L-2021-224, Subsequent License Renewal Application - First Annual Update

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Subsequent License Renewal Application - First Annual Update
ML21334A293
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 11/30/2021
From: Maher W
Point Beach
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2021-224
Download: ML21334A293 (17)
v • d • e


Text

November 30, 2021 L-2021-224 10 CFR 54.17 U.S. Nuclear Regulatory Commission Attention: Document Control Desk 11545 Rockville Pike One White Flint North Rockville, MD 20852-2746 Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 SUBSEQUENT LICENSE RENEWAL APPLICATION - FIRST ANNUAL UPDATE

References:

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

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

The License Renewal Rule, 10 CFR 54.21(b), requires that each year following submittal of an LRA, and at least 3 months before scheduled completion of the NRC review, an update to the LRA must be submitted that identifies any change to the current licensing basis (CLB) of the facility that materially affects the content of the LRA including the Updated Final Safety Analysis Report Supplement.

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

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

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

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

Document Control Desk L-2021-224 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 30th day of November 2021.

Sincerely, William Digitally signed by William Maher DN: cn=William Maher, o=Nuclear, ou=Nuclear Licensing Projects, Maher email=william.maher@fpl.com, c=US Date: 2021.11.30 10:55:50 -05'00' William D. Maher Licensing Director - Nuclear Licensing Projects Cc: Administrator, Region III, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Public Service Commission Wisconsin

Document Control Desk L-2021-224 Page 3 Attachments Index Attachment Subject No.

1 Current Licensing Basis (CLB) Changes Affecting the SLRA 2 Affected SLRA Content Revisions

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 CLB Changes Affecting the SLRA L-2021-224 Attachment 1 Page 1 of 1 CURRENT LICENSING BASIS (CLB) CHANGES AFFECTING THE SLRA Screening / Aging SLRA Section PBN 1 and 2 CLB Change Item 1 Management Affected Review (AMR)

Document Affected Change 1: The Unit 2 Component Cooling Water FPLCORP00036- Sections (CCW) pumps were replaced and a minimum flow REPT-015 2.3.3.2 and (recirculation) cross connections installed. A new P&ID Table 3.3.2-2 was created for the cross connected piping and instruments.

The SLRA is updated to add a new boundary drawing and a new pump casing material. Strainers and orifices are new component types with new intended functions that are added to the SLRA.

Change 2: As part of the transition to NFPA-805, the FPLCORP00036- Sections Nuclear Safety Capability Assessment (NSCA) and the REPT-023 2.3.3.12, Non-Power Operation (NPO) analysis were both FPLCORP00036- 2.3.3.15, 2.4.2, revised, which affects the SLRA. REPT-026 3.3.2.1.12, and FPLCORP00036- Table 3.3.2-12 The SLRA is updated to show that the circulating water REPT-034 (CW) system has a fire protection function, a new CW boundary and drawing, a new component intended function and a new aging effect. The SLRA is updated to add boundary drawing numbers associated with the new components in the condensate (CS) and instrument air (IA) systems, which are added to the SLRA per the NSCA revision. The CW and IA sections of the SLRA are updated, accordingly.

Change 3: Heat trace and insulation was installed FPLCORP00036- Table 3.3.2-15 around Unit 1 and Unit 2 MFIV Actuator Three Way REPT-026 Valves CS-256A & B and CS-257A & B, which are within SLR scope.

The SLRA is updated to add a new component type

[valve body (insulated)] and material (aluminum) combination.

1 Excludes change determinations where the SLRA was unaffected although a Screening / AMR document was affected.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 1 of 13 As a result of PBN current licensing basis (CLB) changes made during the first SLRA annual update period, SLRA Sections 2.3.3.2, 2.3.3.12, 2.3.3.15, 2.4.2, and 3.3.2.1.12 and Tables 3.3.2-2, 3.3.2-12, and 3.3.2-15 are amended as indicated by the following text deletion (strikethrough) and text additions (red underlined font) revisions.

[Change 1]

2.3.3.2 Component Cooling Water The CC system boundaries are reflected on the SLR boundary drawings listed below.

There are differences between these boundaries and the boundaries identified as part of the original PBN license renewal effort due to abandonment of the blowdown evaporator.

PBN Unit 1:

SLR-110E018 Sheet 1SLR-110E018 Sheet 2 SLR-110E018 Sheet 3 PBN Unit 2:

SLR-110E029 Sheet 1 SLR-110E029 Sheet 2 SLR-110E029 Sheet 3 SLR-110E029 Sheet 4 Point Beach Common:

SLR-PBM-230 Table 2.3.3-2 Component Cooling Water System Components Subject to Aging Management Review Component Type Component Intended Function(s)

Bolting Mechanical closure Flow element Leakage boundary (spatial)

Pressure boundary Heat exchanger (component cooling) Heat transfer Pressure boundary Heat exchanger (pressurizer liquid sample) Pressure boundary Heat exchanger (pressurizer steam sample) Pressure boundary Heat exchanger (reactor coolant hot leg Pressure boundary sample)

Heat exchanger (steam generator blowdown Pressure boundary sample)

