L-2023-174, Subsequent License Renewal Application - Third Annual Update

From kanterella
(Redirected from L-2023-174)
Jump to navigation Jump to search
Subsequent License Renewal Application - Third Annual Update
ML23347A094
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 12/13/2023
From: Strand D
Point Beach
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-2023-174
Download: ML23347A094 (1)
v • d • e


Text

December 13, 2023 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One White Flint N mih 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 NEXTera ENERGY.

POINT BEACH L-2023-174 10 CPR 54.17 SUBSEQUENT LICENSE RENEWAL APPLICATION - THIRD ANNUAL UPDATE

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. NextEra Energy Point Beach, LLC (NEPB) Letter L-2021-224 dated November 30, 2021, Subsequent License Renewal Application - First Annual Update (ADAMS Package Accession No. ML21334A293)
3. NextEra Energy Point Beach, LLC (NEPB) Letter L-2022-177 dated November 28, 2022, Subsequent License Renewal Application - Second Annual Update (ADAMS Package Accession No. ML22332A491)
4. NextEra Energy Point Beach, LLC (NEPB) Letter L-2023-073 dated June 1, 2023, Subsequent License Renewal Application - Second Annual Update Request for Additional Information (RAI) Set 1 Response (ADAMS Package Accession No. ML23 l 53A097)

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 first annual update (Reference 2), and the second annual update (References 3 and 4). The License Renewal Rule, 10 CFR 54.2l(b), requires that each year following submittal of an LRA, and at least 3 months before scheduled completion of the NRC review, an update to the LRA must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the Updated Final Safety Analysis Repoti Supplement.

In accordance with the License Renewal Rule, NEPB has petformed the third annual review of PBN Units 1 and 2 CLB changes since SLRA submittal to dete1mine whether any sections of the SLRA were materially affected by these changes. As a result of this annual review, NEPB identified five changes to the PBN Units 1 and 2 CLB materially affecting SLRA content. A description of these changes and the corresponding affected SLRA content revisions are in Attachment 1.

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

Document Control Desk L-2023-174 Page 2 For ease of reference, the index of attached information is provided on page 3 of this letter. Attachment 2 includes associated revisions to the SLRA (Enclosure 3 Attachment 1 of Reference 1) denoted by strikethrough (deletion) and/or bold red underline (inse1iion) text. Previous SLRA revisions are denoted by bold black text. SLRA table revisions are included as excerpts from each affected table.

Should you have any questions regarding this submittal, please contact Mr. Michael Davis, Fleet Licensing Projects Manager at (319) 851-7032.

I declare under penalty of pe1jury that the foregoing is true and correct.

Executed on the 131h day of December 2023.

Sincerely, Dianne Strand General Manager Regulat01y Affairs 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-2023-17 4 Page 3 Attachments Index Attachment No.

Subject I

Current Licensing Basis (CLB) Changes Affecting the SLRA 2

Affected SLRA Content Revisions

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 CLB Changes Affecting the SLRA L-2023-174 Attachment 1 Page 1 of 2 CURRENT LICENSING BASIS (CLB) CHANGES AFFECTING THE SLRA CLB Change ENERCON SLRA Report SLRA Section Affected Affected A new zinc injection system was installed in FPLCORP0003 6-REPT-004 Section 2.3.3.14 including the Unit 1 and 2 PAB Sample Rooms. The FPLCORP00036-REPT-025 Table 2.3.3-14 system will prepare zinc acetate and inject it Section 3.3.2.1.14 into the primary sample system, through which Section 3.3, Table 3.3-1 it will flow to the volume control tank, to the charging pumps, and then into the RCS. The Section 3.3, Table 3.3.2-14 modifications add components that fall into the (and notes) scope of 10 CFR 54.4(a)(2) because of nonsafety-related SSCs that may have the potential to prevent satisfactory accomplishment of safety functions. SLR boundaiy drawings are affected.

SLRA section 2.3.3.14 (including Table 2.3.3-

14) is affected due to the addition of the Unit 1

& 2 zinc injection systems and new component type / intended function / material /

environment combinations affect Section 3.3.2.1.14, Section 3.3, Table 3.3-1, and Table 3.3.2-14 (and notes). Also, referral to Sheet 1 deleted from SLR-541F448 Sheet 1.

The Unit 1 diesel generator G-01 and G-02 FPLCORP00036-REPT-020 Section 3.3, Table 3.3.2-8 carbon steel exhaust piping drain lines were partially replaced with stainless steel piping, piping components, and bolting with heat tracing and insulation. This change adds a "diesel exhaust" internal environment for the stainless steel piping and piping components.

The new component type / material /

environment combinations affect SLRA Section 3.3, Table 3.3.2-8.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 CLB Changes Affecting the SLRA L-2023-174 Attachment 1 Page 2 of2 CLB Change A pennanent packing leakage collection system was added for the Unit 1 and Unit 2 aux feedwater motor-driven pumps (MDAFW), 1 (2)P-53. The modifications add components that fall into the scope of 10 CFR 54.4(a)(2) because of nonsafety-related SSCs that may have the potential to prevent satisfactory accomplishment of safety functions. SLR boundary drawings are affected.

SLRA section 2.3.3.7 is affected due to the addition of the Unit 1 & 2 packing leakage collection systems and new component type /

intended function / material / environment combinations affect Section 3.3, Table 3.3.2-7.

Fuel oil storage tank T-32B and associated piping were removed.

No component/material/combinations are affected because the T-32A FOST components remain in-place. SLR boundary drawings are affected.

Removal ofT-32B affects the SLRA.

PBN letter to the Staff (ML23055A292) provided notification of a change to the control rod guide tube (CRGT) guide card examination frequency for PBN Unit 2. An extension of the CRGT guide card examination frequency from 10 Effective Full Power Years (EFPY) to 20 EFPY aligns with the latest industry approved CRGT guide card evaluation methodology (WCAP-17451-P, Revision 2).

The SLRA is updated to identify the re-evaluation using WCAP-17451-P Revision 2.

ENERCON SLRA Report SLRA Section Affected Affected FPLCO RP0003 6-REPT-0 19 Section 2.3.3.7 Section 3.3, Table 3.3.2-7 FPLCORP00036-REPT-020 Section 2.4.4 FPLCORP00036-REPT-034 Section 3.5, Table 3.5.2-11 FPLCORP00036-REPT-060 notes Appendix A, Section 16.2.2.17 Appendix A, Table 16-3, Commitments 21 & 22 Appendix B, Sections B.2.3.17, B.2.3.18, and B.2.3.34 FPLCORP00036-REPT-046 AppendixB, Section B.2.3.7

Point Beach Nuclear Plant Units I and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 1 of 25 SLRA Section 2.3.3.7, page 2.3-46 is revised as follows:

2.3.3. 7 Heating Steam Description The heating steam system uses steam supplied from the house heating boilers or from a connection in the main and auxiliary steam system to heat areas of the plant.

