.2-28 with and piping elements" in Table intended function M-1, pressure boundary.

2.3.3-28 of the LRA.2.3.3.29 JACKET COOLING SYSTEM LRA-302-283-LR, The drawing depicts expansion tanks as The expansion tanks are not SHO 1& 02; included in scope of license renewal under considered major tanks and 10 CFR 54.4(a)(1).

These components are are included as "Piping, piping LRA-302-284-LR, not included on Table 2.3.3-29 or Table components, piping elements, SH01 & 02; 3.3.2-29 with intended function M-1, and tanks" in Table 2.3.3-29 of pressure boundary.

Other systems the LRA.LRA-302-777-LR, specifically identify major system tanks as SH01 part of an AMP.2.3.3.32 DEMINERALIZED WATER SYSTEM The drawing depicts the auxiliary building Condensate and condensate and demineralized water Demineralized Water Storage storage tank as included in scope of license Tank, DWT-1, is a non-safety renewal under 10 CFR 54.4(a)(2) (shown at related tank located inside the B-3 on the drawing).

This tank is a AB that is in License Renewal LRA-302-182-LR, significant system component and the tank scope for spatial interaction SH02 is not specifically included on. Table 2.3.3- only. This tank is included as 32 or Table 3.3.2-32 with intended function "Piping, piping components, M-1, pressure boundary.

Other systems, piping elements, and tanks" in such as the fuel oil system, identify Table 2.3.3-32.significant system tanks that are subject to an AMP separately.

The drawing depicts the post treatment filter DWFL-1 is a non-safety as included in scope of license renewal related component located in under 10 CFR 54.4(a)(2) at the discharge of the AB that is in License demineralized water pumps DWP-1A and Renewal scope for spatial DWP-1B (shown at D-7 on the drawing).

interaction only. Filtration is The filter is not included on Table 2.3.3-32 not an intended function for H022 or Table 3.3.2-32 with intended function M- the post treatment filter. The 2, filtration.

M-1 pressure boundary associated with the filter housing is included as "Piping, piping components, piping elements, and tanks" in Table 2.3.3-32.

U. S. Nuclear Regulatory Commission 3F1 109-05 Enclosure Page 39 of 47 2.3.3.33 EMERGENCY DIESEL GENERATOR SYSTEM Filters are depicted as included in scope of The filter media for EGFL-1 license renewal under 10 CFR 54.4(a)(1) in through 8 have been screened numerous system drawings.

An example of as replaced.

As stated on this on the referenced drawing occurs at page 2.1-25 of the LRA: locations D-1 and D-8. However, similar "Commodity group LRA-302-282-LR, filters appear in numerous system drawings, components that are replaced SHOI and the filters are not specifically included based on qualified life or on Table 2.3.3-33 nor Table 3.3.2-33 with specified time period (i.e., intended function M-1, pressure boundary short-lived components) are or M-2, filtration.

Filters do not appear to not subject to AMR. " The filter meet the CR-3 definition for piping, piping housings are included as components and piping elements. "Piping, piping components, piping elements, and tanks" in Table 2.3.3-33 of the LRA.The drawing depicts flexible connections in The flexible connections the drawing as included in scope of license shown on drawing 302-282-LRA-302-282-LR, renewal under 10 CFR 54.4(a)(1) at LR, Sheet I are braided SH01 locations E-1 (near EGV-35) and E-8 (near stainless steel hoses and are EGV-39). These components are not included as "Piping, piping included on Table 2.3.3-33 or Table 3.3.2- components, and piping 33 with intended function M-1, pressure elements" in Table 2.3.3-33 of boundary, the LRA.2.3.3.41 MISCELLANEOUS DRAINS SYSTEM The drawing depicts a flash tank as in Flash Tank MDT-2 is a non-scope of license renewal at drawing location safety related component H-3. Typically, a pressure and temperature located in the lB and is in the change allows entrained steam in the drains scope of License Renewal LRA-302-114-LR, to change state to liquid and cool in the solely for spatial interaction SH02 flash tank. Table 2.3.3-41 and Table 3.3.2- only. The M-1 pressure 41 in the LRA only identify components with boundary associated with the an intended function of pressure-boundary flash tank is addressed within (M-1). The flash tank is not identified with "Piping, piping components, an intended function of heat transfer (M-5). piping elements, and tanks" in I Table 2.3.3-41.2.3.3.42 MAKE UP AND PURIFICATION SYSTEM The drawing depicts Y-strainers as in scope Filtration is not an intended of license renewal at drawing locations E-3 function for Y-strainers at and E-7. These components are not drawing locations E-3 and E-7.included on Table 2.3.3-42 or Table 3.3.2- The M-1 pressure boundary LRA-302-661-LR, 42 with intended function M-2, filtration.

