L-2021-221, Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 10 Responses Supplement 1

Subsequent License Renewal Application - Aging Management Requests for Additional Information (RAI) Set 10 Responses Supplement 1

ML21327A033
Person / Time
Site:	Point Beach
Issue date:	11/19/2021
From:	Maher W Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2021-221
Download: ML21327A033 (6)

Text

NEXTera ENERGY ~

POINT BEACH November 19, 2021 L-2021-221 10 CPR 54.17 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746 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 10 RESPONSES 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. NEPB Letter L-2021 -199 dated November 4, 2021 , Subsequent License Renewal Application -

Aging Management Requests for Additional information (RAI) Set 10 Responses (ADAMS Accession No. ML21308A282)

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).

The attachment to this letter supplements the Reference 2 Attachment 2 RAI response.

For ease of reference, the index of attached information is provided on page 3 of this letter. The attachment includes associated revisions to the SLRA (Enclosure 3 Attachment 1 of Reference 1) denoted by bold red underline (insertion) text, with prior SLRA revisions denoted by bold black text.

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

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 19 th day of November 2021.

Sincerely, William D . Maher Licensing Director - Nuclear Licensing Projects NextEra Energy Point Beach, LLC 6610 Nuclear Road , Two Rivers, WI 54241

Document Control Desk L-2021-221 Page 2 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 -221 Page 3 Attachments Index Attachment RAINo. Subject No.

1 B.2.3.34-la Structures Monitoring - Epoxy Grouted Anchors and Bolts

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.34-1 a L-2021-221 Attachment 1 Page 1 of 3 NEPB Supplemental Response to RAI B.2.3.34-1a:

This information supplements the NEPB response in Attachment 2 of Reference 1.

References:

1. NextEra Energy Point Beach, LLC (NEPB) Letter to NRC L-2021-199 dated November 4, 2021, Subsequent License Renewal Application - Aging Management Request for Additional Information (RAI) Set 10 Responses (ADAMS Accession No. ML21308A282)

Associated SLRA Revisions:

SLRA Section 16.2.2.34 (page A-36, as amended by SLRA Aging Management Supplement 1) is revised as follows:

16.2.2.34 Structures Monitoring The PBN Structures Monitoring AMP is an existing AMP that consists of periodic visual inspection and monitoring of the condition of concrete and steel structures, structural components, component supports, and structural commodities to ensure that aging degradation (such as those described in ACI 349.3R, ACI 201.1 R, SEI/ASCE 11, and other documents) will be detected, the extent of degradation determined and evaluated, and corrective actions taken prior to loss of intended functions.

Specific attention is given to the potential for localized distortion of the reactor cavity liner plate as a result of the radiation induced volumetric expansion (RIVE) effect on the underlying concrete.

Structures are monitored on an interval not to exceed 5 years.

Inspections also include seismic joint fillers, elastomeric materials; steel edge supports and bracings associated with masonry walls, and periodic evaluation of ground water chemistry and opportunistic inspections for the condition of below grade concrete. In addition, anchors embedded in epoxy resin-based grout will receive an inspection for tightness (e.g., torque check, as applicable) during inspections. Quantitative results (measurements) and qualitative information from periodic inspections are trended with sufficient detail, such as photographs and surveys for the type, severity, extent, and progression of degradation, to ensure that corrective actions can be taken prior to a loss of intended function. The acceptance criteria are derived from applicable consensus codes and standards. For concrete structures, the program includes personnel qualifications and quantitative evaluation criteria of ACI 349.3R.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRC RAI No. B.2.3.34-1a L-2021-221 Attachment 1 Page 2 of 3 SLRA Section B.2.3.34 (page 8-238) is revised as follows:

B.2.3.34 Structures Monitoring Program Description The Structures Monitoring Aging Management Program (AMP) is an existing AMP based on the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (the Maintenance Rule) and U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.160 (Reference 1.6.70), and Nuclear Management and Resources Council 93-01. These documents provide guidance for development of site/fleet-specific programs to monitor the condition of structures and structural components within the scope of the SLR rule, such that there is no loss of structure or structural component intended function.

The PBN Structures Monitoring AMP consists primarily of periodic visual inspections of plant structures and components (SCs) for evidence of deterioration or degradation, such as described in the American Concrete Institute (ACI) Standards 349.3R, ACI 201.1 R, and Structural Engineering Institute/American Society of Civil Engineers Standard (SEI/ASCE) 11.

Quantitative acceptance criteria for concrete inspections are based on ACI 349.3R.

Inspections and evaluations are performed by personnel qualified in accordance with GALL-SLR requirements using criteria derived from industry codes and standards contained in the plant CLB including but not limited to ACI 349.3R, ACI 318, SEI/ASCE 11, and the American Institute of Steel Construction (AISC) specifications, as applicable. The AMP includes preventive actions to ensure structural bolting integrity. The program also includes periodic sampling and testing of ground water and the need to assess the impact of any changes in its chemistry on below grade concrete structures.

Included in the program is: inspection of structures, including safety-related buildings and the internal structures within containment; inspection of nonsafety-related structures; inspection of structural steel elements; inspection of elastomers, which includes nonmetallic polymer materials used in seals and gaskets and equipment vibration isolation mounts; and inspection of the component supports commodity group and architectural items. In addition. anchors embedded in epoxy resin-based grout will receive an inspection for tightness (e.g .* torque check. as applicable) during inspections.

The earthen berm installed around the above ground fuel oil storage tanks (T-32A and T-328) is part of the yard structures and is intended to contain fuel oil spills and any resulting fire. This berm is the only earthen structure

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NEPB Supplemental Response to NRG RAI No. 8.2.3.34-1 a L-2021-221 Attachment 1 Page 3 of 3 within the scope of license renewal and is potentially susceptible to degradation caused by surface runoff and erosion.

Coatings minimize corrosion by limiting exposure to the environment.

However, coatings are not credited in the determination of aging effects requiring management. Coatings are not credited for license renewal but are used to indicate aging effects of the base material.

Periodic ground water level measurements and chemical analysis of ground/lake water are performed to verify the associated chemistry remains non-aggressive. The frequency of monitoring ground water chemistry (pH, chlorides, and sulfates) is once every 9 months.