ML21208A447

Subsequent License Renewal Application Aging Management Audit Report

ML21208A447
Person / Time
Site:	Point Beach
Issue date:	08/16/2021
From:	Bill Rogers NRC/NRR/DNRL/NLRP
To:	Coffey B Florida Power & Light Co
Rogers B
References
EPID L-2020-SLR-0002
Download: ML21208A447 (145)

Text

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August 16, 2021 Bob Coffey Executive Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company 700 Universe Blvd.

Mail Stop: EX/JB Juno Beach, FL 33408

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2020-SLR-0002)

Dear Mr. Coffey:

By letter dated November 16, 2020 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML20329A292), NextEra Energy Point Beach, LLC (NextEra) submitted an application for subsequent license renewal of Renewed Facility Operating License Nos. DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach), to the U.S. Nuclear Regulatory Commission (NRC). NextEra submitted the application pursuant to Title 10 of the Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.

The NRC staff completed its aging management audit from January 19, 2021 - March 26, 2021, in accordance with the in-office regulatory audit plan (ADAMS Accession No. ML21007A260).

The audit report is enclosed.

If you have any questions, please contact me by email at Bill.Rogers@nrc.gov.

Sincerely,

/RA/

Bill Rogers, Senior Project Manager Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosure:

Audit Report cc w/encl: Listserv

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2020-SLR-0002) DATED: AUGUST 16, 2021 DISTRIBUTION:

PUBLIC RidsNrrDnrl Resource RidsNrrPMPointBeach Resource RidsACRS_MailCTR Resource RidsRgn3MailCenter Resource RidsRgn3Dnms Resource RidsRgn3Drp Resource RidsRgn3Drs Resource RidsRgn3Ora Resource RidsRgn3Opa Resource RidsNrrOd Resource RidsNrrPMPointBeach Resource BRogers, NRR/DNRL LGibson, NRR/DNRL PClark, NMSS/REFS RElliott, NMSS/REFS ABradford, NRR/DNRL BCaldwell, NRR/DNRL RHaskell, NRR/DORL NSalgado, NRR/DORL DRoth, OGC MYoung, OGC JWachutka, OGC TJones, OGC RSkokowski, OEDO MMcCoppin, OEDO SBurnell, HQ/OPA DMcIntyre, HQ/OPA CWolf, OCA LWilkins, OCA VMitlying, RGN III/OPA PChandrathil, RGN III/OPA NFeliz-Adorno, RGN III RNg, RGN III William.Maher@fpl.com Steve.Franzone@fpl.com ADAMS Accession No.: ML21208A447 OFFICE PM:NLRP:DNRL BC:NLRP:DNRL PM:NLRP:DNRL NAME BRogers*

LGibson*

BRogers*

DATE 8/10/21 8/12/21 8/16/21 AUDIT REPORT In-Office Regulatory Audit Point Beach Plant, Units 1 and 2, Subsequent License Renewal Application January 19 - March 26, 2021 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF NEW AND RENEWED LICENSES Docket Nos:

50-266 and 50-301 License No:

DPR-24 and DPR-27 Licensee:

NextEra Energy Point Beach, LLC (NextEra)

Facility:

Point Beach Nuclear Plant, Units 1 and 2 (Point Beach, PBN)

Location:

Rockville, Maryland Dates:

January 19 - March 26, 2021 Approved By:

Steven D. Bloom, Chief Corrosion and Steam Generator Branch (NCSG)

Division of New and Renewed Licenses (DNRL)

Joseph Colaccino, Chief Structural, Civil, Geotech Engineering Branch B (ESEB)

Division of Engineering and External Hazards (DEX)

Lauren Gibson, Chief License Renewal Projects Branch (NLRP)

Division of New and Renewed Licenses (DNRL)

Angie Buford, Chief Vessels and Internals Branch (NVIB)

Division of New and Renewed Licenses (DNRL)

Jeanne A. Johnston, Chief Long-Term Operations and Modernization Branch (ELTB)

Division of Engineering and External Hazards (DEX)

Scott Krepel, Chief Nuclear Systems Performance Branch (SNSB)

Division of Safety Systems (DSS)

Robert Lukes, Chief Nuclear Methods and Fuel Analysis Branch (SFNB)

Division of Safety Systems (DSS)

Matthew A. Mitchell, Chief Piping and Head Penetrations Branch (NPHP)

Division of New and Renewed Licenses (DNRL)

Shilp Vasavada, Acting Chief PRA Licensing Branch B (APLB)

Division of Risk Assessment Brian Wittick, Chief Containment & Plant Systems Branch (SCPB)

Reviewers:

Name Organization Ali Rezai DNLR/NPHP Allen Hiser DNRL Andrew Prinaris DEX/ESEB Austin Young DNLR/NPHP Bart Fu DNLR/NPHP Brian Allik DNRL/NCSG Bryce Lehman DEX/ESEB Carolyn Fairbanks DNRL/NVIB Christopher Sydnor DNRL/NVIB David Dijamco DNRL/NVIB David Nold DSS/SCPB Duc Nguyen DEX/ELTB Eric Reichelt DNLR/NPHP George Thomas DEX/ESEB George Wang DEX/ESEB Greg Makar DNLR/NCSG James Medoff DNRL/NVIB Jim Gavula DNLR/NCSG Johnson, Andrew DNLR/NCSG Juan Lopez DEX/ESEB Kalikian, Roger DNLR/NPHP Leslie Terry DSS/SCPB Luis Colon Fuentes DEX/ESEB Matthew Mitchell DEX/ELTB Matthew Yoder DNLR/NCSG Michael Benson DNRL/NVIB Mohammad Sadollah DEX/ELTB Naeem Iqbal DRA/APLB On Yee DNRL/NVIB Robert Vettori DRA/APLB Seung Min DNLR/NPHP Shie-Jeng Peng DSS/SCPB TABLE OF CONTENTS TABLE OF CONTENTS................................................................................................................ 6 ACRONYMS................................................................................................................................. 9

1.

Introduction..................................................................................................................... 12

2.

Audit Activities................................................................................................................. 13 SLRA AMP B.2.2.1, Fatigue Monitoring................................................................................ 13 SLRA AMP B.2.2.2, Neutron Fluence Monitoring Program.................................................. 15 SLRA AMP B.2.2.4, Environmental Qualification of Electric Equipment............................... 16 SLRA AMP B.2.2.30, Concrete Containment Unbonded Tendon Prestress......................... 17 SLRA AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD.......................................................................................................................... 19 SLRA AMP B.2.3.2, Water Chemistry................................................................................... 20 SLRA AMP B.2.3.3, Reactor Head Closure Stud Bolting...................................................... 22 SLRA AMP B.2.3.4, Boric Acid Corrosion............................................................................. 23 SLRA AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components.................................................................................................................... 25 SLRA AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel......... 26 SLRA AMP B.2.3.7, Reactor Vessel Internals...................................................................... 27 SLRA AMP B.2.3.8, Flow-Accelerated Corrosion................................................................. 40 SLRA AMP B.2.3.9, Bolting Integrity..................................................................................... 42 SLRA AMP B.2.3.10, Steam Generators.............................................................................. 44 SLRA AMP B.2.3.11, Open-Cycle Cooling Water System.................................................... 46 SLRA AMP B.2.3.12, Closed Treated Water Systems.......................................................... 47 SLRA AMP B.2.3.13, Inspection of Overhead Heavy Load Handling Systems.................... 49 SLRA AMP B.2.3.14, Compressed Air Monitoring................................................................ 51 SLRA AMP B.2.3.15, Fire Protection.................................................................................... 52 SLRA AMP B.2.3.16, Fire Water System.............................................................................. 53 SLRA AMP B.2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks................... 55 SLRA AMP B.2.3.18, Fuel Oil Chemistry.............................................................................. 56 SLRA AMP B.2.3.19 Reactor Vessel Material Surveillance.................................................. 57 SLRA AMP B.2.3.20, One-Time Inspection.......................................................................... 58 SLRA AMP B.2.3.21, Selective Leaching............................................................................. 59 SLRA AMP B.2.3.22, ASME Code Class 1 Small-Bore Piping............................................. 61 SLRA AMP B.2.3.23, External Surfaces Monitoring of Mechanical Components................. 62 SLRA AMP B.2.3.24, Flux Thimble Tube Inspection............................................................ 64 SLRA AMP B.2.3.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components....................................................................................................... 66 SLRA AMP B.2.3.26, Lubricating Oil Analysis...................................................................... 67 SLRA AMP B.2.3.27, Buried and Underground Piping and Tanks....................................... 68 SLRA AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks................................................................... 70 SLRA AMP B.2.3.29, ASME Section XI, Subsection IWE.................................................... 72 SLRA AMP B.2.3.30, ASME Section XI, Subsection IWL..................................................... 76 SLRA AMP B.2.3.31, ASME Section XI, Subsection IWF..................................................... 77 SLRA AMP B.2.3.32, 10 CFR Part 50, Appendix J............................................................... 81 SLRA AMP B.2.3.33, Masonry Walls.................................................................................... 83 SLRA AMP B.2.3.34, Structures Monitoring......................................................................... 84 SLRA AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants................................................................................................................... 87 SLRA AMP B.2.3.36, Protective Coating Monitoring and Maintenance................................ 88 SLRA AMP B.2.3.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements............................. 89 SLRA AMP B.2.3.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits............... 91 SLRA AMP B.2.3.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.......... 93 SLRA AMP B.2.3.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.......... 95 SLRA AMP B.2.3.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.......... 96 SLRA AMP B.2.3.42, Metal Enclosed Bus............................................................................ 98 SLRA AMP B.2.3.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification............................................................................................ 99 SLRA AMP B.2.3.44, High-Voltage Insulators.................................................................... 101 SLRA Section 3.5.2.2.2.6, AMR Further Evaluation, Reduction of Strength and Mechanical Properties of Concrete due to Radiation and SLRA Section 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to Irradiation Embrittlement of Reactor Vessel (RV) Supports from NRC Review of the First Three SLRAs.................................................................................. 102 SLRA Section 3.6.2.2.3 AMR Further Evaluation, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections...................................... 109 SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses............................ 110 SLRA TLAA Section 4.2.2, Pressurized Thermal Shock..................................................... 120 SLRA TLAA Section 4.2.3, Upper-Shelf Energy................................................................. 122 SLRA TLAA Section 4.2.4, Adjusted Reference Temperature............................................ 124 SLRA TLAA Section 4.2.5, Pressure-Temperature Limits and Low Temperature Overpressure Protection (LTOP) Setpoints.................................................................. 126 SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components..................................... 127 SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components - Steam Generators.................................................................................................................... 129 SLRA TLAA Section 4.3.2, ASME Code,Section III, Class 1 Component Fatigue Waivers......................................................................................................................... 130 SLRA TLAA Section 4.3.3, Metal Fatigue of Non-Class 1 Components............................. 131 SLRA TLAA Section 4.3.4, Environmentally Assisted Fatigue............................................ 132 SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment..................... 134 SLRA TLAA Section 4.5, Concrete Containment Tendon Prestress.................................. 135 SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue..................................................................................................... 136 SLRA TLAA Section 4.7.1, Leak-Before-Break of Reactor Coolant System Loop Piping............................................................................................................................ 138 SLRA TLAA Section 4.7.2, Leak-Before-Break of Reactor Coolant System Auxiliary Piping............................................................................................................................ 139 SLRA TLAA Section 4.7.3, Flaw Tolerance Evaluation for Reactor Coolant Loop CASS Piping Components............................................................................................ 141 SLRA TLAA Section 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth......... 142

3.

Applicant Personnel Contacted During Audit................................................................ 144

4.

Exit Meeting.................................................................................................................. 145 ACRONYMS ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review AR action report ART adjusted reference temperature ASME American Society of Mechanical Engineers BA boric acid BFB baffle-to-former bolt BMI bottom mounted instrumentation CAP corrective action program CASS cast austenitic stainless steel CCW component cooling water CFR Code of Federal Regulations CLB current licensing basis CR condition report CRGT control rod guide tube CST CUF condensate storage tank cumulative usage factor DM dissimilar metal EAF environmentally assisted fatigue ECCS emergency containment cooling system EFPY effective full power years EPRI Electric Power Research Institute EPU extended power uprate FAC flow-accelerated corrosion FE further evaluation FSAR final safety analysis report GALL-SLR NUREG-2191, Revision 0, Generic Aging Lessons Learned for Subsequent License Renewal HELB high energy line break HX heat exchanger I&E inspection and evaluation IE irradiation embrittlement IR interaction ratio ISG Interim Staff Guidance ISI inservice inspection LAR license amendment request LAWs lower axial welds LBB leak-before-break LFW low flange weld(s)

LR license renewal LTOP low temperature overpressure protection MAWs middle axial welds MOV motor operated valve MRP materials reliability program MRV minimum required value NDE nondestructive examination NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission PBNP Point Beach Nuclear Plant/Point Beach P-T, P/T pressure-temperature PTLR pressure temperature limit report PTS pressurized thermal shock PWR pressurized water reactor PWSCC primary water stress corrosion cracking QATR Quality Assurance Topical Report RAI request for additional information RCI request for confirmation of information RCS reactor cooling system RIS regulatory information summary RIVE radiation-induced volumetric expansion RPV reactor pressure vessel RVI reactor vessel internal SCC stress corrosion cracking SE safety evaluation SER safety evaluation report SG steam generator SIA Structural Integrity Associates SLR subsequent license renewal SLRA subsequent license renewal application SNM susceptible non-modeled SRP-SLR NUREG-2192, Revision 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants SSC structure, system, and component SW service water TLAA time-limited aging analysis(es)

TS technical specification(s)

UFSAR updated final safety analysis report UWG upper girth welds USE upper-shelf energy UT ultrasonic test VLF very low frequency WO work order to Enclosure Report for the In-Office Regulatory Audit Point Beach Nuclear Plant, Units 1 and 2 Subsequent License Renewal Application

1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an in-office audit of NextEra Energys Point Beach, LLC (NextEra, the applicant) (1) plant-specific operating experience; (2) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR)

(Scoping and Screening Portion); and (3) aging management programs (AMPs), AMR items, time-limited aging analyses (TLAAs), and associated bases and documentation as applicable (AMP and TLAA Portion) for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units 1 and 2 (Point Beach, PBN, PBNP). Note that much of the applicants information was reviewed via an electronic portal (ePortal), which allowed the staff to have remote, view-only access to applicant documentation that supported the staffs review.

Due to the travel restrictions associated with the coronavirus, no onsite audit activities of operating experience or visual observations of areas, equipment conditions, or configurations were conducted. Upon the staffs request, the applicant made available pictures of plant conditions via video conferencing. These pictures were not transmitted, were not provided to the staff, and were not placed on the docket.

The purpose of the plant-specific Operating Experience Portion of the audit is to identify examples of age-related degradation, as documented in the applicants corrective action program database. Operating experience was initially placed on the applicants ePortal and additional word searches were performed per the staffs request, and the results were provided to the NRC staff for review.

The purpose of the Scoping and Screening Portion of the audit is to evaluate the scoping and screening process as documented in the license renewal application (LRA), implementing procedures, reports, and drawings, such that the staff:

obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an AMR has sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied The purpose of the AMP and TLAA Portion of the audit is to:

examine AMPs, AMR items, and TLAAs verify the applicants claims of consistency with the corresponding NUREG-2191, Revision 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued July 2017, AMPs, and AMR items assess the adequacy of the TLAAs Enhancements and exceptions will be evaluated on a case-by-case basis. The staffs review of enhancements and exceptions will be documented in the safety evaluation report (SER).

The regulatory bases for the audit was Title 10 of the Code of Federal Regulations (10 CFR),

Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, (10 CFR Part 54). The staff also considered the guidance contained in NUREG-2192, Revision 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191. The SRP-SLR allows an applicant to reference in its license renewal application the AMPs described in the GALL-SLR Report. By referencing the GALL-SLR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.

2. Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information, and, if applicable, to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.

Licensing conclusions or staff findings are not made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information (RCIs), and public meetings. The staffs SER will document the licensing conclusions, staff findings, and resolution of audit items. The questions provided to the applicant to facilitate technical discussions is available at Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21214A035.

The following sections discuss the subsequent license renewal application (SLRA) areas that the staff reviewed.

SLRA AMP B.2.2.1, Fatigue Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.2.1, Fatigue Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff also reviewed the enhancements associated with this AMP.

Audit Activities. The applicant performed a search of the operating experience database using keywords: crack, cycl, damage, fatigue, flaw, monitor, CUF, usage factor, environmental, and transient.

The table below lists the documents that the staff reviewed and found to be relevant to the Fatigue Monitoring Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 1890629 Potential FSAR Change Due to Draft WCAP Information 07/19/2013 AR 2345362 License Renewal Transient Limit Monitoring Program Gaps 02/20/2020 AR 2262609 License Renewal Aging Management Program Effectiveness Reviews 05/3/2018 AR 2262609 L1A License Renewal AMP Effectiveness Reviews 05/3/2018 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-040 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fatigue Monitoring Revision 0 Structural Integrity Associates (SIA) 2000088.301 Development of 80-year Projected Cycles for Point Beach Nuclear Plant Units 1 and 2 Revision 2 SIA 2000088.302 Plant Transition Cycle Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.303 Plant Monitoring CUF Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.310P EAF Refined Analyses (Charging Nozzle, Hot Leg Surge Nozzle, SI Nozzle, SI/RHR Tee)

Revision 1 SIA 2000088.401 Cycle Counts and Fatigue Projections for 80-Years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 2 SIA 2000088.402 Environmentally-Assisted Fatigue Evaluation for 80 Years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 1 PBCH-03Q-301 Evaluation of Thermal Stratification Due to Valve Leakage Revision 3 Westinghouse LTR-RIDA-13-92 Peach Bottom Units 1 and 2 Baffle Bolt Fatigue for Extended Power Uprate Project Revision 0 NP 7.7.19 Procedures Manual: Fatigue Monitoring Program Revision 8 TRM 4.5 Technical Requirement Manual: Cyclic or Transient Limit Monitoring Program Revision 2 Westinghouse LTR-SDA-II-20-05-P Environmentally Assisted Fatigue Screening Results for Point Beach Unit 1 and Unit 2 Safety Class 1 Primary Equipment Revision 2 Westinghouse LTR-SDA-II-20-08-P Environmentally Assisted Fatigue Evaluation Results for the Point Beach Unit 1 and Unit 2 Primary Equipment Sentinel Locations for Subsequent License Renewal Revision 1 Document Title Revision/Date Westinghouse LTR-SDA-II-20-13-P Environmentally Assisted Fatigue Evaluation Results for the Point Beach Unit 1 and Unit 2 Pressurizer Lower Head for Subsequent License Renewal Revision 2 Westinghouse LTR-SDA-20-064-P ASME Section XI Appendix L Evaluation Results for the Point Beach Units 1 and 2 Pressurizer Spray Nozzles Revision 1 In addition, the staff found that, for the parameters monitored or inspected and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

In relation to the parameters monitored or inspected element, the design transients and allowable cycle numbers are described in SLRA Table 4.3.1-1 and SLRA Appendix A, UFSAR supplement, Table 4.1-8. The staff noted that these tables are not consistent.

Therefore, the staff found a need to resolve the inconsistency between the tables in terms of design transients and allowable cycle numbers.

In relation to the monitoring and trending element, the applicant used the FatiguePro computer program to perform stress-based fatigue monitoring for some ASME Code Class 1 and 2 components. Recently, the applicant contracted with Structural Integrity Associates (SIA) to review the FatiguePro data and received an updated report that incorporated the data through 2019 for 80-year fatigue projections. SLRA Section B.2.2.1 indicates that, going forward, the applicant will no longer use the FatiguePro Program and instead will use the manual count method. Therefore, the staff found a need to clarify why the manual counting approach, which is planned for the subsequent period of extended operation, is sufficient to manage fatigue in the components for which stress-based fatigue monitoring has been used.

During the audit of the operating experience associated with the Fatigue Monitoring Program, the staff independently searched the plant-specific database and did not identify any previously unknown or recurring aging effects related to the program.

The staff also audited the description of the SLRA Fatigue Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.2.2, Neutron Fluence Monitoring Program Summary of Information in the Application. The SLRA states that AMP B.2.2.2, Neutron Fluence Monitoring, is an existing program and with enhancements, that will be consistent with the program elements in GALL-SLR Report AMP X.M2, Neutron Fluence Monitoring. To verify this claim of consistency with enhancements, the staff audited the SLRA AMP.

Audit Activities. During its audit, the staff reviewed documentation that the applicant provided.

The Neutron Fluence Monitoring AMP, with enhancements, will be consistent with the 10-elements of NUREG-2191,Section X.M2, Neutron Fluence Monitoring as modified by SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal Guidance.

The SLRA states that AMP B.2.2.2, Neutron Fluence Monitoring, is an existing program with enhancement(s) that will be consistent with the program elements in GALL-SLR Report AMP X.M2, Neutron Fluence Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program (Element 3, parameters monitored or inspected, and Element 6, acceptance criteria). The staff will document its review of the enhancement(s) in the SER.

SLRA AMP B.2.2.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. The SLRA states that the Environmental Qualification (EQ) of Electric Equipment AMP described in Section B.2.2.4 meets the requirements of 10 CFR 50.49 for the applicable electrical components important to safety. The AMP is an existing AMP, previously the EQ Program, which manages the effects of thermal, radiation, and cyclic aging through the use of aging evaluations based on 10 CFR 50.49(f) qualification methods. The applicant stated that this AMP, with an enhancement, will be consistent with the 10 elements of NUREG-2191,Section X.E1, Environmental Qualification of Electric Equipment. The enhancement is to visually inspect accessible, passive EQ equipment for adverse localized environments that could impact qualified life at least once every 10 years with the first periodic visual inspection to be performed prior to the subsequent period of extended operation. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. A keyword search was not performed. During the audit, the staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the EQ of electrical equipment. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02327520 HELB Calcs Revised Twice without Evaluating Impact on EQ 09/22/2019 AR02330722 EQ Rosemont Transmitters is Acceptable in Storage Level B 10/08/2019 AR02338607 Ultra Electronics Qualified Life Change Notice 12/17/2019 AR02340309 Follow Up AR to 02338607 - Qualified Life Change Notice 01/07/2020 AR02388321 EQ Program Review Required for EPRI NP-1558 Revision 03/30/2021 AR02241723 Effectiveness Reviews of PB License Renewal Programs 12/21/2017 AR02262609 L1A: License Renewal Program Effectiveness Reviews 05/03/2018 AR02320373 Incorrect EQCK Referenced for MOV Motors 12/03/2019 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-041 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Environmental Qualification of Electric Equipment Revision 0 Document Title Revision/Date NP 7.7.1 Environmental Qualification of Electrical Equipment Revision 15 DG-G11 Environmental Qualification Service Conditions Revision 9 DG-G12 Environmental Qualification Program Manual Revision 2 ER-AA-112 Environmental Qualification Program Revision 5 LR-AMP-012-EQ Environmental Qualification Program Basis Document for License Renewal Revision 9 EQML EQ Master List Revision 40 11/01/2019 EQCK-FISH-001 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation &

Accident/Post-Accident Evaluation Revision 1 EQCK-PRONTO-001 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation Revision 1 EQCK-WEST-008 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation Revision 2 During the audit, the staff verified the licensees claim the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff notes that the applicant generated action request report number 02388321 during the audit to evaluate whether the recent revision to the Electric Power Research Institute Report NP-1558 has any adverse effects on the qualification of electric equipment (specifically related to the activation energy used to determine the qualification of components).

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A16.2.1.4, Environmental Qualification of Electric Equipment, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.2.30, Concrete Containment Unbonded Tendon Prestress Summary of Information in the Application. The SLRA states that AMP B.2.2.30, Concrete Containment Unbonded Tendon Prestress, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.S1, Concrete Containment Unbonded Tendon Prestress. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. A keyword search was not performed by the staff. During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP0036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 FPLCORP0036-REPT-062 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Concrete Containment Unbonded Tendon Prestress Revision 0 ADAMS ML19352F059 Owners Activity Report - 48th Year IWL for Class CC Examinations 12/18/2019 REP-1149-510 Final Report for the 48th Year Tendon Surveillance at Point Beach Nuclear Power Plant Revision 0 09/16/2019 REP-1149-511 Regression Analysis for 48th Year - 48th YR Surveillance at Point Beach Revision 0 09/16/2019 REP-1095-510 Final Report for the 43rd Year Tendon Surveillance at Point Beach Nuclear Power Plant Revision 1 06/30/2014 AR 02156929 Randomly Selected Containment Tendon Plan 09/20/2016 N/A 3rd Interval-IWL-PB-1/2-Program Plan Revision 0 12/29/2017 FPLCORP00036-CALC-001 Point Beach Units 1 and 2 Time Limited Aging Analysis of the Containment Prestressed Tendons for Subsequent License Renewal (SLR)

Revision 0 FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the acceptance criteria program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the query results that the applicant provided from the plant-specific operating experience to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific operating experience in the SER.

The staff also audited the description of the Concrete Containment Unbonded Tendon Prestress AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that the aging management program (AMP) B2.3.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD.

To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation the applicant provided via the ePortal. The table below lists documents that the staff reviewed and found to be relevant to the program. The documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/

Date AR2303129 License Renewal Commitment to Visually Inspect Upper Tube Bundle Not Met 01/06/2005 AR2280862 FAC Program Assessment 09/20/2018 AR1994517 Maintain License Renewal Aging Management Programs 09/2014 Licensee Event Report 266/2020-001-00 Reactor Coolant System Pressure Boundary Leak on Steam Generator Bowl Drain Line Results in Operation Prohibited by Technical Specifications 11/25/2020 AR01714837 Active Leak at Fitting Just Below FM-32 and Dry BA on FM -1, 9 12/23/2011 AR01827762 Code-Required Visual Examination Near-Miss 12/03/2012 FPLCORP00036-RE PT-042 Point Beach Nuclear Plant Subsequent License Renewal Aging Management Program Basis Documents 11/07/2020 Revision 0 ISI-Class-1-2-3 Program Point Beach Nuclear Plant ISI Class 1, 2, 3 Inservice Inspection Program Revision 12 AR02272677 Nuclear Safety Advisory Letter for CRDM Thermal Sleeve Wear 07/18/2018 AR01387088 Program Health Reports Need Update or Creation (LR) 04/14/2010 NDE-754 Visual Examination of Nuclear Power Plants Revision 21 During the audit, the staff observed in the plant-specific operating experience that PBN had missed a license renewal commitment in 2005. The plant personnel stated that a visual examination to inspect steam generator tube bundles was missed and that it had rescheduled the inspection for the following outage. The staff reviewed AR 2303129, dated February 2, 2019, which documented the final resolution of this issue. AR 2303129 indicated that the licensee had determined that the visual inspection of the portion of the upper tube bundle had not been performed as described in an initial license renewal commitment. The AR further stated that the licensee had concluded that while the performance of the visual inspection would provide an indication of deposits or fouling, it was the performance of Eddy Current testing that would provide indication of any tube degradation, and that any such degradation had been accounted for in the Steam Generator Tube Integrity Assessments. The AR also indicated that the initial license renewal commitment and applicable aging management procedures were to be modified in accordance with the requirements of 10CFR 50.59 to incorporate the results of the AR conclusions and recommended actions. The staff noted that this was a current operation issue and, therefore, had no additional questions relative to the ongoing SLRA review.

During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit, the staff identified an enhancement associated with the detection of aging effects program element. The staff also verified the applicants claim that aspects of the detection of aging effects program element not associated with the enhancement identified in the SLRA AMP are consistent with the corresponding program element in the GALL-SLR Report AMP.

For the audit of the operating experience program element, the staff reviewed the operating experience the applicant provided in the AMP basis document and on the ePortal. The staff performed a search of the operating experience database using keywords: program assessment, peer assessment, self-assessment, missed examination, missed item, missed inspection, missed flaw, and program deficiency. The SER will document the staffs review of relevant operating experience.

The staff also audited the description of the SLRA AMP provided in the updated final safety analysis report (UFSAR) supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.3.2, Water Chemistry, is an existing program with enhancements that will be consistent, with an exception, with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry, as modified by the Interim Staff Guidance (ISG) SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent Renewal Guidance. The staff noted that subsequent to the applicants SLRA submittal, draft SLR-ISG-Mechanical-2020-XX, was issued as final SLR-ISG-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance, dated February 2021 (ADAMS Accession No. ML20181A434). To verify this claim of consistency, the staff audited the SLRA AMP.

Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Water Chemistry Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 02336950 Spent Fuel Pool Sulfate 12/5/2019 AR 02318114 Unit 2 RCS Lithium Action Level 1 07/19/2019 AR 02298916 Unit 1 SGA and SGB Exceeded 8 ppm Admin Limit for ETA 01/30/2019 Document Title Revision/Date AR 02283136 Unit 2 Chlorides Above 10 PPB Admin Value 10/31/2018 AR 02001230 PBNP Has Experienced Higher Than Anticipated Dose Rates 09/13/2018 AR 02181338 NA Finding Chemistry Oversight 01/5/2018 AR 02234809 Sodium is Trending High in Condensate Storage Tanks 11/09/2017 During its audit, the staff interviewed the applicants staff and reviewed documentation the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-043 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Water Chemistry Revision 0 FPLCORP00036-REP T-039 Point Beach Units 1 and 2 Subsequent License Renewal Effects Operating Experience Revision 0 ASME CRTD-Vol 34 Consensus on Operating Practices for the Control of Feedwater and Boiler Water Chemistry in Modern Industrial Boilers 1998 CAMP 010 Lithium Verification, Prediction, and Control Revision 10 CAMP 101 Daily Routine Sampling Schedule for Operating, Refueling, or Shutdown Units Revision 73 CAMP 115 Chemistry Control Monitoring During A Plant Startup Revision 39 CY-AA-101 Chemical Control Program Revision 0 NP 3.2.1 Analytical Quality Assurance Program Revision 28 NP 3.2.2 Primary Water Chemistry Monitoring Program Revision 28 NP 3.2.3 Secondary Water Chemistry Monitoring Program Revision 30 NP 3.2.5 Secondary Strategic Water Chemistry Optimization Plan Revision 10 NP 3.2.6 Strategic Primary Water Chemistry Optimization Plan Revision 8 TRM 3.4.5 Reactor Coolant Oxygen, Chloride and Fluoride Concentrations Revision 1 OE Interview Water Chemistry AMP OE Interview During the audit, the staff verified the licensees claim that, the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the scope of program program element not associated with the exception and enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Water Chemistry Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The SLRA states that AMP B.2.3.3, Reactor Head Closure Stud Bolting, is an existing program with an exception and enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. A search of the applicants operating experience database was conducted using these keywords: bolt, bushing, closure stud, galling, head nut, indication, moly, pitting, SCC, stress corrosion cracking, stuck, thread, washer, and wear. No significant plant-specific operating experience associated with the Reactor Head Closure Stud Bolting AMP was noted by the staff during the keyword search for operating experience.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title or Description Revision/Date FPLCORP00036-REPT-063 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Reactor Head Closure Stud Bolting Revision 0 11/06/2020 FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects - Operating Experience Revision 1 08/26/2020 NRC Regulatory Guide 1.65 Materials and Inspections for Reactor Vessel Closure Studs Revision 1 1RMP 9096-1 Reactor Vessel Head Removal and Installation Using Tensioning Biach Tensioning System (for Unit 1)

Revision 26 2RMP 9096-1 Reactor Vessel Head Removal and Installation Using Tensioning Biach Tensioning System (for Unit 2)

Revision 21 ISI CL 1-2-3 Program Rev 15 Point Beach Nuclear Plant - Class 1, 2, and 3 Inservice Inspection Program - Fifth Inservice Inspection Interval Revision 15 11/15/2017 FPL-1_R22_QATR_L-2019-1 34 NextEra Energy Quality Assurance Topical Report, FPL [Florida Power & Light]-1 Revisions 22 and 24 Volumetric examination records Documented results of volumetric examinations performed for the 48 reactor head closure studs and 48 threads-in-flange various During the audit, the staff verified the licensees claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified the applicants claim that aspects of the preventive actions program element not associated with the exception identified in the SLRA or by the staff during the audit, are consistent with the corresponding program elements in the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff confirmed in the basis document for the Reactor Head Closure Stud Bolting AMP (FPLCORP00036-REPT-063) that the principal objective of the AMP is to manage the aging effects of cracking due to stress corrosion cracking, intergranular stress corrosion cracking, and loss of material due to wear or corrosion in the components within the program scope.