associated with the strainer SH01 Strainers are identified in other systems housings is addressed within such as the nuclear services closed cycle "Piping, piping components, cooling system. The applicant should piping elements, and tanks" in identify Y-strainers in all systems and verify Table 2.3.3-42.that they are included in an AMP. 1 2.3.3.49 NUCLEAR SERVICE AND DECAY HEAT SEA WATER SYSTEM Expansion joint encapsulation sleeves, The encapsulation sleeves for RWEJ-1 through RWEJ-10, shown at expansion joints RWEJ-1 locations F-2, D-2, F-I1, D-9, E-9, D-8, E-8, through RWEJ-10 are flanged LRA-302-61 1-LR, D-7, E-7 and D-6, respectively, are not components constructed of SH01 specifically included in Tables 2.3.3-49 or carbon steel, and are included 3.3.2-49.

as "Piping, piping components, and piping elements" in Table 2.3.3-49.

U. S. Nuclear Regulatory Commission F1 109-05 Page 40 of 47 RAI 2.3.3.22-01 Control Complex Chilled Water System

Background:

10 CFR Section 54.21 (a)(1) requires each applicant to describe and justify the methods used to identify and list those structures and components subject to an AMR.Issue: The LRA includes the control complex chiller lube oil pumps and oil cooler tubes in an AMR. These components are not shown on CR-3 LRA drawing 302-756-LR, SH01. Without a drawing or a more extensive discussion of the system components, it is not possible to validate that all components associated with the lube oil system have been included in scope and evaluated for inclusion in an AMR.Request: Provide supplemental information for staff to verify that all control complex chilled water lube oil components are included in scope of license renewal under 10 CFR Section 54.21 (a)(1) and evaluated for an AMP.Response: The CR-3 Control Complex Chiller lubrication system consists of the lubrication oil pumps, oil filter, oil cooler, and interconnecting piping. These skid mounted components are not depicted on CR-3 flow diagrams.

The oil cooler has no shell, but rather the tubes transfer heat directly to the refrigerant in the refrigerant reservoir.

The lubrication oil filter is a cartridge filter that is replaced regularly, and the short-lived filter cartridge is not subject to aging management.

As such, aging management requirements for the lubrication system are limited to the piping system pressure boundary (M-1) function, and the heat transfer (M-5) function for the lube oil cooler tubes. The Control Complex Chiller Lube Oil Pumps and Control Complex Chiller Oil Cooler Tubes are identified individually in component/commodity line items in LRA Table 2.3.3-22. Lube oil piping components having the M-1 intended function, including the oil filter housing, are included in "Piping, piping components, and piping elements." RAI 2.3.3.27-01 Decay Heat Closed Cycle Cooling System

Background:

10 CFR 54.4(a) requires applicants to identify and list all structures, systems, and components (SSCs) subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: On CR-3 LRA drawing 302-631-LR, SH01, the drawing identifies connected piping to CR-3 LRA drawing 302-181-LR, SH02 as included in scope of license renewal under 10 CFR 54.4(a)(2) through valve DCV-97 at location A-5, but excludes the connection to valve DCV-212 from being in scope for license renewal. CR-3 LRA drawing 302-631-LR, SH02 also depicts connected piping to CR-3 LRA drawing 302-181-LR, SH02 as included in scope of license renewal under 10 CFR 54.4(a)(2) through valve DCV-98 where the connection to valve DCV-213 is excluded from being in scope for license renewal.Request: Provide explanation for why both DCV-212 and DCV-213 valves are excluded from being in scope of license renewal under 10 CFR 54.4(a)(2).

U. S. Nuclear Regulatory Commission F1 109-05 Page 41 of 47 Response: Valves DCV-212 and DCV-213 are in the scope of license renewal for 10 CFR 54.4(a)(2), and should have been highlighted on their respective LRA drawings.