The system supports habitability and equipment reliability by maintaining plant area temperatures within acceptable bounds. The heating steam system includes a portion of the auxiliary feedwater pump packing leakage collection system that discharges condensate to the heating system. In addition to supporting ventilation functions, the heating steam system also provides process steam for other support functions.

Boundary The SLR boundaries are reflected on the SLR boundary drawings listed below.

There are some differences between these boundaries and the boundaries identified as part of the original PBN license renewal effort. On both SLR-M-214 Sheet 1 and 2, the section of the heating steam system with the boric acid evaporator has been removed from the drawings and therefore is no longer within the boundary of subsequent license renewal. A portion of the auxiliary feedwater pump packing leakage collection system has been added to SLR-M-214 Sheet 2.

PBN Unit 1:

SLR-M-214 Sheet 2 PBN Unit 2:

None PBN Common:

SLR-M-214 Sheet 1 SLR-M-2214 System Intended Functions Safety-related functions (10 CFR 54.4(a)(1)):

None Nonsafety-related components that could affect safety-related functions (10 CFR 54.4(a)(2)):

(1) Maintain integrity of nonsafety-related components such that no interaction with safety-related components could prevent satisfactory accomplishment of a safety function.

Fire protection, EQ, PTS, ATWS, and SBO functions (10 CFR 54.4(a)(3)):

None UFSAR References None

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 2 of25 SLRA Section 2.3.3.14, page 2.3-63 is revised as follows:

5.3.2.4 Components Subject to AMR Table 2.3.3-13 lists the containment hydrogen detectors and recombiner system component types that require an AMR and their associated component intended functions.

Table 3.3.2-13 provides the results of the AMR.

Table 2.3.3-13 Containment Hydrogen Detectors and Recombiner System Components Subject to Aging Management Review Steel components adversely affected by boric acid leakage Valve body 2.3.3.14.

Plant Sampling Description Com onent Intended Functions Mechanical closure Pressure bounda Pressure boundary Pressure boundary The plant sampling systems include both the primary and secondary sampling systems. The primary sampling system provides the ability to take samples for laboratory analysis to evaluate reactor coolant and other auxiliary systems' chemistry during normal operation. In addition, this system contains isolation valves for maintaining the containment pressure boundary. The primary sampling system includes a zinc injection system used to inject a zinc acetate solution into the volume control tank, which will flow to the charging pumps, and then into the RCS. The secondary sampling system provides a means to obtain samples from various secondary plant locations for laboratory analysis.

Boundary The SLR boundaries are reflected on the SLR boundary drawings listed below. There are no significant differences bet1A1een these boundaries and the boundaries identified as part of the original PBN license renewal effort. The only significant difference between these boundaries and the boundaries identified as part of the original PBN license renewal effort is the addition of zinc injection systems on boundary drawings SLR-541 F092 Sheet 1 and SLR-541 F448.

PBN Unit 1:

SLR-541 F092 Sheet 1 SLR-M-222 Sheet 2 PBN Unit 2:

SLR-541 F448 Sheet 1 SLR-M-2222 Sheet 2

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 3 of25 SLRA Section 2.3.3.14, Table 2.3.3-14, page 2.3-65 is revised as follows:

(3) Provide pressure boundary integrity for CC (sample heat exchangers).

Nonsafety-related components that could affect safety-related functions (10 CFR 54.4(a)(2)):

(1) Maintain integrity of nonsafety-related components such that no interaction with safety-related components could prevent satisfactory accomplishment of a safety function.

Fire protection, EQ, PTS, ATWS, and SBO functions (10 CFR 54.4(a)(3)):

(1) Perform a function that demonstrates compliance with the Commission's regulations for fire protection and the EQ program.

UFSAR References 9.11 Components Subject to AMR Table 2.3.3-14 lists the plant sampling system component types that require AMR and their associated component intended functions.

Table 3.3.2-14 provides the results of the AMR.

Table 2.3.3-14 Plant Sampling System Components Subject to Aging Management Review Boltin Instrument Orifice Pi in Piping and piping components Steel components adversely affected by boric acid leaka e trainer Tank (SGBD sample sparging and chemical addition Valve o 2.3.3.15.

Plant Air Description Com onent Intended Function s Mechanical closure Leakage boundary (spatial)

Structural inte rit attached Leakage boundary (spatial)

Leakage boundary (spatial)

The plant air system for PBN Units 1 and 2 are essentially identical. On this basis, the following discussion applies to both units. This system includes instrument air (IA), service air (SA), and emergency breathing air (EBA) sub-systems. The IA and SA sub-systems supply compressed air throughout the plant. The IA sub-system supplies dry, oil-free air to various components for the normal operation of both units.

The SA sub-system supplies non-dried, oil-free air to those plant services not

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 4 of 25 SLRA Section 2.4.4, page 2.4-11 is revised to change "Tanks" to "Tank" in the first paragraph as follows:

and floors. The 0GB houses the Train 'B' Emergency Diesel Generators, including their support equipment and distribution switchgear, and the Fuel Oil Storage Tanks, and fuel oil transfer pumps that service all four Emergency Diesel Generators.

The seismic Class I part of the 0GB consists of multiple compartments on two levels. The building's basemat and foundation footings consist of reinforced concrete supported on compacted subgrade. The building's highest level, the reinforced concrete roof is at elevation 66-feet (nominal). The building's nonsafety related seismic Class Ill stairway-passageway enclosure is constructed from structural steel and metal siding.

Boundary The diesel generator building boundary includes all the structural components that comprise the diesel generator building. The differences between the current boundary and those identified as part of the original PBN license renewal are limited to joint and penetration seals conservatively included in the current boundary.

Structure Intended Functions Safety-related functions (10 CFR 54.4(a)(1)):

(1) Provide structural support and housing to safety related SSCs.

Nonsafety-related functions that could affect safety-related functions (10 CFR 54.4(a)(2)):

(1) Provide support to nonsafety-related SSCs whose failure could adversely affect safety related functions.

Fire protection, Station Blackout functions (10 CFR 54.4(a)(3)):

(1) Provide structural support and housing to SSCs relied upon in safety analyses or plant evaluations that perform a function directly supporting the site's implementation of Fire Protection regulation.

(2) Provide structural support and housing to SSCs relied upon in safety analyses or plant evaluations that perform a function directly supporting the site's implementation of the Station Blackout regulation.