Section 4.7 of the basis document for the Reactor Head Closure Stud Bolting AMP does not explicitly state that the Reactor Head Closure Stud Bolting AMP implements Criterion XVI, Corrective Action, of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, as described in Element 7 of GALL-SLR Report AMP XI.M3. However, the staff noted that corrective actions controls are described in the NextEra Energy Quality Assurance Topical Report (QATR), FPL-1, Revision 22, which is referenced in the program basis document. The staff noted that the description of the corrective action program described in Section A.6 Corrective Action of the NextEra Energy QATR, Revision 24 (ADAMS Accession No. ML20171A391) is consistent with the description in Criterion XVI, Corrective Action, of 10 CFR Part 50, Appendix B. Revision 24 of the NextEra Energy QATR is the latest revision of the document submitted to the NRC.

The fifth inservice inspection interval (ISI) Program document (ISI CL 1-2-3 Program Revision 15) indicates there are 48 reactor head closure studs, 48 threads-in-flange, 48 reactor head closure nuts, and 48 reactor head closure washers/bushings. The reactor head closure studs (and head nuts and washers/bushings) are examined in three batches whereas the threads-in-flange are examined all at once.

Records of the most recent required American Society of Mechanical Engineers (ASME)

Code,Section XI volumetric examinations performed for the 48 reactor head closure studs and 48 threads-in-flange show that no recordable indications were detected during the examinations.

The staff also audited the description of the SLRA Reactor Head Closure Stud Bolting AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA AMP B.2.3.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.3.4, Boric Acid Corrosion, is an existing program that with an enhancement will be consistent with the program elements in GALL-SLR Report AMP XI.M10, Boric Acid Corrosion. The staff reviewed the enhancement associated with this AMP during its audit, and will document its review of the enhancement in the SER.

Audit Activities. The staff audited the AMP using in-office technical reviews of the SLRA and information contained in the applicants ePortal, in conjunction with in-office break-out sessions.

No onsite audit activities of operating experience or visual observations of areas, equipment conditions, or configurations were conducted for this AMP.

During the audit, the staff interviewed the applicants staff and reviewed the following documents found to be relevant to the Boric Acid Corrosion Program. The documents were provided by the applicant or were identified in the staffs review of operating experience provided on the ePortal. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-044 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Boric Acid Corrosion Revision 0 FPLCORP00036-REP T-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 N/A Master System Health Report Boric Acid Corrosion Q1-2015 through Q1-2020 03/3/2020 AR2176346 Replace Relief Valve with All Stainless Steel. Bronze body of valve is corroding in borated water 12/21/2016 AR2176303 Replace Relief Valve with All Stainless Steel. Bronze body of valve is corroding in borated water 12/21/2016 AR2262609 License Renewal Aging Management Program Effectiveness Reviews 05/3/2018 N/A SealPRO Leak List Open Boric Acid WR/WO Status Report 02/19/2021 During the audit, the staff verified the applicants statements that the scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified that the aspects of the parameters monitored or inspected program element, not associated with the enhancement, are consistent with the corresponding element in the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the plant-specific information associated with this AMP that the applicant provided on its ePortal.

The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also reviewed the summary description of the program provided in SLRA Appendix A, Updated Final Safety Analysis Report Supplement, Section 16.2.2.4, Boric Acid Corrosion.

The staff verified this description is consistent with the corresponding program description in GALL-SLR Report Table XI-01.

SLRA AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The SLRA states that AMP B.2.3.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancement associated with this AMP. The staff will document its review of the enhancement in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation in the SLRA that the applicant provided via the ePortal. The table below lists documents the staff reviewed and found to be relevant to the Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-R EPT-045 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Revision 0 11/06//2020 ER-SR-107 Alloy 600 Management Program (Fleet)

Revision 1 01/15/2015 NP 7.7.31 Alloy 600 Management Program (Point Beach)

Revision 6 LR-AMP-013-RCA 600 Reactor Coolant System Alloy 600 Inspection Program Basis Document for License Renewal Revision 10 EC0000288078 Engineering Change, Steam Generator Channel Head Alloy 600 Drain and Heat -Affected Zone Modification to Prevent PWSCC Revision 4 01/18/2018 AR02345306 Increasing Trend on 1RE-211 Particulate Monitor 02/20/2020 AR02351418 Active Boric Acid Leak Identified in Unit 1 Containment 04/05/2020 AR02370198 1RC-526B, As-Found Boric Acid Leak 10/03/2020 AR02370320 1RC-526B Liquid Penetration Indications, Unit 1 B Steam Generator Bowl Drain 10/04/2020 LER 2020-001-00 Licensee Event Report, Point Beach Unit 1 Reactor Coolant System Pressure Boundary Leak on Steam Generator Bowl Drain Line Results in Operation Prohibited by Technical Specifications 11/25/2020 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the detection of aging effects program element not associated with the enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

For the audit of the operating experience program element, the staff reviewed the operating experience the applicant provided in the AMP basis document and on the ePortal. The staff performed a search of the provided operating experience using keywords: Alloy 600, Dissimilar metal, DM weld, 82 weld, Nickel alloy weld, RCS leak, and PWSCC. The staff will document its review of relevant operating experience in the SER.

The staff also audited the description of the SLRA Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Summary of Information in the Application. The SLRA states that AMP B.2.3.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel, is a new program that is consistent with the program elements in GALL-SLR Report AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS). To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. A search of the applicants operating experience database was conducted using keywords: Cast Stainless Steel, Cast, CASS, Embrittlement, Thermal Aging, Fracture Toughness, Valve Body, Elbow, and Pump Casing. No significant plant-specific operating experience associated with the Thermal Aging Embrittlement of Cast Austenitic Stainless Steel was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-079 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Revision 0 11/06/2020 Westinghouse LTR-PAFM-05 P/NP Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Piping Components in Point Beach Units 1 and 2 for 80-years Revision 3 07/2020 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

From its review of the program basis document, the staff verified that this AMP is a new program developed for Point Beach to manage thermal aging embrittlement of CASS piping components that are subjected to the operating temperature above 482 degrees Fahrenheit (o F). No plant-specific operating experience to verify its effectiveness was identified by the applicant. The applicant determined that the reactor coolant loop piping elbows in the hot leg, crossover leg, and cold leg piping constructed from CASS A-351 Grade CF8M material are susceptible to thermal aging embrittlement. The applicant has chosen the flaw tolerance evaluation method to demonstrate that the thermally-embrittled CASS material has tolerance for large flaws. The flaw tolerance evaluation performed for the thermally-embrittled CASS material in the hot leg, crossover leg, and cold leg piping demonstrated that even with thermal aging, the thermally-embrittled CASS material can tolerate large flaws.

The staff noted that the applicant used the latest guidance provided in NRC NUREG-2191 and NRC SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal, to perform flaw tolerance evaluation.

During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. There was no plant-specific operating experience identified.

The staff also audited the description of the SLRA Thermal Aging Embrittlement of Cast Austenitic Stainless Steel provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.7, Reactor Vessel Internals Summary of Information in the Application. The SLRA states that AMP B.2.3.7, Reactor Vessel Internals, is an existing program with enhancements that, with one identified exception, will be consistent with the program elements in GALL-SLR Report AMP XI.M16A, PWR Vessel Internals. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. In-Office Audit of Applicable Operating Experience. The staff did not perform a keyword search of the applicants operating experience/corrective actions database for relevant condition reports (CRs), corrective action program reports (CAPs), action reports (ARs), or work orders (WOs) related to the reactor vessel internal (RVI) components in the units. However, the staff reviewed those CRs, CAPs, ARs, and WOs involving RVI components or RVI assessments that the applicant had determined were relevant to the Reactor Vessel Internals Program and provided on the ePortal for the SLRA.

The table below lists the ARs and WOs that the staff reviewed as part of its operating experience audit review and that were found to be relevant to SLRA AMP B.2.3.7, Reactor Vessel Internals. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date Action Reports (ARs) or Documents Included in Action Reports (with Action Report in Parentheses)

PBNP AR No. 01953761 Point Beach Unit 2 Guide Card Wear 04/15/2014 Westinghouse Class 3 Non-Proprietary Technical Bulletin No. TB-16-4 (AR No. 02152736)

Fuel Alignment Pin Malcomized Surface Degradation 08/15/2016 PBNP AR No. 02165156 MRP-227 Inspection of Guide Tube G-11 for Guide Card Wear (applies to PNBP Unit 1) 10/27/2016 EPRI MRP Letter No. MRP-2016-021, (AR No. 02193700)

Transmittal of NEI-03-08 Needed Interim Guidance Regarding Baffle Former Bolt Inspections for Tier 1 Plants as Defined in Westinghouse NSAL 16-01 07/25/2016 PBNP AR No. 02241723 Reactor Vessel Internals Program 04/07/2018 PWR Owners Group Letter No. OG-18-61 (AR No. 02242495-1)

Transmittal of Final Report, PWROG-17071-NP, Revision 0, WCAP-17096-NP-A Interim Guidance 03/15/2018 PBNP AR No. 02242495-2 Inquiry - WCAP-17096-NP-A, Rev. 2 Revisions Timeline Emails: Two on 06/04/2018 and one on 06/05/2018 PBNP AR No. 02242495-3 Tasks - Voluntary Baffle Bolt Evaluation NextEra Energy Internal Emails: Two on 03/13 and 3/14/2018 PBNP AR No. 02235785 St. Lucie, Unit 1 10-Year Reactor Pressure Vessel NDE Examination Final Report 12/18/2018 PBNP AR No. 02245034-1 Fleet Review of MRP 2018-022 03/14/2018 MRP-2017-023 (AR No. 02245034-2)

Notification of Recent PWR Baffle-Former Bolt Clustering and Recommended Plant Actions to Prepare for Pending Interim Guidance for Augmented Expansion to Barrel to Former Bolts 09/14/2017 MRP-2017-007 (AR No. 02253333) Fleet Review, MRP 2018-007 Guide Card Interim Guidance (for AR);

Transmittal of NEI 03-08 Needed Interim Guidance to Address Accelerated Guide Card Wear Operating Experience (OE) Discussed in NSAL-17-1 (for MRP Interim Guidance included in the AR) 03/07/2018 (11/29/2018 for AR)

Document Title Revision/Date EPRI MRP Interim Guidance No.

MRP 2019-009 (AR No. 02321810)

Transmittal of NEI 03-08 Good Practice Interim Guidance Regarding MRP-227-A and MRP-227, Rev. 1 PWR Core Barrel and Core Support Barrel Inspection Requirements 07/17/2019 Work Orders (WOs)

WO No. 40201462-01 1R-1 / Reactor Vessel Internals Examination per MRP-227-A (Unit 1) 03/24/2013 WO No. 40201463-01 2R-1 / Reactor Vessel Internals Examination per MRP-227-A (Unit 2) 03/04/2014 WO No. 40321136-01 2R-1 / Completion of MRP-227 Exams (Unit 2) 10/09/2015 Potential Need for Onsite Audit of Components Associated with the Reactor Vessel Internals Program. The staff did not implement an onsite audit of the design and licensing basis for RVI components associated with the Reactor Vessel Internals Program or perform onsite walkdowns of the RVI components. The staff noted that Chapter 3 in the applicants final safety analysis report (FSAR) provides a detailed description and discussion of the design and function of the RVI and core support structure components at Point Beach.

In-Office Audit Breakout Meeting Discussions with the Applicant. The staff conducted two audit breakout sessions for this AMP with the applicant via teleconferences. These virtual meetings took place on March 16, 2021, and March 23, 2021. A summary of these audit breakouts sessions may be accessed by connecting to the staffs Agencywide Documents Access and Management System (ADAMS) at https://adams.nrc.gov/wba/) and by searching the database system using a document property query on Accession number and searching on ADAMS Accession No. ML21214A035.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided, including additional documents the applicant posted to the ePortal for the SLRA at the staffs request. The staff reviewed the following additional documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date SLRA Section B.2.3.7 (SLRA AMP)

Reactor Vessel Internals Revision 0 SLRA Section 16.2.2.7 (SLRA FSAR Supplement for the AMP)

Reactor Vessel Internals Revision 0 NextEra Energy Report No.

LR-AMP-015-RVINT Reactor Vessel Internals Program Basis Document for License Renewal Revision 10 Enercon Report No. FPLCORP00036-REPT-046 Point Beach Nuclear Plant Units 1 and 2, Aging Management Program Basis Document - Reactor Vessel Internals Revision 0 Final Safety Analysis Report, Section 3.2.3, Including Mechanical and Design Evaluation Year 2015 Version Reactor Internals Design Description (Subsection 3.2.3.1)

Document Title Revision/Date Subsections 3.2.3.1, 3.2.3.2, and 3.2.3.3 Core Components Design Description (Subsection 3.2.3.2)

Evaluation of Core Components (Subsection 3.2.3.3)

NextEra Energy AR No. 02338211 PB-1 Guide Card Re-Evaluation Summary (MRP-227 Component) 03/16/2021 NextEra Energy AR No. 02338063 PB-2 Guide Card Re-Evaluation Summary (MRP-227 Component) 03/16/2021 Westinghouse Non-Proprietary Class 3 Letter No. LTR-REA-20-29-NP Comparison of Point Beach Unit 1 Reactor Internals Fluence Values to Representative 3-Loop Plant for MRP-191, Revision 2 07/07/2020 (Refer to Attachment 21 in ADAMS Accession No. ML20329A264)

Westinghouse Proprietary Class 2 Letter No. LTR-REA-20-29-P Comparison of Point Beach Unit 1 Reactor Internals Fluence Values to Representative 3-Loop Plant for MRP-191, Revision 2 07/07/2020 (ADAMS Accession No. ML20329A273)

NRC Subsequent License Renewal Interim Staff Guidance (SLR-ISG)

Document No. SLR-ISG-2021-01-PWRVI Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized-Water Reactors 01/08/2021 (ADAMS Accession No. ML20217L203)

Westinghouse Non-Proprietary Class 3 Report WCAP-17096-NP-A Fluence Determination with RAPTOR-M3G and FERRET Revision 0 (ADAMS Accession No. ML18204A010)

NRC Letter and Safety Evaluation Final Safety Evaluation for Westinghouse Electric Company Topical Report WCAP-18124-NP-A, Fluence Determination with RAPTOR-M3G and FERRET 06/15/2018 (ADAMS Accession No. ML18156A018 for the cover letter and No. ML18156A066 for the safety evaluation)

Electric Power Research Institute (EPRI) Non-Proprietary Report No. 3002017168 Materials Reliability Program:

Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227, Rev. 1-A) 12/2019 (ADAMS Accession No. ML19339G350)

During the audit, the staff reviewed the applicants exception taken to the scope of program element in GALL-SLR Report AMP XI.M16A. Staff observations made in relation to the applicants exception of the scope of program program element are described below.

During the audit, the staff reviewed the applicants claim that the preventive actions program element is consistent with the corresponding element in GALL-SLR Report AMP XI.M16A. Staff observations made in relation to the preventive actions program element of the Reactor Vessel Internals Program are described below.

During the audit, the staff verified the applicants claim that the parameters monitored or inspected and corrective actions program elements of SLRA AMP B.2.3.7, Reactor Vessel Internals, are consistent with the corresponding elements in GALL-SLR Report AMP XI.M16A.

During the audit, the staff reviewed the applicants enhancements associated with the detection of aging effects, monitoring and trending, and acceptance criteria program elements. Staff observations made in relation to the applicants enhancements of the detection of aging effects, monitoring and trending, and acceptance criteria, program elements are described below.

During the audit, the staff observed the following:

The staff reviewed SLRA AMP Section B.2.3.7, Reactor Vessel Internals, and noted that the AMP takes an exception to the scope of program element in GALL-SLR Report AMP XI.M16A. Specifically, the staff noted that SLRA AMP B.2.3.7 states that the scope of the program applies the methodology and guidance in MRP-227 Revision 1-A (as supplemented by a gap analysis) in lieu of the earlier version of the EPRI MRP guidance in MRP-227-A. The staff also noted that the applicant developed its AMP and the need for the program element exception based on the contents of the version of GALL-SLR Report AMP XI.M16A in NUREG-2191, Volume 2 (GALL-SLR Report, Volume 2). The staff observed that, if the version of GALL-SLR Report AMP XI.M16A in SLR-ISG-2021-01-PWRVI were used as the basis for the AMP, the applicant may not have needed to take an exception in the scope of program element for the AMP, as the updated version of GALL-SLR Report AMP XI.M16A in the SLR-ISG states that the program is based on MRP-227, Revision 1-A, as supplemented by a gap analysis.

The staff discussed this matter during the audit breakout sessions held on March 16 and March 23, 2021. The applicant stated that it may supplement AMP B.2.3.7, Reactor Vessel Internals, to be consistent with the version of GALL-SLR Report AMP XI.M16A, PWR Vessel Internals, in SLR-ISG-2020-01-PWRVI. The staff will evaluate the scope of program element of the Reactor Vessel Internals Program in the SER. The staff made the following observations:

The staff reviewed SLRA Section B.2.3.7, Reactor Vessel Internals, and noted that, in the SLRA AMP, the applicant asserts that the preventive actions program element of the AMP is consistent with the preventive actions program element in GALL-SLR Report AMP XI.M16A, which states (in part) that the program relies on PWR water chemistry control to prevent or mitigate aging effects that can be induced by corrosive aging mechanisms (e.g., loss of material induced by general, pitting or crevice corrosion, or stress corrosion cracking or any of its forms SCC, PWSCC, or IASCC). The staff observed that this creates an apparent inconsistency with the applicants assessment in SLRA Table 3.1.1, Table 1 AMR item 3.1.1.-087, because the applicant did not use the applicable AMR item in the GALL-SLR Report, Table 3.1-1, item 087 as the basis for managing loss of material due to pitting or crevice corrosion in the components. For more information, refer to the staffs audit observations on SLRA AMR item 3.1.1-087 that follows later in this audit report section and provides additional observations on this matter.

The staff noted that, in SLRA Section B.2.3.7, Reactor Vessel Internals, the applicant enhanced the detection of aging effects program element of the AMP as follows:

o detection of aging effects: The SLRA states that the AMP will be enhanced to implement MRP-227, Revision 1-A, as supplemented by the gap analysis or an NRC-approved version of MRP-227, which addresses 80 years of operation if available prior to the subsequent period of extended operation.

o monitoring and trending: The SLRA states that the examination and re-examination schedules in the AMP will be enhanced in accordance with MRP-277, Revision 1-A (as supplemented by a gap analysis).

o acceptance criteria: The SLRA states that the AMP will be enhanced to incorporate the updated examination acceptance criteria, Primary / Expansion links, expansion criteria, and expansion item criteria in MRP-227, Revision 1-A.

During the audit breakout session of March 16, 2021, the staff informed the applicant that these programmatic enhancements may not have been necessary if the version of GALL-SLR Report AMP XI.M16A in SLR-ISG No. SLR-ISG-2021-01-PWRVI had been applied as the basis for the Reactor Vessel Internals Program. During the followup audit breakout session of March 23, 2021, the applicant informed the staff that it may be submitting an SLRA supplement that will adopt the SLR-ISG-2021-01-PWRVI as the basis for SLRA AMP B.2.3.7, Reactor Vessel Internals, and related AMR items in the SLRA. The staff will evaluate the detection of aging effects, monitoring and trending, and acceptance criteria program elements of the Reactor Vessel Internals Program in the SER. The staff had the following observations:

The staff reviewed SLRA Appendix C, Table C.A1 and PBN Basis Document No. LR-AMP-015-RVINT and noted that, in the documents, the applicant identified that the hold-down spring in Unit 2 was made from Type 403 martensitic stainless steel.

During the audit breakout session of March 16, 2021, the staff discussed the material of fabrication for the Unit 1 hold-down spring with the applicant. The applicant confirmed that the hold-down spring in Unit 1 was also made from Type 403 martensitic stainless steel. The applicant clarified that, based on this material of fabrication, the hold-down springs in Units 1 and 2 may be placed in the No Additional Measures category for the program. The staff noted that, in Line Item W8 of Table 4-3 in the MRP-227, Revision 1-A report, the Electric Power Research Institute (EPRI) Materials Reliability Program (MRP) designates that only hold-down springs made from Type 304 austenitic stainless steel need to be inspected under the Primary inspection protocols for Westinghouse-designed hold-down springs in Line Item W8 of the report. The staff had no further inquiries on this matter and this matter was closed for the audit.

The staff reviewed AR Nos. 02242495-1 and 02242495-2 and noted that the ARs discuss the applicants application of Westinghouse Class 3 Non-Proprietary Report No. WCAP (Westinghouse Commercial Atomic Power) 17096-NP as a supplemental methodology for establishing the acceptance criteria and data analysis requirements for the program. During the audit breakout session of March 16, 2021, the staff discussed the use of WCAP-17076-NP with the applicant and the version of the report that that the applicant is currently applying to the Reactor Vessel Internals Program. The applicant clarified and verified that it is currently using the staff-approved version in WCAP-17096-NP-A, Revision 2 as the current version of the PWROGs acceptance criteria and data analysis criteria methodology for the program. The applicant stated that it may convert over to the version of the report in WCAP-17096-NP, Revision 3, if it is approved by the staff, and that, regardless of the version it uses, the applicant will address all conditions on the WCAPs assessment methods for the current staff-approved version of WCAP-17096 that is being applied to the program. The staff observed that the updated version of GALL-SLR Report AMP XI.M16A in SLR-ISG-2021-01-PWRVI permits application WCAP-17096-NP-A, Revision 2, as part of the program because the staff considers it to be a supplemental methodology for these types of AMPs. The staff had no further inquiries on this matter and this matter was closed for the audit.

The staff reviewed AR No. 02245034-1 and noted that the AR identifies the program implements the staff-approved neutron fluence methodology in WCAP-18124-NP-A, Revision 0. The staff discussed the neutron fluence methodology that is being applied to the RVI components with the applicant during the breakout sessions on March 16 and 23, 2021. During the breakout sessions, the applicant confirmed that the neutron fluence projected for the components at 72 effective full power years (EFPY) were bounded by those for the generic 3-Loop PWR in MRP-191, Revision 2, and that the neutron fluence calculations for the RVI components are being performed in accordance with the methods defined in WCAP-18124-NP-A, Revision 0.

Following the audit sessions, the staff verified that Westinghouse Proprietary Class 2 Letter No. LTR-REA-20-29-P provides the applicants benchmarking comparisons for neutron fluence projections that were established for the RVI components, as compared to those derived for the same components in the generic Westinghouse 3-Loop PWR plant design assessed in MRP-191, Revision 2, using the methods in WCAP-18124-NP-A, Revision 0. The staff noted that LTR-REA-20-29-P sufficiently demonstrates that the component-specific neutron fluence projections reported for the RVI components in LTR-REA-20-29-P for 72 EFPY are sufficiently bounded by those established for the corresponding components in the generic 3-loop PWR in MRP-191, Revision 2. The staff also noted that the applicant has performed and completed the benchmarking activities for RVI neutron fluence projections that were requested in the staffs June 15, 2018, safety evaluation for WCAP-18124-NP-A, Revision 0. The staff had no further inquiries on this matter and this matter was closed for the audit.

During the audit of the operating experience program, the staff searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER. The staff did not identify any aging effects or mechanisms outside of the those already identified for the AMP in the parameters monitored or inspected program element for the AMP. The staff discussed the following operating experience related matters with the applicant:

During the audit, the staff reviewed SLRA Appendix C, Table C.A1, Item W6; WO No. 40201462-01; WO No. 40201463-01; AR No. 02193700; AR No. 02442495-03; and AR No. 02245034-02. It discussed relevant operating experience associated with baffle-to-former bolts (BFBs) with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that the BFBs are treated as potentially susceptible components that are subject to ultrasonic test (UT) inspections for cracking, preload, and loss of material effects. The applicant confirmed that the BFBs in Unit 1 were last inspected in 2013, and that the BFBs in Unit 2 were last inspected in 2014.

The applicant stated that the inspections were being implemented in accordance with the applicable guidelines for performing UT inspections of the BFBs at the time of the inspections (i.e., MRP-227-A). The applicant confirmed that any BFBs in which the initial inspections did not yield UT readable results were reinspected with UT several years later. The applicant explained that the past UT inspections of the BFBs in Unit 1 did not result in any observable UT indications that might indicate the presence of defects in the bolts. The applicant stated that the UT inspections of the Unit 2 BFBs revealed observable indications of defects in only 12 to 15 of the bolts. It said the number of bolts with detected defects were not of a sufficient number or percentage to initiate the need for Expansion inspections of the lower support column bolts. The applicant also stated that it evaluated the past BFB UT results against the interim guidance in NSAL-16-1, Revision 1 and stated that the results did not indicate any evidence of degraded bolt clustering, as defined in the NSAL document. The applicant stated that the past UT inspections and inspection results continue to support performance of BFB reinspections on a 10-year augmented inservice inspection (ISI) frequency per the Primary inspection and evaluation (I&E) criteria for the bolts in MRP-227, Revision 1-A. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the BFB operating experience matter and this matter was closed for the audit.

During the audit, the staff reviewed SLRA Appendix C, Table C.A1, item W1; AR No. 01953761; AR No. 02165156; AR No. 02253333; WO No. 40201462-01; and WO No. 40201463-01 and discussed relevant operating experience associated with control rod guide tube (CRGT) assembly guide plates (CRGT guide cards) with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that the CRGT guide cards are treated as potentially susceptible Primary components for loss of material due to wear, and to a lesser extent, as indicators for potential cracking that may occur in the components. The applicant stated that it is using the augmented inspection and evaluation methods in Westinghouse Proprietary Report WCAP-17451-P, Revision 1 as the basis for performing the current CRGT guide card inspections, including potential Expansion inspections of those components designated as the Expansion components for the inspections in the proprietary WCAP report. The applicant explained that the EPRI MRPs basis for evaluating potential wear that may be occurring in the guide cards is based on an aggregate basis. The applicant also identified that the limiting guide cards for wear were the G11 CRGT guide card in Unit 1 and the K07 CRGT guide card in Unit 2.

During the audit breakout session of March 23, 2021, the applicant clarified that any wear or cracking indications in the guide cards were evaluated with the interim guidance in MRP 2018-007 and that the past VT-3 inspections of CRGT guide cards in Units 1 and 2 did not reveal sufficient evidence of wear or cracking in aggregate levels that might induce the applicant to take further corrective actions or reduce the augmented inspection frequency for the components below a 10-year augmented inspection frequency for the components.

Following the audit breakout sessions of March 16 and 23, 2021, the staff reviewed AR Nos. 02338211 and 02338063 and verified that the ARs provide sufficient information to support the applicants decision to perform the next reinspections of the CRGT guide cards in 2022 for Unit 1 and 2023 for Unit 2. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the CRGT guide card operating experience matter and this matter was closed for the audit.

During the audit, the staff reviewed the information in SLR Appendix C; MRP-227, Revision 1-A; NRC ISG No. SLR-ISG-2021-01-PWRVI; and Enercon Report No. FPLCORP-00036-REPT-046 and discussed the EPRI MRP inspection category for the CRGT support pins (CRGT split pins) with the applicant. The staff observed that, in Table 3-3 of the MRP-227, Revision 1-A report, the CRGT split pins only screen in as Existing Program components for the aging effects of cracking due to SCC or loss of material due to wear if the split pins were made from X-750 type nickel alloy materials. During the audit breakout session of March 16, 2021, the applicant informed the staff that the CRGT split pins in Units 1 and 2 were replaced and that the replacement pins are made from Type 316 austenitic stainless steel materials. The staff verified that Table C.3-1 in SLRA Appendix C confirms that the CRGT split pins are made from Type 316 austenitic stainless steel materials. The staff observed that this provides sufficient demonstration that the CRGT split pins may be placed in the No Additional Measures category of the applicants Reactor Vessel Internals Program. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the CRGT split pin inspection category matter and this matter was closed for the audit. The staff had the following observations:

During the audit, the staff reviewed the information in SLR Appendix C, Table C.A1, items W10 and W14, and it discussed relevant operating experience associated with clevis insert assembly components with the applicant. During the audit breakout session of March 16, 2021, the applicant stated that it has been performing VT-3 inspections of the clevis inserts and their components (e.g., dowels and bolts) in accordance with the ASME Code,Section XI requirements for the components. The applicant stated that the past VT-3 inspections did not reveal any evidence of cracking or loss of material in the components, and that the past inspection results continue to support reinspections of the clevis insert assemblies at Units 1 and 2 on a 10-year augmented inservice inspection (ISI) frequency. The applicant also confirmed that the past inspections of the clevis insert assemblies at Units 1 and 2 did not reveal any evidence of distortion occurring in the clevis insert assemblies. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the CRGT split pin inspection category matter and this matter was closed for the audit.

During the audit, the staff reviewed the information in SLR Appendix C, Table C.A2, items W4.2 and W4.3; AR No. 02235758; and AR No. 02321810 and discussed relevant operating experience associated with core barrel axial welds with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that it has included the interim staff guidelines in MRP-2019-009 in the scope of the Reactor Vessel Internals Program. The applicant explained that, even though the core barrel middle axial welds (MAWs) and lower axial welds (LAWs) remain as Expansion category components for the AMP, it will be performing the one-time VT-3 visual examinations of the core barrel MAWs and LAWs in 2022 (for Unit 1) and 2023 (for Unit 2). The staff confirmed that, although the core barrel MAWs and LAWs continue to be designated as Expansion category components per Items W4.2 and W4.3 in Table 4-6 of the MRP-227, Revision 1-A report, the EPRI MRP has recommended that owners of W-design reactor units should perform a one-time VT-3 visual inspection of the core barrel MAWs and LAWs to confirm that cracking has not occurred in the welds. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the relevant operating experience or the applicants planned activities for conducting a one-time VT-3 visual inspection of the core barrel MAWs and LAWs in Units 1 and 2, and this matter was closed for the audit.

During the audit, the staff reviewed the information in SLR Appendix C, Table C.A1, item W11, and discussed relevant operating experience associated with radial support keys with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that, consistent with the EPRI MRP criteria in MRP-2018-022, it has elevated the radial support keys to Primary category components for the program and that it will be performing VT-3 visual inspections of the radial support keys using a 10-year augmented inspection frequency for the components. The staff verified that the inspections of the radial support keys are performed as part of the clevis insert assembly inspections. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries on the inspection category for the radial support keys or the applicants planned activities to perform VT-3 visual inspections of the radial support keys using a 10-year augmented ISI frequency, and this matter was closed for the audit.

During the audit, the staff reviewed the information in SLR Appendix C, Table C.A1, items W15, W16, and W17, and discussed relevant operating experience associated with core plate alignment pins and upper and lower internal assembly fuel alignment pins keys with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that, consistent with the EPRI MRP criteria in MRP-2018-022, core plate alignment pins and fuel alignment pins remain as Existing Program category components for the program and that it will be performing VT-3 visual inspections of the fuel alignment pins and core plate alignments pins using the ASME Code,Section XI inspection requirements for the components. The staff verified that the EPRI MRP calls for the program to implement the ASME Code,Section XI VT-3 visual inspections of these pins using the ASME 10-year ISI frequency set for the inspections.

Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries in regard to the applicants planned activities for performing VT-3 visual inspections of the fuel alignment pins and core plate alignment pins using the ASME Code, Section 10-year ISI frequency for the components, and this matter was closed for the audit.