These valves are represented within "Piping, piping components, and piping elements" in Table 2.3.3-27.RAI 2.3.3.32-01 Demineralized Water System

Background:

10 CFR Section 54.21(a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.Issue: On CR-3 LRA drawing 302-182-LR, SH01, the drawing identifies numerous area exclusions where spatial interaction concerns do not exist. In the CR-3 LRA, the applicant states that "...non-safety related piping (including air/gas systems) and ducting components located inside seismic Class I structures have been conservatively included in scope unless specific evaluations were performed to justify exclusion." However, the demineralized water system area exclusions are not described in any detail in the CR-3 LRA. Without a more extensive discussion of these area exclusions, it is not possible to validate that all components associated with the demineralized water system have been included in scope and evaluated for inclusion in an AMP.Request: Provide justification for excluding the component types from the scope of license renewal to permit the staff to identify all portions of the systems within the license renewal boundary as specified in 10 CFR 54.21 (a)(1).Response: CR-3 has revised its methodology for spatial interaction scoping to narrowly permit exclusions only in areas where there are no safety related components, that are adequately protected and isolated from other areas of the plant, and are equipped with drain systems which are themselves in the scope of license renewal (See RAI 2.1-2 response in CR-3 to NRC letter, 3F0909-04, "Crystal River Unit 3 -Response to Requests for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)," dated September 18, 2009 (ML092650272)).

Based on these criteria, spatial interaction scoping exclusions associated with the Demineralized Water System are limited to three demineralized water supply valves (DWV-235, DWV-237, and DWV-238) and associated piping located in the Radwaste Processing Area of the AB. The balance of Demineralized Water System piping components located inside Seismic Class 1 Structures has been included in License Renewal scope. These components are represented by the component/commodity group "Piping, piping components, piping elements, and tanks" in Table 2.3.3-32.RAI 2.3.3.38-01 Instrument Air System

Background:

10 CFR Section 54.21(a)(1) requires applicants to identify and list components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing the components within the license renewal boundary.

U. S. Nuclear Regulatory Commission F1109-05 Page 42 of 47 Issue: On CR-3 LRA drawing 302-271-LR, SH01, the drawing depicts the backup air system for ADVs as in scope of license renewal under 10 CFR 54.4(a)(2) for the instrument air system. However, in LRA Section 2.3.4.16, Main Steam System, the applicant identified the following two 10 CFR 54.4(a)(1) functions for the main steam system: The system provides relief capacity to protect the steam generators from overpressurization for a loss of electric power.The system controls steam generator pressure and thereby provides a mechanism for controlled decay heat removal for a loss of electrical power, steam line failure, loss of coolant accident, feedwater line break, and steam generator tube failure.The ADV support of the 10 CFR 54.4(a)(1) functions of the main steam system would seem to indicate that the backup air system should be included as in scope of license renewal under 10 CFR 54.4(a)(1).

It follows that equipment in the turbine building may be included as in scope of license renewal under 10 CFR 54.4(a)(2), nonsafety related components that could potentially affect the function of 10 CFR 54.4(a)(1) components.

Request: Justify the exclusion of the backup air system as within scope of license renewal under 10 CFR 54.4 (a)(1).Response: FSAR Section 10.2.1.4 discusses the atmospheric dump valves (ADVs) and states that the atmospheric dump valve relief capacity or control functions are not required to mitigate any limiting FSAR accident.

The backup bottled air system for the ADVs provides a backup source of motive power to comply with the operability requirements for the coping period following a Station Blackout (SBO), which is a 10 CFR 54.4 (a)(3) function.RAI 2.3.3.38-02 Instrument Air System

Background:

10 CFR 54.21(a)(1) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: In the response letter to NRC request for additional information, dated May 11, 2009, the applicant provided 10 CFR 54.4(a)(1)and (a)(2) functions for LRA systems. In the instrument air system, the applicant identified an 10 CFR 54.4(a)(1) function that indicates the system contains components associated with air reservoirs that provide an assured source of air to various safety related components.

However, the main instrument air receivers were identified on the CR-3 LRA drawings 302-271-LR, SH01 and SH02. No individual component air reservoirs were identified on the drawings or included in the AMR tables for the instrument air system.

• U. S. Nuclear Regulatory Commission F1109-05 Page 43 of 47 Request: Provide an explanation on why individual air reservoirs were excluded from being in scope of license renewal under 10 CFR 54.4(a).Response: Individual air reservoirs were not excluded from the scope of License Renewal. The referenced air receivers are small passive tanks and are included in the scope of License Renewal in the Air Handling Ventilation and Cooling System, Control Complex Ventilation System, Industrial Cooling System, Circulating Water System, Main Feedwater System, Main Steam System, Make Up & Purification System, Secondary Services Closed Cycle Cooling System, and the Nuclear Services Closed Cycle Cooling System. As an example, the subject Main Steam System air receivers are in scope, and included in LRA Table 2.3.4-12 as "Piping, piping components, piping elements, and tanks." RAI 2.3.3.52-01 Station Drains System

Background:

10 CFR 54.4(a) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: On CR-3 LRA drawing 302-281-LR, SH01, the drawing shows two "2" to Nearest Floor Drain" lines at locations E-3 and E-6. These lines appear to exit the building through a dividing wall and are shown to be within the scope of license renewal. If these lines are fluid-filled and go to the auxiliary building they can affect a safety-related component if they break.Request: Describe where these lines go, and if any additional components should be included in the scope of license renewal.Response: The two 2 in. lines routed to the nearest floor drains, shown at locations E-3 and E-6 on drawing 302-281-LR, SH01, exit the Diesel Generator Building into the Clean Maintenance Shop.The portion of these lines that are within the Diesel Generator Building are included in the scope of License Renewal. These piping components are included in LRA Table 2.3.3-52 as "Piping, piping components, and piping elements," RAI 2.3.3.53-01 Spent Fuel Cooling System

Background:

10 CFR 54.21(a)(1) requires applicants to identify and list all SSCs subject to AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: On CR-3 LRA drawing 302-621-LR, SH01, the drawing indicates two heat exchangers in the spent fuel storage pools "A" and "B" that are not included in the scope of license renewal. Heat exchanger FHX-2 is shown at location B-6 and heat exchanger FHX-3 is shown at location B-9.

U. S. Nuclear Regulatory Commission F1 109-05 Page 44 of 47 Request: Provide the function of these heat exchangers and justify their exclusion from being in scope of license renewal under 10 CFR 54.4(a).Response: Tag numbers FHX-2 and FHX-3 are not heat exchangers, but fuel pool gates, as denoted by the term "Gate" immediately over FHX-2.RAI 2.3.4.3-01 Condensate Chemical Treatment System

Background:

10 CFR 54.21 (a)(1) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: LRA Section 2.3.4.3, states that the condensate chemical treatment system is located within the turbine building, but has components in scope under 10 CFR 54.4 (a)(2), because the system has non-safety related components whose failure could prevent satisfactory accomplishment of the safety related functions.

However, LRA Section 2.4.2.18, states that the turbine contains only non safety-related components.

The hydrazine addition tank is part of the chemical treatment system. LRA Figure 2.2-1 indicates that the hydrazine addition tank is within the scope of license renewal; however, 'tank' is not included as mechanical component type in the scope of license renewal. Yet, LRA Section 2.4.2.15, Miscellaneous Structures, describes the hydrazine addition tank foundation as being within the scope of license renewal because of a calculation for non-safety affecting safety identified the tank as required to support a design basis event.Request: Provide an explanation for why the hydrazine tank foundation was included in the scope of license renewal for possible interaction with safety-related components; indicate which safety-related component interacts with the hydrazine addition tank, and provide justification of the exclusion of the hydrazine addition tank on the foundation from the scope of license renewal.Response: The Hydrazine Batch Tank, referred to in LRA Section 2.3.4.3, is in the Condensate Chemical Treatment System, and is not in the scope of License Renewal. The Hydrazine Addition Tank is part of the Condensate System and is included in LRA Table 2.3.4-3 as "Piping, piping components, piping elements, and tanks." The Hydrazine Addition Tank is not adjacent to any Class I structure and is therefore not a seismic interaction concern. The topical calculation for 10 CFR 54.4(a)(2) scoping identified the Condensate System as a non-safety related system necessary to support main condenser vacuum during a steam generator tube rupture event. The Hydrazine Addition Tank was included in scope for 10 CFR 54.4(a)(2) as part of the Condensate System. As such, the Hydrazine Addition Tank foundation is within the scope of License Renewal.

U. S. Nuclear Regulatory Commission F1109-05 Page 45 of 47 RAI 2.3.4.3-02 Condensate Chemical Treatment System

Background:

10 CFR 54.21 (a) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: The LRA stated the 10 CFR 54.4(a)(2) function for this system describes pressure boundary seals that support the control complex habitability envelope.The seals are also considered to be civil components.

The LRA does not contain any AMR tables listing mechanical components for the chemical treatment system, but does indicate that there are civil and electrical components in this system that are in scope for license renewal. The LRA does not provide details on what type of components (mechanical or electrical) are associated with these pressure boundary seals.Request: Identify the components transitioning through these seals; and if they are liquid filled, then justify their exclusion from the scope of license renewal under 10 CFR 54.4(a)(2).

Also, identify the LRA table depicting the AMR for these pressure boundary seals.Response: The Condensate Chemical Treatment System includes three in-scope civil discipline fire barrier penetration seals located in the control complex. These fire barrier penetration seals are age-managed as identified in LRA Table 3.5.2-6, Containments, Structures, and Component Supports -Summary of Aging Management Evaluation

-Control Complex. The Condensate Chemical Treatment System does not contain any liquid-filled piping inside the control complex.RAI 2.3.4.7-01 Condensate Demineralizer System

Background:

10 CFR 54.21(a)(1) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: LRA Section 2.3.4.7 refers to an acid/caustic drain line in paragraph 4 that is located in the auxiliary building.