UFSAR References 8.8 A.5.9 0.2 Subsequent License Renewal Drawing The subsequent license renewal drawing for the diesel generator building is LR-C-3.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 5 of25 SLRA Section 3.3.2.1.14, page 3.3-18 is revised as follows:

3.3.2.1.14 Plant Sampling Materials The materials of construction for the plant sampling system components are:

  • Glass
  • Polymeric
  • Stainless steel Environments The plant sampling system components are exposed to the following environments:
  • Air - indoor uncontrolled
  • Air with borated water leakage
  • Treated borated water
  • Treated borated water >140°F
  • Treated water
  • Treated water >140°F Aging Effects Requiring Management The following aging effects associated with the plant sampling system require management:
  • Cracking
  • Cumulative fatigue damage
  • Hardening or loss of strength
  • Loss of material
  • Loss of preload Aging Management Programs The following AMPs manage the aging effects for the plant sampling system components:
  • Bolting Integrity (B.2.3.9)
  • External Surfaces Monitoring of Mechanical Components (B.2.3.23)
  • One-Time Inspection (B.2.3.20)
  • Water Chemistry (B.2.3.2)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 6 of25 SLRA Section 3.3, Table 3.3-1, page 3.3-79 is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Aging Management Number Effect/Meehan ism Program (AMP)/TLAA 3.3-1, 249 Steel heat exchanger Loss of material due to AMP XI.M38, tubes internal to general, pitting, crevice "Inspection of Internal components exposed corrosion Surfaces in Miscellaneous to air-outdoor, Piping and Ducting air-indoor Components" uncontrolled, condensation 3.3-1, 250 Steel reactor coolant Loss of material due to AMP XI.M32, pump oil collection general, pitting, crevice "One-Time Inspection" system tanks, piping, corrosion, MIC piping components exposed to lubricating oil (waste oil) 3.3-1, 252 Aluminum piping, Loss of material due to AMP XI.M41, "Buried piping components pitting, crevice and Underground Piping and exposed to soil, corrosion Tanks" concrete 3.3-1, 253 PVC piping, piping Loss of material due to AMP XI.M20, components exposed wear; flow blockage "Open-Cycle Cooling Water to raw water, raw due to fouling (raw System," AMP XI.M27, "Fire water (potable),

water only)

Water System," or AMP treated water, waste XI.M38, water "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" Further Evaluation Discussion Recommended No Consistent with NUREG-2191.

This item is also used for piping and piping components. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25) AMP is used to manage loss of material of steel piping, piping components, piping elements, and heat exchanger components exposed to uncontrolled air.

No Not used.

The Lubricating Oil Analysis (B.2.3.26) and One-Time Inspection (B.2.3.20)

AMPs are used to manage loss of material in steel piping exposed to lubricating oil per line item 3.3-1, 097.

No Not applicable.

There are no aluminum piping or piping components exposed to soil or concrete in the Auxiliary Systems.

No Consistent with NUREG-2191.

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25) AMP is used to manage loss of material of plastic piping exposed to waste water and treated water.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 7 of 25 SLRA Section 3.3, Table 3.3-1, page 3.3-82 is revised as follows:

Table 3.3-1: Summary of Aging Management Evaluations for the Auxiliary Systems Item Component Aging Effect/Mechanism Aging Management Number Proi:tram (AMP)/TLAA 3.3-1, 263 Polymeric piping, Hardening or loss of AMP XI.M36, piping components, strength due to "External Surfaces ducting, ducting polymeric degradation; Monitoring of Mechanical components, seals loss of material due to Components," or AMP exposed to air, peeling, delamination, XI.M38, condensation, raw wear; cracking or "Inspection of Internal water, raw water blistering due to Surfaces in Miscellaneous (potable), treated exposure to ultraviolet Piping and Ducting water, waste water, light, ozone, radiation, or Components" underground, chemical attack; flow concrete, soil blockage due to fouling 3.3-1, 265 Steel heat exchanger Reduction of heat transfer XI.M30, "Fuel Oil radiator tubes due to fouling Chemistry," and XI.M32, exposed to fuel oil "One-Time Inspection" 3.3-1, 266 Steel heat exchanger Reduction of heat transfer XI.M30, "Fuel Oil radiator tubes due to fouling Chemistry,"

exposed to fuel oil Further Evaluation Discussion Recommended No Consistent with NUREG-2191. The lnsQection of Internal Surfaces in Miscellaneous PiQing and Ducting ComQonents {B.2.3.25} and External Surfaces Monitoring of Mechanical ComQonents {B.2.3.23} AMPs are used to manage hardening or loss of strength 1 loss of material 1 and cracking of QOl)lmeric QiQing and QiQing comQonents exQosed to treated water or indoor uncontrolled air. The Structures Monitoring (B.2.3.34) AMP is credited with managing blistering, cracking, hardening, loss of material, and loss of strength of polymer manhole cover components exposed to air - outdoor in the yard, instead of the External Surfaces Monitoring of Mechanical Components (B.2.3.23).

No Not applicable.

There are no steel heat exchanger radiator tubes exposed to fuel oil in the Auxiliary Systems.

No Not applicable.

There are no steel heat exchanger radiator tubes exposed to fuel oil in the Auxiliary Systems.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 8 of 25 SLRA Section 3.3, Table 3.3.2-7, page 3.3-192 is revised as follows:

Table 3.3.2-7: Heating Steam System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Type Function Requiring Management Piping Leakage boundary Carbon Steam (int)

Wall thinning -

(spatial) steel erosion Piping Leakage boundary Carbon Steam (int)

Wall thinning -

(spatial) steel FAC Piping Leakage boundary Carbon Treated water Loss of material (spatial) steel (int)

Piping Leakage boundary Carbon Treated water Wall thinning -

(spatial) steel (int) erosion Piping Leakage boundary Carbon Treated water Wall thinning -

(spatial) steel (int)

FAC Piping Leakage Stainless Air-indoor Cracking boundary steel uncontrolled

{spatial}

{ext}

Piping Leakage Stainless Air-indoor Loss of boundary steel uncontrolled material

{spatial}

{ext}

Piping Leakage Stainless Treated water Loss of boundary steel

{int}

material

{spatial}

Piping Leakage boundary Carbon Air-indoor Loss of material (insulated)

(spatial) steel uncontrolled ( ext)

Piping and Leakage boundary Carbon Steam (int)

Cumulative piping (spatial) steel fatigue damage components Pump casing Leakage boundary Gray cast Air-indoor Loss of material (spatial) iron uncontrolled ( ext)

Pump casing Leakage Gray cast Treated water Loss of material boundary (spatial) iron (int)

Aging Management NUREG-2191 Table 1 Notes Program Item Item Flow-Accelerated Corrosion VIII.B1.S-408 3.4-1, 060 A

(B.2.3.8)

Flow-Accelerated Corrosion VIII.B1.S-15 3.4-1, 005 A

(B.2.3.8)

Water Chemistry (B.2.3.2)

VIII.D1.SP-74 3.4-1, 014 B

One-Time Inspection A

(B.2.3.20)

Flow-Accelerated Corrosion VIII.D1.S-408 3.4-1, 060 A

(B.2.3.8)

Flow-Accelerated Corrosion VIII.E.S-16 3.4-1, 005 A

(B.2.3.8)