During the audit, the staff reviewed the information in SLR Appendix C, Table C.A1, item W9 and discussed relevant generic operating experience associated with W-design thermal shield flexures with the applicant. During the audit breakout session of March 16, 2021, the applicant informed the staff that inspection of the thermal shield flexures are performed on a 10-year ISI reinspection frequency and that the past VT-3 inspections of the thermal shields flexures did not identify any evidence of cracking or wear in the thermal shield flexures in Units 1 and 2. The applicant clarified that it is aware of the generic experience (i.e., significant amount of flaw indications detected in the thermal shield flexures at another U.S. Westinghouse-designed PWR) and that it will be reinspecting the thermal shield flexures in Unit 1 in 2022, and the thermal shield flexures in Unit 2 in 2023. The staff verified that the EPRI MRP calls for the program to implement Primary category VT-3 visual inspections of the thermal shield flexures using a 10-year augmented ISI frequency, as established in Item W9 of Table 4-3 in the MRP-227, Revision 1-A report. Based on is its review of the relevant documents and the applicants explanations, the staff had no further inquiries regarding the applicants planned activities for performing VT-3 visual inspections of the thermal shield flexures using a 10-year augmented ISI frequency for the components, and this matter was closed for the audit.

The staff also audited the description of the SLRA Appendix A, Section 16.2.2.7, Reactor Vessel Internals, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

STAFF REVIEW OF AMR DETAILS Summary of Information in the Application. During the audit, the staff reviewed the AMR items and plant documentation associated with SLRA Table 3.1.2-2, Reactor Vessel Internals -

Summary of Aging Management Evaluation. The table below lists the documents that the staff reviewed and found to be relevant to the review of these items. These documents were provided by the applicant, constitute staff, or industry documents related to PWR RVI components that are listed. They include, as applicable, NRC records in the NRCs Agencywide Documents Access and Management System (ADAMS).

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date NRC Subsequent License Renewal Interim Staff Guidance (SLR-ISG)

Document No. SLR-ISG-2021-01-PWRVI Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized-Water Reactors 01/08/2021 (ADAMS Accession No. ML20217L203)

NUREG-2191, Volume 1 Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report 02/07/2017 (ADAMS Accession No. ML16274A389)

Electric Power Research Institute (EPRI) Report No. 3002017168 Materials Reliability Program:

Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227, Revision 1-A) 12/2019 (ADAMS Accession No. ML20175A112)

During the audit, the staff observed the following, relative to the AMR items that the applicant included in SLRA Tables 3.1.1 and 3.1.2-2 for RVI components:

The staff observed that the applicant developed its AMR items for the RVI components based on a comparison of the AMR items for Westinghouse-design RVI components in Table 3.1-1 of the SRP-SLR report and in Table IV.B2 of the GALL-SLR Report. The staff also observed that the applicant had developed its SLRA prior to the date of the staffs issuance of updated ISG for Westinghouse-design RVI components in ISG No. SLR-ISG-2020-01-PWRVI. The staff noted that the applicants set of AMR items for the components were consistent with updated versions of the AMR items for Westinghouse-design RVI components in Appendices A and B.1 of the ISG, with the exception of the following SLRA Table 3.1.1 or Table 3.1.2-2 AMR items included in the SLRA:

o AMR item for managing loss of material in Westinghouse-design control rod guide tube (CRGT) assembly support pins (split pins) in SLRA Table 3.1.1, item 3.1.1, 028 o AMR item for managing RVI loss of material due to pitting or crevice corrosion, as given in SLRA Table 3.1.1, item 3.1.1, 087 o AMR item for core barrel outlet nozzles in Table 3.1.2-2 (SLRA page 3.1-76) o AMR items for the bottom mounted instrument (BMI) column bodies in SLRA Table 3.1.2-2 (SLRA page 3.1-77) o AMR items for CRGT assembly lower flange welds (LFWs) in SLRA Table 3.1.2-2 (SLRA pages 3.1-78 and 3.1-79) o plant-specific AMR items for the clevis insert wear surfaces in SLRA Table 3.1.2-2 (SLRA page 3.1-75) o plant-specific AMR item for the upper core plate alignment pins in SRLA Table 3.1.2-2 (SLRA page 3.1-76) o plant-specific AMR item for the radial support keys in SLRA Table 3.1.2-2 (SLRA page 3.1-84 The staff will provide its evaluation of the GALL-SLR Report-based AMR items for the RVI components in SER Section 3.1.2.2.9.

In SLRA Table 3.1.1, AMR item 3.1.1, 028, the applicant states that SRP-SLR Table 3.1-1, item 028 was not used for the SLRA because the CRGT split pins in the reactor units are designated as No Additional Measures components for the applicants Reactor Vessel Internals Program. The staff noted that, in the updated version of SRP-SLR Table 3.1-1, AMR item 028 in Appendix A of SLR-ISG-2021-01-PWRVI, the staff updated the item to account for the fact that the CRGT split pins could be designated No Additional Measures components if they involved replaced pins made from austenitic stainless steel (e.g., Type 316 or 316L stainless steels). Thus, the staff noted that the applicant could still adopt SRP-SLR Table 3.1.1, item 028 and use the applicable GALL-SLR Report item for Westinghouse-design No Additional Measures components (i.e., GALL-SLR Report item IV.B2.RP-265) if the applicant had replaced the original X-750 split pins with split pins made from stainless steel materials and used the updated version of SRP-SLR Table 3.1.1, item 028 in the SLR-ISG. The staff discussed this matter with the applicant during the audit breakout session. The staff will provide its review of SLRA item 3.1.1, 028 in SER Section 3.1.2.2.9.

In SLRA Table 3.1.1 AMR item 3.1.1-087, the applicant states that the staffs SRP-SLR item (i.e., AMR item 087 in SRP-SLR Table 3.1-1) for managing loss of material due to pitting or crevice corrosion in the RVI components was not applicable and not used for development of the AMR items for RVI components in the SLRA. The staff observed that the applicant made its applicability conclusion for SLRA item 3.1.1, 087 based on the following statements:

Loss of material for reactor vessel internal components exposed to reactor coolant and neutron flux is addressed in rows 3.1-1, 059a, 3.1-1, 059b, 3.1-1, 059c, and 3.1-1, 119. While these items address loss of material due to wear, the reactor vessel internals AMR depends on the screening performed in MRP-191 which does not distinguish loss of material mechanisms.

The staff discussed this matter with the applicant during the audit breakout session for the AMP because: (1) the methodology in MRP-227, Revision 1-A, only assesses the RVI components in terms of the aging mechanisms that the report methodology is used to manage, and (2) MRP-227, Revision 1-A, does not include pitting or crevice corrosion as an assessed aging mechanism in Section 3.2. The staff will provide its review of SRLA Table 3.1.1, item 3.1.1-028 in SER Section 3.1.2.2.9.

The staff noted that the applicant includes an AMR item on loss of material of the bottom mounted instrumentation (BMI) column bodies on SLRA page 3.1-77. The staff performed an audit comparison of this item to the corresponding AMR and management criteria in Item W2.2 of Table 4-6 of the MRP-227, Revision 1-A. The staff observed that, in Item W2.2 of the MRP-227, Revision 1-A report, the EPRI MRP identifies that irradiation embrittlement (IE) is an applicable aging effect and mechanism combination for the BMI column bodies. During the audit breakout session with the applicant on the Reactor Vessel Internals Program, the staff discussed the non-cracking effects (and mechanisms) that may be applicable to the BMI column bodies with the applicant and whether they should include loss of fracture toughness (due to IE) in addition to loss of material. The staff will provide its review of the AMR bases for the BMI column bodies in SER Section 3.1.2.2.9.

The staff noted that the applicant includes an AMR item on loss of material and an AMR item on cracking of the core barrel outlet nozzles on SLRA page 3.1-80. For the item on cracking, the applicant cross-references the item to the AMR item criteria in SRP-SLR Table 3.1-1, item 053b and to GALL-SLR Report item IV.B2.RP-278, citing Nuclear Energy Institute (NEI) Note B as the consistency basis for the line item. For the item on loss of material, the applicant cross-references the item to the AMR item criteria in SRP-SLR Table 3.1-1, item 059b and to GALL-SLR Report item IV.B2.RP-290b, citing NEI Note D as the consistency basis for the line item.

The staff also noted that, in MRP-227, Revision 1-A, the EPRI MRP removed the core barrel outlet nozzles as designated Expansion category components for the Primary programmatic inspections applied to the peripheral CRGT lower flange welds and downgraded the inspection category basis for core barrel outlet nozzles to the No Additional Measures category. The staff observed that, based on the cross-referencing to items 053b and 059b in SRP-SLR Table 3.1-1, the items for the core barrel outlet nozzles could potentially be interpreted to connotate that the outlet nozzles are Expansion category components for the Reactor Vessel Internals Program because the referenced 053b and 059b items are the staffs cracking and non-cracking commodity group items for Westinghouse-design Expansion category components. Thus, during the audit breakout session with the applicant, the staff discussed the EPRI MRP inspection category that is being applied to the core barrel outlet nozzles in the SLRA and whether the two items for the core barrel outlet nozzles are cross-referencing to the proper GALL-SLR Report and SRP-SLR items for the components (as updated in ISG No. SLR-ISG-2021-01-PWRVI). The staff will provide its review of the AMR bases for the core barrel outlet nozzles in SER Section 3.1.2.2.9.

The staff noted that, on SLRA page 3.1-82, the applicant includes an AMR item on cracking of the core barrel upper girth welds (UGWs), in which the applicant credits the Reactor Vessel Internals to manage cracking in the UGWs during the subsequent period of extended operation. The staff observed that in this AMR line item, the applicant cross-references the AMR item to SLRA Table 3.1.1, item 3.1.1, 053a, which designates the UGWs as Primary category components for the applicants AMP. However, the staff also observed that this basis is not consistent with the aging management basis for the core barrel UGWs in item W3.1 of SLRA Appendix C, Table C.A-2, which designates the core barre UGWs as Expansion category components for the applicants AMP.

Thus, during the audit breakout session with the applicant, the staff discussed the EPRI MRP inspection category being applied to the core barrel UGWs with the applicant and whether the AMR item on cracking of the core barrel UGWs is cross-referencing the proper GALL-SLR Report and SRP-SLR items for the core barrel UGWs (as updated in ISG No. SLR-ISG-2021-01-PWRVI). The staff will provide its review of the AMR basis for the core barrel UGWs in SER Section 3.1.2.2.9.

The staff noted that the applicant includes a plant-specific AMR item on loss of material and a plant-specific AMR item on cracking of the clevis insert assembly stellite wear surfaces on SLRA page 3.1-75. The staff noted that the applicants AMR item on cracking of the clevis insert assembly wear surfaces is consistent with the staffs updated version of GALL-SLR Report item IV.B2.RP-399 in ISG No. LR-ISG-2021-01-PWRVI. The staff also noted that the applicants AMR item on loss of material of the clevis insert wear surfaces was consistent with the staffs updated version of GALL-SLR Report item IV.B2.RP-285 in ISG No. LR-ISG-2021-01-PWRVI.

However, the staff observed that, during its update of GALL-SLR Report item IV.B2.RP-285 in ISG No. SLR-ISG-2021-01-PWRVI, it also included changes in dimension due to distortion as a potential aging effect and mechanism combination for the clevis insert assembly wear surfaces; the staffs inclusion of changes in dimension in the updated version of the RP-285 AMR item was based on a recent report of distortion being detected in one of the clevis insert assemblies at an NRC-licensed PWR. Thus, during the audit breakout session with the applicant, the staff discussed the generic operating experience involving clevis insert distortion with the applicant and whether it would have any impact on the plant-specific non-cracking AMR item for the clevis insert wear surfaces on SLRA page 3.1-75. The staff will provide its evaluation of the plant-specific AMR items for the clevis insert wear surfaces in SER Sections 3.1.2.3 or 3.1.2.2.9, provided that the applicant amends the SLRA to adopt the applicable GALL-SLR Report items for the clevis insert assembly surfaces in SLR-ISG-2021-01-PWRVI.

The staff noted that the applicant includes a plant-specific AMR item on loss of material of the upper core plate alignment pins on SLRA page 3.1-. The staff noted that the applicants plant-specific AMR item on loss of material of the core plate alignment pins is consistent with the staffs existing version of item IV.B2.RP-299 in Table IV.B2 of the GALL-SLR Report. The staff noted that the applicant also included a GALL-SLR Report-based item on cracking of the upper core plate alignment pins in which the applicant crosslinked the AMR item to SLRA item 3.1.1, 053c and GALL-SLR Report item IV.B2.RP-355, citing NEI Note D as the consistency basis for the line item. The staff observed that the applicants AMR item on cracking of the upper core plate alignment pins was consistent with the staffs updated version of GALL-SLR Report item IV.B2.RP-301 in ISG No. SLR-ISG-2021-01-PWRVI. The staff will provide its evaluation of the plant-specific AMR item on loss of material due to wear of the upper core plate alignment pins in SER Sections 3.1.2.3, or 3.1.2.2.9, provided that the applicant amends the SLRA to adopt GALL-SLR Report item IV.B2.RP-299 as the basis for managing loss of material due to wear in the core plate alignment pins.

The staff noted that the applicant includes a plant-specific AMR item on cracking and loss of material and a plant-specific item on wear of the radial support keys on SLRA page 3.1-84. The staff noted that neither the GALL-SLR Report nor SLR-ISG-2021-01-PWRVI includes any AMR items for these components. The staff will provide its evaluation of the plant-specific AMR items for the radial support keys in SER Section 3.1.2.3.

SLRA AMP B.2.3.8, Flow-Accelerated Corrosion Summary of Information in the Application. The SLRA states that AMP B.2.3.8, Flow-Accelerated Corrosion, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion.

To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Flow-Accelerated Corrosion Program. The applicant provided these documents and? the staff identified them as relevant to the Flow-Accelerated Corrosion Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date N/A Point Beach Nuclear Plant Unit No. 1, Spring 2019 Refueling Outage U1R38, Flow-Accelerated Corrosion Pass 2 Report N/A CSI-FAC-PBN-2-36 Point Beach Nuclear Plant Unit No. 2, Fall 2018 Refueling Outage U2R36, Flow-Accelerated Corrosion Outage Report Revision 0 12/03/2018 N/A Master System Health Report - FAC 03/08/2020 Work Orders (WO) 40357758-02, -07, -12 Nondestructive Examination of Secondary Components FAC Exams 03/12/2016 Action Request (AR) 1632159 FAC with Component Below 87.5 percent Nominal Wall 03/22/2011 AR01634111 Wall Thinning of High Pressure Turbine Governor Valve Drain Line 03/27/2011 AR1697765 Replace IMSEB04-100 Due to Wall Thinning 10/18/2011 AR1858564 Replace 90 Elbow 1FDEB06-055 03/21/2013 AR1996497 Wall Thinning on IOS-6-EB-4-23-87 10/6/2014 AR2230479 U1R37 Thin Spots on 1FDEB06-113 10/15/2017 AR2308331 Replaced of FAC Location 1MSEB04-065 04/01/2019 AR2320950 2MS-74A Leakby Identified 07/15/2019 WO40408887-03 01-HB-6A4 SHT. 1 / FAC Exam (UT) 03/31/2016 AR2304521 Negative Trend in Fleet Engineering Program Implementation 03/06/2019 During its audit, the staff interviewed the applicants staff, reviewed documentation provided by the applicant, the licensee, and other documentation relevant to the Flow-Accelerated Corrosion Program. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date FPLCORP00036-REP T-047 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Flow-Accelerated Corrosion Revision 0 11/19/2020 17-0299-TR-001 Flow Accelerated Corrosion Program - System Susceptibility Evaluation Revision 0 01/2019 17-0299-TR-002 Flow Accelerated Corrosion Program - Susceptible Non-Modeled (SNM) Analysis Revision 0 01/2019 ER-AA-111 Flow-Accelerated Corrosion (FAC) Program Revision 3 ER-AA-111-1000 Flow-Accelerated Corrosion (FAC) Activities Revision 4 ER-AA-111-1001 Feedwater Heater Shell Inspection for Detection of Flow-Accelerated Corrosion Revision 0 Document Title/Description Revision/Date N/A Program Owner Interview Form 02/10/2020 During the audit, the staff verified the licensees claim that, the preventive actions and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the detection of aging effects and corrective actions program elements not associated with the enhancements identified in the SLRA or by the staff during the audit, are consistent with the corresponding program elements in the GALL-SLR Report AMP.

In addition, the staff found that, for the scope of program, parameters monitored or inspected, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements in the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Flow-Accelerated Corrosion Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP XI.M18, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. A search of the applicants operating experience database was conducted using these key words: bolt, leak, submerge, moly, and loss. No significant plant-specific operating experience associated with the Bolting Integrity Program was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-048 Subsequent License Renewal Aging Management Program Basis Document - Bolting Integrity Revision 0 FP-E-SE-04 System Engineering Walkdowns Revision 12 Document Title Revision/Date DG-M18 Fastener Design Guideline Revision 4 MI 32.1 Flange and Closure Bolting Revision 26 PBF-9142 Point Beach Nuclear Plant Bolting - Torque and Loading Revision 5 MI 32.14 Visual Inspections for License Renewal Revision 6 NDE-701 Visual Examination of Components in Support of License Renewal Revision 3 ISI CL 1, 2, 3 Point Beach Nuclear Power Plant Class 1, 2, and 3 Inservice Inspection Program Fifth Inservice Inspection Interval Revision 15 AR 01392091 G-500 Torque Converter Cooler Head Cracks While Filling G500 Coolant System, Mechanics Noted Leaks At Two Flange Connections 07/02/2010 AR 01704960 IP-029 Replace Remaining Mounting CAP Screws 11/09/2011 AR 02230085 Excessive Leakage at body to Bonnet Diaphragm on IWL-1721 10/12/2017 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the detection of aging effects and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed FPLCORP00036-REPT-048 and SLRA Section B.2.3.9 and noted that the basis describing why the operating conditions at each unit are similar was not sufficient to justify the acceptability of the proposed reduction in the number of inspections. The staff will review a voluntary supplement and/or consider issuing an RAI to obtain the information necessary to verify consistency.

During the audit of the operating experience program element, the staff reviewed the plant-specific database search results to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Bolting Integrity Program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA Bolting Integrity Program. The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B.2.3.10, Steam Generators, is an existing program with an exception and an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M19, Steam Generators.

To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancement associated with this AMP. The staff will document its review of the exception and enhancement to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Steam Generators (SGs) Program. The documents were provided by the applicant or were identified by the staff to be relevant to the SGs program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date ML19287A002 Unit 1 Spring 2019 Steam Generator Tube Inspection Report (U1R38) 10/12/2019 ML17264A354 Unit 2 Spring 2017 Steam Generator Tube Inspection Report (U2R35) 09/21/2017 N/A PBN Program Owner Interview Form - XI.M19 Steam Generator Integrity 02/10/2020 ML20097E887 Point Beach Nuclear Plant, Unit 1 - Review of the Spring 2019 Steam Generator Tube Inspections During Refueling Outage 38 (EPID L-2019-LRO-0084) 04/17/2020 ML18095A899 Point Beach Nuclear Plant, Unit 2 Review of The Spring 2017 Steam Generator Tube Inspection Report (EPID:

L-2017-LRO-0033) 04/20/2018 FPLCORP00036-REP T-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 08/26/2020 Action Request (AR) 2324396-12 Aging Management Program (AMP) Effectiveness Review and Assessment Worksheet - PBNP License Renewal 08/28/2019 AR 02230281 Recordable Indication on Steam Generator A Support 10/13/2017 AR 02328341 LR2019 Phase IV - Steam Generator Feeding Support Inspections 09/18/2019 AR 02370320 Liquid Penetrant Examination of the Unit 1 B Steam Generator Bowl Drain Welds and Piping 10/04/2020 AR 02351418 Active Boric Acid Leak Identified in Unit 1 Containment 04/05/2020 AR 02370198 1RC-526B, As-Found Boric Acid Leak 10/03/2020 AR 02298916 Unit 1 SGA and SGB Exceeded 8 PPM Admin Limit for ETA 01/23/2019 During its audit, the staff interviewed the applicants staff, reviewed documentation that the applicant provided, and other documentation relevant to the SGs Program. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date Master System Health Report Q4-2019 Steam Generators 03/09/2020 Master System Health Report Q1-2020 Steam Generators 03/09/2020 FPLCORP00036-REP T-049 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Steam Generators Revision 0 11/6/2020 NP 7.7.16 Steam Generator Program Revision 19 10/22/2019 NP 7.7.17 Requirements for Steam Generator Primary Side Activities Revision 21 NP 7.7.18 Requirements for Steam Generator Secondary Side Activities Revision 14 NP 3.2.4 Primary to Secondary Leak Rate Monitoring Program Revision 10 SEM 7.11.20 Eddy Current Testing of the Unit 1 Steam Generators Revision 15 ER-AP-121 Steam Generator Integrity Revision 8 SG-CDMP-19-8 Point Beach Unit 1 U1R38 Condition Monitoring and Operational Assessment Revision 0 04/2019 SG-SGMP-16-20 Point Beach U2R35 Steam Generator Degradation Assessment Revision 0 03/2017 SEM 7.11.21 Sludge Lancing and Bundle Flush of the Unit 2 Steam Generators Revision 7 SEM 7.11.22 Unit 1 2 Steam Generator Secondary Side Visual Inspections Revision 7 NP 7.7.33 Implementation of the Steam Generator Program Revision 5 FPLCORP00036-REP T-009 Point Beach Units 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review -

Steam Generators Revision 0 11/06/2020 Technical Requirements Manual Section 4.8, Steam Generator Tube Surveillance Program Revision 3 01/2016 During the audit, the staff verified the licensees claim that, the preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program and parameters monitored or inspected program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The carbon steel seismic lugs, transition cone, steam outlet nozzle, and feedwater nozzle are at elevations above the reactor coolant piping; therefore, they are not exposed to an air with borated water leakage environment.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA SGs Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.11, Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B2.3.11, Open-Cycle Cooling Water System, is an existing program with an exception and enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. The applicant performed a search of its operating experience database using a standard set of keywords and provided the results to the NRC staff for review. The table below lists the documents that the staff reviewed and found to be relevant to the Open-Cycle Cooling Water System Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02325784 Effectiveness Review of -OCCW Program Found SW ISI Annual Report was not performed for 2018 08/26/2019 AR2286065 QA Report on CFC HXs-015-A1-A8 05/14/2019 AR02324396-06 AMP Effectiveness Review of OCCW 03/21/2018 PMCR2131765 Change PM Frequency for CFC/Motor Cooler Inspections 05/13/2016 AR01385147 1HX-15A1-8, CFC, Tube Blockage Exceeds Limits 03/14/2010 AR01366158 Corrective actions for degraded carbon steel HXs 05/30/2009 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP-36-REPT-050 Point Beach Units 1 and 2 SLR AMP Program Basis Document - Open Cycle Cooling Water Revision 0 GL 89-13 Generic Letter 89-13 Program Document Revision 19 Document Title Revision/Date NP 7.7.22 SW and FP Inspection Program Revision 8 NP 7.7.15 Biofouling Control Methods Revision 9 NP 3.2.8 Open Cooling Water Systems Optimization Plan Revision 4 DBD-12-029 (SW)

SW Design Basis Document Revision 29 HX-01 Heat Exchanger Condition Assessment Program Revision 8 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA Open-Cycle Cooling Water System AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the parameters monitored or inspected program element not associated with the exception identified in the SLRA are consistent with the corresponding program element in the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the results provided by the applicant of the operating experience database, to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP for the Open-Cycle Cooling Water System provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP for the Closed Treated Water Systems. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.12, Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B2.3.12, Closed Treated Water Systems, is an existing program with exceptions and enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems, and the enhancements, in the SER.

Audit Activities. The applicant performed a search of its operating experience database using a standard set of keywords and provided the results to the staff for review. The table below lists the documents that the staff reviewed and found to be relevant to the Closed-Treated Water Systems Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02324396-08 Effectiveness Review of Closed Cycle Cooling Water System Surveillance Program Basis Document for LR 08/26/2019 Document Title Revision/Date AR02241723-15 Effectiveness Review of Closed Cycle Cooling Water System Surveillance Program Basis Document for LR 02/27/2018 AR02251707 LR-AMP-023-CCCW Surveillance - Need to Update Item PB 11-0071 as This Item Was Cancelled 08/17/2016 AR01840042 HX-12B - Small Pits on Gasket Sealing Surfaces 01/16/2013 AR01385133 Tube Vibration Damage in RHR HX-11A 03/13/2010 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP000-36-REP T-051 Point Beach Units 1 and 2 SLR AMP Program Basis Document - Closed Treated Water Systems Revision 0 1007820 EPRI Closed Cooling Water Chemistry Guideline Revision 1 3002000590 EPRI Closed Cooling Water Chemistry Guideline Revision 2 During the audit, the staff verified the licensees claim that scope of program, preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA Closed Treated Water System AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the parameters monitored or inspected program element not associated with the exception identified in the SLRA are consistent with the corresponding program element in the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the results the applicant provided of the operating experience database, to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP for the Closed Treated Water Systems provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.13, Inspection of Overhead Heavy Load Handling Systems Summary of Information in the Application. The SLRA states that AMP B2.3.13, Inspection of Overhead Heavy Load Handling Systems, is an existing AMP with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. The staff asked the applicant to search its operating experience database using the keywords: lifts, hoist, and 7.7.9. The table below lists the documents that the staff reviewed and found to be relevant to the AMP Section B.2.3.13, Inspection of Overhead Heavy Load Handling Systems. The applicant provided these documents in its ePortal, or they were identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 01353413 Stud and Nut Fell From Above When Positioning Polar Crane (Z-013) 10/16/2008 AR 01362819 Structural Issue with Z-015 PAB Crane 03/31/2009 AR 01363822 Bolting on the Z-016 PAB Crane 04/17/2009 AR 01366778 PAB Crane Is Not In Accordance with Drawing C-332 06/10/2009 AR 01367892 PAB Superstructure May Need Additional Reinforcement East of SFP 06/30/2009 AR 01368219 Hoist Separation from Lift Beam During P-032E SW Pump Maintenance 07/08//2009 AR 01619071 Turbine Building Overheld Crane (Z-014): Missing Rail Clamp Bolts on West Side Locations 167, 153, 140 02/11/2011 AR 01627060 Replace the Polar Crane (Z-013) Bridge Drive Axle Coupling Bolts 03/07/2011 AR 01627331 Z-013 Polar Cane Drive Coupling on G1 and G2 Output Shaft Require Replacement 03/08/2011 AR 01627505 Unit 2 Polar Crane Making Abnormal Noises.

03/09/2011 AR 01819810 Z-13 Crane rail moves in excess of 2RMP-9118-1 11/03/2012 AR 01823911 Adjust rail clips for polar crane Z-013 11/15/2012 AR 01942554 Z-12 Inspection Results 02/20/2014 AR 02118276 Z-994 Damaged fastener 03/17/2016 AR 02197229 R-1 Reactor Vessel Internals: Residue & Peeling paint, FME concerns.

04/07/2017 AR 02329787 Repair Coatings on WVS-24 Transfer Cask 09/30/2009 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date PBN UFSAR Point Beach Nuclear Plant Units 1 & 2 Final Safety Analysis Report 2012 FPLCORP00036-REP T-064 Point Beach Units 1 and 2 SLR AMP Basis Document -

Inspections of Overhead Heavy Load Handling Systems Revision 0 FPLCORP00036-REP T-060 Point Beach Units 1 and 2 SLR AMP Basis Document -

Structures Monitoring Revision 0 FPLCORP00036-REP T-039 - Keyword Searches Revision 1 NP 8.4.7 Control of Safe Load Path and Rigging Manual Revision 15 NP 7.7.9 Facilities Monitoring Program Revision 21 MWP 148 G-03 G-04 EDG Room Crane Inspection Revision 13 NDE-701 Visual Examination of Components in Supports of LR Revision 3 1RMP 9118-1 Containment Building Crane OSHA Operability Inspection Revision 15 2RMP 9118-1 2Z-013, Containment Building Crane OSHA Operability Inspection Revision 16 1RMP 9096-1 Reactor Vessel Head Removal and Installation Using BIACH Tensioning System Revision 26 2RMP 9096-1 Reactor Vessel Head Removal and Installation Using BIACH Tensioning System Revision 21 RMP 9002-1 Reactor Coolant Pump Motor Removal and Installation Revision 59 PBF-9060C Reactor Coolant Pump Motor Lift Rig Revision 9 RMP 9119 Auxiliary Building Crane Inspection Revision 27 RMP 9120 Turbine Building Crane Inspection Revision 15 Health Report - Structures Master System Health Report (Total: 94.75)

Q1-2020 NRC Inspection Report - IP 71003 PBN Plant, Unit 1, Post-Approval Site Inspection for LR Inspection Report 05000266/2010-0118 10/8/2010 NRC Inspection Report - IP 71003 PBN Plant, Unit 2, Post-Approval Site Inspection for LR Inspection Report 05000301/2013-008 03/18/2013 LR-AMP-022-STRMON Structures Monitoring Program Basis Document for LR Revision 10 Wisconsin Electric Power Company Response to NRC Bulletin 96-02 Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related Equipment, Point Beach Nuclear Plant, Units 1 and 2.

05/09/1996 CMAA Specification

1. 70, From the NextEras ePortal Specifications for Electric Overhead Traveling Cranes -

NextEra considered Class B (Light Service) 2000 PBN Program Owner Interview Overhead Heavy Load and Light Load Handling Systems.

02/05/2020 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the SLRA AMP are consistent with or will be consistent with enhancement(s) with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the acceptance criteria and corrective actions program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed FPLCORP00036-REPT-064, Revision 0, and noted that the applicant stated throughout this basis document that.2005 Edition of ASME B30.2, or other applicable industry standard in the ASME B30 series. However, it was not clear to the staff which of the ASME B30 standards are applicable for the B2.3.13, Inspection of Overhead Heavy Load Handling Systems. During the breakout session, the applicant stated that it will revise its procedures to refer to the applicable standard(s) of the ASME B30 series.

During the audit of the operating experience program element, the staff reviewed the plant-specific database search results to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement in Section 16.2.2.13, Inspection of Overhead Heavy Load Handling Systems. The staff verified this description is consistent with the description provided in the GALL-SLR Report, Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs.

SLRA AMP B.2.3.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.3.14, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Compressed Air Monitoring Program. The applicant provided these documents.

The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02238594 T-60D EDG Air Receiver Wall Thickness Below TMIN 12/17/2017 AR02131722 IA [Instrument Air] Samples Have Particulates Larger Than 40 Microns 05/13/2016 AR2262609 License Renewal Aging Management Program Effectiveness Reviews Revision 3 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-065 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Compressed Air Monitoring Revision 0 0-PT-IA-003 Periodic Sampling for Instrument Air Quality Revision 8 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Compressed Air Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.15, Fire Protection Summary of Information in the Application. The SLRA states that AMP B.2.3.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Fire Protection Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date Action Request (AR) 01623991 Degraded Fire Seal Between Primary Auxiliary Building and Auxiliary Feedwater Pump Room 02/25/2011 Work Order (WO) 00381971, Task No. 25 EC 13403, Phase 2 Firewrap for D04-7 01/09/2012 (Complete)

AR02236169 Grout Seal for Penetration in Vital Switch Gear Room Damaged, Blockout Cracked 11/14/2017 AR02247880 Penetration M-7-3-15-N11 Grout has Crack 02/05/2018 AR02254207 NRC Identified Surface Cracking in Penetration Seal 03/14/2018 AR02297058 Triennial Fire Protection Inspection 01/08/2019 AR02152508 Fire Penetration Seals Not Inspected 08/26/2016 AR02164269 Work Request for Fire Protection Component Inspections 10/21/2016 Document Title/Description Revision/Date AR02045825 Damaged Fire Barrier Seal 05/06/2015 AR02153752 Fire Barrier Materials Not Approved for use by NP 3.1.1 09/01/2016 AR02115101 Crack in Turbine Building Wall and Penetration 03/04/2016 During its audit, the staff interviewed the applicants staff, reviewed documentation that the applicant provided, and other documentation relevant to the Fire Protection Program.