Instrument Pressure boundary Orifice Pressure boundary Throttle

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 2 of 13 Component Type Component Intended Function(s)

Piping Leakage boundary (spatial)

Pressure boundary Piping and piping components Structural integrity (attached)

Pump casing Leakage boundary (spatial)

Pressure boundary Steel components adversely affected by boric Leakage boundary (spatial) acid leakage Pressure boundary Strainer Filter Pressure boundary Tank (surge) Pressure boundary Thermowell Pressure boundary Valve body Leakage boundary (spatial)

Pressure boundary

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 3 of 13 Table 3.3.2-2: Component Cooling Water - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Type Function Requiring Program Item Item Management Orifice Pressure Stainless Treated water Loss of Closed Treated Water VII.C2.A-52 3.3-1, B boundary steel (int) material Systems (B.2.3.12) 049 Orifice Throttle Stainless Treated water Loss of Closed Treated Water VII.C2.A-52 3.3-1, B steel (int) material Systems (B.2.3.12) 049 Orifice Pressure Stainless Air - indoor Cracking External Surfaces VII.E1.AP-209b 3.3-1, A boundary steel uncontrolled Monitoring of 004 (ext) Mechanical Components (B.2.3.23)

Orifice Pressure Stainless Air - indoor Loss of External Surfaces VII.E1.AP-221b 3.3-1, A boundary steel uncontrolled material Monitoring of 006 (ext) Mechanical Components (B.2.3.23)

Pump casing Pressure Carbon steel Air - indoor Loss of External Surfaces VII.I.A-77 3.3-1, A boundary uncontrolled material Monitoring of 078 (ext) Mechanical Components (B.2.3.23)

Pump casing Pressure Carbon steel Treated water Loss of Closed Treated Water VII.C2.AP-202 3.3-1, B boundary (int) material Systems (B.2.3.12) 045 Strainer Filter Stainless Treated water Loss of Closed Treated Water VII.C2.A-52 3.3-1, B steel (int) material Systems (B.2.3.12) 049 Strainer Pressure Stainless Air - indoor Cracking External Surfaces VII.E1.AP-209b 3.3-1, A boundary steel uncontrolled Monitoring of 004 (ext) Mechanical Components (B.2.3.23)

Strainer Pressure Stainless Air - indoor Loss of External Surfaces VII.E1.AP-221b 3.3-1, A boundary steel uncontrolled material Monitoring of 006 (ext) Mechanical Components (B.2.3.23)

Strainer Pressure Stainless Treated water Loss of Closed Treated Water VII.C2.A-52 3.3-1, B boundary steel (int) material Systems (B.2.3.12) 049

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 4 of 13

[Change 2]

2.3.3.12 Circulating Water Description The circulating water system provides a reliable supply of water from Lake Michigan to condense the steam exhausted from the low-pressure turbines. It is a non-seismic piping system whose primary function is to remove heat from the steam cycle via the main condensers. The principal components of the circulating water system (CW) are the circulating water pumps, traveling screens and screen wash pumps and the associated piping and valves.

The CW system does not perform any safety related functions. The A portion of the circulating water system that is in-scope includes the screen wash piping and associated components within the service water pump room. These are in-scope of SLR in accordance with 10 CFR 54.4(a)(2) due to the potential for leakage which could prevent the performance of a service water system safety function. The forebay inlet MOVs 1/2CW-2 are in-scope because these valves perform a fire protection function.

The portions of the CW system containing components subject to an AMR include the flood dampers and screen wash piping, valves, and associated components.

Boundary The SLR boundaries are reflected on the SLR boundary drawings listed below. There are significant differences between these boundaries and the boundaries identified as part of the original PBN license renewal effort due to the addition of flood dampers to the circulating water pump house (CWPH) structure floor. These dampers eliminate the possibility for flooding from the circulating water system to affect safety related service water components. These damper housings are addressed as part of plant structures in Section 2.5.1.2.

The subsequent license renewal boundaries include interfaces with the service water system as can be seen on drawings SLR-M-212, Sheet 1 at G-7 and SLR-M-2212 at A-8. The forebay inlet MOVs 1/2CW-2 are shown on SLR-M-212, Sheet 2 at G-4 &

7. The circulating water system also interfaces with the fire water system as can be seen on drawing SLR-M-212, Sheet 2 at C-7.

PBN Unit 1:

SLR-M-212 Sheet 1

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 5 of 13 System Intended Functions Safety-related functions (10 CFR 54.4(a)(1)):

None.

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

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

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

(1) Perform a function that demonstrates compliance with the Commissions regulations for fire protection program.

None.

UFSAR References 10.1 Components Subject to AMR Table 2.3.3-12 lists the circulating water system component types that require AMR and their associated component intended functions.

Table 3.3.2-12 provides the results of the AMR.