External Surfaces VIII.G.SP-3.4-11 002 A

Monitoring of Mechanical 118b Components {B.2.3.23}

External Surfaces VIII.G.SP-3.4-11 003 A

Monitoring of Mechanical 127b Components {B.2.3.23}

Water Chemistry {8.2.3.2}

VIII.G.SP-87 3.4-11 085

~

One-Time Inspection A

{B.2.3.20}

External Surfaces Monitoring VII.I.A-405a 3.3-1, 132 A

of Mechanical Components (B.2.3.23)

TLAA-VII.E1.A-34 3.3-1, 002 A

Section 4.3.3, Metal Fatigue of Non-Class 1 Components External Surfaces Monitoring Vll.1.A-77 3.3-1, 078 A

of Mechanical Components (B.2.3.23)

Selective Leaching (B.2.3.21 )

VIII.A.SP-27 3.4-1, 033 A

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 9 of 25 SLRA Section 3.3, Table 3.3.2-8, pages 3.3-216 through 3.3-217, are revised as follows:

Table 3.3.2-8: Emergency Power System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management Program Type Function Requiring Management Piping Pressure Copper alloy Fuel oil (int)

Loss of material Fuel Oil Chemistry (B.2.3.18) boundary One Time Inspection (B.2.3.20)

Piping Pressure Copper alloy Lubricating oil (int)

Loss of material Lubricating Oil Analysis boundary (B.2.3.26) One-Time Inspection (B.2.3.20)

Piping Pressure Stainless Air-indoor Cracking Inspection of Internal boundary steel uncontrolled (int)

Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25)

Piping Pressure Stainless Air-indoor Loss of Inspection of Internal boundary steel uncontrolled material Surfaces in (int)

Miscellaneous Piping and Ducting Components (B.2.3.25)

Piping Pressure Stainless Air - dry (int)

Loss of material Compressed Air Monitoring boundary steel (B.2.3.14)

Piping Pressure Stainless Air-indoor Cracking External Surfaces Monitoring of boundary steel uncontrolled ( ext)

Mechanical Components (B.2.3.23)

Piping Pressure Stainless Air - indoor Loss of material External Surfaces Monitoring of boundary steel uncontrolled ( ext)

Mechanical Components (B.2.3.23)

Piping Pressure Stainless Diesel exhaust Cracking Inspection of Internal bounda~

steel (int)

Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25)

Piping Pressure Stainless Diesel exhaust Loss of Inspection of Internal bounda~

steel (int) material Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25)

NUREG-2191 Table 1 Notes Item Item VI I. H 1.AP-132 3.3-1, 069 8

A VII.H2.AP-133 3.3-1, 099 A

VII.H2.AP-209c 3.3-1, 004 A

VII.H1.AP-221c 3.3-1, 006 A

VII.D.A-764 3.3-1, 235 A

VII.H1.AP-209b 3.3-1, 004 A

VII.H1.AP-221 b 3.3-1, 006 A

VII.H2.AP-128 3.3-11 083 A

VII.H2.AP-104 3.3-11 088 A

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 10 of25 Table 3.3.2-8: Emergency Power System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management Program Type Function Requiring Management Piping Pressure Stainless Lubricating oil Loss of material Lubricating Oil Analysis (B.2.3.26) boundary steel (int)

One-Time Inspection (B.2.3.20)

Piping Pressure Stainless Air-indoor Cracking External Surfaces Monitoring of

{insulated}

boundarv steel uncontrolled {ext}

Mechanical Components

{B.2.3.23}

Piping Pressure Stainless Air-indoor Loss of material External Surfaces Monitoring of

{insulated}

boundart steel uncontrolled {ext}

Mechanical Components

{B.2.3.23}

Piping and Pressure Carbon steel Diesel exhaust Cumulative TLAA-Section 4.3.3, Metal Fatigue piping boundary (int)

Fatigue Damage of Non-Class 1 Components components Piping and Structural Carbon steel Air-indoor Loss of material External Surfaces Monitoring of piping integrity uncontrolled (ext)

Mechanical Components (B.2.3.23) components (attached)

Piping and Structural Carbon steel Treated water Loss of material Closed Treated Water Systems piping integrity (int)

(B.2.3.12) components (attached)

Piping and Pressure Stainless Diesel exhaust Cumulative TLAA - Section 4.3.32 Metal lllP.i.n.9.

boundart steel

{int}

Fatigue Damage Fatigue of Non-Class 1 components Components Pump casing Pressure Carbon steel Air-indoor Loss of material External Surfaces Monitoring of boundary uncontrolled ( ext)

Mechanical Components (B.2.3.23)

Pump casing Pressure Carbon steel Fuel oil (int)

Loss of material Fuel Oil Chemistry (B.2.3.18) boundary One Time Inspection (B.2.3.20)

Pump casing Pressure Carbon steel Lubricating oil Loss of material Lubricating Oil Analysis (B.2.3.26) boundary (int)

One-Time Inspection (B.2.3.20)

Pump casing Pressure Carbon steel Treated water Loss of material Closed Treated Water Systems boundary (int)

(B.2.3.12)

NUREG-2191 Table 1 Notes Item Item VII.H2.AP-138 3.3-1, 100 A VII.I.A-734c 3.3-12 205 A Vll.I.A-761 c 3.3-12 232 A VII.E1.A-34 3.3-1, 002 A VII.I.A-77 3.3-1, 078 A VII.F1.AP-202 3.3-1, 045 B

VII.E1.A-57 3.3-12 002 A VII.I.A-77 3.3-1, 078 A VII.H1.AP-105 3.3-1, 070 B

A VII.H2.AP-127 3.3-1, 097 A

VII.F1.AP-202 3.3-1, 045 B

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 11 of25 SLRA Section 3.3, Table 3.3.2-14, page 3.3-269 is revised as follows:

Table 3.3.2-14: Plant Sampling - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Type Function Requiring Management Instrument Leakage Stainless Treated borated Loss of material boundary steel water (int)

(spatial)

Instrument Leakage Stainless Treated water Loss of material boundary steel (int)

(spatial)

Orifice Leakage Stainless Air-indoor Cracking boundary steel uncontrolled (spatial)

(ext)

Orifice Leakage Stainless Air-indoor Loss of material boundary steel uncontrolled (spatial)

(ext)

Orifice Leakage Stainless Treated Loss of material boundary steel borated water (spatial)

(int)

Piping Leakage Pol:i£meric Air-indoor Hardening or loss boundarv uncontrolled of strength

{spatial}

{ext}

Loss of material Cracking Piping Leakage Pol:i£meric Treated water Hardening or loss boundarv

{int}

of strength

{spatial}

Loss of material Cracking Piping Leakage Stainless Air-indoor Cracking boundary steel uncontrolled (spatial)

(ext)

Piping Leakage Stainless Air-indoor Loss of material boundary steel uncontrolled (spatial)

(ext)

Aging Management Program NUREG-2191 Table 1 Notes Item Item Water Chemistry (B.2.3.2)

VII.E1.AP-79 3.3-1, 125 B

One-Time Inspection (B.2.3.20)

