L-2021-208, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 9 Response Supplement 1

Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 9 Response Supplement 1

ML21308A283
Person / Time
Site:	Point Beach
Issue date:	11/04/2021
From:	Maher W Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2021-208
Download: ML21308A283 (8)

Text

NEXTera ENERGY .

POINT BEACH November 4, 2021 L-2021-208 10 CFR 54.17 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One \'\lhite Flint North Rockville, MD 20852-27 46 Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 SUBSEQUENT LICENSE RENEWAL APPLICATION -AGING MANAGEMENT REQUESTS FOR ADDITIONAL INFORMATION (RAI) SET 9 RESPONSE SUPPLEMENT 1

References:

1. NextEra Energy Point Beach, LLC (NEPB) Letter NRC 2020-0032 dated November 16, 2020, Application for Subsequent Renewed Facility Operating Licenses (ADAMS Package Accession No. ML20329A292)

2. NRC Public Meeting with NextEra Energy to Discuss Point Beach Nuclear Plant Units 1 and 2, Subsequent License Renewal Application - Proposed Aging Management Programs, October 19, 2021 (ADAMS Accession No. ML21281A077)

3. NEPB Letter L-2021-174 dated October 1, 2021, Subsequent License Renewal Application -Aging Management Request for Additional Information (RAI) Set 9 Response (ADAMS Accession No. ML21274A053)

NEPB, owner and licensee for Point Beach Nuclear Plant (PBN) Units 1 and 2, has submitted a subsequent license renewal application (SLRA) for the Facility Operating Licenses for PBN Units 1 and 2 (Reference 1).

Based on the public meeting between the NRC and NEPB (Reference 2), NEPB is providing the attached information supplementing Attachment 1 of Reference 3.

For ease of reference, the index of attached information is provided on page 3 of this letter. Attachments may include associated revisions to the SLRA (Enclosure 3 Attachment 1 of Reference 1) denoted by strikethrough (deletion) and/or bold red underline (insertion) text. Any previous SLRA revisions are denoted by bold black text, and SLRA table revisions are included as excerpts from each affected table.

Should you have any questions regarding this submittal, please contact me at (561) 304-6256 or William.Maher@fpl.com.

NextEra Energy Point Beach, LLC 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk L-2021 -208 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 4 1" day of November 2021.

Sincerely, William l>'.<J'U'/ilgf'W!d!Tf l'li'.llm~t>t*

O:l:ma\'lilUtn/.~""'*o-1/udo*,

ou.oJludH1Uc:trulr>gP1ojt(\I, f<"'<li-v>ili&m.tNhttit fpl<OIT\C*US Maher 0 111: 202 1.1 1.IMO'llAl*J I 44W William D . Maher Licensing Director - Nuclear Licensing Projects Cc: Administrator, Region III, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Public Service Commission Wisconsin

Document Control Desk L-2021-208 Page 3 Attachments Index Attachment RAI N o. Subject No.

1 B.2.3.27-l a Cathodic Protection for Buried Steel Piping/Preventive Action Ca tegory E

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.27-1a L-2021-208 Attachment 1 Page 1 of 5 NEPB Supplemental Response to RAI B.2.3.27-1a:

Based on the public meeting conducted between NEPB and NRC on October 19, 2021 (Reference 1), the following information supplements the NEPB response in Attachment 1 of Reference 2.

A review of the fuel oil and service water buried steel piping was performed in order to determine what percentage of that piping would be considered to have cathodic protection coverage . The results of that review are presented below:

Approximate Approximate length of in-length of in-scope scope buried steel piping System buried steel piping covered by the cathodic (linear-feet) protection system (linear-feet)

Fuel Oil 3305 1500 Service 325 151 Water Based on the above, approximately 45% of the buried fuel oil piping within the scope of SLR can be considered to have cathodic protection coverage. Of the buried service water piping within the scope of SLR, approximately 46% can be considered to have cathodic protection coverage. Overall, 45% of the combined buried fuel oil and service water piping can be considered to have cathodic protection coverage.

Reference 2 provided PB N's justification for why additional cathodic protection was not necessary based on excellent operating experience associated with buried steel piping, including the non-cathodically protected piping, and soil conditions considered non-aggressive based on sampling. Thus, PBN considers that the in SLR scope buried steel piping at the site appropriately meets the Preventive Action Category E classification per NUREG-2191, Table Xl.M41-2. During the Reference 1 meeting, however, the NRC staff indicated that it was not its intent that Preventive Action Category E be used where cathodic protection only provided partial coverage.