SLRA AMP B.2.3.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B.2.3.16, Fire Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M27, Fire Water System. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Fire Water System Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date AR1307840 Sprinkler Piping Inspection 11/22/2006 AR1307837 Sprinkler Head Replacement or Inspection 11/22/2006 WO40558669 50-Year Sprinkler Head Testing N/A AR01907108 Pinhole Leak in Fire Sprinkler Line 09/26/2013 AR01372922 Buried Fire Protection Piping Inspection Results (Portion of Piping Missing Coating) 09/28/2009 AR01860519 NRC IN 2013-06 Corrosion in FP Piping Due to Air and Water 03/27/2013 AR01874286 Fire Sprinkler Internal Piping Inspection 05/14/2013 AR01827881 Fire Header Piping is Submerged and Corroded 11/28/2012 AR02252399 Corrosion Downstream FP-33 and FP-36 Header Isolation Valves 03/02/2018 AR02287092 Standing Water in North and South Fire Protection Chases 10/21/2018 AR02291517 North and South Fire Protection Chases Require Pumping 11/18/2018 AR02297675 Water Found Above North Fire Protection Piping Chase 01/13/2019 AR02298598 Standing Water in North and South Fire Protection Chases 01/20/2019 AR02326438 Water in Circulating Water Pumphouse Fire Water Piping Pit 09/01/2019 Document Title/Description Revision/Date AR2262609 License Renewal Aging Management Program Effectiveness Reviews 04/23/2018 AR02241723 Effectiveness Review of Point Beach License Renewal Programs 12/21/2017 AR2321547 NFPA 805 PRA Results Update 07/18/2019 AR2040202 FH-30 Significant Leak 04/13/2015 AR02250272 Corrosion Identified on P-035B-E Fuel Oil Lines 02/19/2018 During its audit, the staff interviewed the applicants staff, reviewed documentation that the applicant provided, and other documentation relevant to the Fire Water System Program. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title/Description Revision/Date FPLCORP00036-REP T-066 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fire Water System Revision 0 11/06/2020 N/A PBN Program Owner Interview Form - Fire Water System N/A N/A Fire Water System Interview Notes 02/05/2020 NP 7.7.22 Service Water and Fire Protection Inspection Program Revision 8 PC 73 Part 2 Monthly Surveillance of Fire Hose Stations Revision 28 PC 78 Part 2 Fire Main Pressure Maintenance Equipment Surveillance Revision 4 01/23/1995 PC 78 Part 6 Quarterly North Service Building Automatic Sprinkler and Alarm Test Revision 10 TS 76 Quarterly Automatic Sprinkler and Water Spray System Surveillance Test Revision 28 0-PT-FP-005 Annual Underground Fire Main Flow Test Revision 15 0-PT-FP-002 Diesel Engine-Driven Fire Pump Functional Test Revision 28 0-PT-FP-004 Annual Fire Pump Capacity Test Revision 21 N/A Sprinkler Systems Replacement Report N/A During the audit, the staff verified the licensees claim that the scope of program and preventive actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

In addition, the staff found that for the parameters monitored or inspected program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

Plant-specific operating experience appears to show recurring internal corrosion of fire water system piping.

Raw water is not an applicable environment for the gray cast iron compressor casing because it is upstream of the accumulator tank and separated from raw water by two check valves.

The accumulator tank is mounted on a stand; therefore, the tank bottom is not exposed to concrete.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Fire Water System Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.17, Outdoor and Large Atmospheric Metallic Storage Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Outdoor and Large Atmospheric Metallic Storage Tanks Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WO 40707125 T-072 NDE Thickness Exams External Inspection 11/04/2020 AR01366027 Integrity Testing/Inspection Reports on Oil Storage Tanks 01/07/2016 AR01399942 T-32A Internal Coating/Lining Degradation 11/22/2010 AR01400258 T-32B Internal Coating/Lining Degradation 11/23/2010 uring its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-053 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Outdoor and Large Atmospheric Metallic Storage Tanks Revision 0 C-142_R20 Auxiliary Bldg South Wing & Façade Plan at Elevation 6-6

& 8-0 Revision 20 C-144_R08 Auxiliary Bldg North Wing Plan at Elevation 8-0 & 1-0 Revision 8 DWG L-23944 CST Drawing Revision 9 DWG L-24015 1T13 RWST Assembly & Details Revision 7 PC 49 Part 4_R32 Auxiliary Building Miscellaneous and Facades Revision 36 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the plant-specific information associated with this AMP. The applicant provided this information on its ePortal. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also reviewed the summary description of the program provided in SLRA Appendix A, UFSAR Supplement, Section 16.2.2.17, Outdoor and Large Atmospheric Metallic Storage Tanks. The staff verified this description is consistent with the corresponding program description in GALL-SLR Report Table XI-01.

SLRA AMP B.2.3.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B2.3.18, Fuel Oil Chemistry, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. The table below lists the document and pictures that the staff reviewed and found to be relevant to the Fuel Oil Chemistry Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date CR FPL COR 00036-REPT-054 Point Beach Subsequent License Renewal Project - Aging Management Program Evaluation Report - Fuel Oil Chemistry 11/19/2020 Document Title Revision/Date Descriptions of Tanks (PDF format pictures)

T-30 Diesel Driven Fire Pump, T31A/B Generators Day Tank, T-176A/B Emergency Generator Day Tanks, T-504 Fuel Oil Tank for Generator, T-505 Fuel Oil Tank for Generator, T-506 Unburned Fuel Accumulator Tank N/A The staff reviewed the Fuel Oil Chemistry Program using information contained in the SLRA and the applicants ePortal. The table below lists the documents that the staff reviewed and found to be relevant to the Fuel Oil Chemistry Program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 2262609 L1 for LR AMP Effectiveness Review 11/12/2020 FPL-1 Next Era Energy Quality Assurance Topical Report Revision 22 07/12/2019 LR-AMP-002-FOCHE M

Fuel Oil Chemistry Control Program Basis Document for License Renewal Revision 8 NP 3.4.0 Environmental Programs Revision 12 PBF-3005a Quarterly Sampling of Emergency Fuel Oil Tanks Revision 9 Tech Specs 80 Tech Specs 80 Sampling of Fuel Oil Day Tanks (quarterly)

Revision 25 TRM 4.12 Technical Requirements Manual Diesel Fuel Oil Revision 7 01758436 04T - 175 A B Tanks Inspections 03/08/2012 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.19 Reactor Vessel Material Surveillance Summary of Information in the Applications. The SLRA states that AMP B.2.3.19, Reactor Vessel Material Surveillance, is an existing program with exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.M31, Reactor Vessel Material Surveillance. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the exceptions associated with this AMP. The staff will document its review of the exceptions to the GALL-SLR Report AMP in the SER.

Audit Activities. During its audit, the staff reviewed documentation that the applicant provided.

The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date BAW-1543 NP, Supplement 6-A Supplement to the Master Integrated Reactor Vessel Surveillance Program Revision 4 09/07/2007 LR-AMP-016-RVSUR V-008 Reactor Vessel Surveillance Program Basis Revision 8 LR-AMP-016-RVSUR V-009 Reactor Vessel Surveillance Program Basis Revision 9 NA Final Report on Point Beach Nuclear Plant Unit 1 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/15/1973 WCAP-8739 Analysis of Capsule S from the Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1976 WCAP-9357 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-10736 Analysis of Capsule T from the Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 12/1984 NA Final Report on Point Beach Nuclear Plant Unit 2 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/10/1975 WCAP-9331 Analysis of Capsule T from the Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-9635 Analysis of Capsule R from the Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 12/1979 BAW-2140 Reactor Vessel Surveillance Capsule Test Report and RTPTS [reference temperature - pressurized thermal shock] Submittal Point Beach Nuclear Plant, Unit 2 and Charpy Upper-Shelf Energy Status, Point Beach nuclear Plant Units 1 and 2 10/15/1991 The staff will evaluate the identified plant-specific operating experience and the proposed revision to the reactor vessel surveillance material withdrawal schedule in SER Appendix A.

SLRA AMP B.2.3.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B.2.3.20, One-Time Inspection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified in this report will be addressed in the SER.

Audit Activities. The applicant performed a search of its operating experience database using a standard set of keywords and provided the results to the staff for review. The table below lists the documents that the staff reviewed and found to be relevant to the One-Time Inspection Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 01306542 Localized corrosion was noted during NDE, Aux Feed Nozzle 12/04/2006 AR 01327540 Several small areas of pitting noted during NDE, 1CC-00743D relief valve 08/07/2008 AR 01341891 Visual examination noted erosion of neck flange 2RH-00624 05/30/2008 AR 01385133 Tube Vibration Damage noted during Eddy Current of RHR Heat Exchanger 06/15/2011 AR 02262609 License Renewal effectiveness review 09/10/2019 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date NDE-104 Ultrasonic A-Scan Thickness Measurement Utilizing Panametrics DL Plus Series Thickness Gauges Revision 29 NDE-701 Visual Examination of Components in Supports of License Renewal.

Revision 3 LR-AMP-024-OTINSP One-Time Inspection Program Basis Document for License Renewal Revision 11 LR-TR-519 License Renewal Technical Report Revision 3 N/A PBN Program Owner Interview Form 02/06/2020 FPLCORP00036-REPT-0 56 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

One-Time Inspection Revision 0 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA One-Time Inspection AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the results that the applicant provided of the operating experience database, to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP for One-Time Inspection provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B.2.3.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Selective Leaching Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 01392740 Dezincification Identified in Solenoid Valve SW-02832B-S 07/13/2010 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-080 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Selective Leaching Revision 0 LR-AMP-024-OTINSP One-Time Inspection Program Basis Document for License Renewal Revision 11 During the audit, the staff verified the applicants claim that the parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, preventive actions, and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP.

The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed FPLCORP00036-REPT-080 and noted (a) the Selective Leaching AMP includes components made of ductile iron; (b) a majority of voltage potentials measured during the 2015 cathodic protection survey did not meet the -850 millivolt polarized potential criterion; and (c) cathodic protection system performance will determine whether the Selective Leaching Program may exclude buried and cathodically-protected components from scope.

The staff reviewed LR-AMP-024-OTINSP, which states [d]uring the aging management review process it was not always possible to determine whether the cast iron components in question were constructed of gray or ductile cast iron and [s]hould further material evaluation determine that the material is ductile cast iron and therefore not susceptible to selective leaching, these components will be removed from the selected set of components to be inspected.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Selective Leaching Program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Selective Leaching Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.22, ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The SLRA states that AMP B2.3.22, ASME Code Class 1 Small-Bore Piping, is an existing program that, with enhancements, will be consistent with the program elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The table below lists documents that the staff reviewed and found to be relevant to the ASME Code Class 1 Small-Bore Piping Program. The staff will document its review of this information in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP000 36-REPT-67 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - ASME Code Class 1 Small-Bore Piping Revision 0 11/06/2020 NP 7.2.5 Repair Replacement Program Revision 29 NP 7.4.13 Inservice Inspection Program Procedure Revision 14 SEM 7.11.2 ISI Datasheet Review and Indication Evaluation Guideline Revision 16 ISI CL 1-2-3 Program Point Beach Nuclear Plant Fifth Interval Inservice Inspection Program PBNP Class 1, 2, and 3 Revision 15 11/15/2017 LR-AMP-017-I WBDC ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program Basis Document for License Renewal Revision 9 LER 90-008-00 Licensee Event Report, Point Beach Unit 1 Shutdown Due to Reactor Coolant System Leakage Exceeding Technical Specification Limit 06/24/1990 LER 99-012-00 Licensee Event Report, Point Beach Unit 1 Through Wall Defect on Steam Generator Drain Valve Weld 12/02/1999 LER 2020-001-00 Licensee Event Report, Point Beach Unit 1 Reactor Coolant System Pressure Boundary Leak on Steam Generator Bowl Drain Line Results in Operation Prohibited by Technical Specifications 11/25/2020 Document Title Revision/Date AR 02370320 1RC-526B Liquid Penetrant Indications, Unit 1B Steam Generator Bowl Drain Welds 10/04/2020 AR 02373107 RC System MR Reliability Performance Criteria Exceeded, Pressure Boundary Leakage 10/25/2020 AR 02192286 2CV-D-05, Identify Leakage Location and Repair, Unit 2 03/13/2017 AR 01860155 NRC Observations From NDE Performed During Unit 1 R34 08/22/2013 AR 01782020 Failed Socket Weld Testing, Unit 2 07/16/2012 AR 01705218 Small Bore Piping Vibration Evaluation Issues 04/03/2012 IN 2007-21, Supp. 1 ADAMS ML20225A204 Pipe Wear Due to Interaction of Flow-Induced Vibration and Reflective Metal Insulation Supplement 1 12/11/2020 During the audit, the staff verified the applicants claim that the preventive actions program element in the SLRA AMP is consistent with the corresponding element of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements not associated with the enhancements identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.

For the audit of the operating experience program element, the staff reviewed the operating experience the applicant provided in the AMP basis document and on the ePortal. The staff performed a search of the provided operating experience using the following keywords: low cycle, high cycle, thermal fatigue, stress corrosion, PWSCC, small bore, socket weld, and weldolet. The staff will document its review of relevant operating experience in the SER.

The staff also audited the description of the SLRA ASME Code Class 1 Small-Bore Piping AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B.2.3.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. The applicant performed a search of its operating experience database using a standard set of keywords and provided the results to the staff for review. The table below lists the documents that the staff reviewed and found to be relevant to the External Surfaces Monitoring of Mechanical Components Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02062786 Piping to and from T32A/B corroded and pitted 07/27/2015 AR02120211 1 piping HB-19 touch up paint - Unit 1 A CFC return pipe 03/25/2016 AR02120212 1 piping HB-19 touch up paint - Unit 1 C CFC return pipe 03/25/2016 AR02319547 WR Clean and Coat Stainless Steel Valve Body 1AF-4067 06/28/2019 AR02319549 WR Clean and Coat Stainless Steel Valve Body 1AF-4067 06/28/2019 AR02252399 NRC ID: Corrosion Downstream FP-33 & FP-36 Header Isolation Valves 03/02/2018 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-068 Subsequent License Renewal Aging Management Program Basis Document - External Surfaces Monitoring of Mechanical Components Revision 0 1007933 EPRI Aging Assessment Field Guide 12/2003 FP-E-SE-04 System Engineering Walkdowns Revision 12 1009743 EPRI Aging Identification and Assessment Checklist 08/2004 PI-AA-104-1000 Condition Reporting Revision 25 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA External Surfaces Monitoring of Mechanical Components AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the results of the operating experience database provided by the applicant, to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP for External Surfaces Monitoring of Mechanical Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.24, Flux Thimble Tube Inspection Summary of Information in the Application. The SLRA states that AMP B.2.3.24, Flux Thimble Tube Inspection, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M37, Flux Thimble Tube Inspection. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. The staff conducted an independent search of the applicants operating experience database using the keywords: inspection, frequency, and wear rate. No significant plant-specific operating experience associated with the Flux Thimble Tube Inspection AMP was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP-00036-RE PT-057 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Flux Thimble Tube Inspection Revision 0 11/06/2020 HX-02 Thimble Tube Condition Assessment Program Revision 11 01/20/2012 P-88-030 Determination of Acceptable Thimble Tube Wear 10/22/1988 LR-AMP-006-TTI Thimble Tube Inspection Program Basis Document for License Renewal Revision 11 NPM-2013-0123 2013 U1R34 Thimble Tube Eddy Current Inspection Report 04/09/2013 NPM-2012-0352 2012 U2R32 Thimble Tube Eddy Current Inspection 11/12/2012 PMCR 02057808 Thimble Tube Eddy Current Inspection Deferral Point Beach Unit 1 12/10/2015 FPLE-132-PB1-01 Final Inspection Report Incore Thimble Tubes at Point Beach Nuclear Plant U1R37 Outage 10/2017 FPLE-120-PB2-01 Final Inspection Report Incore Thimble Tubes (Point Beach Nuclear Plant U2R35 Outage) 03/2017 During the audit, the staff verified the licensees claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. The staff notes that the corrective actions program element was enhanced to require that flux thimble tubes that cannot be inspected over the tube length, that are subject to wear due to restriction or other defects, and that cannot be shown by analysis to be satisfactory for continued service, will be removed from service to maintain the integrity of the reactor cooling system pressure boundary.

During the audit, the staff observed the following:

The staff reviewed FPLCORP-00036-REPT-057 and confirmed that the Flux Thimble Tube Inspection Program uses eddy current testing to determine thimble tube wall thickness and to predict wear rates for the early identification of thimble tube failures.

The staff reviewed FPLCORP-00036-REPT-057 and noted that the applicant provided a maximum allowable wall loss acceptance criteria of 83 percent for the flux thimble tubes, based on calculation P-88-030. The applicant also provided a capping limit of 63 percent wall loss, based on the wall loss acceptance criteria adjusted for error and uncertainty.

The staff reviewed FPLCORP-00036-REPT-057 and noted that the applicant described how to calculate the flux thimble tube inspection frequency based on measured wall loss, wear rate, and the capping limit discussed in the previous bullet. The staff also noted the applicant stated that inspections must occur at least once every 6 years.

The staff reviewed HX-02 and verified that inspection frequencies were calculated for the limiting flux thimble tubes in Units 1 and 2 consistent with requirements discussed in FPLCORP-00036-REPT-057.

The staff reviewed HX-02 and noted that flux thimble tube inspections were performed in Spring 2010 (Unit 1) and Spring 2011 (Unit 2). The staff also noted that flux thimble tube inspections were scheduled for Spring 2013 (Unit 1) and Fall 2012 (Unit 2).

The staff reviewed NPM-2013-0123 and verified that Unit 1 flux thimble tube inspections were performed in Spring 2013 as discussed in HX-02. The staff also noted that thimble tube inspections were scheduled for Spring 2016, based on program requirements indicating a 4.5-year inspection interval, and a desire to inspect earlier than the program interval to observe if power uprate conditions altered the thimble tube fretting patterns.

The staff reviewed NPM-2012-0352 and verified that Unit 2 flux thimble tube inspections were performed in Fall 2012 as discussed in HX-02. The staff also noted that thimble tube inspections were scheduled for Fall 2015, based on program requirements indicating a 6-year inspection interval and a desire to inspect earlier than the program interval to observe if power uprate conditions altered the thimble tube fretting patterns.

The staff reviewed PMCR 02057808 and noted that the Unit 1 flux thimble tube inspection scheduled for Spring 2016 was deferred to Fall 2017, based on technical justification. The staff also noted that this justification was consistent with the provision in Bulletin 88-09 that permits licensees to establish the programmatic inspection frequencies and the need for potential corrective actions, based on the minimum wall requirement for the program and the latest plant-specific wear and wear rate data obtained from the past inspections of the thimble tubes. The staff also noted that the licensees justification affirmed the 4.5-year inspection interval going forward for Unit 1.

The staff reviewed FPLE-132-PB1-01 and FPLE-120-PB2-01 and verified that flux thimble tube inspections were performed in Fall 2017 (Unit 1) and Spring 2017 (Unit 2).

The staff also verified that these inspections were performed consistent with the provision in Bulletin 88-09 that permits the licensees to establish the programmatic inspection frequencies and the need for potential corrective actions, based on the minimum wall requirement for the program and the latest plant-specific wear and wear rate data obtained from past inspections of the thimble tubes.

The staff also audited the description of the SLRA Flux Thimble Tube Inspection AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The SLRA states that AMP B.2.3.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 01385133 Tube vibration damage in RHR [Residual Heat Removal]

HX-11A 03/13/2010 AR 01385537 Tube vibration damage in RHR HX-11B 03/19/2010 AR 01633239 Results of followup license renewal inspection on 2RH-624 03/24/2011 AR 01698683 Downstream flange erosion 1RH-00624 10/21/2011 AR 01804740 G-01 exhaust piping UT [Ultrasonic Testing] result below acceptance criteria 09/19/2012 AR 01858109 Service water piping supply to 1P30B degraded 03/20/2013 AR 02053119 G04 K4D starting air compressor expansion joint corroded 06/09/2015 AR 02286065 U2 A containment fan cooler tubes need plugging 10/16/2018 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-081 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Revision 0 LR-AMP-004-PSPM Periodic Surveillance and Preventive Maintenance Program Basis Document for License Renewal Revision 10 MA-AA-204-1000 Preventive Maintenance and Surveillance Procedure Revision 18 MI 32.14 Visual Inspections for License Renewal Revision 3 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff will consider issuing RAIs to obtain the information necessary to determine whether the applicants SLRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program can be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program provided in the UFSAR supplement.

The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.26, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B2.3.26, Lubricating Oil Analysis, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Lubricating Oil Analysis Program. The applicant provided these documents, which the applicant identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-RE PT-069 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Lubricating Oil Analysis Revision 0 11/06/2020 PDM 2.0 Lubricating Analysis Program Revision 13 FPLCORP00036-RE PT-032 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Auxiliary Feedwater System Revision 1 FPLCORP00036-RE PT-015 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Component Cooling Water System Revision 1 Document Title Revision/Date FPLCORP00036-RE PT-020 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Emergency Power System Revision 1 LR-TR-519 One-Time Inspection Program Sampling Methodology Revision 3 CR1958641 Oil sample obtained from 2P-029 outboard had a dark grey/black appearance 04/16/2014 CR2196985 G-04 EDG lube oil analysis indicates small trend of fuel oil 04/17/2017 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP Lubricating Oil Analysis Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.27, Buried and Underground Piping and Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

During the audit, the staff reviewed the exception and enhancements associated with this AMP.

The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Buried and Underground Piping and Tanks Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02040202 FH-30 broke causing significant fire header leak due to freezing 04/13/2015 AR02088673 More than expected water leakage during excavation of fire protection valve 11/04/2015 AR01827881 Fire header piping is submerged and corroded 11/28/2012 AR2158241 Asset Management Plan Point Nuclear Station Underground Piping and Tank Integrity Program Revision 2 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-058 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Buried and Underground Piping and Tanks Revision 0 SEM 8.0 Buried Services Monitoring Program Revision 6 FPLCORP00036-REP T-066 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fire Water System Revision 0 0-PT-FP-005 Annual Underground Fire Main Flow Test Revision 15 NPM-92-0746 Groundwater Monitoring Wells/Soil Analysis in Unit 1 and Unit 2 Facades 09/01/1992 DG-M03 Bechtel Piping Class Summary Revision 41 PB-241 Point Beach Nuclear Plant Specification for Furnishing, Installing and Testing Fire Protection Piping Revision 0 NEER-RSC-19356 2016 Survey of the Cathodic Protection System for the Containment Structures and Circulating Water Piping at NextEras Point Beach Nuclear Plant 08/09/2016 ER-AA-102-1000 Underground Piping and Tanks Integrity Examination Procedure Revision 5 During the audit, the staff verified the licensees claim that, the parameters monitored or inspected, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, preventive actions, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed FPLCORP00036-REPT-058 and noted that: (a) Point Beach is not committing to any of the alternative polarization criteria that would require soil sampling; (b) uncoated fire water system piping is inspected at a 10-year frequency; (c) Point Beach does not have any cathodically protected buried tanks; (d) buried steel piping was wrapped and/or coated and lined per original construction requirements; and (e) external coatings were fabricated and applied in accordance with the requirements of American Water Works Association Specification C203, Coal-Tar Protective Coatings and Linings for Steel Water Pipes.

The staff reviewed SEM 8.0 and noted that a susceptible location in the fire protection system will be inspected once prior to the period of extended operation and at least every 10 years during the period of extended operation.

The staff reviewed AR2158241 and noted that the cathodic protection systems were originally installed to provide corrosion control for the containment structures and buried circulating water piping.

The staff reviewed AR01827881 and noted that: (a) the north and south fire protection supply headers are constantly submerged in water and exhibit surface corrosion at the above ground to below ground transition pits inside the pumphouse; and (b) the piping does not appear to be externally coated in this area.

The staff reviewed NEER-RSC-19356 and noted that 11 zinc anodes were installed for the purpose of evaluating the performance of the cathodic protection systems.

The staff reviewed ER-AA-102-1000 and noted that condition reports should be written documenting any conditions that conflict with design requirements, such as cathodic under or over protection.

During its audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff will consider issuing RAIs to obtain the information necessary to determine whether the applicants SLRA Buried and Underground Piping and Tanks Program can be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA Buried and Underground Piping and Tanks Program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the Buried and Underground Piping and Tanks Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application. The SLRA states that AMP B.2.3.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, is a new program with an exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as modified by SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal Guidance.

The staff noted that subsequent to the applicants submittal of its SLRA, draft SLR-ISG-Mechanical-2020-XX was issued as final SLR-ISG-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance (ADAMS Accession No. ML20181A434). To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP in the SER.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program. The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 0181263 As-found conditions inside CSTs [Condensate Storage Tanks] T-24A and T-24B 01/28/2010 AR 01399942 T-32A Internal Coating/Lining Degradation 11/11/2010 AR 01608880 Small pits on HX [heat exchanger]-12B gasket sealing surfaces and cover 01/14/2011 AR 01613027 Delaminating coating and small pits inside 2HX-12D 01/26/2011 AR 01848161 Delaminating coating and small pits inside 2HX-12D 02/13/2013 AR 01885085 Delaminating coating and small pits inside HX-12C 06/25/2013 AR 02023154 Delaminating coating and small pits inside 2HX-12D 02/04/2015 AR 02026056 Delaminating coating and small pits inside HX-12B 02/17/2015 AR 02040202 FH-30 Significant Leak 04/13/2015 AR 02184297 Delaminating coating and pits inside 2HX-12D 02/07/2017 AR 02188565 Delaminating coating and pits inside HX-12B 02/28/2017 AR 02206502 1HX-12A as-found condition 05/22/2017 AR 02208844 HX-12C as-found coating inspection 06/06/2017 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-082 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Revision 0 RMP 9367 Level 1 and Level 3 Coatings Revision 25 During the audit, the staff verified that, for the program elements that the applicant declared were consistent, the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed FPLCORP00036-REPT-082 and noted that:

(a) microbiologically-influenced corrosion is suspected to be an issue on the raw water side of component cooling water (CCW) heat exchangers, as exhibited by routine discovery of soft spots in the coating, which, when pierced, exude a black material along with pitting of the carbon steel; and (b) the CCW heat exchangers are currently inspected on a 3-year frequency.

During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff will consider issuing RAIs to obtain the information necessary to determine whether the applicants SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program can be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The SLRA states that AMP B.2.3.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. A review was conducted of the applicants operating experience database based on a standard set of keywords: bolt, corros, coat, crack, degrad, fatigue, leak, pit, SCC, and moisture barrier. The table below lists the documents that the staff reviewed and found to be relevant to the ASME Code,Section XI, Subsection IWE Program. The applicant provided these documents from the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience, Attachment 4 - Aging Effect OE for Structures, Structural Components and Commodities Revision 1 AR 01205024 Containment Penetrations Corroding - Unit 2 12/30/1998 AR 01220374 Mechanical Penetrations (CCP-45, 46, 50, 51) Indicate Base Metal Reduction - Unit 1 11/12/1999 AR 01209111 Containment Liner Concern Unit 1 with greater than 10 percent thickness reduction 04/26/2001 AR 01217953 Liner Plate Degradation - Unit 1 & 2 with greater than 10 percent thickness reduction 04/11/2001 Document Title Revision/Date AR 01219725 Containment Liner Corrosion Unit 1 & 2 - Containment Sump A and Instrumentation Tunnel (keyway) 07/07/1998 AR 01220386 Unit 1 Liner Plate Base Metal Reduction Greater than 10 percent Allowable (CP-130 near & to right of EQ hatch) 11/16/1999 AR 01396364 Industry OE 31490 (CR-3) Applicable to PBNP Containment Liner Plate Bulges (Significance Level 3) 10/30/2010 AR 01399237 &

AR 01608687 Turkey Point Rapid OE - Unit 3 Containment Liner Sump Coating 01/13/2011 AR 01627045 U2 Containment Liner Plate Blisters (Coating) and Rust at EL 8, SW Quadrant 03/07/2011 AR 01820987 Unit 2 Containment Keyway Sump A Liner Plate Corrosion due to Boric Acid (at liner - concrete floor interface including photos).

11/07/2012 AR 02083303 Boric Acid Found on Unit 2 Liner Plate and Floor - 8 ft Elevation including photos 10/19/2015 AR 02085864 Boric Acid Remaining on Unit 2 Liner Plate and Floor (and leakchase penetration) - 8 ft EL 10/26/2015 AR 02192512 Unit 2 Keyway / Containment Sump A Liner Plate Corrosion 03/20/2017 AR 02197395 Unit 2 Recordable Indications on Containment Moisture Barrier (8ft EL) (including photos) 04/08/2017 AR 02310028 Recordable Indications Unit 1 Containment Moisture Barriers (8 ft EL and in Keyway) 04/11/2019 WO 40325484_06 ASME IWE Containment Interior Examinations (U1 - Visual Exam of Concrete Floor Expansion Joints).

10/01/2014 WO 40325303_06 U2 - Visual Exam of Concrete Floor Expansion Joints 10/01/2015 WO 40462965 2C-1 Equipment Access Air Lock Removal and Replacement 08/13/2017 AR 01858862 NRC Inspector has Concerns Re Containment ISI (IWE)

Program (2nd interval) 03/21/2013 AR 01859126 Apparent Inconsistencies in IWE Inspection Data Sheets (NRC identified documentation inconsistency issue) 03/22/2013 AR 01861158 An Additional NRC Concern Re: Containment ISI (IWE)

Program 05/22/2013 AR 01964239 Issuance of NRC IN 2014-07 Evaluation 05/07/2014 AR 02131443 NRC RIS 2016-07 Evaluation 05/12/2016 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-070 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Program Basis Document - ASME Section XI, Subsection IWE Revision 0 Document Title Revision/Date 3RD INT IWE BASIS DOCUMENT 3rd Interval IWE Basis Document - Point Beach Nuclear Power Plant Units 1 and 2 (see Sec 3.2.9 p22); In addition to liner-floor interface MBs, MBs between containment concrete surfaces also included under E1.30 in IWE plan at EL 8 dwg PBC-308) to liner at EL 6 6. Also MBs exist in core holes (9 U1, 6 U2) to allow monitoring of liner below also monitored under E1.30.