A Water Chemistry (B.2.3.2)

VIII.B1.SP-87 3.4-1, 085 B

One-Time Inspection (B.2.3.20)

A External Surfaces Monitoring VII.E1.AP-209b 3.3-1, 004 A

of Mechanical Components (B.2.3.23)

External Surfaces Monitoring VII.E1.AP-221b 3.3-1, 006 A

of Mechanical Components (B.2.3.23)

Water Chemistry (B.2.3.2)

VII.E1.AP-79 3.3-1, 125 B

One-Time Inspection (B.2.3.20)

A External Surfaces VII.I.A-797a 3.3-1, 263

~

Monitoring of Mechanical Components {B.2.3.23}

Inspection of Internal VII.E5.A-797b 3.3-1, 263

~

Surfaces in Miscellaneous Piping and Ducting Components {B.2.3.25}

External Surfaces VII.E1.AP-209b 3.3-1, A

Monitoring of Mechanical 004 Components (B.2.3.23)

External Surfaces VI I. E 1.AP-221 b 3.3-1,

A Monitoring of Mechanical 006 Components (B.2.3.23)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 12 of 25 SLRA Section 3.3, Table 3.3.2-14, page 3.3-271 is revised as follows:

Table 3.3.2-14: Plant Sampling - Summary of Agin! Management Evaluation Component Type Intended Material Environment Aging Effect Function Requiring Management Piping and piping Structural Stainless Treated borated Cracking components integrity (attached) steel water> 140°F (int)

Piping and piping Structural integrity Stainless Treated water Loss of components (attached) steel (int) material Piping and piping Structural integrity Stainless Treated water Cracking components (attached) steel

> 140°F (int)

Piping and piping Structural integrity Stainless Air-indoor Cracking components (attached) steel uncontrolled ( ext)

(insulated)

Piping and piping Structural integrity Stainless Air-indoor Loss of components (attached) steel uncontrolled (ext) material (insulated)

PumQ casing Leakage PVC Air-indoor None bounda!Y uncontrolled (sQatial}

(ext}

PumQ casing Leakage PVC Treated water Loss of bounda!Y (int}

material (sQatial}

Steel components Leakage boundary Carbon steel Air with borated Loss of (spatial) water leakaqe material Strainer Leakage boundary Stainless Air-indoor Cracking (spatial) steel uncontrolled (ext)

Strainer Leakage boundary Stainless Air-indoor Loss of (spatial) steel uncontrolled ( ext) material Strainer Leakage boundary Stainless Treated water Loss of (spatial) steel (int) material Aging Management Program NUREG-2191 Table 1 Item Notes Item Water Chemistry (B.2.3.2)

VII.E1.A-103 3.3-1, 124 B

One-Time Inspection A

(B.2.3.20)

Water Chemistry (B.2.3.2)

VIII.B1.SP-87 3.4-1, 085 B

One-Time Inspection A

(B.2.3.20)

Water Chemistry (B.2.3.2)

VIII.B1.SP-88 3.4-1, 011 B

One-Time Inspection A

(B.2.3.20)

External Surfaces Monitoring VI I. I.A-734c 3.3-1, 205 A

of Mechanical Components (B.2.3.23)

External Surfaces Monitoring VII.I.A-761c 3.3-1, 232 A

of Mechanical Components (B.2.3.23)

None VII.J.AP-268 3.3-1, 119

~

lnsQection of Internal VII.G.A-787b 3.3-1, 253 Ll Surfaces in Miscellaneous PiQing and Ducting ComQonents (B.2.3.25}

Boric Acid Corrosion (B.2.3.4) VII.I.A-79 3.3-1, 009 A

External Surfaces Monitoring VII.E1.AP-209b 3.3-1,

A of Mechanical Components 004 (B.2.3.23)

External Surfaces Monitoring VII.E1.AP-221b 3.3-1, 006 A

of Mechanical Components (B.2.3.23)

Water Chemistry (B.2.3.2)

VIII.B1.SP-87 3.4-1, 085 B

One-Time Inspection A

(B.2.3.20)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 13 of 25 SLRA Section 3.3, Table 3.3.2-14, page 3.3-272 is revised as follows:

Table 3.3.2-14: Plant Sampling - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Function Requiring Management Tank (SGBD Leakage Stainless Air-indoor Cracking sample sparging boundary steel uncontrolled (ext) and chemical (spatial) addition)

Tank (SGBD Leakage Stainless Air-indoor Loss of material sample sparging boundary steel uncontrolled (ext) and chemical (spatial) addition)

Tank (SGBD Leakage Stainless Treated water Loss of material sample sparging boundary steel (int) and chemical (spatial) addition)

Valve bod)£ Leakage PVC Air-indoor None boundarv uncontrolled (s~atial)

(ext}

Valve bod)£ Leakage PVC Treated water Loss of material bounda!:)l (int)

(s~atial)

Valve body Leakage Stainless Air-indoor Cracking boundary steel uncontrolled ( ext)

(spatial)

Valve body Leakage Stainless Air-indoor Loss of material boundary steel uncontrolled ( ext)

(spatial)

Aging Management NUREG-2191 Table 1 Notes Program Item Item External Surfaces VII.E1.AP-209b 3.3-1, 004 A

Monitoring of Mechanical Components (B.2.3.23)

External Surfaces Vll.1.A-751c 3.3-1, 222 A

Monitoring of Mechanical Components (B.2.3.23)

Water Chemistry VIII.E.SP-162 3.4-1, 083 B

(B.2.3.2)

A One-Time Inspection (B.2.3.20)

None VII.J.AP-268 3.3-11 119 A lns~ection of VII.G.A-787b 3.3-11 253 Ll Internal Surfaces in Miscellaneous Pi~ing and Ducting Com~onents (B.2.3.25)

External Surfaces VII.E1.AP-209b 3.3-1, 004 A

Monitoring of Mechanical Components (B.2.3.23)

External Surfaces VII.E1.AP-221b 3.3-1, 006 A

Monitoring of Mechanical Components (B.2.3.23)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 14 of25 SLRA Section 3.3, Table 3.3.2-14 notes, page 3.3-273 is revised as follows:

Generic Notes A

Consistent with component, material, environment, aging effect and aging management program listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

B.

Consistent with component, material, environment, aging effect and aging management program listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

E.

Consistent with NUREG-2191 material, environment, and aging effect but a different AMP is credited or NUREG-2191 identifies a plant-specific AMP.

Plant Specific Notes NeRe 1.,_

The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25) AMP is used to manage loss of material for the interior surfaces of PVC components exposed to treated water.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 15 of 25 SLRA Section 3.5, Table 3.5.2-11 note 4, page 3.5-131 is revised as follows (Note: "tanks" changed to "tank" in Note 4):

Table 3.5.2-11: Yard Structures - Summary of Aging Management Evaluation Component Type Intended Material Environment Aging Effect Aging NUREG-2191 Function Requiring Managemen Item Management t Program Structural bolting Structural support Steel Air - outdoor Loss of material Structures III.A3.TP-274 Monitoring (B.2.3.34J Generic Notes able 1 Item 3.5-1, 082 A.