The staff could not locate this drain line on the LRA drawings.Request: Identify this drain line referred to in the text located in the auxiliary building.Response: LRA Subsection 2.3.4.7 refers to two drain lines, one acid and one caustic, associated with the Condensate Demineralizer System. These two lines have been cut, capped, and disconnected from the Condensate Demineralizer System.One drain line is associated with a connection to the neutralizer tank and is identified on License Renewal scoping drawings 302-681-LR, Sheet 1 (G-1) and 302-163-LR, Sheet 2 (H-4). This drain line and associated piping components have been brought into the scope of License Renewal per the response to RAI 2.1-2. The response to RAI 2.1-2 was submitted to the NRC a U. S. Nuclear Regulatory Commission F1 109-05 Page 46 of 47 in CR-3 letter, 3F0909-04, "Crystal River Unit 3 -Response to Requests for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application (TAC NO. ME0274)," dated September 18, 2009 (ML092650272).

The second drain line is associated with a connection to the spare mix tank and is identified on License Renewal scoping drawings 302-671-LR, Sheet I (A-I) and 302-163-LR, Sheet 2 (H-4).Since the two cut, capped, and disconnected drain lines could not be verified as non-pressurized in the plant, the lines have been included in scope as non-safety related pressure boundary components in Seismic Class 1 structures having the potential for spatial interactions with safety related SSCs.RAI 2.3.4.8-01 Emergency Feedwater System Back.ground:

10 CFR 54.21(a)(1) requires applicants to identify and list all SSCs subject to an AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: The main condenser is located within the turbine building and the Emergency Feedwater (EFW) pumps are located within the intermediate building (as noted in FSAR Section 10.5.3). CR-3 LRA Drawing 302-082-LR, SH01 shows a cross-connect between main condenser 3B and the suction for EFW pumps Emergency Feedwater Pump (EFP)-I and EFP-2. The cross-connect for EFP-1, the motor driven EFW pump, is through a normally-locked-closed motor operated gate valve shown at location F-7 (EFV-2). Similarly, the cross-connect for EFP-2, the turbine driven EFW pump, is also through a normally-locked-closed motor operated gate valve shown at location E-7 (EFV-1).The condensate-boundary side of both these valves shows a change from ANSI 31.1 ES to ANSI B31.1 Non-Safety Related, and a change from seismic class III to seismic class I. However, where the change between seismic class occurs for these valves (EFV-1, -2) is not indicated on CR-3 LRA drawing 302-082-LR, SH01, nor does it also indicates where the system piping, components, or structures transition from the turbine building to the intermediate building.Request: Provide supplemental information on CR-3 LRA drawing 302-082-LR, SH01 to identify where the condensate system supply line to the EFW pumps enters the intermediate building and if there are any changes in the piping classification.

Response: The condensate supply line to the EFW pumps enters the lB between the connection to the Auxiliary Feedwater Pump (which is installed in the TB) and the tee where it splits to go to EFP-1 and EFP-2 (which is located in the IB).As identified on CR-3 LRA drawing 302-082-LR, SH01, the piping class break from Seismic Class Ill to Seismic Class I does not occur until the upstream connections to EFV-1 and EFV-2, which are downstream of the tee located inside the lB.RAI 2.3.4.16-01 Main Steam System U. S. Nuclear Regulatory Commission F1109-05 Page 47 of 47

Background:

10 CFR 54.21(a)(1) requires applicants to identify and list all SSCs subject to AMR. The staff confirms inclusion of these SSCs subject to an AMR by reviewing the component types within the license renewal boundary.Issue: On CR-3 LRA drawing 302-011-LR, SH01, there are two unidentified components (RM-G25/G28) shown at locations B-2 and E-2. Both components are attached to an atmospheric line from a normally-closed valve (MSV-25).Both components are shown as being included in the scope of license renewal.Request: Provide clarification on what the components are and their intended function for being in scope of license renewal under 10 CFR 54.4(a).Response: The two components (RM-G25/G28) are main steam line radiation monitors, and are included in the scope of License Renewal in the Radiation Monitoring (RM) system. A sample line from the Main Steam System is routed past the radiation monitors.

These two radiation monitors perform a post-accident monitoring function in accordance with Regulatory Guide 1.97.Radiation monitors RM-G25 (MSV-25) and RM-G28 (MSV-26) monitor a sample from the atmospheric dump valve discharge for gamma dose rate and provide confirmatory indication of atmospheric dump valve position during a Steam Generator Tube Rupture.