Revision 0 11/08/2016 3RD INT IWE-PB-1/2 PROGRAM Third IWE Inspection Interval Program Plan, including Appendices A-E, Point Beach Nuclear Power Plant Unit 1 and Unit 2 Revision 1 ISI IWE Appendix A IWE Classification Boundary Document Revision 0 ISI IWE Appendix B IWE Code Cases and Relief Requests Revision 1 ISI IWE Appendix C IWE Augmented Examinations (Note: Section 3 identifies areas subject to augmented examinations per E-C)

Revision 0 ISI IWE Appendix D IWE Implementation Schedule Unit 1 Revision 1 ISI IWE Appendix E IWE Implementation Schedule Unit 2 Revision 1 LR-AMP-028-IWEL ASME Section XI, Subsections IWE and IWL Inservice Inspection Program Basis Document for [First] License Renewal Revision 11 NMP 2014-0044 Memo on Removal of Items from the IWE Augmented Examination Schedule 01/24/2014 AR 02241723-11 AMP Effectiveness Review and Assessment Worksheet:

Program LR-AMP-028-IWEL 03/12/2018 PB/ISI-ISI Master System Health Report (Quarterly Q1-2015 thru Q1-2020) 03/08/2020 N/A PBN Program Owner Interview Form - ASME Section XI

_IWB, IWC, IWD, IWE, IWF 02/05/2020 PBC-300 ISI Classification Drawing - Containment Vessel and Electrical/Mechanical Penetrations Location, Point Beach Unit 1 Revision 00 PBC-301 ISI Classification Drawing - Containment Vessel and Electrical/Mechanical Penetrations Location, Point Beach Unit 2 Revision 00 PBC-302 SH. 1 ISI Classification Drawing Mechanical Penetrations, Point Beach Unit 1& 2 Revision 00 PBC-302 SH. 2 ISI Classification Drawing Mechanical Penetrations, Point Beach Unit 1& 2 Revision 01 PBC-303 ISI Classification Drawing - Containment Vessel Dome (Looking Up), Point Beach Unit 1 & 2 Revision 00 PBC-304 SH. 1 ISI Classification Drawing C-1: Equipment Access Airlock (Lower), Point Beach Unit 1 & 2 Revision 00 PBC-304 SH. 2 ISI Classification Drawing C-1: Equipment Access Airlock (Lower), Point Beach Unit 1 & 2 Revision 00 PBC-304 SH. 3 ISI Classification Drawing C-1: Equipment Access Airlock (Lower), Point Beach Unit 1 & 2 Revision 00 PBC-305 SH. 1 ISI Classification Drawing C-2: Personnel Access Airlock, Point Beach Unit 1 & 2 Revision 00 Document Title Revision/Date PBC-305 SH. 2 ISI Classification Drawing C-2: Personnel Access Airlock, Point Beach Unit 1 & 2 Revision 00 PBC-307 ISI Classification Drawing: Integral Attachments, Point Beach Unit 1 & 2 Revision 00 PBC-308 ISI Classification Drawing: Moisture Barriers (SH.1 of 1),

Point Beach Unit 1 & 2 Revision 00 PBC-311 ISI Classification Drawing: Construction Concrete Keyways

@ 6 -6 & (-) 3-0 Elevations, Point Beach Unit 1 & 2 Revision 00 PBC-312 ISI Classification Drawing: Electrical Penetrations, Point Beach Unit 1 & 2 Revision 00 DG-M18 Fastener Design Guideline Revision 4 MI 29.1 Use of Thread Lubricants and Sealants - Maintenance Instruction (includes Molybdenum disulfide (Molycote) as a solid lubricant but says should not be used unless evaluated on a case-by-case basis with consideration of its potential to cause SCC - Section 3.3.5)

Revision 14 NDE-760 VT-1, VT-3 & General Visual Examination of IWE Boundary Components - NDE Procedures Manual (includes reference bars to monitor bulges)

Revision 10 NP 7.2.5 Repair/Replacement Program - Plant Procedures Manual Revision 29 NP 7.4.13 Inservice Inspection Program Procedure - Plant Procedures Manual Revision 14 SEM 7.11.2 ISI Datasheet Review and Indication Evaluation Guideline Revision 16 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, program elements of the SLRA AMP are consistent with or will be consistent with enhancement(s) with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the detection of aging effects and corrective actions program elements, sufficient information was not available to determine they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed 3RD INT IWE-PB-1/2 PROGRAM PLAN and noted in Section 2.4.10, Augmented Examinations, that Point Beach is performing the following containment augmented examination which are not mandated by ASME Code,Section XI requirements: (a) core drilled holes at EL 8-0 to monitor floor liner degradation, and (b) containment liner reference bars to monitor liner bulging.

The staff reviewed FPLCORP00036-REPT-070, Section 4.10, and noted that the core drilled holes were installed in the liner plate in 1988, as a result of standing water discovered on the 8-ft elevation of containment as a means to provide monitoring of corrosion of the horizontal liner plate. Several other areas in both units were identified for augmented examination such as various mechanical penetrations (corrosion),

Sump A and keyway tunnel due to indications adjacent to inaccessible liner plate, liner plate gouges deeper than 10 percent and C-2 personnel access airlock due to observed wetted conditions.

The staff reviewed SLRA Table 3.5-1 and the further evaluations in SLRA Sections 3.5.2.2.1.5 and 3.5.2.2.1.6 and noted several inconsistencies and lack of clarity between the discussion column of Table 3.5-1 for AMR items 3.5-1, 009, 010, and 027, the further evaluations, and the corresponding AMR items in SLRA Table 3.5.2-1. The applicant indicated that it may provide a voluntary supplement to address this issue. If a voluntary supplement is not provided, the staff will consider issuing an RAI to resolve the inconsistencies and lack of clarity.

During the audit of the operating experience program element, the staff searched the applicants plant-specific database query results provided on the ePortal to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP ASME Code Section XI, Subsection IWE provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP ASME Code,Section XI, Subsection IWE. The staff will review a voluntary supplement offered by the applicant and/or consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA AMP B.2.3.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The SLRA states that AMP B.2.3.30, ASME Section XI, Subsection IWL, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S2, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the SLRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the ASME Code,Section XI, Subsection IWL Program.

The applicant provided these documents. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP0036-REPT

-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 FPLCORP0036-REPT

-071 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - ASME Section XI, Subsection IWL Revision 0 N/A 3rd Interval-IWL-PB-1/2-Program Plan Revision 0 NDE-761 Visual Examination of Concrete Containment Components (IWL)

Revision 12 NP 7.4.13 Inservice Inspection Program Procedure Revision 14 Document Title Revision/Date NP 7.2.5 Repair / Replacement Program Revision 29 ADAMS ML19352F059 Owners Activity Report - 48th Year IWL for Class CC Examinations 12/18/2019 N/A 2019 IWL Completed Exams U1 Posted on ePortal 3/18/21 N/A 2019 IWL Completed Exams U2 Posted on ePortal 3/18/21 REP-1149-510 Final Report for the 48th Year Tendon Surveillance at Point Beach Nuclear Power Plant Revision 0 REP-1095-510 Final Report for the 43rd Year Tendon Surveillance at Point Beach Nuclear Power Plant Revision 1 PBN Program Owner Interview Form Containment Tendon Prestress ASME Section XI, Subsection IWL 02/06/2020 AR 01216214 Sheathing Filler Voids Found During 28-Year Tendon Surveillance 07/06/1999 AR 02021710 NRC Questions Regarding Evaluation of Grease Leakage on CTMT 01/29/2015 AR 02316032 Water Seepage with Crystalized Material on Concrete 05/29/2019 AR 01700598 Tendon Gallery Roof Leak at 1SI-850A 10/29/2011 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the applicants results from the search of the plant-specific operating experience database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the ASME Code,Section XI, Subsection IWL Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B.2.3.31, ASME Section XI, Subsection IWF, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-SLR Report AMP B.2.3.31, ASME Section XI, Subsection IWF. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The staff will document its review of the exception to the GALL-SLR Report AMP and the enhancements in the SER.

Audit Activities. A review was conducted of the applicants operating experience database using a standard set of keywords: bolt, Boric, corros, crack, indication, preload, SCC, and structural support. The table below lists the documents that the staff reviewed and found to be relevant to the ASME Code,Section XI, Subsection IWF Program. The applicant provided these documents from its search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience, Attachment 4 - Aging Effect OE for Structures, Structural Components and Commodities Revision 1 AR 02196068 Recordable Indications of Piping Support EB-9-H19, Unit 2 04/03/2017 AR 02196264 Indications on Motor Oil Cooler Support AC-152N-4-NOTE4, Unit 2 04/04/2017 AR 02220951 Recordable Indications on Containment Spray Pump 1P-14A Pump, Unit 1 08/17/2017 AR 02229610 Recordable Indications on SW Piping Support HB-19-H28, Unit 1 (loose nut on pipe clamp; nut was taken to snug fit) 10/14/2017 AR 02230281 Recordable Indications on Steam Generator A Support, Unit 1 (loose nut on Earthquake Bracket in SW corner 10/13/2017 AR02231474 Recordable Indications on RHR Piping Support AC-601R-6-H28, Unit 1; missing jam nuts on rod below spring and rod misalignment between spring and pipe clamp; acceptable as-is 10/19/2017 AR 02286960 Unable to Determine Acceptance of Constant Support Settings, Unit 2 (Spray Line to Pressurizer 2T1; as-left VT-3 on constant supports RC-7, -8, -9 noted that travel indicator was not in between hot and cold positions as expected; found acceptable as-is) 10/20/2018 AR 02309598 Recordable Indications on RTD Bypass Piping Support RC-2501R-14-102R, Unit 1 04/09/2019 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-0 59 Subsequent License Renewal Aging Management Program Basis Document - ASME Section XI, Subsection IWF Revision 0 (11/03/2020)

ISI CL 1, 2, 3 PROGRAM Point Beach Nuclear Plant Class 1, 2, and 3 Inservice Inspection Program Fifth Inservice Inspection Interval Revision 15 1ISI CL 1, 2, 3 SCHEDULE Point Beach Nuclear Plant Unit 1 - Class 1, 2, and 3 Inservice Inspection Program Schedule Revision 5 2ISI CL 1, 2, 3 SCHEDULE Point Beach Nuclear Plant Unit 2 - Class 1, 2, and 3 Inservice Inspection Program Schedule Revision 4 LR-AMP-027-IWF ASME Section XI, Subsection IWF Inservice Inspection Program Basis Document for [First] License Renewal Revision 9 Document Title Revision/Date N/A PBN Program Owner Interview Form - ASME Section XI _IWB, IWC, IWD, IWE, IWF 02/05/2020 DG-M18 Fastener Design Guideline (Section 6.4.1 on p11-12 states: Molybdenum disulfide based thread lubricant should not be used unless evaluated on a case-by-case basis with consideration given for the potential for SCC.

When selecting a lubricant, one of the approved lubricants should be selected. These have been tested for plant system applications. There are two main types of lubricants used at PBNP, Neolube nickel-base anti-seize, (Fel Pro N-5000 or Chesterton 772), and copper-base anti-seize (Loctite 77164).

Revision 4 MI 29.1 Use of Thread Lubricants and Sealants - Maintenance Instruction (includes Molybdenum disulfide (Molycote) as a solid lubricant but says should not be used unless evaluated on a case-by-case basis with consideration of its potential to cause SCC - Section 3.3.5, Attachment A proprietary brands of Thread Lubricants Used at Point Beach includes Molykote. P11)

Revision 14 NDE-754 Visual Examination (VT-3) of Nuclear Power Plant Components - Point Beach Nuclear Plant NDE Procedures Manual (specifies requirements for VT-3 of Class 1, 2, and 3 components to determine general mechanical and structural conditions)

Revision 21 NP 7.2.5 Repair/Replacement Program - Plant Procedures Manual Revision 29 NP 7.4.13 Inservice Inspection Program Procedure - Plant Procedures Manual Revision 14 SEM 7.11.2 ISI Datasheet Review and Indication Evaluation Guideline Revision 16 AR 01992168 Industry OE - CRDM Seismic Supports Not in ISI Program (INPO OE 322397) - applies to both PBN Units, non-compliance corrected and CRDM Supports included in IWF program to be VT-3 examined every 10-years; Both Units examined within next 2 refueling outages 09/18/2014 AR 01992168 Perform VT-3 Exam of CRDM Seismic Supports -

Unit 1 09/23/2014 754-0002/0416358 Visual Examination Record (U1R29) - Unit 1 RPV Support [Boric acid staining of support, light surface corrosion of bolting], [boric acid washed off) 09/28/2005 0416358/754-0200 Visual Examination Record (U1R29) - Unit 1 RPV Supports and Bolting After Clean-up in Keyway (As-Left) (boric acid washed off) 11/01/2005 2006VT-009 Visual Examination of Pipe Hanger, Support or Restraint (VT-3) U2R28, RPV Support [light corrosion on supports, boric acid leakage above cavity seals noted]

10/24/2006 Document Title Revision/Date 2008VT-007 Visual Examination of Pipe Hanger, Support or Restraint (VT-3) U2R29, RPV Support [General Light Corrosion on all components]

04/14/2008 2007VT-028 Visual Examination of Pipe Hanger, Support or Restraint (VT-3) U1R30, RPV Support [General Corrosion noted on all supports but no apparent loss of material]

04/26/2007 2015U2VT-003 Visual Examination of Pipe Hanger, Support or Restraint (VT-3) U2R34, RPV Support [Examined accessible portions only (TYP). Boric acid from leakage above cavity seals and sandbox covers noted. Light corrosion on supports, no degradation apparent. No concrete degradation noted.]

10/28/2015 2016U1VT-029 Visual Examination of Pipe Hanger, Support or Restraint (VT-3) U1R36, RPV Support [Examined accessible portions only (TYP). Light surface corrosion on all components. No discernible change since last examination. Camera with 8x optical zoom utilized in areas >4ft from eyes.]

04/04/2016 WO 40367277-01 & WO 40367277-02 1R-1/RPV Supports - Cavity - ISI Exams during U1R36 04/07/2016 WO 40321016-01 & WO 40321016-02 2R-1/ISI Exams of RPV Supports during U2R34 10/30/2015 AR 2262609 License Renewal Aging Management Program Effectiveness Reviews 04/23/2018 to 05/3/2018 During the audit, the staff verified the licensees claim that the parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent or will be consistent with enhancement(s) with the corresponding elements of the GALL-SLR Report AMP.

The staff also verified the applicants claim that aspects of the scope of program program element not associated with the exception identified in the SLRA is consistent with the corresponding program element in the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program, preventive actions, and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staffs review of SLRA Table 3.5-1 AMR items related to the ASME Code,Section XI, Subsection IWF AMP noted omissions and inconsistencies with regard to AMR items 3.5-1, 057, 3.5-2, 074; 3.5-1, 075; and 3.5-1, 085. The staff will review a voluntary supplement offered by the applicant and/or consider issuing RAIs to address the issues with the AMR items.

From review of the further evaluation in SLRA Section 3.5.2.2.2.7 for loss of fracture toughness due to irradiation embrittlement of reactor vessel (RV) supports, the staff noted that there is a potential for enhancement of the ASME Code,Section XI, Subsection IWF AMP for the irradiation aging effects. Changes, if any, to the IWF AMP that may result from the staffs review of SLRA Section 3.5.2.2.2.7 will be addressed as part of that further evaluation review.

During the audit of the operating experience program element, the staff searched the applicants plant-specific database query results provided on the ePortal to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA ASME Code,Section XI, Subsection IWF AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B.2.3.32, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this audit report in the SER.

Audit Activities. A review was conducted of the applicants operating experience database on the ePortal using a standard set of keywords: leak, equipment hatch, pressures boundary, and penetration. The table below lists the documents that the staff reviewed and found to be relevant to the 10 CFR Part 50, Appendix J Program. The applicant provided these documents.

The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR 02308223 IRC-528 ORT-31 Failed with High Leakage 04/11/2019 WR 94192038 Work Request 94192038, IRC-528 ORT-31 Failed with High Leakage 03/31/2019 AR 02308453 ICV-1296 ORT 46 Leak Test Failed Admin Limit 04/09/2019 AR 02231919 ORT24 LLRT Test Result for ISI-879B Exceed 50 percent of Adm Limit 10/25/2017 WR 94167856 Work Request 94167856, ORT24 LLRT Test Result for ISI-879B Exceed 50 percent of Adm Limit 10/22/2017 WO 40473311 Work Order 40473311, ORT 24, SI Test Line CIV Leakage Test 01/28/2018 AR 02229022 ORT70 Test Results for PEN 1Q-12>50 percent of Admin Limit 10/11/2017 AR 02229020 ORT70 Test Results for PEN Q-11>50 percent of Admin Limit 10/11/2017 Document Title Revision/Date AR 02229019 ORT70 Test Results for PEN 1Q-10>50 percent of Admin Limit 10/11/2017 AR 02229017 ORT70 Test Results for PEN 1Q-17>50 percent of Admin Limit 10/11/2017 AR 02194649 2CV-370 Experienced Increased Seat Leakage During ORT 34 03/31/2017 AR 02193957 High Leakage Found During ORT 66A Unit 2 04/14/2017 AR 02193724 TS-10A Acceptance Criteria Unsat on U1 Cont Lower Outer Door 03/28/2017 AR 02192895 ORT 27, 2CV-313A Exceeds Admin Leak Limit 04/13/2017 AR 02122292 66 Hatch Inner Door Penetration is Out of Adjustment 04/05/2016 AR 02071906 Leakage Greater Than Acceptance Criteria on Containment Door 09/10/2015 AR 02041066 2C-2, Unit 2 Containment Airlock Leakage Trending Up 04/21/2015 AR 01695646 1RC-529 Exceeds ORT 42 Leakage Limit 05/29/2012 AR 02311433 Failed TS-10A Containment Air Lock Door Seal Testing Unit 1 09/04/2019 AR 02320305 Contingency Work Order for 2CV-371A 07/11/2019 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-072 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

10 CFR Part 50, Appendix J Revision 0 CLRT Testing Program Point Beach Nuclear Plant Containment Leakage Rate Testing Program Basis Document Revision 21 ER-AA-114 Appendix J Testing Program Revision 5 NED-762 General Visual Examination Structure Surveillance of Containment Revision 7 NED-760 VT-1, VT3, and General Visual Examination of IWE Boundary Components Revision 10 FPL-1 NextEra Energy Quality Assurance Topical Report Revision 22 LA-AMP-028-IWEL ASME Section XI, Subsections IWE & IWL Inservice Inspection Program Basis Document for License Renewal Revision 11 UFSAR Point Beach Nuclear Plant Unit 1 & 2 Final Safety Analysis Report 2020 FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 FPLCORP00036-REPT-070 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - ASME Section XI Subsection IWE Revision 0 Document Title Revision/Date FPLCORP00036-REP T-071 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - ASME Section XI Subsection IWL Revision 0 FPLCORP00036-REP T-033 Point Beach Units 1 and 2 Subsequent License Renewal Screening and Aging Management Review Containment Building Structure Revision 0 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

In addition, the staff found that for the scope of program program element, sufficient information was not available to verify whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the query results that the applicant provided from the plant-specific operating experience to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific operating experience in the SER.

The staff also audited the description of the 10 CFR Part 50, Appendix J AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.33, Masonry Walls Summary of Information in the Application. The SLRA states that AMP B.2.3.33, Masonry Walls, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this audit report in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. A review was conducted of the applicants operating experience database using a standard set of keywords: crack, grout, CMU, block, and mortar. The table below lists the documents that the staff reviewed and found to be relevant to the Masonry Walls Program. The applicant provided these documents from its search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP0036-REPT

-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 AR 01702381 Unit 2 turbine building block wall degradation 11/2/2011 Document Title Revision/Date AR 01702779 Cracked block in masonry walls 11/2/2011 AR 02115101 Crack in turbine building wall and penetration M-5-3-35-N21 03/4/2016 AR 02146394 Degraded condition of block wall in Units 1 and 2 facade 07/27/2016 AR 02280677 Cracked/loose grout under pipe support near SW-526 09/17/2018 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REP T-073 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Masonry Walls Revision 0 NP 7.7.9 Facilities monitoring program Revision 21 N/A AMP owner interviews Posted on ePortal on 11/18/2020 LR-AMP-022-STRMO N

Structures monitoring program basis document for license renewal Revision 10 UFSAR Point Beach Nuclear Plant Unit 1 & 2 Final Safety Analysis Report 2020 During the audit, the staff verified the licensees claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the acceptance criteria program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the applicants results from the search of the plant-specific operating experience database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Masonry Walls Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.34, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.3.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the SLRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. A review was conducted of the applicants operating experience database using standard keywords: struct, corros, degra, concr, leak, seepage, and crack.

The table below lists the documents that the staff reviewed and found to be relevant to the Structures Monitoring Program. The documents were provided by the applicant or were identified during the staffs review of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-RE PT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 NPM 2020-0017 Point Beach Nuclear Plant Facilities Monitoring Program Comprehensive Report for the 5-year Interval 2015-2019 01/29/2020 NPM 2016-0102 Point Beach Nuclear Plant 2014 Facilities Monitoring Program Annual Report 07/19/2016 NPM 2016-0102 Point Beach Nuclear Plant 2014 Facilities Monitoring Program Annual Report 07/19/2016 PBF-3231 Point Beach Nuclear Plant - Ground Water Monitoring Well Samples 04/14/2009 EC 289039 Fuel Oil Storage Tanks T-032A/B Spill Containment Rehabilitation Revision 1 AR 02294157 Water Seeping into 8 TB1 Col E-1 04/16/2020 AR 01810878 Tendon Galleries/Groundwater Intrusion Through Wall Cracks 10/04/2012 AR 01880564 Inspection of CWPH Roof Needed 06/13/2013 AR 01814079 U1 and U2 RHR Pipeways/Sign of Groundwater Intrusion 10/17/2012 AR 02316032 Water Seepage with Crystalized Material on Concrete N/A AR 02327517 Inconsistency Reporting in Facilities Monitoring Report (no measurement provided for cracks) 09/11/2019 AR 01689129 Inspection of Opportunity Performed 09/28/2011 AR 02328598 LR Phase IV Observation RE: NP 7.7.9, Facilities Monitoring 09/20/2019 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-060 Subsequent License Renewal Aging Management Program Basis Document - Structures Monitoring Revision 0 FPLCORP00036-REPT-034 Subsequent License Renewal Screening and Aging Management Renewal Results Plant Structures Revision 0 NP 7.7.9 Facilities Monitoring Program Revision 21 DG-M18 Fastener Design Guideline Revision 4 MI 29.1 Use of Thread Lubricants and Sealants Revision 14 CAMP 920 Groundwater Protection Sampling Procedure Revision 9 Document Title Revision/Date UFSAR Point Beach Nuclear Plant Unit 1 & 2 Final Safety Analysis Report 2020 During the audit, the staff verified the licensees claim the preventive actions, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-SLR Report AMP.

During the audit, the staff observed the following:

The staff reviewed Section 3.5 of NP 7.7.9, Facilities Monitoring Program, and noted that the procedure requires a minimum of 2 years of experience to meet the qualification requirements for responsible engineer. Chapter 7 of ACI 349.3 requires at least 10 years of experience. The licensee may provide a voluntary supplement and/or the staff may consider issuing an RAI to clarify this inconsistency.

The staff reviewed Section 4.2.4 of NP 7.7.9, Facilities Monitoring Program, and noted that the program stated that accessible areas subject to similar conditions may be evaluated in lieu of inaccessible areas. The GALL-SLR recommends evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of degradation. The staff will review a voluntary supplement and/or consider issuing an RAI to clarify this inconsistency.

The staff reviewed Section 4.1 of NP 7.7.9, Facilities Monitoring Program, and noted that the applicant stated that there are no sliding surfaces located outside the containment, and those located inside containment are being managed by the ASME Code,Section XI, Subsection IWF Program. However, an item in SLRA Table 3.5.2-1, associated with sliding surfaces, indicates that the Structures Monitoring Program will be used to manage the aging effects. The staff will review a voluntary supplement and/or consider issuing an RAI to clarify this inconsistency.

During the audit of the operating experience program element, the staff reviewed the plant-specific database search results to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff will consider issuing an RAI to obtain the information necessary to determine whether the applicants Structures Monitoring AMP can be adequate to manage the associated aging effects.

The staff also audited the description of the SLRA Structures Monitoring Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The SLRA states that AMP B.2.3.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the SLRA AMP. The staff will address issues identified but not resolved in this audit report in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Inspection of Water-Control Structures Associated with Nuclear Power Plants Program. The applicant provided these documents from its search of its operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP0036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 FPLCORP00036-REPT-074 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Inspection of Water-Control Structures Associated with Nuclear Power Plants Revision 0 NP 7.7.9 Facilities monitoring program Revision 21 PBF-9153 Divers inspection report - pumphouse Revision 4 RMP 9155 - 1 Control of diver activities in pump bay east to traveling water screens Revision 28 RMP 9155 - 2 Control of diver activities in surge chamber, seal well, and lake intake piping to crib Revision 18 RMP 9155 - 3 Control of diver activities at traveling water screens Revision 15 RMP 9155 - 4 Control of diver activities in forebay Revision 20 NPM 2016 -

01022014 Facilities monitoring program annual report 07/19/2016 NPM 202 - 0017 2019 facilities monitoring program annual report 01/29/2020 AR 1722707 Repair corroded rebar behind 2CW-3 06/12/2020 AR 1880564 Degradation of the circulating water pump house roof 06/07/2013 AR 2310924 Concrete floor beam crack/spall at 1P-30A floor opening in the circulating water pump house 04/17/2019 AR 2286670 Underwater cracks in the forebay walls and floor 10/18/2018 AR 2060881 Exposed rebar with loose aggregate in the floor of circulating water pump house 07/16/2015 AR 2179637 Minor spalled exterior concrete on circulating water pump house 01/13/2017 During the audit, the staff verified the licensees claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the preventive actions program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL-SLR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed the applicants results from the search of the plant-specific operating experience database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Inspection of Water-Control Structures Associated with Nuclear Power Plants program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.36, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B2.3.36, Protective Coating Monitoring and Maintenance, is an existing program that, with enhancements, will be consistent with NUREG-2191,Section XI.S8, Protective Coating Monitoring and Maintenance as modified by SLR-ISG-Structures-2020-XX, Updated Aging Management Criteria for Structures Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP.

Audit Activities. The table below lists the documents that the staff reviewed and found to be relevant to the Protective Coating Monitoring and Maintenance Program. The documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02309757 U1-Containment/Scraping Coatings on Upper SG Cubicle Walls 04/09/2019 AR2196918 U2R35 Containment Coatings Closeout Inspection 05/26/2017 AR2231914 U1R37 Containment Coatings Closeout Inspection 10/26/2017 AR2286777 U2R36 Containment Coatings Closeout Inspection 10/19/2018 AR2130214 U1R38 Containment Coatings Closeout 04/11/2019 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date Calculation 2006-9912 Coatings Inputs for ECCS Strainer Design & Testing Revision 4 NRC 2017-0045 (ML17363A253)

Updated Final Response to NRC Generic Letter 2004-02 12/19/2017 Program Owner Effectiveness OE Interview S8 Program Owner Effectiveness OE Interview S8 11/17/2020 ER-AA-109_Rev 4 Nuclear Fleet Protective Coatings Revision 4 NDE-802_Rev 9 Condition Monitoring & Assessment of Containment Coatings Revision 9 NP 8.4.15_Rev 10 Protective Coating Program Revision 10 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP. During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA AMP Protective Coating Monitoring and Maintenance Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.3.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date CR1392842 Excessive amount of hard water deposits on cable trays JA01, JB01, JC01, and JD07 07/2010 CR2081811 Cracked insulation on a load wire off the device 49 on C phase of 2B52-314M 10/2015 CR2283541 Cracked wire jacketing on Aux Diesel (G-501) 10/2018 CR01633253 Adverse localized area was identified for cable trays 2UA, 2W, 2WJ, and 2VM 03/2011 CR01661586 Turbine #1 bearing had wiring grounded due to heat embrittlement 06/16/2011 FPLCORP00036-REPT-036 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-076 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 NP 7.7.28 Cable Condition Monitoring Program Revision 7 ER-AA-CBL-106 Cable Condition Monitoring Program Revision 4 FPLCORP00036-REPT-037 Point Beach Units 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review - Electrical Commodities Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP, are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff reviewed FPLCORP00036-REPT-076, Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Electrical Cables and Connections Not Subject to Environmental Requirements, Revision 0.

Under parameters monitored or inspected, of this document the applicant stated that a sample of accessible in-scope cable and connection electrical insulation subject to an adverse localized environment are visually inspected for surface anomalies. The applicant also stated that the component sampling methodology utilizes a population that includes a representative sample of in-scope electrical cable and connection types regardless of whether the component was included in a previous aging management or maintenance program. The corresponding program element in GALL-SLR Report AMP XI.E1 states that accessible in-scope cable and connection electrical insulation subject to an adverse localized environment is visually inspected for surface anomalies. It was not clear to the staff that the applicant program element was consistent with those in GALL-SLR Report AMP XI.E1. During the audit, the staff requested the applicant to explain how inspecting a sample of accessible cables and connections in an adverse localized environment is consistent with those in GALL-SLR AMP XI.E1. In response to the staffs request, the applicant revised the basis document to require that all in-scope accessible cables and connections in an adverse localized environment are inspected for insulation anomalies. With these revisions, the staff finds that the program element is consistent with the correspondent program element in GALL-SLR Report AMP XI.E1.

Under the detection of aging effects program element, the applicant states that if testing is deemed necessary, a sample of 20 percent of each cable and connection type with a maximum sample size of 25 is tested. The corresponding element in GALL-SLR Report AMP XI.E1 states that for a large number of cables and connections identified as potentially degraded, a sample population is tested. A sample of 20 percent of each cable and connection type with a maximum sample size of 25 is tested. GALL-SLR Report AMP XI.E1 also states that the following factors are considered in the development of the cable and connection insulation test sample: environment including identified adverse localized environments (e.g., high temperature, high humidity, vibration), voltage level, circuit loading, connection type, location (e.g., high temperature, high humidity, vibration), and insulation material. During the audit, the staff requested that the applicant clarify sample testing criteria and describe factors considered in the development of the cable and connection insulation testing sample. In response to the staffs request, the applicant revised the basis document to clarify that for a large number of cables and connections identified as potentially degraded, a sample population is tested. The applicant also revised the basis document to describe factors that are considered in the development of the cable and connections insulation test sample. These factors are consistent with those in GALL-SLR Report AMP XI.E1. With the revisions, the staff finds that the program element is consistent with those in GALL-SLR Report AMP XI.E1.

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant specific operating experience in the SER.

The staff also audited the description of the SLRA A16.2.2.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Summary of Information in the Application. The SLRA states that AMP B.2.3.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits, is an existing program that was previously part of the cable conditioning monitoring program, and that will be consistent with the ten program elements from GALL-SLR Report AMP XI.E2, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet developed all the documents necessary to implement this program and the staffs audit addressed the program elements described in the applicants basis document, as well as the available supporting documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR01950845 2N-42 High-Voltage Cable 04/21/2020 AR02031691 High-Voltage/Signal Cable Needs Replacing on Detector 03/17/15 FPLCORP00036-REPT-077 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Revision 0 Revision 1 NP 7.7.28 Cable Condition Monitoring Program Revision 7 HPCAL 3.5 Point Beach Nuclear Plant Health Physics Calibration Manual Revision 26 ICP 13.001 Radiation Monitoring System Electronic Calibrations Revision 3 ICP 04.024 NIS Source Range Channels Calibration and Char Testing of Source and Intermediate Range Channels Revision 20 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The staff reviewed FPLCORP00036-REPT-077, Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, Revision 0. Section 4.1, Scope of the Program, states that the conditioning monitoring AMP applies to non-EQ electrical cables and connections (cable system) electrical insulation used in circuits with sensitive high-voltage, low-level current signals, such as cables and connections subject to an adverse localized environment. This would include those used in nuclear instrumentation: Excore Source, Intermediate, and Power range channels. GALL-SLR Report AMP XI.E2 states that this AMP applies to high-range-radiation and neutron flux monitoring instrumentation cables in addition to other cables used in high-voltage, low-level current signal applications that are sensitive to reduction in electrical insulation resistance. The staff noted that high range radiation monitoring system cables and connections were not included in this AMP. During the audit, the staff requested that the applicant explain why the high range radiation monitoring system cables and connections were not included as part of the AMP. In response to the staffs question, the applicant clarified that the high range radiation monitoring system cables and connections are subject to 10 CFR 50.49, therefore, this equipment is addressed under SLRA B.2.2.4, Environment Qualification of Electric Equipment. The staff finds the applicants response acceptable because the high range radiation monitoring system cable and connections are not in-scope of SLRA B.2.3.38. The staff finds that the program element is consistent with those in GALL-SLR Report AMP XI.E2.

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant specific operating experience in the SER.

The staff also audited the description of the SLRA A 16.2.2.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits program provided in the UFSAR supplement.

The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA stated that AMP B.2.3.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3A, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR01701449 PBSA-ENG-12-10 Cable Aging Management Quick Hit Assessment 11/17/2020 RCE 01119996-02 Loss of 1X-04 and 1B-04 Revision 1 AR2004696 Bottom medium voltage conductors in MH-4 submerged in water N/A AR1641291 Cable support in MH-2 were severely degraded to the point of collapse due to rust N/A AR2004682 Identified issue with MH-4 and P-295: JB-4 inside MH-4 was found full of water N/A FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-078 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 FPLCORP00036-REPT-037 Point Beach Units 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review - Electrical Commodities Revision 0 NP 7.7.28 Cable Condition Monitoring Program Revision 7 RMP 9390 Very Low Frequency (VLF) Insulation Resistance and Tan Delta Testing for Cables Revision 0 ER-AA-106 Cable Condition Monitoring Program Revision 6 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The SLRA states that AMP B.2.3.39 will be consistent with the program elements in GALL-SLR Report AMP XI.E3A as modified by SLR-ISG-2021-04-ELECTRICAL.