Consistent with component, material, environment, aging effect and aging management program listed for NUREG-2191 line item.

AMP is consistent with NUREG-2191 AMP description.

C.

Component is different, but consistent with material, environment, aging effect and aging management program listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

E.

Consistent with NUREG-2191 material, environment, and aging effect but a different aging management progrpim is credited or NUREG-2191 identifies a plant-specific aging management program.

Plant Specific Notes

1.

Groundwater is considered to be water-flowing.

2.

Rainfall tends to wash surfaces. However, times of significant precipitation or areas of water collection/flowing such as ground/wall interfaces are conservatively susceptible to leaching.

3.

Consistent with the currently renewed licenses, concrete block manholes are underground and exposed to soil.

4.

Berm surrounding the fuel oil storage tanks provides a fire barrier.

5.

Whereas the NUREG-2191/2192 item calls for a plant-specific AMP, PBN credits an existing AMP consistent with SLR-ISG-Structures-2020-XX, "Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance".

6.

Fire Protection AMP, in conjunction with the Masonry Walls AMP is focused on certain fire barriers in the yard recognizing that other barriers in the yard have additional functions that are managed by the Masonry Walls AMP.

7.

Polystyrene (polymer) inserts in yard manhole covers that have ports allowing for inspection may be susceptible to degradation though exposure to heat or sunlight is limited and are inspected by the Structures Monitoring AMP.

Notes A

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 16 of25 SLRA Appendix A, Section 16.2.2.17, page A-24 is revised as follows:

provide reasonable assurance that the fire water systems are capable of performing their intended function. Inspections and testing are performed in accordance with the nuclear insurance carrier's fire protection system testing requirements and generally follows the guidance of applicable NFPA Codes and Standards.

The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions are initiated. Piping wall thickness measurements are conducted when visual inspections detect surface irregularities indicative of unexpected levels of degradation. When the presence of sufficient organic or inorganic material sufficient to obstruct piping or sprinklers is detected, the material is removed, the source of the material is identified, and the source is corrected.

Inspections and tests follow site procedures that include inspection parameters for items such as lighting, distance, offset, presence of protective coatings, and cleaning processes for an adequate examination. This AMP manages carbon steel, components exposed to Lake Michigan raw water in which potential recurring internal corrosion may become evident based on a search of site-specific OE.

16.2.2.17. Outdoor and Large Atmospheric Metallic Storage Tanks The PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP is an existing AMP, previously known as the Tank Internal Inspection Program. This condition monitoring AMP manages aging effects associated with outdoor tanks sited on concrete and indoor large-volume tanks containing water designed with internal pressures approximating atmospheric pressure that are sited on concrete. The tanks included within the scope of this AMP are as follows:

1T-013, Refueling Water Storage Tank (RWST) 2T-013, Refueling Water Storage Tank (RWST)

T-021, Reactor Makeup Water Tank (RMWf)

T-032A, Fuel Oil Storage Tank (FOST)

T 032B, Fuel Oil Storage Tank (FOST)

This AMP includes preventive measures to mitigate corrosion by protecting the external surfaces of steel components per standard industry practice. This AMP manages loss of material and cracking by conducting periodic internal and external visual and surface examinations. Surface exams are conducted to detect cracking when susceptible materials are used. Thickness measurements of tank bottoms are conducted to detect degradation. The external surfaces of insulated tanks are periodically inspected using a sampling of inspection points. Inspections are conducted in accordance with ASME Code Section XI requirements as applicable or are conducted in accordance with plant-specific procedures that include inspection parameters such as lighting, distance, offset, and surface conditions.

16.2.2.18. Fuel Oil Chemistry The PBN Fuel Oil Chemistry AMP is an existing AMP, previously known as the Fuel Oil Chemistry Control Program, that manages loss of material in tanks, components, and piping exposed to an environment of diesel fuel oil. This AMP includes (a) surveillance and maintenance procedures to mitigate corrosion, and periodic and/or conditional visual inspections of internal surfaces and/or wall thickness

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 17 of 25 SLRA Appendix A, Table 16-3, Commitment 21, page A-79 is revised as follows:

No.

Aging NUREG-2191 Commitment Management Section Program or Activity (Section) 21 Outdoor and Large XI.M29 Continue the existing PBN Outdoor and Large Atmospheric Metallic Storage Atmospheric Tanks AMP, including enhancement to:

Metallic Storage a)

Ensure that caulking or sealant is applied to the concrete-to-tank interface Tanks (16.2.2.17) for the FOSTs, T-032A and T 032B, prior to the SPEO.

b)

Create a new procedure, and/or associated preventive maintenance requirements (PMRQs), to:

Address the interfaces, handoffs, and overlaps between the PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP and the following AMPs:

0 PBN Structures Monitoring AMP; 0

PBN External Surfaces Monitoring of Mechanical Components AMP; 0

PBN Water Chemistry AMP; 0

PBN Fuel Oil Chemistry AMP; Implementation Schedule No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO i.e.:

PBN1: 04/05/2030 PBN2: 09/08/2032 Implement the AMP and start the one-time and 10-year interval inspections no earlier than 10 years prior to the SPEO.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 18 of25 SLRA Appendix A, Table 16-3, Commitment 21, page A-81 is revised as follows:

No.

Aging NUREG-2191 Commitment Management Section Program or Activity (Section)

  • Clarify that where practical, identified degradation is projected until the next scheduled inspection.
  • Clarify that results are evaluated against acceptance criteria to confirm or adjust timing of subsequent inspections.
  • State the acceptance criteria as follows:

0 No degradation of paints or coatings (e.g., cracking, flakes, or peeling), or insulation/jacketing, or the RMWT internal diaphragm.

0 No non-pliable, cracked, or missing caulking/sealant for the FOST-concrete interface.

0 No indications of cracking of an RWST.

0 No tank bottom thickness measurements or thickness projections less than the design thickness and/or no exceedance of the corrosion allowance.

  • State the appropriate corrective actions to perform for when degradation (e.g., sealant/caulking flaws, paint/coating flaws, loss of material, cracking, etc.) is identified, which include the following:

0 Report degradation via a condition report (CR) then perform an engineering evaluation.

0 Repair or replace the degraded component as determined by engineering evaluation and perform follow-up examinations.

0 Expand the inspection to include both tanks (for FOST or RWSTs for degradation1.

0 Double the sample size (for RWST surface examination degradation).

0 Sample expansion inspections that happen in the next insoection interval are oart of the orecedinq interval.

Implementation Schedule

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 19 of 25 SLRA Appendix A, Table 16-3, Commitment 22, page A-83 is revised as follows:

No.