Accordingly, for the Buried and Underground Piping and Tanks AMP, PBN proposes to proceed with the number of piping inspections in each ten-year interval, beginning in the ten-year period prior to the SPEO, through the SPEO based on Preventive Action Category E in NUREG-2191, Table Xl.M41-2. However, PBN will take an exception to the guidance for Preventive Action Category E that all buried steel piping have some level of cathodic protection. The justification for this exception is the excellent PBN operating experience associated with buried steel piping, including the non-cathodically protected piping, and soil conditions considered non-aggressive based on sampling (Reference 2). Furthermore, PBN has also committed to performing two additional inspections of buried fire protection piping in each ten-year interval, beginning in the ten-year period prior to the SPEO, through the SPEO beyond that recommended by Preventive Action Category E (Reference 3). Finally, as an additional measure , PBN

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.27-1a L-2021-208 Attachment 1 Page 2 of 5 commits to performing at least three inspections of the non-cathodically protected steel piping as part of the five inspections recommended by Preventive Action Category E for PBN in each ten-year interval, beginning in the ten-year period prior to the SPEO, through the SPEO.

The SLRA is revised as noted below.

References:

1. NRC Public Meeting with NextEra Energy to Discuss Point Beach Nuclear Plant, Units 1 and 2, Subsequent License Renewal Application - Proposed Aging Management Programs, October 19, 2021 (ADAMS Accession No. ML21281A077)

2. NextEra Energy Point Beach, LLC (NEPB) Letter to NRC L-2021-174 dated October 1, 2021, Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) Set 9 Response (ADAMS Accession No. ML21274A053)

3. NextEra Energy Point Beach, LLC (NEPB) Letter to NRC L-2021-144 dated August 11, 2021, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 2 Responses (ADAMS Accession No. ML21223A308)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.27-1 a L-2021-208 Attachment 1 Page 3 of 5 Associated SLRA Revisions:

SLRA Appendix A, Section 16.4, Table 16-3 (Item 31) , page A-100, as revised by SLRA Aging Management Supplement 1 and Reference 3, is amended as follows:

Table 16-3 L"ISt 0f SLR C omm1"t mens t an d Imp emen tafion Shdl c e ue No. Aging NUREG-2191 Commitment Implementation Management Section Schedule Program or Activity (Section)

!}. Perform ins12ections on the uncoated/unwra1212ed 12ortions of the buried fire 12rotection system 12i12ing no earlier than 10 years 12rior to the SPEO and at least eve!Y 10 years during the SPEO. The ins12ections include at least two 10-ft segments of uncoated/unwra1212ed fire 12rotection QiQing.

y} Perform at least 3 ins12ections of non-cathodically 12rotected steel 12i12ing as 12art of the 5 12reventive action catego[Y E ins12ections 12erformed in each 10 year interval beginning no earlier than 10 years 12rior to the SPEO and at least eve!}'. 10 years during the SPEO.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.27-1 a L-2021-208 Attachment 1 Page 4 of 5 SLRA Appendix B, Section B.2.3.27, page B-196, is amended as follows:

Exception to NUREG-2191

• The PBN cathodic protection was last evaluated in accordance with NACE SP0169-2013 rather than NACE SP0169-2007 specified in GALL-SLR. The PBN Buried and Underground Piping and Tanks AMP will take an exception to performing cathodic protection testing and evaluations in accordance with all of NACE SP0169-2007.

Instead, the cathodic protection testing and evaluations shall be performed in accordance with NACE SP0169-2013 (with the exception of Section 6, "Criteria and Other Considerations for Cathodic Protection"). The information from NACE SP0169-2007 will be used instead of NACE SP0169-2013 for Section 6. Per LR-ISG-2015-01, the NRC disagreed with portions of NACE SP0169-2013, Section 6.

! PBN will take an exception to the guidance for Preventive Action Category E that all buried steel piping have some level of cathodic protection. The justification for this exception is the excellent PBN operating experience associated with buried steel piping, including the non-cathodically protected piping, and soil conditions considered non-aggressive based on sampling. Additional justification is that PBN has also committed to performing two inspections of buried fire protection piping in each ten-year interval, beginning in the ten-year period prior to the SPEO, through the SPEO beyond that recommended by Preventive Action Category E. Finally, as an additional measure, PBN commits to performing at least three inspections of the non-cathodically protected steel piping as part of the five inspections recommended by Preventive Action Category E for PBN in each ten-year interval, beginning in the ten-year period prior to the SPEO, through the SPEO.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2 .3.27-1a L-2021 -208 Attachment 1 Page 5 of 5 SLRA Appendix B, Section B.2 .3.27, page B-197, as revised by SLRA Ag ing Management Supplement 1 and Reference 3, is amended as follows:

Element Affected Enhancement

4. Detection of Aging *

- Clarify that inspections will be performed on the Effects uncoated/unwrapped portions of the buried fire protection system piping no earlier than 10 years prior to the SPEO and at least everv 10 years during the SPEO.

The inspections include at least two 10-ft segments of uncoated/unwrapped fire protection piping.

• Perform at least 3 inspections of non-cathodically protected steel piping as part of the 5 preventive action category E inspections performed in each 10 year interval beginning no earlier than 10 years prior to the SPEO and at least everv 10 vears durina the SPEO.

Associated

Enclosures:

None.