SLR-ISG-2021-04-ELECTRICAL states that the program applies to inaccessible or underground (e.g., installed in buried conduits, cable trenches, cable troughs, duct banks, underground vaults, or direct buried installations) cables that are within the scope of license renewal and potentially exposed to significant moisture. The staff reviewed FPLCORP00036-REPT-078, Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Electrical Insulation for Inaccessible Medium-Voltage Power Cable Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, Revision 0. Based on its review of this document, the staff found that the scope of the program element did not include the term potentially. During the audit, the staff requested the applicant to explain why the term potentially was not included in the scope of program. In response to the staffs request, the applicant revised the basis document to include the term potentially in the scope of program to be consistent with the corresponding element on SLR-ISG-2021 ELECTRICAL. The staff finds the scope of program is now consistent with those in SLR-ISG-2021-04-ELECTRICAL.

During its audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples provided by the applicant to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA A16.2.2.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.3.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that, when implemented, will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program.

Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR2130023 Megger testing of P-206A control cable N/A AR1643858 Z-065A/Manhole #1 degraded cable support N/A AR1641291 Manhole #2 degraded cable support N/A AR1791933 Potential cable manhole alarm and sump pump performance issue N/A AR2004682 P-295/MH-4 wiring/pump issues N/A FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-083 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document

- Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 FPLCORP00036-REPT-001 Point Beach Units 1 and 2 Subsequent License Renewal System/Structure Scoping Report Revision 0 FPLCORP00036-REPT-037 Point Beach Units 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review - Electrical Commodities Revision 0 Document Title Revision/Date LR-AMP-014-CCMON Cable Conditioning Monitoring Program Basis Document for License Renewal Revision 11 AMP XI.E3B, REPT-083 Wetted Instrument and Control Cable Evaluation N/A NP 7.7.28 Cable Condition Monitoring Program Revision 7 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP as modified by SLR-ISG-2021-04-ELECTRICAL.

The SLRA states that AMP B.2.3.40 will be consistent with the program elements in GALL-SLR Report AMP XI.E3B as modified by SLR-ISG-2021-04-ELECTRICAL.

SLR-ISG-2021-04-ELECTRICAL states that the program applies to inaccessible or underground (e.g., installed in buried conduits, cable trenches, cable troughs, duct banks, underground vaults, or direct buried installations) cables that are within the scope of license renewal and potentially exposed to significant moisture. The staff reviewed FPLCORP00036-REPT-083, Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, Revision 0. Based on its review of this document, the staff found that the scope of program does not include the term potentially. During the audit, the staff requested the applicant to explain why the term potentially was not included in the scope of program. In response to the staffs request, the applicant revised the basis document to include the term potentially in the scope of program to be consistent with the corresponding element on the staffs SLR-ISG-2021-04-ELECTRICAL. The staff finds the scope of program is now consistent with those in SLR-ISG-2021-04-ELECTRICAL.

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A16.2.2.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B.2.3.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that that the staff reviewed and found to be relevant to the Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR2004682 JB-4 inside MH-4 was found full of water N/A AR1641291 Cable supports in MH-2 have degraded to the point of collapse due to rust N/A AR1384974 Manhole Z-066C was inspected and had cables under water N/A AR1641275 Cable supports in MH-1 have degraded to the point of collapse due to rust.

N/A FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-084 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 0 NP.7.728 Cable Condition Monitoring Program Revision 7 ER-AA-106 Cable Condition Monitoring Program Revision 4 RMP 9390 Very Low Frequency (VLF) Insulation Resistance and Tan Delta Testing for Cables Revision 0 FPLCORP00036-037 Point Beach Units 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review -

Electrical Commodities Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

The SLRA states that AMP B.2.3.41 will be consistent with the program elements in GALL-SLR Report AMP XI.E3C as modified by SLR-ISG-2021-04-ELECTRICAL.

SLR-ISG-2021-04-ELECTRICAL states that the program applies to inaccessible or underground (e.g., installed in buried conduits, cable trenches, cable troughs, duct banks, underground vaults, or direct buried installations) cables that are within the scope of license renewal and potentially exposed to significant moisture. The staff reviewed FPLCORP00036-REPT-084, Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, Revision 0. Based on its review of this document, the staff found that the scope of program does not include the term potentially.

During the audit, staff requested that the applicant explain why the term potentially was not included in the scope of program. In response to the staffs request, the applicant revised the basis document to include the term potentially in the scope of program to be consistent with the corresponding element of the staffs SLR-ISG-2021-04-ELECTRICAL. The staff finds the scope of program is now consistent with those in SLR-ISG-2021-04-ELECTRICAL.

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A16.2.2.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.42, Metal Enclosed Bus Summary of Information in the Application. The SLRA states that AMP B.2.3.42, Metal Enclosed Bus, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Metal Enclosed Bus Program.

The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR2195759 Unused washers found on bus bar (removed) prior to torqueing 04/2017 AR2262078 Previous nick of bus bar insulation material identified 04/2017 AR01712367 The insulation on the C phase bus is showing signs of degradation N/A AR164498164498Foreign material in the metal enclosed bus duct between the surge arrestor cubicles and bus connections N/A AR1389293 White residue found at the point where H-509 bus bars connected to the G-05 stator N/A Document Title Revision/Date FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-085 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Metal Enclosed Bus Revision 0 MI 32.14 006 Visual Inspection for License Renewal Revision 6 RMP 9370 Bus Inspection and Cleaning Revision 21 FPLCORP00036-REPT-01 Point Beach Units 1 and 2 Subsequent License Renewal System/Structure Scoping Report Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A16.2.2.42, Metal Enclosed Bus program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Summary of Information in the Application. The SLRA states that AMP B.2.3.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program.

Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program. The staff will document its review of relevant operating experience in the SER.

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RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 AR 220476220476While performing WO 40509151, inter-tie cable connection resistance reading, post 22-23 and 54-55 were above admin limit but within functional limit 08/27/2012 AR 1908114 During performance of WO 40222104-04 corrosion was noted on stage 3 C phase insulator and connection points 10/16/2013 AR 1396321 During troubleshooting under WO 394772, Crimps ad wiring for IPOS-1003A was found to be in poor condition.

12/17/2015 AR 2016479 While performing façade freeze terminal connection checks, found multiple terminal connections to be corroded 01/13/2015 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-087 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Electrical Cable Connections Not Subject to 10 CFR 50.49 EQ Requirements Revision 0 FPLCORP 00036 - REPT00037 Point Beach Unit 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review -

Electrical Commodities Revision 0 LR-AMP-004-PSPM Periodic Surveillance and Preventive Maintenance Program Basis Document for License Renewal - License Renewal Aging Management Program Basis Document Revision 9 NEE-565-PI-003 Enercon Services, Inc. Project Instructions - Point Beach Subsequent License Renewal Aging Management Program Basis Document Revision 1 DG-E16 Nuclear Power Business Unit Design and Installation Guidelines - Insulated Cable Termination/Splices and Connections Revision 1 EPRI 002010401 Long Term Operations - Subsequent License Renewal Electrical Handbook 04/2018 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed examples of operating experience corrective actions program that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

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The staff also audited the description of the SLRA Appendix A 16.2.2.43, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA AMP B.2.3.44, High-Voltage Insulators Summary of Information in the Application. The SLRA states that AMP B.2.3.44, High-Voltage Insulators, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E7, High-Voltage Insulators as modified by SLR-ISG-Electrical-2020-XX, Updated Aging Management Criteria for Electrical Portions of the Subsequent License Renewal Guidance. To verify this claim of consistency, the staff audited the SLRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program. Therefore, the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.

Audit Activities. A keyword search was not performed. The staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the High-Voltage Insulators Program. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 AR 1785184 Trip of 245 kV breaker occurred during a severe thunderstorm due to a bad polymer insulator. The original porcelain insulator was replaced with a polymer insulator in 2008. There are no polymer insulators in scope of SLR.

07/21/2012 AR 1866053 Chipped and cracked insulators and epoxy repaired sections falling off. The cause is mostly old age of the insulators and improper repairs. This also applies to the following ARs: 1866231, 2086837, 2266011 04/20/2013 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-088 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

High-Voltage Insulators Revision 0 FPLCORP 00036 - REPT00037 Point Beach Unit 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review -

Electrical Commodities Revision 0 LR-AMP-004-PSPM Periodic Surveillance and Preventive Maintenance Program Basis Document for License Renewal - License Renewal Aging Management Program Basis Document Revision 9

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Document Title Revision/Date RMP 9177 NNSR Point Beach Nuclear Plant Routine Maintenon Procedures

- PBNP Switchyard Inspections Revision 3 NEE-565-PI-003 Enercon Services, Inc. Project Instructions - Point Beach Subsequent License Renewal Aging Management Program Basis Document Revision 1 LR-AMR-124-E Aging Management Review for Electrical Commodities (Cable and Connections, Electrical Penetration Assemblies, Phase and Switchyard Bus, Transmission Conductors, and High-Voltage Insulators)

Revision 0 PMRQ 56400-01 Inspect/Clean/Lubricate Operator 01/21/2009 PMRQ 56403-01 2F89-152 Inspect/Clean/Lubricate Operator 01/21/2009 PMRQ 55472 -02 345 kV Switchyard Components Thermography Inspection 09/03/2014 EPRI 002010401 Long Term Operations - Subsequent License Renewal Electrical Handbook 04/2018 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.

During the audit of the operating experience program element, the staff reviewed examples of operating experience corrective actions program that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A 16.2.2.44, High-Voltage Insulators, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

STAFF REVIEW OF AMR ITEM DETAILS SLRA Section 3.5.2.2.2.6, AMR Further Evaluation, Reduction of Strength and Mechanical Properties of Concrete due to Radiation and SLRA Section 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to Irradiation Embrittlement of Reactor Vessel (RV) Supports from NRC Review of the First Three SLRAs Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:

SLRA Sections 3.5.2.2.2.6 and 3.5.2.2.2.7, which describe the applicants Further Evaluation of the aging effects of irradiation on the concrete Bioshield and Primary Shield Walls and the Reactor Vessel (RV) Steel Support Assembly. Based on the evaluation, the SLRA states that a plant-specific aging management program is not required to manage the effects of irradiation. This further evaluation is associated with SLRA Table 3.5.1, item 3.5.1-097.

Audit Activities. The staff conducted a search of the applicants ePortal for operating experience using keywords: irradiated concrete, liner, sliding feet. The table below lists the documents

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that the staff reviewed and found to be relevant to SLRA Sections 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete due to Radiation and 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to Irradiation Embrittlement of Reactor Vessel (RV) Supports from NRC Review of the First Three SLRAs. The documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WO 0416358 PBNP/U1R29, Visual Examination Record, RPV Supports, as-found. (Pics) 09/23/2005 WO 7540200 PBNP/U1R29, Visual Examination Record, RPV Supports and Bolting, after clean-up in keyway - as-left. (Pictures included) 11/01/2005 WO 288812-01 PBNP/U1R30 ISI, Visual Examination (VT-3) of RPV Supports (1998 ASME Section XI Code, 2000 Addenda) -

Containment, Keyway - Examined accessible portions only. (Pictures included) 09/05/2007 WO 40367277 PBNP/U1R36 ISI, Visual Examination (VT-3) of RPV Supports (1998 ASME Section XI Code, 2008 Addenda).

Containment, Keyway - Examined portions of supports on ledge in keyway.

03/13/2016 WO 40367277-01 PBNP/U1R36 ISI, Visual Examination (VT-3) of RPV Supports (1998 ASME Section XI Code, 2008 Addenda).

Containment, Keyway - Light surface corrosion on all components viewed.

03/29/2016 WO 00220394 PBNP/U2R28 ISI, Visual Examination (VT-3) of RPV Supports (1998 ASME Section XI Code, 2000 Addenda).

Containment, Keyway - Examined accessible portions only. (Pictures included) 10/17/2006 WO 330969-01 PBNP/U2R29 ISI, Visual Examination (VT-3) of RPV Supports (1998 ASME Section XI Code, 2000 Addenda).

Containment, Keyway - Light corrosion on all portions.

RPV support lug and surrounding components. (Pictures included) 04/12/2008 WO 40321016 PBNP/U2R34 ISI, Visual Examination (VT-3) of RPV Supports (2007 ASME Section XI Code, 2008 Addenda).

Containment, Keyway - Examined accessible portions only. Boric acid from leakage above (cavity seals and sandbox/NI covers) noted. Light corrosion on supports, no degradation apparent. No concrete degradation noted.

Examine lower support region on 10/5/15 and portions from sandboxes on 10/24/15. Some regions in sandboxes are obscured due to insulation/piping configuration (piping offset inside sandbox). (Pictures included) 10/30/2015 WO Package 4032101601 NextEra Quality Record. ISI exams of RPV supports during U2R34 10/30/2015

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Document Title Revision/Date WO Package 4032101602 NextEra Quality Record. ISI exams of RPV supports during U2R34. (Includes NDE-754, Visual Examination (VT-3 ) of Nuclear Power Plant Components.)

10/30/2015 WO Package 4036727701 NextEra Quality Record. ISI exams of RPV supports during U1R36. Access thru sandbox covers (Pics).

04/07/2016 WO Package 4036727702 NextEra Quality Record. ISI exams of RPV supports during U1R36. Examined portions of ledge in keyway.

04/07/2016 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the program. The applicant provided these documents.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date UFSAR 4.2 Reactor Coolant System Design and Operation, Reactor Vessel - Support Structure 2012 UFSAR 4.4 Tests and Inspections Reactor Coolant System, Inservice inspection 2007 UFSAR 5.1.1.1 General Design Criteria 2010 UFSAR 11.6.2.1 Shielding Functions, Primary Shielding 2010 LTR-REA-20-28-NP ML20329A264 (Public)

Reactor Vessel, Reactor Vessel Supports, and Concrete Bioshield Exposure Data in Support of the Point Beach Unit 2 Subsequent License Renewal (SLR) Time-Limited Aging Analysis (TLAA), Westinghouse Revision 0 07/31/2020 WCAP-18554-NP (Incorporated in ML20329A264 -

Public)

Fracture Mechanics Assessment of Reactor Pressure Vessel Structural Steel Supports for Point Beach Units 1 and 2 Revision 1 09/2020 WCAP-18554-P ML20329A287 Proprietary Fracture Mechanics Assessment of Reactor Pressure Vessel Structural Steel Supports for Point Beach Units 1 and 2 Revision 1 09/2020 WCAP-14439-P ML20329A291 Proprietary Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Point Beach Nuclear Plant Units 1 and 2 for the Subsequent License Renewal Program (80 Years), Westinghouse Revision 4 06/2020 Westinghouse Calculation Note Number CN-ME-20-3 Proprietary Point Beach Units 1 and 2 Reactor Vessel Support Stress Calculations for Critical Flaw Size Revision 0 06/17/2020 Westinghouse letter RT-LTR-19-12, Rev. 0 Proprietary Reactor Vessel Support Embrittlement Revision 0 02/19/2019 NRC 2009-0030 ML091250564 License Amendment Request (LAR) 261, Extended Power Uprate (EPU) 04/07/2009

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Document Title Revision/Date ML091250566 -

Part 1, FPL Energy Point Beach, LLC. Point Beach Nuclear Plant Units 1 and 2, LAR 261, EPU Licensing Report 04/2009 ML091250569 -

Part 2, FPL Energy Point Beach, LLC. Point Beach Nuclear Plant Units 1 and 2, LAR 261, EPU Licensing Report 04/2009 ML110450159 Safety Evaluation Amendment No. 241, to renewed facility operating license number D PR-24 and amendment No. 245 to renewed facility operating license number D PR-27.

NextEra Energy Point Beach, LLC. Point Beach Nuclear Plant, Units 1 and 2.

05/03/2011 ML110880039 Letter from NRC Terry Belts to Larry Meyer, NextEra Point beach. PBNP, Units 1 and 2 - Issuance of License Amendments regarding EPU 05/03/2011 NEI 08-05 Industry Initiative on Control of Heavy Loads Revision 0 NRC 2005-0094 Point Beach Nuclear Plants 1 and 2, Request for Review of Heavy Load Analysis 07/24/2005 UFSAR 14.3.6 Reactor vessel head drop event 2010 Bechtel Job 6118 Volume 6 (7), Book 29 PBN Civil Structural Calcs. Containment Interior Unit 1.

Interior Structure - Reinforced Concrete. 1. Biological Shield Wall; 2. Floors.

12/27/1967 Bechtel Specification No. 6118-C-10 Specification for Detailing, Fabrication and Delivery of Major Component Support Structures for the Point Beach Nuclear Plant Unit 1. Wisconsin Michigan Power Company. Bechtel Corporation, San Francisco CA for Westinghouse Electric Corporation Atomic Power Divisions Revision 2 08/06/1968 Bechtel Specification No.0852 Structural Design Criteria for the Point Beach Nuclear Plant.

Bechtel Corporation, San Francisco CA Revision 2 07/1967 Westinghouse LTR-REA-20-27 Reactor Vessel, Reactor Vessel Support, and Concrete Bioshield Exposure Data in Support of the Point Beach Unit 1 Subsequent License Renewal (SLR) Time Limited Aging Analysis Revision 1 05/28/2020 Bechtel Job No. 10447 Point Beach Units 1 and 2 Evaluation of Containment Internal Structures for Seismic Loads. Bechtel Corporation San Francisco CA Revision 0 02/26/1997 PBNWEC-20-0023 Point Beach Nuclear Plant Units 1 and 2 Subsequent License Renewal Project. NEXTERA Response to Westinghouse Letter WEC-NEE-PB-SLR-20-003, NEXT-20-33 04/27/2020 FPLCORP00036-CA LC-002 Evaluation of the Primary Shield Wall for CLB loading, Enercon Revision 0 FPLCORP00036-CA LC-003 Evaluation of the Irradiated Primary Shield Wall, Enercon Revision 1

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Document Title Revision/Date FPLCORP00036-REPT-035 Point Beach Units 1 and 2 Subsequent License Renewal Primary Shield Wall and Reactor Vessel Support Irradiation Evaluation, Enercon Revision 0 - FPL Energy Point Beach, LLC Extended Power Uprate Licensing Report. Point Beach Nuclear Plant Units 1 and 2. License Amendment Request 261.

04/2009 CR96-1686 Containment Interior Structure Loading (Seismic). Prompt Operability Determination 12/12/1996 Bechtel Calculation 10447-9611-001 Evaluation of Containment Internal Structures for Seismic Loads. Closeout of CR 96-1686 Revision 0 02/26/1997 EPRI Report 3002002676 Expected condition of reactor cavity concrete after 80 years of radiation exposure 02/2014 EPRI Report 3002011710 Irradiation damage of the concrete biological shield - Basis for evaluation of concrete biological shield wall for aging management 05/2018 EPRI Report 3002013051 Irradiation damage of the concrete biological shield that utilizes a neutron shield tank - basis for concrete biological shield wall for aging management 05/2018 EPRI Report 3002013995 Irradiation damage of the concrete biological shield wall - example evaluation of concrete biological shield wall for aging management 07/2018 Journal of Advanced Concrete Technology, volume 14, pages 368 to 383 T. M. Rosseel, et. al., Review of the current state of knowledge on the effects of radiation on concrete 2016 Journal of Advanced Concrete Technology, volume 15, pages 440 to 523 I. Maruyama, et. al., Development of soundness assessment procedure for concrete members affected by neutron and gamma-ray irradiation.

2017 T-1 Standards for welding T-1 material, Lasker Boiler &

Engineering Corp., Magnaflux Corp., U.S. Steel Supply Division, U.S. Steel Corp.

08/23/1968 WCAP - 14422, Rev Licensing Renewal Evaluation: Aging Management for Reactor Coolant System Supports Revision 2-A CMTRs, Fiche 1-3, Rows 1-5 US Steel Corporation, US steel supply division, A/C Bechtel Corporation, Unit 1, Point Beach Nuclear Project -

Certification of Test Results/Test Reports (CMTRs Fiche 1-3, Rows 1-5) 05/01/1969 Bechtel DWG C-325 Containment structure biological shield liner plate penetrations Westinghouse - PBN Units 1 and 2, Wisconsin Michigan Power Company Revision 7 Bechtel DWG C-326 Containment structure biological shield liner plate Westinghouse - PBN Units 1 and 2, Wisconsin Michigan Power Company Revision 3 Bechtel DWG C-329 Containment structure biological shield liner plate Westinghouse - PBN Units 1 and 2, Wisconsin Michigan Power Company Revision 2

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Document Title Revision/Date Bechtel DWG C-320 Reactor steel supports sheet 1, Westinghouse - PBN Units 1 and 2, Wisconsin Michigan Power Company Revision 11 06/30/1971 Westinghouse DWG 618F159 Reactor vessel support hardware (shoe) 02/27/1970 Westinghouse DWG 5656D73 Reactor vessel support hardware assembly 02/27/1970 Nooter DWG JND34527 Reactor girder assembly for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 2 05/25/1970 Nooter DWG JND34528 Reactor girder side assembly weldment details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 3 01/19/1970 Nooter DWG JND34529 Assembly of sides to corner plates for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 4 05/25/1970 Nooter DWG JND34530 Reactor girder machining details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 4 05/25/1970 Nooter DWG JND34531 Reactor girder details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 0 10/22/1969 Nooter DWG JND34532 Reactor girder overlay details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 2 12/15/1969 Nooter DWG JND34534 Reactor girder support assembly for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 0 10/23/1969 Nooter DWGs JND34535 and JND34536 Reactor girder support details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 0 10/23/1969 Nooter DWG JND345237 Reactor girder support overlay details for Point Beach Nuclear Plant, Bechtel, San Francisco Revision 0 10/23/1969 Lasker DWG 4455-8 Reactor support elevation 31-9 and 3/8 for Point Beach, U.S. Steel Supply Division Revision 8 04/15/1969 Lasker DWG 4457-5 Detail of post supports for Point Beach, U.S. Steel Supply Division Revision 5 05/22/1968 During the audit, the staff observed the following for SLRA Sections 3.5.2.2.2.6, Reduction of Strength and Mechanical Properties of Concrete due to Radiation, and 3.5.2.2.2.7, Expected Further Evaluation for Loss of Fracture Toughness due to Irradiation Embrittlement of Reactor Vessel (RV) Supports from NRC Review of the First Three SLRAs, hereinafter referenced as FE sections:

The staff noted that the SLRA FE sections did not include sufficient information and clarity, and need to be augmented with:

(a) The following two additional AMPs:

1. Boric Acid Corrosion

2. Structures Monitoring (b) Enhancements to the following two AMPs:

1. ASME Code,Section XI Subsection IWF

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2. Structures Monitoring (c) Additional AMR items, for example, to manage the effects of aging for:

1. reduction/loss of fracture toughness of the RV structural steel support assembly due to neutron irradiation

2. expansion, cracking of concrete Bioshield Wall due to RIVE (radiation induced volumetric expansion)

3. loss of structural integrity function of Bioshield Wall liner due to RIVE induced deformation, bulging Fluence conservative bias and fluence uncertainty estimate may equally offset. The FE sections, where appropriate, need to address the ex-vessel estimated/calculated fluence uncertainty, as:

(a) Fluence incident upon bioshield exceeds threshold of concern identified in NUREG-2192 for onset of concrete material properties degradation.

(b) Potential higher fluence could increase the SLRA reported (approx.) 4 inches of concrete damage to the Bioshield Wall and could also result in increased RIVE (radiation-induced volumetric expansion) effect, imposing a quasistatic pressure on the cavity liner. This could affect the structural integrity (remain in place) of Bioshield Wall concrete and expansion of aggregates under applicable operating conditions.

(c) Effects of a potential bulging of concrete liner due to RIVE developed quasi-static lateral pressure on cavity liner need to be evaluated. Excessive bulging of cavity liner could result in interaction with the RV.

(d) Effects of potential failure of cavity liner due to induced loads (RIVE, thermal, seismic) could result in concrete falling in RV cavity and potentially adverse interaction with the RV.

Stress Interaction Ratios (IR = applied stresses/allowable stresses) of irradiated support components (SLRA Table 3.5.2.2-4) need to be recalculated due to previously unreviewed weld configuration in the structural steel assembly.

The fracture mechanics evaluation of the RV structural steel support assembly is based on postulated critical flaw sizes, with the caveat that selected T-1 welds used in the assembly have been subject to magnetic particle testing and ultrasonically examined during construction as noted in reviewed WCAP-18554-NP/ WCAP-18554-P and Standards for welding T-1 material, Lasker Boiler & Engineering Corp., Magnaflux Corp., U.S. Steel Supply Division, U.S. Steel Corp.

The staff will consider issuing RAIs subsequent to its review and evaluation of the applicants voluntarily offered SLRA supplement to obtain the necessary information related to the staffs observations above.

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SLRA Section 3.6.2.2.3 AMR Further Evaluation, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following five AMR items discussed in SLRA 3.6.2.2.3 further evaluation (FE) section:

SLRA Table 3.6.1-004, transmission conductors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.1-005, transmission connectors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.1-006, switchyard bus and connections composed of aluminum, copper, bronze, stainless steel, and galvanized steel exposed to air-outdoor SLRA Table 3.6.1-007, transmission conductors composed of aluminum, and steel exposed to air-outdoor SLRA Table 3.6.1-021, transmission conductors composed of aluminum exposed to air-outdoor The table below lists the documents that the staff reviewed and found to be relevant to the review of these items. The applicant provided these documents.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP 00036 - REPT00037 Point Beach Unit 1 and 2 Subsequent License Renewal Screening Results and Aging Management Review -

Electrical Commodities Revision 0 FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 LR-AMP-004-PSPM Periodic Surveillance and Preventive Maintenance Program Basis Document for License Renewal - License Renewal Aging Management Program Basis Document Revision 9 RMP 9177 NNSR Point Beach Nuclear Plant Routine Maintenance Procedures - PBNP Switchyard Inspections Revision 3 LR-AMR-124-E Aging Management Review for Electrical Commodities (Cable and Connections, Electrical Penetration Assemblies, Phase and Switchyard Bus, Transmission Conductors, and High-Voltage Insulators)

Revision 0 WO 40454710-19 1X-03: Modify High Side Bus for Shorter Bushings (EC 292812) 04/11/2019 WO 40712336-01 345 Switchyard Component Thermography 01/18/2021 PMRQ 56403-01 2F89-152 Inspect/Clean/Lubricate Operator 01/21/2009

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Document Title Revision/Date PMRQ 55472 -02 345 kV Switchyard Components Thermography Inspection 09/03/2014 PDM 3.0 Infrared Thermography Program Revision 8 The staff noted a minor discrepancy in SLRA Table 3.6.2-1 associated with Table 3.6.1 item 3.6.1-005. The Structure and/or Component description of this item states Transmission Conductors. However, the appropriate description of this item according to Table 3.6.1 is Transmission Connectors. The staff will address this discrepancy in the SER.

The staff reviewed the applicants further evaluation in SLRA Section 3.6.2.2.3, Loss of Material Due to Wind-Induced Abrasion, Loss of Conductor Strength Due to Corrosion, and Increased Resistance of Connection Due to Oxidation or Loss of Preload for Transmission Conductors, Switchyard Bus, and Connections. This input will be used in SER Section 3.6.2.2.3.

SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses Summary of Information in the Application. SLRA Section 4.1, Identification and Evaluation of Time-Limited Aging Analyses, provides a written discussion of the methodology the applicant used to search for analyses, calculations, evaluations, or assessments that may qualify as time-limited aging analyses (TLAAs) and need to be included and evaluated in the SLRA.

SLRA Section 4.1 also discusses the results of the applicants search to identify any regulatory exemptions that the Commission granted in accordance with the requirements of 10 CFR 50.12 that were: (1) based on the analysis in a TLAA, and (2) remain in effect for the current licensing basis (CLB).

Regulatory Basis for Conducting Audit Activities on SLRA Section 4.1 TLAA Identification and Evaluation Requirements. The Commissions regulation in 10 CFR 54.3(a) defines six criteria for TLAAs, all of which must be met to qualify an analysis, calculation, evaluation, or assessment (henceforth analysis) as a TLAA:

(1)

The analysis must involve systems, structures, or components (SCCs) within the scope of license renewal, as delineated in 10 CFR 54.4(a).

(2)

The analysis must consider the effects of aging.

(3)

The analysis must involve time-limited assumptions defined by the current operating period (e.g., 40 years).

(4)

The analysis must be determined to be relevant by the licensee in making a safety determination.

(5)

The analysis must involve conclusions related to the capability of the SCC to perform its intended function, as delineated in 10 CFR 54.4(b).

(6)

The analysis must be contained or incorporated by reference in the CLB.

For each analysis that is determined to meet the definition of a TLAA in 10 CFR 54.3(a), the regulation in 10 CFR 54.21(c)(1) requires the applicant to evaluate the TLAA in the SLRA and to demonstrate that either:

(i) the analysis will remain valid for period of extended operation, or (ii) the analysis has been projected to the end of the period of extended operation, or

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(iii) the effects of aging on the intended function(s) of the component(s) assessed in the TLAA will be adequately managed during the period of extended operation.

Regulatory Exemption Identification and Evaluation Requirements. The Commissions regulation in 10 CFR 54.21(c)(2) requires the applicant to include a list of all plant-specific regulatory exemptions that were: (1) granted in accordance with 10 CFR 50.12 and remain in effect for the CLB, and (2) are based on a TLAA. For each regulatory exemption that meets and is based on these criteria, the regulation in 10 CFR 54.21(c)(2) requires the applicant to provide an evaluation of the exemption in the SLRA that justifies its continuation during the period of extended operation.

Audit Activities. The staff conducted two audit breakout sessions with the applicant through performance of virtual teleconferences held on Friday, March 12, 2021, and Tuesday, March 23, 2021. During these teleconferences, the staff interviewed the applicants staff and reviewed documentation that the applicant provided.

Audit of the Applicants Methodology for Identifying TLAAs and TLAA Search Results. The staff audited the applicants methodology for identifying TLAAs in the CLB and the results of the applicants CLB search for relevant documents on records that may be or include TLAAs. As part of its audit, the staff searched for any analysis that, contrary to the applicants determination in the SLRA, might conform to the six criteria for TLAAs in 10 CFR 54.3(a), but was not included within the scope of the analyses that were identified and evaluated as TLAAs in the SLRA.

The staff did not perform an independent keyword search (as part of its audit activities) to look for those analyses that might need to be identified and evaluated as TLAAs in the SRLA.

Instead, the staff relied on the keyword search that the applicant performed to search for TLAAs. Documents reviewed in relation to this aspect of the audit are listed in the Relevant Documents - TLAA Identification Methodology and Results table that follows.

Staff observations made in relation to TLAA identification methodology and results are documented and summarized in this audit report input after the Relevant Documents - TLAA Identification Methodology and Results table. The staff will document the results of its review in SER Section 4.1.

RELEVANT DOCUMENTS - TLAA IDENTIFICATION METHODOLOGY AND RESULTS Document Title Date or Revision PBNP Report No. LT-TR-510-TLAA License Renewal Technical Report, Point Beach Nuclear Plant, Time Limited Aging Analysis Report Revision 0 January 30, 2004 Enercon Report No. FPLCORP00036-REPT-038 Point Beach Units 1 and 2, Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0

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Document Title Date or Revision PBNP Final Safety Analysis Report (FSAR), including Appendix A, Section A.2 Section A.2, High Energy Pipe Failure Outside Containment, including Subsection A.2.5.