Aging NUREG-2191 Commitment Management Section Program or Activity (Section)

T-031 B, G-02 Diesel Generator Day Tank T-032A, Fuel Oil Storage Tank T 0328, Fuel Oil Storage Tank T-072, Emergency Fuel Oil Storage Tank (buried)

T-176A, G-03 EOG Fuel Oil Day Tank T-176B, G-04 EOG Fuel Oil Day Tank T-504, Gas Turbine Generator Starting Diesel Engine Fuel Oil Tank T-505, G-501 Gas Turbine Generator Auxiliary Power Diesel Engine Fuel Oil Tank EDG G-01 and G-02 Skid/Sump (Base)-Mounted Tanks (no equipment tag/ID) f)

Drain and clean the G-01 and G-02 EOG skid tanks to the best extent practical. Perform visual inspection of accessible locations of the skid tank internals and volumetric (UT) inspection of accessible portions of the skid tank as close to the bottom of the skid tank as possible. This draining, cleaning, and surveillance shall occur at least once during the 10-year period prior to the SPEO and repeat at least once every 10 years.

g) Project all identified tank degradation through the next scheduled inspection, where practical.

h) Evaluate tank inspection results against acceptance criteria to confirm that the timing of subsequent inspections will maintain the components' intended functions throughout the SPEO based on the projected rate of degradation.

i)

Report and evaluate all degradation using the corrective action program.

Thickness measurements of the tank bottom are evaluated against the design thickness and corrosion allowance.

j)

Perform corrective actions to prevent recurrence when the specified limits for fuel oil standards are exceeded or when water is drained during periodic surveillance.

Implementation Schedule

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 20 of25 SLRA Appendix 8, Section 8.2.3.7, page 8-76, is revised as follows:

Plant Specific Operating Experience PBN has inspected 100 percent of CRGT guide cards on both units as a part of its baseline inspections. The results of these inspections were evaluated based on the methodology described in WCAP17451 Revision 1 and reinspection or repair of one limiting guide tube within each tube was recommended for the 2020 refueling outages. The publishing of WCAP-17451 Revision 2 prompted a re-evaluation to extend the reinspection interval of the limiting guide tube to align with the reinspection timing of the other guide tubes. Re-evaluation was performed using both methods (WCAP-17451-P Revision 1 and Revision 2) (References ML22053A149 and ML23055A292). Additionally, PBN has spare CRGTs to support any repair activities if needed.

PBN Units 1 and 2 have completed all MRP-227-A initial license renewal required inspections with no inspection deferrals and no deviations to NEI 03-08. All baseline inspections completed were performed prior to loss of safety function which demonstrates that the inspection timing defined in MRP-227-A has been adequate and the PBN Water Chemistry AMP (Section 8.2.3.2) has sufficiently prevented or mitigated accelerated aging effects. All degradation identified has been consistent with industry experience resulting in acceptable results for all inspections. There has not been an examination which required Expansion Components inspections.

Program Assessments and Evaluations o

Phase 2 Point Beach Nuclear Plant, Unit 1 and Unit 2 NRC Post Approval Site Inspection Reports for License Renewal (ADAMS Accession no.

ML102850469 and ML13077A472)

In 2010 and 2013, the NRC performed the 71003 Phase 2 Inspections at PBN Units 1 and 2, respectively. The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for the PBN Reactor Vessel Internals AMP. The inspectors verified that the program meets current industry guidance and tracking is in place for incorporating any changes resulting from NRC review of the industry guidance. Based on review of the timeliness and adequacy of PBN's actions, the inspectors determined that the PBN had met all commitments.

o Level 1 License Renewal Aging Management Program Effectiveness Re-view In 2018, an effectiveness review of the PBN Reactor Vessel Internals AMP was performed following the guidelines provided in NEI 14-12. The effectiveness review covered the applicable ten program elements. There were no gaps identified and the effectiveness review found the PBN Reactor Vessel Internals AMP continued to be effectively implemented.

AMP effectiveness reviews are performed at least every five years.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 21 of25 SLRA Appendix B, Section B.2.3.17, page B-134 is revised as follows:

B.2.3.17 Outdoor and Large Atmospheric Metallic Storage Tanks Program Description Program Description The PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP is an existing AMP that consolidates and coordinates existing activities for subject tanks that are associated with the following AMPs credited for the original renewed licenses:

Tank Internal Inspection Program Structures Monitoring Program Systems Monitoring Program Water Chemistry Control Program Fuel Oil Chemistry Control Program One-Time Inspection Program This AMP manages aging effects associated with outdoor tanks sited on concrete and indoor large-volume tanks (100,000 gallons or greater) containing water designed with internal pressures approximating atmospheric pressure that are sited on concrete. The tanks included within the scope of this AMP are as follows:

1T-013, Refueling Water Storage Tank (RWST) 2T-013, Refueling Water Storage Tank (RWST)

T-021, Reactor Makeup Water Tank (RMWT)

T-032A, Fuel Oil Storage Tank (FOST)

T 032B, Fuel Oil Storage Tank (FOST)

This AMP manages loss of material and cracking by conducting periodic internal and external visual and surface examinations. Surface exams are conducted to detect cracking when susceptible materials are used. Thickness measurements of tank bottoms are conducted to detect degradation and ensure corrosion from the inaccessible undersides will not cause a loss of intended tank function.

The external surfaces of insulated tanks will be periodically inspected using a sampling of inspection points. Inspections will be conducted in accordance with ASME Code Section XI requirements as applicable or are conducted in accordance with plant-specific procedures that include inspection parameters such as lighting, distance, offset, and surface conditions. Both the carbon steel and the stainless steel tanks will have external visual inspections performed every refueling outage.

The tank bottom thickness measurements will be performed at a 10-year frequency.

Where practical, identified degradation will be projected until the next scheduled inspection. Results will be evaluated against acceptance criteria to confirm that the timing of subsequent inspections will maintain the component intended functions throughout the SPEO based on the projected rate of degradation. Applicable operating experience or inspection results may also be used to justify performing the periodic inspections more frequently.

The acceptance criteria for the internal visual inspection and bottom thickness of the tanks are the design corrosion allowance for the tank. Thus, any loss of material

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 22 of25 SLRA Appendix B, Section B.2.3.18, page 8-135 is revised as follows:

2.
3.
4.
5.
6.
7.

intended functions of the tanks are maintained under all CLB design conditions.

Results will be evaluated against acceptance criteria for the in scope tanks to confirm that the timing of the subsequent inspections will maintain the component intended functions throughout the SPEO based on the projected rate of degradation.

Acceptance criteria for the tank to concrete interface inspection are to confirm there are no signs of degradation (minimal corrosion) or water intrusion. Any degradation of paints, coatings, or tank diaphragms or evidence of corrosion is reported and further evaluation is required to determine if repair or replacement of the paints, coatings, or tank diaphragms should be conducted. Any deficiencies are documented, evaluated, and repaired as necessary.