Methodologies for Locations, Size, and Orientation of Breaks 2015 Version (ADAMS Accession No. ML16251A168)

SLRA, Table 4.1.5-1 Review of Generic TLAAs Listed in NUREG-2192, Table 4.1-2 Revision 0 SLRA Table 4.1.5-2 Review of Plant-Specific TLAAs Listed in NUREG-2192, Table 4.7-1 Revision 0 The staff observed the following in relation to the applicants TLAA identification methodology and results:

Except for the potential TLAA omission matters raised in the bullet that follows, the staff observed that the applicant appears to have identified all analyses required to be identified as TLAAs in accordance with the TLAA definition criteria in 10 CFR 54.3(a) and has evaluated those TLAAs in either SLRA Section 4.2, 4.3, 4.4, 4.5, 4.6, or 4.7, or in one of their subsections. The staff will evaluate these TLAAs in either SER Sections 4.2, 4.3, 4.4, 4.5, 4.6, or 4.7, or in one of their subsections.

Table 2.1-1 in Report No. FPLCORP00036-REPT-038 indicates that the applicant used the following keywords to search its database for relevant TLAA records: (1) year, (2) cycle, (3) wear, (4) crack, (5) life, (6) allowance, (7) erosion, (8) fatigue, (9) EFPY, (10) licensing period, and (11) license term. The staff observed that the applicant did not include fluence within the scope of the keywords the applicant used for its database search.

The staff discussed this topic and matter with the applicant during the audit breakout session of Friday, March 12, 2021. During that breakout session, the applicant stated that it would perform an additional keyword search of its databases to confirm that the neutron fluence-based TLAAs reported in SLRA Section 4.2 are the only applicable fluence-dependent TLAAs that need to be evaluated in accordance with the TLAA evaluation requirements that are specified in 10 CFR 54.21(c)(1). The staff has no further questions in relation to this matter, because the applicant will be required to supplement the SLRA if its search on fluence identifies that there are additional fluence-dependent analyses (i.e., beyond those already reported and evaluated as fluence-dependent TLAAs in SLRA Sections 4.2 or 4.7) that conform to the definition of TLAA in 10 CFR 54.3(a) and need to be evaluated in accordance with the TLAA disposition requirements in 10 CFR 54.21(c)(1).

In SLRA Table 4.1.5-1 and Note 1 of the table, the applicant states that the high energy line break (HELB) analyses for Units 1 and 2 are not TLAAs because they do not involve time-dependent assumptions defined by the current operation term. The staff observed that the applicant includes the HELB analysis basis for Units 1 and 2 in Section A.2 of Appendix A in the FSAR. The staff also observed that, contrary to the applicants statement in the SLRA, the applicants HELB basis for intermediate non-Class 1 piping segments in Section A.2.5 of the UFSAR could potentially involve time dependent assumptions defined by the current operating term because they appear to be based on the same time-dependent thermal expansion stress

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and operating temperature stress parameters (i.e., SA and Sh parameters) that are evaluated in the applicants metal fatigue TLAA for non-Class 1 piping segments (which is evaluated in SLRA Section 4.3.3).

The staff discussed this topic and matter with the applicant during two audit breakout session teleconferences that were held with the applicant on Friday, March 12, 2021, and on Tuesday, March 23, 2021. During the breakout session, the applicant informed the staff, that upon further review, the aspects of the HELB analysis that apply to intermediate pipe locations should have been identified as a TLAA for the SLRA because they are based on the same time-dependent SA and Sh parameters evaluated in the SLRAs metal fatigue TLAA for non-Class 1 components (refer to SLRA Section 4.3.3). On March 12, 2021, the applicant verified that it would amend and supplement SLRA Table 4.1.5-1 accordingly to identify the HELB analysis as a TLAA for the SLRA and adjust the metal fatigue TLAA for non-Class 1 components in SLRA Section 4.3.3 to link the HELB analysis to the time-dependent treatment and evaluation of the SA and Sh parameters in SLRA Section 4.3.3. The staff will evaluate this matter in the safety evaluation report. The staff may issue a request for confirmation in relation to the referenced SLRA supplement activities that pertain to the HELB analysis assessment for the SLRA.

The staff observed that Point Beach is among NextEra Energys fleet of reactors that also includes the two PWR units at the St. Lucie Nuclear Power Station (i.e., St. Lucie Units 1 and 2).

The staff noted that the applicant did not identify that were any time-dependent flaw growth or fracture analyses for Point Beach that needed to be identified as TLAAs in SLRA Section 4.1 flaw growth. However, the staff noted that, in the past license renewal application (LRA) for St.

Lucie Units 1 and 2, the applicant identified that the flaw growth analysis for the 1/2-nozzle repair designs included in the St. Lucie units were TLAAs for the past SLRA.

The staff discussed this topic and matter with the applicant during a virtual audit breakout session teleconference that was held with the applicant on Friday, March 12, 2021. During the audit breakout session, the applicant explained that the MNSA [mechanical nozzle seal assembly] or half-nozzle are only approved for Combustion Engineering-designed PWRs and that the design of the reactor units do not include these types of repair assemblies because the RPVs and reactor coolant pressure boundaries of the units were designed by Westinghouse-Electric Company. Thus, the staff found this to be a sufficient explanation for establishing that the design of the Point Beach units do not include any MNSA or half-nozzle repair assemblies, which, otherwise, if present in the plant designs, may have been evaluated with a time-dependent flaw growth or flaw tolerance analysis. This matter is closed for the audit and does not need to be reflected in the SER.

Audit of Regulatory Exemptions. For this aspect of the staffs audit, the staff searched the NRCs Agencywide Documents Access and Management System (ADAMS) to locate those regulatory exemptions that were previously granted in accordance with the exemption approval and authorization requirements of 10 CFR 50.12 and included in the Dockets for Point Beach (i.e., Docket No. 50-266 for Unit 1 and 50-301 for Unit 2). For those exemptions granted in accordance with 10 CFR 50.12, the staff audited the past staff-performed regulatory exemption evaluations that were included and issued as part of authorization letters for the exemptions to ascertain whether the exemptions were based on a time-dependency associated with a TLAA assessment. The staff also searched ADAMS for applicable records that might indicate that a specific 10 CFR 50.12-based regulatory exemption had been formally and legally withdrawn from the scope of the CLB by the applicant.

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Documents reviewed in relation to this aspect of the audit are listed in the Relevant Documents

- Exemption Results table that follows. Staff observations made in relation to these audit activities are provided after the Relevant Documents - Exemption Results table. The staff will document the results of its review in SER Section 4.1.

RELEVANT DOCUMENTS REVIEWED - EXEMPTION RESULTS Document Title Date or Revision SLRA, Section 4.1.5 Identification and Evaluation of Exemptions Revision 0 Enercon Report No. FPLCORP00036-REPT-038 Point Beach Units 1 and 2, Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Appendix K,Section I.D.3 and I.D.5 Requirements) 03/08/1989 (ADAMS Accession No. ML021960280)

NRC Exemption Evaluation and Authorization of Exemption to NextEra Energy Point Beach, LLC Exemption (From 10 CFR 50.46 and 10 CFR Part 50, Appendix K, Section I.A.5 Requirements) 05/09/2014 (ADAMS Accession No. ML14058B055)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.44(c)(3)(iii) requirements) 01/25/1983 (ADAMS Accession No. ML20028F574)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.44(c)(3)(iii)

Requirements) 12/30/1983 (ADAMS Accession No. ML20083G648)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix E, Section IV.F.1 requirements) 10/7/1982 (ADAMS Accession No. ML20027D547)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.47 and 10 CFR Part 50, Appendix E, Section IV.F.2.b Requirements) 11/28/1995 (ADAMS Accession No. ML20095K053)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.48(c) and 10 CFR Part 50, Appendix R, Section III.F, III.G, III.M and III.O requirements) 05/04/1982 (ADAMS Accession No. ML20052F809)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.G Requirements) 07/03/1985 (ADAMS Accession No. ML20129J053)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.G Requirements) 12/31/1986 (ADAMS Accession No. ML20212F358)

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Document Title Date or Revision NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.G.3.b Requirements) 05/23/1988 (ADAMS Accession No. ML20154N326)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.G.2 Requirements) 07/18/1995, as amended 10/24/1995 (ADAMS Accession Nos. ML021970169 and ML021970307)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.J Requirements) 05/07/1998 (ADAMS Accession No. ML20247H898)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix R, Section III.G.1 and III.L.1 Requirements) 06/02/2005 (ADAMS Accession No. ML050550077)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.54(w) Requirements) 10/3/1988 (ADAMS Accession No. ML20155F620)

Wisconsin Electric Power Company Letter No. VPNPD-93-089 (NRC-93-053) to the NRC Document Control Desk Dockets 50-266 and 50-301, Request for Exemption from the Requirements of 10 CFR 50.60, Overpressure Mitigating System Setpoint, Point Beach Nuclear Plant, Units 1 and 2 04/20/1993 (ADAMS Accession No. ML20035G121)

Wisconsin Electric Power Company Letter No. VPNPD-93-120 (NRC-93-078) to the NRC Document Control Desk Dockets 50-266 and 50-301, Withdrawal of Request for Exemption Overpressure Mitigating System Setpoint, Point Beach Nuclear Plant, Units 1 and 2 06/21/1993 (ADAMS Accession No. ML20045D638)

Wisconsin Electric Power Company Letter No. VPNPD-96-04 to the NRC Document Control Desk Dockets 50-266 and 50-301, Request for Exemption from the Requirements of 10 CFR 50.60, Overpressure Mitigating System Setpoint, Point Beach Nuclear Plant, Units 1 and 2 07/01/1996 (ADAMS Accession No. ML20115A920)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.60(a) and 10 CFR Part 50, Appendix G Requirements to allow use of ASME Code Case N-514) 01/27/1997 (ADAMS Accession No. ML20134B737)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.60(a) and 10 CFR Part 50, Appendix G Requirements to allow use of ASME Code Case N-641) 10/06/2000 (ADAMS Accession No. ML003758475)

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Document Title Date or Revision NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR 50.61 and 10 CFR Part 50, Appendix G Requirements to allow use of AREVA Report BAW-2308, Revisions 1-A and 2-A as alternative fracture toughness methodology for reactor pressure vessel [RPV]

beltline welds) 06/30/2014 (ADAMS Accession No. ML14126A594)

NRC Exemption Evaluation and Authorization of Exemption to Wisconsin Electric Power Company Exemption (From 10 CFR Part 50, Appendix J Requirements) 06/25/1982 (ADAMS Accession No. ML20055A321)

The staff noted that, in SLRA Section 4.1.4 (as supported by information in Enercon Report No. FPLCORP00036-REPT-038), the applicant identifies that it did not find any exemptions granted in accordance with 10 CFR 50.12 that: (1) remain in effect, and (2) are based on a TLAA.

Based on its search and review of relevant exemption records in ADAMS, the staff observed that the Commission granted a total of 18 regulatory exemptions in accordance with the exemption approval and authorization criteria in 10 CFR 50.12. The staff observed the following in relation to these exemptions:

Exemption Authorization Evaluation of March 8, 1989 - 10 CFR Part 50, Appendix K.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix K. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of alternative emergency containment cooling system (ECCS) heat removal models. The staff also observed that the basis for alternate heat removal models did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of aging effects in the ECCS systems.

Exemption Authorization Evaluation of May 9, 2014 - 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The staff observed that this exemption request (as referenced in the exemption authorization evaluation), requested staff approval and 10 CFR 50.12 authorization that permitted the applicant to use an Optimized ZIRLOTM alloy as the fuel cladding material for the reactors. The staff also observed that the basis for the exemption request did not rely on any analysis involving time-limited aging assumptions defined by the current operating term or an assessment of aging effects in the Optimized ZIRLOTM fuel cladding material.

Exemption Authorization Evaluations of January 25, 1983, and December 30, 1983 -

10 CFR 50.44. The staff noted that, on these dates, the staff granted the applicant two regulatory exemptions from the requirements specified in 10 CFR 50.44. The staff observed that the incoming exemption requests (as referenced in the exemption

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authorization evaluations) involved schedular (non-time dependent) requests, which (upon authorization) permitted the applicant to defer the date for completing installation of required reactor coolant system high point vents from July 1, 1982, to January 1, 1984, and then again to December 31, 1994.

Exemption Authorization Evaluation of October 7, 1982 - 10 CFR Part 50, Appendix E.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix E. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a one-time schedular (non-time dependent) request, which (upon authorization) permitted the applicant to defer the time for performing a full scale emergency preparedness exercise from March 1983 to September 20, 1983.

Exemption Authorization Evaluation of November 28, 1995 - 10 CFR Part 50, Appendix E. The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix E.

The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a one-time schedular (non-time dependent) request, which (upon authorization) permitted the applicant to use a Federal Emergency Management Agency-required emergency exercise performed on December 16, 1994, to satisfy the utility-only emergency exercise the applicant was required to perform in 995.

Exemption Authorization Evaluation of May 4, 1982 - 10 CFR Part 50, Appendix R. The staff noted that, on May 4, 1982, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a one-time schedular (non-time dependent) request that allowed the applicant to use alternate dates for submitting fire protection system design details to the staff, or for implementing modifications of the fire protection system from the required date of March 19, 1981.

Exemption Authorization Evaluation of July 3, 1985 - 10 CFR 50.48(c) and 10 CFR Part 50, Appendix R. The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR 50.48(c) and 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of proposed alternatives to the specified fire protection system separation and suppression requirements in 10 CFR Part 50, Appendix R. The staff also observed that the basis for the alternate fire protection separation and suppression requirements did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of aging effects in the fire protection systems.

Exemption Authorization Evaluation of December 31, 1986 - 10 CFR Part 50, Appendix R. The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R.

The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of alternate fire protection criteria for the auxiliary building, service water pump room, and residual heat removal pump room in lieu of the automatic fire protection pump or systems required for the building or rooms. The staff also observed that the basis for the alternate fire protection

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criteria did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of May 23, 1988 - 10 CFR Part 50, Appendix R.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of alternative fire protection criteria from the fixed fire suppression systems that were required to be included in the component cooling water heat exchanger and boric acid tank rooms and in the computer and instrument rack rooms. The staff also observed that the basis for the alternate fire protection criteria did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of July 18, 1995, as Amended on October 24, 1995

- 10 CFR Part 50, Appendix R. The staff noted that, on these dates, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of alternative fire protection criteria from the fire protection requirements for separation of safe shutdown cables and combustible materials in the auxiliary buildings (including the auxiliary feedwater pump fire areas). The staff also observed that the basis for the alternate fire protection criteria did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of May 7, 1998 - 10 CFR Part 50, Appendix R.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for staff approval of alternate hand-held portable lighting in lieu of the permanent emergency lighting that is required for building areas containing safe shutdown equipment and for access and egress routes. The staff also observed that the basis for use of the alternate hand-held, portable lighting did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of June 5, 2005 - 10 CFR Part 50, Appendix R.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix R. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request for exemption from the requirements of 10 CFR Part 50, Appendix R, Section III.G.1.a, for an electrical repair of a dedicated air compressor, where the source of power to the compressor was coming from one of two pre-planned 480-volt power sources. The staff also observed that the basis for use of the exemption did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of October 3, 1988 - 10 CFR 50.54(w). The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the

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requirements specified in 10 CFR 50.54(w). The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved a request to approval of alternate dollar amounts for onsite property damage insurance that was required in the staffs August 5, 1987, amendment to the 10 CFR 50.54(w) rule.

The staff observed that the basis for use of the alternate property insurance dollar amounts did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of June 25, 1982 - 10 CFR Part 50, Appendix J.

The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR Part 50, Appendix J. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved alternative 10 CFR Part 50, Appendix J, criteria for air supply lines used in performance of the applicants 10 CFR Part 50, Appendix J, Type A, containment leak rate tests. The staff noted that the exemption request included specific requests for staff authorization to use Appendix J, Type C, local leak rate tests for the isolation valves located in the air supply lines, and to allow use of periodic hydrostatic testing of the residual heat removal system containment isolation valves in lieu of the pneumatic Type C local leak rate testing required for these valves in 10 CFR Part 50, Appendix J. The staff also observed that the basis for the alternate containment and local leak rate test criteria did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term or an assessment of the effects of aging.

Exemption Authorization Evaluation of June 30, 2014 - 10 CFR 50.61 and 10 CFR Part 50, Appendix G. The staff noted that, on this date, the staff granted the applicant a regulatory exemption from the requirements specified in 10 CFR 50.61 and 10 CFR Part 50, Appendix G, for establishment of adjusted reference temperature (ART) values. The staff observed that the incoming exemption request (as referenced in the exemption authorization evaluation) involved approval to use the methods in AREVA Report Nos. BAW-2308, Revision 1-A, and BAW-2308, Revision 2-A, as the basis for establishing alternate generic unirradiated ART values (i.e., RTNDT(U) or RT0 values) for specified Babcock and Wilcox reactor pressure vessel (RPV) weld materials included in the design of the RPVs. The staff also observed that the basis for the alternate RTNDT(U) values was based on an assessment of deterministic Charpy-impact data for the weld materials and did not rely on any analysis that involved time-limited aging assumptions defined by the current operating term.

Exemption Authorization Evaluations of January 27, 1997, and October 6, 2000 -

10 CFR 50.60 and 10 CFR Part 50, Appendix G. The staff noted that, on these dates, the staff granted the applicant two different regulatory exemptions from the requirements specified in 10 CFR Part 50, Appendix G, for low temperature overpressure protection (LTOP) system pressure lift and arming temperature setpoints. The staff observed that, in the exemption authorization of January 27, 1997, the staff authorized use of ASME Code,Section XI, Code Case N-514 as an alternate methodology for calculating the LTOP system setpoint values. The staff observed that, in the exemption authorization of October 6, 2000, the staff authorized use of a different ASME Code,Section XI, Code Case (i.e., Code Case N-641) for calculation of the LTOP system setpoint values. Thus, the staff noted that the CLB includes two different regulatory exemptions related to specific alternate Code Case methodologies that may be applied for LTOP system

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pressure lift and arming temperature setpoint calculations. The staff also made the following additional observations in relation to these exemptions:

o The exemptions may have a relationship to the LTOP system pressure lift and arming temperature requirements specified in technical specification (TS)

Section 3.4.12.

o The Code Case methodologies referenced in the authorized exemptions may have a relationship to the methodologies required for calculation of LTOP system setpoints values, as referenced in TS Section 5.6.5.

o SRP-SLR Section 4.1.3 identifies that exemptions regarding use of ASME Code,Section XI, Code Case N-514 for LTOP setpoint calculations are an example of regulatory exemptions that may be based on a TLAA and remain in effect for the CLB.

The staff discussed these exemption matters with the applicant during the two virtual audit breakout session teleconferences held with the applicant on Friday, March 12, 2021, and on Tuesday, March 23, 2021. During the audit breakout session of March 12, 2021, the applicant verified that, while the exemption for Code Case N-514 is still part of the CLB, it no longer is being relied upon as the technical basis for calculating the pressure lift and system arming temperature setpoints for the LTOP system (which also may be referred to as the cold overpressure mitigation system (COMS) in some plants). During the subsequent breakout session that was held with the applicant on March 23, 2021, the applicant clarified that it will be submitting a supplement of SLRA Section 16.3.1, Identification of Time-Limited Aging Analyses

[and] Exemptions, to clarify that it no longer relies on Code Case N-514 and the exemption for the code case as the basis for establishment of the LTOP system setpoints. The staff will evaluate this regulatory exemption in SER Section 4.1.3. The staff may issue a request for confirmation in relation to this referenced SLRA supplement activity.

Audit of UFSAR Supplement. The applicant is not required in 10 CFR 54.21(d) to include a UFSAR supplement for SLRA Section 4.1, Identification of Time-Limited Aging Analyses, because the section only applies to the applicants methodology that the applicant used to search for TLAAs that need to be identified and evaluated in the SLRA in accordance with 10 CFR 54.21(c)(1) and those regulatory exemptions required to be evaluated in accordance with 10 CFR 54.21(c)(2), and the applicants results of those searches. However, the staff observed that the applicant conservatively includes a UFSAR Supplement Section for its TLAA and exemption identification activities, as given in SLRA Section 16.3.1, Identification of Time-Limited Aging Analyses [and] Exemptions. The staff will evaluate SLRA Section 16.3.1 in SER Section 4.1.

SLRA TLAA Section 4.2.2, Pressurized Thermal Shock Summary of Information in the Application. SLRA Section 4.2.2, Pressurized Thermal Shock, discusses pressurized thermal shock (PTS) analyses for the reactor pressure vessels (RPVs).

The TLAA (henceforth referred to as the TLAA on PTS) applies to RPV base metal and weld components that are made from ferritic steel materials (e.g., carbon steels or low alloy steels) and exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter evaluated in the TLAA. The TLAA on PTS includes the applicants PTS calculations for the RPV inner surface. The calculations apply to those RPV components located in the beltline of the RPV, with the beltline defined by the applicant to

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include all components projected to receive a fluence of greater than or equal to 1 x 1017 n/cm2 (E > 1 MeV) through the period of extended operation (80 years or 72 EFPY).

The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) and stated that the PTS analyses have been projected to the end of the subsequent period of extended operation.

To verify that the applicant had provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. Consistent with the guidance in SRP-SLR Section 3.1.2.2.3, item 2, the operating experience for the TLAA on PTS is provided by the applicants RPV surveillance capsule reports that apply to the TLAA. Since the applicant is required to submit the reports to the NRC in accordance with specified reporting requirements in 10 CFR Part 50, Appendix H, the staff did not perform a keyword search of relevant terms (e.g., RPV, capsule) that may apply to the TLAA. Instead, the staff performed a search of NRC records to locate those RPV surveillance capsule reports and other records that apply to the TLAA on PTS. The relevant RPV surveillance capsule reports for TLAA on PTS are specified in the Relevant Documents Reviewed table below.

During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WCAP-18555-NP Point Beach Units 1 and 2 Time-Limited Aging Analyses on Reactor Vessel Integrity for Subsequent License Renewal (ADAMS Accession No. ML20329G264)

Revision 1 08/2020 AREVA Report BAW-2308-NP Initial RTNDT of Linde 80 Weld Materials (ADAMS Accession Number ML081270388)

Revision 2-A 03/2008 BAW-2166 B&W Owners Group Response to Generic Letter 92-01 06/1992 BAW-2325 B&W Owners Group, Reactor Vessel Working Group, Response to Request for Additional Information (RAI)

Regarding Reactor Pressure Vessel Integrity (ADAMS Accession No. ML14162A108)

Revision 1 01/01/1999 WCAP-7513 Point Beach Nuclear Plant Unit No. 1 Pressure Vessel Surveillance Program: Evaluations of Capsule V 06/15/1973 WCAP-8739 Analysis of Capsule S from the Wisconsin Electric Power Company and Wisconsin Michigan Power Company Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1976 WCAP-9357 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit 1 Reactor Vessel Radiation Surveillance Program 12/1984 WCAP-10736 Analysis of Capsule T from the Wisconsin Electric Power Company Point Beach Nuclear Plant No. 1 Reactor Vessel Radiation Surveillance Program 01/1990

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Document Title Revision/Date WCAP-7712 Wisconsin Michigan Power Co. and the Wisconsin Electric Power Co. Point Beach Unit No. 2 Reactor Vessel Radiation Surveillance Program 06/1971 BMI-0675 Point Beach Nuclear Plant Unit No. 2 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/10/1975 WCAP-9331 Analysis of Capsule T from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-9635 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Program 06/1979 BAW -2140 Analysis of Capsule S Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 08/1991 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). During the audit, the staff observed the following:

The staff reviewed WCAP-18555 and verified via spot-check that the updated 80-year fluence values were correctly applied to the PTS TLAA.

The staff reviewed WCAP-18555 and noted that the applicant provided a description of surveillance capsule withdrawal schedule.

The staff reviewed WCAP-18555 and noted that the applicant provided a description of the licensing basis behind determining chemistry factor when surveillance data is available.

The staff reviewed BAW-2308-NP and noted that the applicant appropriately applied the unirradiated RTNDT and sigma adjustments for Linde 80 welds.

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

The staff also audited the description of the SLRA TLAA Pressurized Thermal Shock provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.2.3, Upper-Shelf Energy Summary of Information in the Application. SLRA Section 4.2.3, Upper-Shelf Energy, discusses the evaluation of the time-limited aging analysis (TLAA) that assesses the projected reduction in the upper-shelf energy (USE) properties of reactor pressure vessel (RPV) base metal and weld components projected through the subsequent period of extended operation.

The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that the applicant provided a sufficient basis to support its disposition of the TLAA and that the update will comply with the requirements in 10 CFR Part 50, Appendix G, the staff audited the TLAA.

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Audit Activities. A search of the applicants operating experience database was conducted using keywords: upper-shelf energy, USE, RPV, RV, reactor vessel, Regulatory Guide 1.99, RG 1.99, position 2.2, position 1.2, ema, and equivalent margins. No significant plant-specific operating experience associated with SLRA TLAA 4.2.3, Upper-Shelf Energy was noted by the staff during its audit.

During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date BAW-1543 NP, Supplement 6-A Supplement to the Master Integrated Reactor Vessel Surveillance Program Revision 4 09/07/2007 LR-AMP-016-RVSUR V-008 Reactor Vessel Surveillance Program Basis Revision 8 LR-AMP-016-RVSUR V-009 Reactor Vessel Surveillance Program Basis Revision 9 NA Final Report on Point Beach Nuclear Plant Unit 1 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/15/1973 WCAP-8739 Analysis of Capsule S from the Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1976 WCAP-9357 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-10736 Analysis of Capsule T from the Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 12/1984 NA Final Report on Point Beach Nuclear Plant Unit 2 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/10/1975 WCAP-9331 Analysis of Capsule T from the Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-9635 Analysis of Capsule R from the Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 12/1979 BAW-2140 Reactor Vessel Surveillance Capsule Test Report and RTPTS Submittal Point Beach Nuclear Plant, Unit 2 and Charpy Upper-Shelf Energy Status, Point Beach Nuclear Plant Units 1 and 2 10/15/1991 BAW-2166 B&W Owners Group Response to Generic Letter 92-01 06/1992 BAW-2222, Rev. 1 Reactor Vessel Working Group Response to Closure Letters to NRC Generic Letter 92-01 06/1994

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Document Title Revision/Date BAW-2192 Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Level A & B Service Loads 12/1979 BAW-2178 Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Level C & D Service Loads 06/1994 BAW-2467 Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessel of Point Beach Units 1 and 2 for Extended Life through 53 Effective Full Power Years 07/2004 BAW-2192, Revision 0, Supplement 3P/3NP Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels A & B Service Loads 10/2020 BAW-2178, Revision 0, Supplement 2P/2NP Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels C & D Service Loads 10/2020 ANP-3886P/NP, Revision 0, PWROG-20043-P/NP PWROG - PBN Unit 1 IS Plate A9811-1 Equivalent Margins Analysis for SLR 10/2020 The staff also audited the summary description of the TLAA for the Upper-Shelf Energy Analyses provided in the UFSAR supplement. The staff verified this summary description is consistent with the generic description provided in the SRP-SLR.

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

SLRA TLAA Section 4.2.4, Adjusted Reference Temperature Summary of Information in the Application. SLRA Section 4.2.4, Adjusted Reference Temperature, discusses the applicants adjusted reference temperature (ART) analyses for the reactor pressure vessels (RPVs). The TLAA (henceforth referred to as the TLAA on ART) applies to RPV base metal and weld components made from ferritic steel materials (e.g., carbon steels or low alloy steels) and are exposed to a reactor coolant with neutron flux environment, with neutron fluence being the time-dependent aging parameter evaluated in the TLAA. The TLAA on ART includes the applicants ART calculations for the 1/4T and 3/4T locations postulated for the RPV components. The calculations apply to those RPV components located in the beltline of the RPV, with the beltline defined by the applicant to include all components projected to receive a fluence of greater than or equal to 1 x 1017 n/cm2 (E > 1MeV) through the period of extended operation (80 years or 72 EFPY).

The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii) and stated that the ART analyses have been projected to the end of the subsequent period of extended operation.

To verify that the applicant had provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

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Audit Activities. Consistent with the guidance in SRP-SLR Section 3.1.2.2.3, item 2, the operating experience for the TLAA on ART is provided by the applicants RPV surveillance capsule reports that apply to the TLAA. Since the applicant is required to submit the reports to the NRC in accordance with specified reporting requirements in 10 CFR Part 50, Appendix H, the staff did not perform a keyword search of relevant terms (e.g., RPV, capsule) that may apply to the TLAA. Instead, the staff performed a search of NRC records to locate those RPV surveillance capsule reports and other records that apply to the TLAA on ART. The relevant RPV surveillance capsule reports for TLAA on ART are specified in the Relevant Documents Reviewed table below.

During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WCAP-18555-NP Point Beach Units 1 and 2 Time-Limited Aging Analyses on Reactor Vessel Integrity for Subsequent License Renewal (ADAMS Accession No. ML20329G264)

Revision 1 08/2020 AREVA Report BAW-2308-NP Initial RTNDT of Linde 80 Weld Materials (ADAMS Accession Number ML081270388)

Revision 2-A 03/2008 BAW-2166 B&W Owners Group Response to Generic Letter 92-01 06/1992 BAW-2325 B&W Owners Group, Reactor Vessel Working Group, Response to Request for Additional Information (RAI)

Regarding Reactor Pressure Vessel Integrity ( ADAMS Accession No. ML14162A108)

Revision 1 01/1999 WCAP-7513 Point Beach Nuclear Plant Unit No. 1 Pressure Vessel Surveillance Program: Evaluations of Capsule V 06/15/1973 WCAP-8739 Analysis of Capsule S from the Wisconsin Electric Power Company and Wisconsin Michigan Power Company Point Beach Nuclear Plant Unit No. 1 Reactor Vessel Radiation Surveillance Program 11/1976 WCAP-9357 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit 1 Reactor Vessel Radiation Surveillance Program 12/1984 WCAP-10736 Analysis of Capsule T from the Wisconsin Electric Power Company Point Beach Nuclear Plant No. 1 Reactor Vessel Radiation Surveillance Program 01/1990 WCAP-7712 Wisconsin Michigan Power Co. and the Wisconsin Electric Power Co. Point Beach Unit No. 2 Reactor Vessel Radiation Surveillance Program 06/1971 BMI-0675 Point Beach Nuclear Plant Unit No. 2 Pressure Vessel Surveillance Program: Evaluation of Capsule V 06/10/1975 WCAP-9331 Analysis of Capsule T from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Surveillance Program 08/1978 WCAP-9635 Analysis of Capsule R from the Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 Reactor Vessel Radiation Program 06/1979

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Document Title Revision/Date BAW -2140 Analysis of Capsule S Wisconsin Electric Power Company Point Beach Nuclear Plant Unit No. 2 08/1991 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). During the audit, the staff observed the following:

The staff reviewed WCAP-18555 and verified via spot-check that the updated 80-year fluence values were correctly applied to the ART TLAA.

The staff reviewed WCAP-18555 and noted that the applicant provided a description of surveillance capsule withdrawal schedule.

The staff reviewed WCAP-18555 and noted that the applicant provided a description of the licensing basis behind determining chemistry factor when surveillance data is available.

The staff reviewed BAW-2308-NP and noted that the applicant appropriately applied the unirradiated RTNDT and sigma adjustments for Linde 80 welds.

During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

The staff also audited the description of the SLRA TLAA Adjusted Reference Temperature provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.2.5, Pressure-Temperature Limits and Low Temperature Overpressure Protection (LTOP) Setpoints Summary of Information in the Application. SLRA Section 4.2.5, Pressure-Temperature Limits and Low Temperature Overpressure Protection (LTOP) Setpoints, summarizes the applicants evaluation of the time-limited aging analysis (TLAA) related to pressure-temperature (P-T) limit and LTOP setpoint calculations for the reactor pressure vessel (RPV) components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii), which requires the applicant to demonstrate that the effects of aging on the intended function of the RPV components will be managed during the subsequent license renewal period. To satisfy this requirement, the applicant stated in the SLRA that it will update the P-T limits and LTOP setpoints through the 10 CFR 50.90 process later. Per the review guidance in SRP-SLR Section 4.2.3.1.4.3, the staff audited the TLAA to verify that the P-T limit and LTOP setpoints methodology for the update will comply with the requirements in 10 CFR Part 50, Appendix G.

Audit Activities. A search of the applicants operating experience database was conducted using keywords: vessel internals, primary water stress corrosion cracking, wall loss, embrittlement, cycle, transient, start/stop, flaw, wastage, stress corrosion cracking, and starts and stops. No significant plant-specific operating experience associated with the SLRA TLAA 4.7.4, was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed the following relevant documents that the applicant provided.

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RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date Point Beach Technical Specifications Section 3.4.3 RCS Pressure Temperature (P/T) Limits 08/10/2020 Point Beach Technical Specification Section 3.4.12 Low Temperature Overpressure Protection (LTOP) System 08/10/2020 Point Beach Technical Specification Section 5.6.5 RCS Pressure Temperature Limit Report (PTLR) 08/10/2020 LR-TR-510-TLAA Revision 0 Section 3.1.3 Pressure Temperature Limits Revision 0 1/30/2004 FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 TRM 2.2 Pressure Temperature Limits Report Revision 11 12/2019 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

During the audit of the operating experience program associated with the TLAA, the staff independently searched the plant-specific database using keywords related to P-T limits and LTOP setpoints to identify any previously unknown or recurring aging effects. The staff did not identify any operating experience associated with SLRA TLAA 4.2.5 based on the keyword search.

The staff also audited the UFSAR supplement summary description of SLRA TLAA 4.2.5 in SLRA Appendix A, Section 16.3.2.5, Pressure-Temperature Limits and Low Temperature Overpressure Protection (LTOP) Setpoints. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components Summary of Information in the Application. SLRA Section 4.3.1, Metal Fatigue of Class 1 Components, discusses the fatigue analysis for ASME Code Class 1 components. The analysis calculates fatigue cumulative usage factors (CUFs) to demonstrate that the CUFs will not exceed the design allowable limit of 1.0 during the subsequent period of extended operation.

For the pressurizer spray piping, the applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). For the other Class 1 components, the applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. The applicants performed a search of the operating experience database using keywords: crack, cycl, damage, fatigue, flaw, monitor, CUF, usage factor, environmental, and transient.

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The table below lists the document that the staff reviewed and found to be relevant to the fatigue TLAA for the Class 1 components. The applicant provided this document. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENT REVIEWED Document Title Revision/Date AR 1890629 Potential FSAR Change Due to Draft WCAP Information 7/19/2013 During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 FPLCORP00036-REPT-040 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fatigue Monitoring Revision 0 SIA (Structural Integrity Associates) 2000088.301 Development of 80-year Projected Cycles for Point Beach Nuclear Plant Units 1 and 2 Revision 2 SIA 2000088.302 Plant Transition Cycle Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.303 Plant Monitoring CUF Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 LTR-RIDA-13-92 Peach Bottom Units 1 and 2 Baffle Bolt Fatigue for Extended Power Uprate Project Revision 0 NP 7.7.19 Procedures Manual: Fatigue Monitoring Program Revision 8 TRM 4.5 Technical Requirement Manual: Cyclic or Transient Limit Monitoring Program Revision 2 SIA 2000088.401 Cycle Counts and Fatigue Projections for 80 Years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 2 During the audit of the TLAA, the staff reviewed the relevant documents to verify that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii) for the pressurizer spray piping and its disposition of 10 CFR 54.21(c)(1)(iii) for the other Class 1 piping. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. The staff will consider issuing an RAI to obtain the necessary information.

The staff found a need to clarify why SLRA Table 4.3.1-1 does not identify the 80-year allowable cycle numbers for the feedwater cycling at hot standby and boron concentration equilibrium transients as part of fatigue evaluations.

During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database and did not identify any previously unknown or recurring aging effects related to the TLAA.

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The staff also audited the description of the SLRA TLAA on the metal fatigue of Class 1 components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.1, Metal Fatigue of Class 1 Components - Steam Generators Summary of Information in the Application. SLRA Section 4.3.1, Metal Fatigue of Class 1 Components, discusses the high cycle fatigue and wear analyses for the steam generator tubes. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. The applicant performed a search of its operating experience database using a standard set of keywords and provided the results to the NRC staff for review. No significant plant-specific operating experience associated with TLAA Section 4.3.1, Metal Fatigue of Class 1 Components, that was relevant to steam generator tube high cycle fatigue or wear was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date ML110750120 Point Beach Units 1 and 2 EPU Licensing Report 04/07/2009 ML110450159 Point Beach EPU SER 05/03/2011 FPLCORP00036-RPT-038 TLAA Report Revision 0 FPLCORP00036-RPT-049 Point Beach Units 1 and 2 - Subsequent License Renewal AMP Basis Document - Steam Generators Revision 0 LTR-SDA-11-20-05-P Environmentally Assisted Fatigue Screening Results for Point Beach Units 1 and 2 - Safety Class 1 Primary Equipment Revision 0 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. The staff will consider issuing RAIs to obtain the necessary information.

During the audit of the operating experience associated with the TLAA, the staff reviewed the results that the applicant provided of the plant-specific database search to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the Steam Generator Tube Wear Evaluation provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

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SLRA TLAA Section 4.3.2, ASME Code,Section III, Class 1 Component Fatigue Waivers Summary of Information in the Application. SLRA Section 4.3.2, ASME Code,Section III, Class 1 Component Fatigue Waivers, discusses the fatigue analysis for the Class 1 components that conform to the waiver of fatigue requirements in ASME Code,Section III.

Specifically, the applicant evaluated the six fatigue exemption conditions in N-415.1 of ASME Code,Section III, 1965 Edition through Summer 1966 Addenda for Class 1 components in lieu of an explicit calculation of the usage factor. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. The applicants performed a search of the operating experience database using keywords: crack, cycl, damage, fatigue, flaw, monitor, CUF, usage factor, environmental, and transient. No document relevant to the TLAA was found in the operating experience database search.

During its audit, the staff also interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 FPLCORP00036-REPT-040 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fatigue Monitoring Revision 0 SIA (Structural Integrity Associates) 2000088.301 Development of 80-year Projected Cycles for Point Beach Nuclear Plant Units 1 and 2 Revision 2 SIA 2000088.302 Plant Transition Cycle Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.303 Plant Monitoring CUF Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 NP 7.7.19 Procedures Manual: Fatigue Monitoring Program Revision 8 TRM 4.5 Technical Requirement Manual: Cyclic or Transient Limit Monitoring Program Revision 2 SIA 2000088.401 Cycle Counts and Fatigue Projections for 80-years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 2 During the audit of the TLAA, the staff reviewed the relevant documents to verify that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the Class 1 steam generator components that conform to the waiver of fatigue requirements in ASME Code,Section III.

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During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database and did not identify any previously unknown or recurring aging effects related to the TLAA.

The staff also audited the description of the SLRA TLAA on the metal fatigue of Class 1 components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.3, Metal Fatigue of Non-Class 1 Components Summary of Information in the Application. SLRA Section 4.3.3, Metal Fatigue of Non-Class 1 Components, discusses the fatigue analysis for non-Class 1 components. The applicant stated that the piping and components designed in accordance with ANSI B31.1 design rules are not required to have an explicit analysis of cumulative fatigue usage, but cyclic loading is considered in a simplified manner in the design process per the design rules. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. The applicants performed a search of the operating experience database using keywords: crack, cycl, damage, fatigue, flaw, monitor, CUF, usage factor, environmental, and transient. No document relevant to the fatigue analysis on non-Class 1 components was found in the operating experience database search.

During its audit, the staff also interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date LR-TR-516 Estimate of Thermal Cycles for the RCS Hot Leg Sample Line Revision 2 FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 SIA (Structural Integrity Associates) 2000088.301 Development of 80-year Projected Cycles for Point Beach Nuclear Plant Units 1 and 2 Revision 2 SIA 2000088.302 Plant Transition Cycle Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.303 Plant Monitoring CUF Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.401 Cycle Counts and Fatigue Projections for 80-years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 2 NP 7.7.19 Procedures Manual: Fatigue Monitoring Program Revision 8 TRM 4.5 Technical Requirement Manual: Cyclic or Transient Limit Monitoring Program Revision 2

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During the audit of the TLAA, the staff reviewed the relevant documents to verify that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for the non-Class 1 components, which were originally designed in accordance with the ANSI B31.1 code. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. The staff will consider issuing an RAI to obtain the necessary information.

It was not clear to the staff which design transients, other than plant heatup and cooldown transients, in USFAR supplement Table 4.1-8 and SLRA Table 4.3.1-1, can contribute to the equivalent full temperature cycles for the non-Class 1 piping systems.

During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database and did not identify any previously unknown or recurring aging effects related to the TLAA.

The staff also audited the description of the SLRA TLAA on the metal fatigue of non-Class 1 components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.3.4, Environmentally Assisted Fatigue Summary of Information in the Application. SLRA Section 4.3.4, Environmentally Assisted Fatigue, discusses the environmentally assisted fatigue (EAF) analysis for reactor coolant system (RCS) pressure boundary components and piping. These components and piping were originally designed in accordance with ANSI B31.1. After the plant began operation, some of the components and piping were additionally evaluated in accordance with the fatigue analysis provisions of ASME Code,Section III. For the RCS pressure boundary components and piping, the applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. A search of the applicants operating experience database was conducted using keywords: crack, cycl, damage, fatigue, flaw, monitor, CUF, usage factor, environmental, and transient. No document found relevant to the EAF TLAA was found in the operating experience database search.

During its audit, the staff also interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 FPLCORP00036-REPT-040 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Fatigue Monitoring Revision 0

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Document Title Revision/Date SIA (Structural Integrity Associates) 2000088.301 Development of 80-year Projected Cycles for Point Beach Nuclear Plant Units 1 and 2 Revision 2 SIA 2000088.302 Plant Transition Cycle Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.303 Plant Monitoring CUF Update for Point Beach Nuclear Plant Units 1 and 2 Revision 0 SIA 2000088.310P EAF Refined Analyses (Charging Nozzle, Hot Leg Surge Nozzle, SI Nozzle, SI/RHR Tee)

Revision 1 SIA 2000088.401 Cycle Counts and Fatigue Projections for 80-years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 2 SIA 2000088.402 Environmentally-Assisted Fatigue Evaluation for 80 Years of Plant Operation for Point Beach Nuclear Units 1 and 2 Revision 1 PBCH-03Q-301 Evaluation of Thermal Stratification Due to Valve Leakage Revision 3 Westinghouse LTR-RIDA-13-92 Peach Bottom Units 1 and 2 Baffle Bolt Fatigue for Extended Power Uprate Project Revision 0 NP 7.7.19 Procedures Manual: Fatigue Monitoring Program Revision 8 TRM 4.5 Technical Requirement Manual: Cyclic or Transient Limit Monitoring Program Revision 2 Westinghouse LTR-SDA-II-20-05-P Environmentally Assisted Fatigue Screening Results for Point Beach Unit 1 and Unit 2 Safety Class 1 Primary Equipment Revision 2 Westinghouse LTR-SDA-II-20-08-P Environmentally Assisted Fatigue Evaluation Results for the Point Beach Unit 1 and Unit 2 Primary Equipment Sentinel Locations for Subsequent License Renewal Revision 1 Westinghouse LTR-SDA-II-20-13-P Environmentally Assisted Fatigue Evaluation Results for the Point Beach Unit 1 and Unit 2 Pressurizer Lower Head for Subsequent License Renewal Revision 2 Westinghouse LTR-SDA-20-064-P ASME Section XI Appendix L Evaluation Results for the Point Beach Units 1 and 2 Pressurizer Spray Nozzles Revision 1 WCAP-13509 Structural Evaluation of the Point Beach Units 1 & 2 Pressurizer Surge Lines, Considering the Effects of Thermal Stratification 10/1992 During the audit of the TLAA, the staff reviewed the relevant documents to verify that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the RCS pressure boundary components and piping. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. The staff will consider issuing an RAI to obtain the necessary information.

Specifically, the staff noted the potential inconsistency of pressurizer surge line leading locations between SLRA Section 4.3.4 (hot-leg surge and pressurizer surge nozzles) and WCAP-13509 (surge line piping location) that is an existing fatigue analysis. The staff will consider issuing an RAI to address this inconsistency.

The staff also required justification why the EAF analysis results of the Surry plant can represent the applicants reactors in terms of identifying plant-specific locations that may be more limiting

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than the leading EAF locations of NUREG/CR-6260. The staff will consider issuing an RAI to request the justification to be provided.

During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database and did not identify any previously unknown or recurring aging effects related to the TLAA.

The staff also audited the description of the SLRA TLAA on the EAF of Class 1 components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualification (EQ) of Electric Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and I&C equipment. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. A keyword search was not performed. During the audit, the staff reviewed examples of operating experience condition reports that the applicant provided. The table below lists the documents that the staff reviewed and found to be relevant to the Environmental Qualification of Electric Equipment. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date AR02327520 HELB Calcs Revised Twice without Evaluating Impact on EQ 09/22/2019 AR02330722 EQ Rosemount Transmitters is Acceptable in Storage Level B

10/08/2019 AR02338607 Ultra Electronics Qualified Life Change Notice 12/17/2019 AR02340309 Follow Up AR to 02338607 - Qualified Life Change Notice 01/07/2020 AR02388321 EQ Program Review Required for EPRI NP-1558 revision 03/30/2021 AR02241723 Effectiveness Reviews of PB License Renewal Programs 12/21/2017 AR02262609 L1A: License Renewal Program Effectiveness Reviews 05/03/2018 AR02320373 Incorrect EQCK Referenced for MOV Motors 12/03/2019 During its audit, the staff reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-041 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Environmental Qualification of Electric Equipment Revision 0 NP 7.7.1 Environmental Qualification of Electrical Equipment Revision 15

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Document Title Revision/Date DG-G11 Environmental Qualification Service Conditions Revision 9 DG-G12 Environmental Qualification Program Manual Revision 2 ER-AA-112 Environmental Qualification Program Revision 5 LR-AMP-012-EQ Environmental Qualification Program Basis Document for License Renewal Revision 9 EQML EQ Master List Revision 40 (11/01/2019)

EQCK-FISH-001 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation &

Accident/Post-Accident Evaluation Revision 1 EQCK-PRONTO-001 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation Revision 1 EQCK-WEST-008 (Attachment 2)

Checklist for Environmental Qualification Assessment of Electrical Equipment - Thermal Qualified Life Calculation Revision 2 The staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). The staff notes that the applicant generated action request report number 02388321 during the audit to evaluate whether the recent revision to the Electric Power Research Institute report NP-1558 has any adverse effects on the qualification of electric equipment at Point Beach (specifically related to the activation energy used to determine the qualification of components).

During the audit of the operating experience program element, the staff reviewed operating experience corrective actions program examples that the applicant provided to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.

The staff also audited the description of the SLRA Appendix A16.2.1.4, Environmental Qualification of Electric Equipment, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the Section 4.4.3.2 and Table 4.4-2 of the SRP-SLR Report.

SLRA TLAA Section 4.5, Concrete Containment Tendon Prestress Summary of Information in the Application. SLRA Section 4.5, Concrete Containment Tendon Prestress, discusses the analysis of the prestressing forces in unbonded tendons of the containment prestressing system, based on time-dependent losses due to steel tendon relaxation, and concrete creep and shrinkage. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).

To verify that the applicant provided a basis to support its disposition of the containment unbonded tendon prestress TLAA, the staff audited the TLAA.

Audit Activities. A keyword search was not performed by the staff. During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

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RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP0036-REPT-062 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Concrete Containment Unbonded Tendon Prestress Revision 0 REP-1149-510 Final Report for the 48th Year Tendon Surveillance at Point Beach Nuclear Power Plant Revision 0 09/16/19 REP-1149-511 Regression Analysis for 48th Year - 48th YR Surveillance at Point Beach Revision 0 09/16/19 AR 02156929 Randomly Selected Containment Tendon Plan 09/20/2016 N/A Precision Surveillance Corporation - 28th Year Physical and Visual Surveillance of Unit 1 and 2 Containment Buildings at the Point Beach Nuclear Plant 1999 WEPCo Contract No. 247680 Final Report Point Beach Nuclear Power Plant 23-Year Post Tensioning System Surveillance, Prepared by DYWIDAG Systems International 09/1994 FPLCORP00036-CALC-001 Point Beach Units 1 and 2 Time Limited Aging Analysis of the Containment Prestressed Tendons for Subsequent License Renewal (SLR)

Revision 0 FPLCORP00036-REPT-038 Point Beach Units 1 and 2 Subsequent License Renewal Time-Limited Aging Analyses and Exemptions Based on Time-Limited Assumptions Revision 0 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).

During the audit, the staff observed the following:

Based on the audit review of Precision Surveillance Corporations summary reports for the 23rd and 28th year physical tendon surveillances, the staff verified that the appropriate corrective actions had been taken for the two dome tendons that were found with lift-off forces below the minimum required value (MRV), as shown in SLRA Figures 4.5-1 and 4.5-4. In both cases, the sample was expanded, and liftoff forces were measured for the two tendons adjacent to the impacted tendon, in accordance with ASME Code,Section XI, Subsection IWL. The liftoff forces were found to be acceptable.

Additionally, the dome average prestress force was above the minimum requirements and the tendons with lower than MRV prestress force values were retensioned to appropriate values.

The staff also audited the description of the SLRA Concrete Containment Unbonded Tendon Prestress TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.

SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue Summary of Information in the Application. SLRA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue, discusses the analyses for fatigue of the containment liner plate and containment piping penetrations. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i) for containment liner plate and piping penetrations of

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carbon steel material. The applicant also claimed partial disposition in accordance with 10 CFR 54.21(c)(1)(iii) for containment penetrations other than carbon steel piping penetrations (i.e., personnel airlocks, equipment hatch, personnel hatch, electrical penetrations, piping penetrations with dissimilar metal welds, and the expansion joints of containment fuel transfer tube), for which the applicant stated that it has been unable to locate the original fatigue analysis or confirm if a fatigue analysis exists.

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities The applicants performed a search of the operating experience database using keywords: crack, fatigue, containment, liner, and penetration. No significant plant-specific operating experience associated with the TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date Calculation PBCH-06Q-301 Containment Penetration Fatigue Evaluation, Point Beach Units 1 and 2, Structural Integrity Associates [Included as SLRA Enclosure 4, Attachment 15]

Revision 1 (11/11/2003)

Report No. 2000088.401 Cycle Counts and Fatigue Projections for 80-years of Plant Operation for Point Beach Nuclear Units 1 and 2, Structural Integrity Associates Inc. Report [Included as SLRA, Attachment 7]

Revision 2 (10/19/2020)

UFSAR Section 5.1.2.2 Containment System Structure - Mechanical Design Bases, Point Beach Units 1 and 2 2018 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i) for containment liner plate and carbon steel piping penetrations. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its partial TLAA disposition in accordance with 10 CFR 54.21(c)(1)(iii) for the penetrations for which the applicant claimed a CLB fatigue analysis does not exist. In order to obtain the necessary information, the staff will use a voluntary SLRA supplement that the applicant offered during the audit or it will consider issuing RAIs.

During the audit, the staff observed the following:

The staff reviewed SLRA Section 4.6 and noted that the applicants partial TLAA disposition in accordance with 10 CFR 54.21(c)(1)(iii) for containment penetrations other than carbon steel piping penetrations (i.e., personnel airlocks, equipment hatch, personnel hatch, electrical penetrations, piping penetrations with dissimilar metal welds, and the expansion joints of containment fuel transfer tube), for which the applicant stated that it has been unable to locate the original fatigue analysis or confirm if a fatigue analysis exists, is not in the scope of AMR item 3.5-1, 009, for which TLAA 4.6 applies and is inconsistent with the requirements for TLAAs in 10 CFR 54.3 and

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10 CFR 54.21(c)(1). The licensee may provide a a voluntary SLRA supplement or the staff may consider issuing an RAI to resolve this inconsistency.

The staff also audited the description of the SLRA Containment Liner Plate, Metal Containments, and Penetrations Fatigue, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA 4.6, Containment Liner Plate, Metal Containments, and Penetrations Fatigue, specifically with regard to the partial disposition in accordance with CFR 54.21(c)(1)(iii). The staff will review a voluntary SLRA supplement offered by the applicant during the audit and/or consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.

SLRA TLAA Section 4.7.1, Leak-Before-Break of Reactor Coolant System Loop Piping Summary of Information in the Application. SLRA Section 4.7.1, Leak-Before-Break, discusses the leak-before-break (LBB) analysis for the reactor coolant system piping. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this report in the SER.

Audit Activities. A search of the applicant operating experience database was conducted using keywords: leak-before-break, rupture, leak, crack, leak rate, leaks in RCS loop piping, through wall leaks in RCS loop piping.

The table below lists the documents that the staff reviewed and found to be relevant to TLAA Section 4.7.1, Leak-Before-Break of Reactor Coolant System Loop Piping. The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database. During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate the LBB analysis may not be adequate to manage the aging effects. The staff also reviewed the operating experience portal with the applicants staff during the audit breakout session. The database search did not identify any operating experience that would indicate the LBB analysis may not be adequate to manage the aging effects. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date OE PBN OE_spreadsheet_landscape_Part 1 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 2 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 3 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 4 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 5 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 6 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 7 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 8 02/03/2021

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During the audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WCAP-14439 Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Point Beach Nuclear Plant Units 1 and 2 for the Subsequent License Renewal Program (80-years)

Revision 4 06/2020 WCAP-14439 Technical Justification for Eliminating Large Primary Loop Rupture as the Structural Design Basis for the Point Beach Nuclear Plant Units 1 and 2 for the Subsequent License Renewal Program (80-years)

Revision 3 05/2020 WCAP-14439 Technical Justification for Eliminating Large Primary Loop Pipe Units 1 and 2 for the Power Uprate and License Renewal Program Revision 2 09/2003 NUREG-0800, Section 3.6.3 Leak-Before-Break Evaluation Procedures Revision 1 03/2007 NUREG/CR-4513 Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems Revision 2 05/2016 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). The staff found that sufficient information was available to complete its review of the applicants basis for its TLAA disposition. If further information is needed to complete the staffs safety evaluation (SE) input, the staff will consider issuing RAIs.

The staff also audited the description of the SLRA LBB TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the information provided in the UFSAR supplement of the SLRA LBB TLAA. The staff will consider issuing RAIs if further information is needed to complete the staffs SE input.

SLRA TLAA Section 4.7.2, Leak-Before-Break of Reactor Coolant System Auxiliary Piping Summary of Information in the Application. SLRA Section 4.7.2, Leak-Before-Break, discusses the leak-before-break (LBB) analysis for the reactor coolant system auxiliary piping.

The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i).

To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified and discussed in this report.

Audit Activities. A search of the applicant operating experience database was conducted using keywords: leak before break, rupture, leak, crack, leak rate, leaks in RCS loop piping, and through wall leaks in RCS loop piping.

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The table below lists the documents that the staff reviewed and found to be relevant to TLAA Section 4.7.2, Leak-Before-Break of Reactor Coolant System Auxiliary Piping. The documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database. During the audit of the operating experience program element, the staffs independent database search did not identify any operating experience that would indicate the LBB analysis may not be adequate to manage the aging effects. The staff also reviewed the operating experience portal with the Point Beach staff during the audit breakout session. The database search did not identify any operating experience that would indicate the LBB analysis may not be adequate to manage the aging effects. The staff will document its review of relevant operating experience in the SER.

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date OE PBN OE_spreadsheet_landscape_Part 1 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 2 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 3 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 4 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 5 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 6 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 7 02/03/2021 OE PBN OE_spreadsheet_landscape_Part 8 02/03/2021 During the audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date WCAP-15065 Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for Point Beach Units 1 and 2 Nuclear Plants Revision 1 06/2001 WCAP-15105 Technical Justification for Eliminating Residual Heat Removal (RHR) Rupture as the Structural Design Basis for Point Beach Units 1 and 2 Nuclear Plants Revision 1 06/2001 WCAP-15107 Technical Justification for Eliminating Accumulator Rupture as the Structural Design Basis for Point Beach Units 1 and 2 Nuclear Plants Revision 1 06/2001 Westinghouse LTR-SDA-II-20-06 Leak-Before-Break Reconciliation of the Point Beach Units 1 and 2 Pressurizer Surge Line, Residual Heat Removal Line, and Accumulator Line Piping Systems for the Subsequent License Renewal Program Revision 1 05/2020 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). The staff found that sufficient information was available to complete its review of the applicants basis for its TLAA disposition. The staff will consider issuing RAIs if further information is needed to complete the staffs SE input.

The staff also audited the description of the SLRA LBB TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the information provided in the

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UFSAR supplement of the SLRA LBB TLAA. If further information is needed to complete the staffs SE input, the staff will consider issuing RAIs.

SLRA TLAA Section 4.7.3, Flaw Tolerance Evaluation for Reactor Coolant Loop CASS Piping Components Summary of Information in the Application. SLRA Section 4.7.3, Flaw Tolerance Evaluation for Reactor Coolant Loop CASS Piping Components, discusses the applicants TLAA for the reactor coolant primary loop piping elbows made of A-351 Grade CF8M as related to the thermal aging embrittlement of cast austenitic stainless steel (CASS) material and its flaw tolerance evaluation. The applicant dispositioned this TLAA in accordance with 10 CFR 54.21(c)(1)(ii), stating that the analysis has been projected to the end of the subsequent period of extended operation. To verify that the applicant provided a basis to support its disposition of this TLAA, the staff audited the TLAA.

Audit Activities. A search of the applicants operating experience database was conducted using keywords: cast stainless steel, cast, CASS, embrittlement, thermal aging, fracture toughness, and elbow. No significant plant-specific operating experience for this TLAA was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date FPLCORP00036-REPT-079 Point Beach Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document - Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Revision 0 11/06/2020 Westinghouse LTR-PAFM-05 P/NP Flaw Tolerance Evaluation for Susceptible Reactor Coolant Loop Cast Austenitic Stainless Steel Piping Components in Point Beach Units 1 and 2 for 80 years Revision 3 07/2020 FPLCORP00036-REPT-038NP Subsequent License Renewal Time-Limited Aging Analysis and Exemptions Based on Time-Limited Assumptions Revision 0 11/05/2020 WCAP-14439-P Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the Point Beach Nuclear Plant Units 1 and 2 for the Subsequent License Renewal Program (80-years)

Revision 4 07/2020 During the audit of TLAA, the staff verified the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).

During the audit, the staff observed the following:

From review of the TLAA basis document and Westinghouse LTR-PAFM-05-58-P/NP, Revision 3, the staff noted that the documents provide supporting evidence that the applicant performed the flaw tolerance evaluation of the susceptible CASS in accordance with ASME Code,Section XI, IWB-3640 and Appendix C consistent with NUREG-2191 and SLR-ISG-Mechanical-2020-XX, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal, guidance. The staff noted that, consistent with the acceptance criteria defined in SRP-SLR Section 4.7.2.1.2 and

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the review procedures defined in SRP-SLR Section 4.7.3.1.2, this provides sufficient demonstration that the TLAA is acceptable in accordance with the acceptance criterion defined in 10 CFR 54.21(c)(1)(ii). This staffs determination will be reflected in the staffs SLRA SER.

During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff did not identify any additional aging effects that would have an impact on the applicants evaluation of the TLAA.

The staff also audited the description of the SLRA Flaw Tolerance Evaluation for Reactor Coolant Loop CASS Piping Components provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.

SLRA TLAA Section 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth Summary of Information in the Application. SLRA Section TLAA 4.7.4, Reactor Coolant Pump Flywheel Fatigue Crack Growth, discusses the fatigue crack growth analyses for the reactor coolant pump flywheel. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(i). To verify that the applicant provided an acceptable technical basis to support its disposition of the TLAA, the staff audited the TLAA.

Audit Activities. A search of the applicants operating experience database was conducted using keywords: cycle, transient, flywheel, design cycle, fatigue cracking, CUF, usage factor, start/stop, and starts and stops. No significant plant-specific operating experience associated with the SLRA TLAA 4.7.4 was noted by the staff during its review.

During its audit, the staff interviewed the applicants staff and reviewed documentation that the applicant provided. The staff reviewed the following relevant documents:

RELEVANT DOCUMENTS REVIEWED Document Title Revision/Date LR-TR-510-TLAA Revision 0 Section 3.3.2 Reactor Coolant Pump Flywheel Analysis Revision 0 01/30/2004 FPLCORP00036-REPT-039 Point Beach Units 1 and 2 Subsequent License Renewal Aging Effects Operating Experience Revision 1 TRM 4.6 Reactor Coolant Pump Flywheel Inspection Program Revision 11 12/2019 During the audit of the TLAA, the staff verified that the applicant has provided its technical basis that supports its disposition of 10 CFR 54.21(c)(1)(i).

During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff did not identify any additional aging effects that would have an impact on the evaluation of the TLAA.

The staff also audited the summary description of the TLAA for the Reactor Coolant Pump Flywheel Fatigue Crack Growth Analyses provided in the UFSAR supplement. The staff verified this summary description is consistent with the generic description provided in the SRP-SLR.

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3. Applicant Personnel Contacted During Audit Aaron Halstrom (ENERCON)

Andy hawk (Westinghouse)

Allison Hoke (ENERCON)

Andrew Watry (NEE)

Anees Udyawar (Westinghouse)

Anthony Ploplis (ENERCON)

Austin Frenkel (NEE)

Basil Pagnozzi (NEE)

Benjamin Amiri (Westinghouse)

Brad Borchardt (NEE)

Brenda Scherwinski (NEE)

Brian Guza (NEE)

Brian Hall (Westinghouse)

Brian Norman (ENERCON)

Bruce Beisler (ENERCON)

Caleb Trainor (ENERCON)

Carrie Welnicke (NEE)

Charles Kato (NEE)

Clay Corley (ENERCON)

Craig Neuser (NEE)

Danielle Page-Blair (Framatome)

Dave Gerber (SIA)

Dave Taylor (NEE)

David Butterbrodt (NEE)

David Hartmangruber (ENERCON)

Derek Hung (NEE)

Donna Slivon (NEE)

Duygu Saydam (ENERCON)

Eric Christopher (NEE)

Eric Johnson (Westinghouse)

Frederick Eichhorst (NEE)

Greg Imbrogno (Westinghouse)

Ian Miller (ENERCON)

Jacki Mielke (NEE)

Jay White (Westinghouse)

James Golding (NEE)

James Hamlen (ENERCON)

James V. Wicks (ENERCON)

Jeff Gromatzky (ENERCON)

Jeffrey Head (ENERCON)

Jim McGough (NEE)

John T Ahearn (Westinghouse)

John Daily (NEE)

JR (Jack) Hoffman (ENERCON)

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Kester Thompson (NEE)

Kevin Muggleston (NEE)

Kevin Vance (NEE)

LaToya Bennett (ENERCON)

Maribel Valdez (NEE)

Mark Joseph (NEE)

Matt Wilkinson (ENERCON)

Michael Friedman (NEE)

Michael Omillian (NEE)

Michael Wavrunek (NEE)

Min Noh (ENERCON)

Mitch McFarland (ENERCON)

Philip Baranowski (NEE)

Randy Richards (NEE)

Richard LaPlante (NEE)

Richard Orthen (NEE)

Richard Wood (NEE)

Ron Barker Jr. (NEE)

Ronald Hepp (ENERCON)

Scott Boggs (NEE)

Scott Kahl (NEE)

Shane (Chris) Webb (NEE)

Stephen Hale (ENERCON)

Stephen K Longwell (Westinghouse)

Steve Franzone (NEE)

Steve Marlette (Westinghouse)

Swadesh (Chuck) Ramdeen (NEE)

Taylor Zindren (Westinghouse)

Terry Herman (SIA)

Timothy Cleary (ENERCON)

Tim Wattleworth (NEE)

Tom Joseph (Westinghouse)

Thomas Kendall (NEE)

Trevor Peterman (NEE)

Tyler Kite (ENERCON)

William Maher (NEE)

4. Exit Meeting An exit meeting was held with the applicant on March 29, 2021, to discuss the results of the in-office regulatory audit. The staff is considering the issuance of RAIs and RCIs to support the completion of the staffs SLRA review.