Additional inspections will be conducted if one of the inspections does not meet acceptance criteria due to current or projected degradation (i.e., trending). The number of increased inspections is determined in accordance with the PBN corrective action program; however, for inspections where only one in-scope tank of a material and environment combination is inspected, all tanks in that grouping will be inspected, including tanks from both units.

NU REG-2191 Consistency The PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP, with enhancements, will be consistent with the 10 elements of NUREG-2191,Section XI.M29, "Outdoor and Large Atmospheric Metallic Tanks."

Exceptions to NUREG-2191 None Enhancements The PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP will be enhanced as follows, for alignment with NUREG-2191. This AMP is to be implemented and its inspections and tests begin no earlier than 10 years prior to the SPEO. The inspections and tests are to be completed no later than six months prior to entering the SPEO or no later than the last refueling outage prior to the SPEO.

Element Affected Enhancement Preventive Actions Ensure that caulking or sealant is applied to the concrete-to-tank interface for the FOSTs, T-032A aAEI + QJ2B, prior to the SPEO.

Parameters Create a new procedure, and/or associated preventive maintenance Monitored or requirements (PMRQs), to:

Inspected; Address the interfaces, handoffs, and overlaps between the Detection of Aging PBN Outdoor and Large Atmospheric Metallic Storage Tanks Effects AMP and the following AMPs:

Monitoring and 0

PBN Structures Monitoring AMP; 0

PBN External Surfaces Monitoring of Mechanical Trending; Components AMP; Acceptance Criteria 0

PBN Water Chemistry AMP; Corrective Actions 0

PBN Fuel Oil Chemistry AMP; 0

PBN One-Time Inspection AMP;

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 23 of 25 SLRA Appendix B, Section B.2.3.18, page B-137 is revised as follows:

4.

Element Affected Enhancement loss of material, cracking, etc.) is identified, which include the following:

a.

Report degradation via a condition report (CR) then perform an engineering evaluation.

b.

Repair or replace the degraded component as determined by engineering evaluation and perform follow-up examinations.

C.

Expand the inspection to include both tanks (for FOST or RWSTs for degradation1.

d.

Double the sample size (for RWST surface examination degradation).

Sample expansion inspections that happen in the next inspection interval are part of the preceding interval.

Detection of Aging Perform baseline LFET tank bottom thickness examinations of an Effects RWST and the RMWT, with follow-on UT at discrete locations, and a baseline sample surface examination of an RWST tank exterior (with insulation temporarily removed).

Operating Experience Industry Operating Experience There have been instances within the nuclear industry that have involved tank defects such as wall thinning, cracks, pinhole leaks, through-wall flaws, as well as internal blistering, coating delamination, rust stains, and holiday which are frequently identified on tank bottoms. This industry operating experience (OE) provided clear examples to check for with respect to the site-specific OE review. With respect to these issues, PBN has experienced some coating/paint delamination and some rusting/corrosion on the subject tanks, but none that threatened the function of the tanks.

Plant Specific Operating Experience A recent operating experience search was performed for SLR which covered a date range of January 1, 2011 through January 1, 2020. This search was supplemented using the NextEra NAMS system to identify action requests (ARs) linked to tank 1T-013, 2T-013, T-021, T-032A, and T-0328, which also included ARs prior to 2011.

This search identified several ARs related to the in-scope tanks:

RWSTs, 1T-013 and 2T-013:

o In April 2007, while removing a heat exchanger, a load shift occurred that caused the bridge trolley to slide on the bridge beam to the north trolley stops. This caused the heat exchanger to swing and strike the insulation on the RWST. As part of the immediate corrective actions, the insulation was removed and the affected area of the RWST was inspected. The damage was only to the aluminum insulation cover of the RWST. The tank itself showed no evidence of being struck. The insulation was subsequently repaired and reinstalled.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 24 of25 SLRA Appendix 8, Section 8.2.3.18, page 8-141 is revised as follows:

8.2.3.18 Fuel Oil Chemistry Program Description The PBN Fuel Oil Chemistry AMP is an existing AMP, previously known as the Fuel Oil Chemistry Control Program, that manages loss of material in tanks, components, and piping exposed to an environment of diesel fuel oil by verifying the quality of fuel oil and controlling fuel oil contamination as well as periodic draining, cleaning, and inspection of tanks. This AMP includes surveillance and maintenance procedures to mitigate corrosion of components exposed to a fuel oil environment.

This objective is accomplished by offload sampling and testing of new fuel oil and periodic sampling and chemical analysis of the stored fuel oil. The AMP will also perform periodic draining, cleaning, internal visual inspections, and bottom thickness measurements (via ultrasonic testing) of all in-scope fuel oil tanks, except for the underground fuel tanks (T-175A and T-175B), which will only be drained and inspected if deemed necessary based on the results of fuel oil sample analysis or as recommended by the system engineer.

The PBN Fuel Oil Chemistry AMP includes (a) surveillance and maintenance procedures to mitigate corrosion and (b) measures to verify the effectiveness of the mitigative actions and confirm the insignificance of an aging effect. Fuel oil quality is maintained by monitoring and controlling fuel oil contamination in accordance with the PBN Technical Specifications and Technical Requirements Manual. Guidelines of the American Society for Testing and Materials (ASTM) Standards are also used.

Exposure to fuel oil contaminants, such as water and microbiological organisms, is minimized by periodic draining and/or cleaning of tanks and by verifying the quality of new fuel oil before its introduction into the storage tanks. However, corrosion may occur at locations in which contaminants may accumulate, such as tank bottoms.

Accordingly, the effectiveness of the fuel oil chemistry controls is verified to provide reasonable assurance that significant degradation is not occurring. The PBN One-Time Inspection AMP (Section B.2.3.20), the PBN Buried and Underground Piping and Tanks AMP (Section B.2.3.27), the PBN Outdoor and Large Atmospheric Metallic Storage Tanks AMP (Section B.2.3.17), and the PBN Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP (Section B.2.3.25) are also used to verify the effectiveness and supplement this AMP.

Components within the scope of the PBN Fuel Oil Chemistry AMP are the diesel fuel oil storage tanks, piping, and other metal components subject to aging management review that are exposed to an environment of diesel fuel oil. The primary tanks within the scope of this AMP are listed below:

T-030, P-35B Diesel Driven Fire Pump Fuel Oil Day Tank T-031A, G-01 Diesel Generator Day Tank T-031 B, G-02 Diesel Generator Day Tank T-032A, Fuel Oil Storage Tank T 0328, Fuel Oil Storage Tank T-072, Emergency Fuel Oil Storage Tank (buried)

T-175A, G-01 and G-02 EOG Fuel Oil Storage Tank (underground/within

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2023-174 Attachment 2 Page 25 of25 SLRA Appendix B, Section B.2.3.34, page B-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--a-R1

~) 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 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

Retrieved from "https://kanterella.com/w/index.php?title=L-2023-174,_Subsequent_License_Renewal_Application_-_Third_Annual_Update&oldid=3765157"