Table 2.3.3-12 Circulating Water System Components Subject to Aging Management Review Component Type Component Intended Function(s)

Bolting Mechanical closure Piping Leakage boundary (spatial)

Pump casing Leakage boundary (spatial)

Valve body Leakage boundary (spatial)

Pressure boundary 2.3.3.15 Plant Air Description The plant air system for PBN Units 1 and 2 are essentially identical. On this basis, the following discussion applies to both units. This system includes instrument air (IA),

service air (SA), and emergency breathing air (EBA) sub-systems. The IA and SA sub-systems supply compressed air throughout the plant. The IA sub-system supplies

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 6 of 13 dry, oil-free air to various components for the normal operation of both units. The SA sub-system supplies non-dried, oil-free air to those plant services not requiring dry air.

The EBA sub-system is no longer credited after implementation of NFPA 805 and therefore not in the scope of SLR.

The IA sub-system consists of two air compressors, air receivers, air dryer units, filters, and air header piping and valves. The air compressors and aftercoolers are cooled by the service water system (SW). Normally one IA compressor is sufficient to supply plant requirements. The instrument air sub-system is normally in continuous operation during normal plant operation and shutdown.

In order to maintain operability on loss of IA, some components use nitrogen bottles, regulators, check valves, and/or air accumulators to maintain pressure at a component for varying periods of time to support or as a backup for the subsequent license renewal component intended function (including air to the pressurizer PORVs, purge supply and exhaust boot seals, main steam isolation valves, main feedwater isolation valves, and auxiliary feedwater discharge and mini-recirc valves).

The in-scope portion of the IA sub-system includes those IA components that support the pressurizer PORVs, the IA containment isolation valves, and the main feed isolation valve operators, and fire protection. The compressors, air receivers, and air dryers for IA are not required as the system has sufficient accumulators and tanks to support the system intended functions following loss of the compressors.

The SA sub-system consists of two air compressors, receivers, and the SA header piping and valves. The air compressors and aftercoolers are cooled by the SW system. In addition to supplying normal SA loads, SA is also a backup supply to IA, and a backup supply to the EBA sub-system. Normally one SA compressor is sufficient to supply system demands. The SA sub-system is normally in either continuous or intermittent operation during normal plant operation and shutdown. The portions of the SA system containing components subject to an AMR include the containment isolation valves.

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

SLR-M-209, Sheets 5 and 7 contain containment isolation valves that are included in the containment isolation system (Section 3.2.2.1.4). Boundary changes since the initial license renewal include the addition of the air supplies to the new main feedwater isolation valves to support EPU, the removal of the connection to the charging pump controller and variable drives (this change removed all required components on SLR-M-209, Sheet 8), and the installation of the backup pneumatic supply to the PORVs. Additionally, removal of the EBA system via due to plant conversion to NFPA 805 [Ref. 8.18], removal of the EBA system from the SLR

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 7 of 13 scope removed deleted all required components from SLR-M-209 Sheet 13 and added isolation valves credited in the Nuclear Safety Capability Assessment on SLR-M-209, Sheets 5, 6, 7, 9 and 10. Other than these changes there are no other significant differences between these boundaries and the boundaries identified as part of the original PBN license renewal effort. Boundaries with other systems include the feedwater system at the feedwater isolation valve actuators on SLR-M-209 Sheet 5 and Sheet 7, the reactor coolant and connected piping system at the PORVs on SLR-M-209 Sheet 11, the auxiliary feedwater system valves on SLR-M-217 Sheet 2, the safety injection system at valve 1/2SI-905 on SLR-110E017 Sheet 1 and SLR-110E035 Sheet 1, and the containment ventilation system at the purge exhaust and supply fan suction boot seals on SLR-PBM-332 and SLR-PBM-2332.

PBN Unit 1:

SLR-110E017 Sheet 1 SLR-PBM-332 PBN Unit 2:

SLR-110E035 Sheet 1 SLR-M-209, Sheet 10 SLR-PBM-2332 PBN Common:

SLR-M-209 Sheet 2 SLR-M-209 Sheet 5 SLR-M-209, Sheet 6 SLR-M-209 Sheet 7 SLR-M-209, Sheet 9 SLR-M-209 Sheet 11 SLR-M-217 Sheet 2

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 8 of 13 2.4.2 Circulating Water Pumphouse Structure Boundary The circulating water pumphouse boundary includes all the structural components that comprise the circulating water pumphouse and forebay. There are no significant differences between the current boundaries and those identified as part of the original PBN license renewal effort.

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

(1) Support and house six service water pumps.

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

(1) Provide nonsafety-related flood barriers.

Fire protection functions (10 CFR 54.4(a)(3)):

(1) Structurally support and house two fire water pumps, and a jockey pump, and the forebay inlet motor-operated valves.

(2) Provide fire barriers.

UFSAR References 2.5 2.6 2.8 9.6 10.1 Subsequent License Renewal Drawing The subsequent license renewal drawing for the circulating water pumphouse structure is LR-C-3.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 9 of 13 3.3.2.1.12 Circulating Water Materials The materials of construction for the circulating water system components are:

  • Air - indoor uncontrolled
  • Raw water Aging Effects Requiring Management The following aging effects associated with the circulating water system require management:
  • Cracking
  • Long-term loss of material
  • Loss of preload
  • Loss of material
  • Bolting Integrity (B.2.3.9)
  • External Surfaces Monitoring of Mechanical Components (B.2.3.23)
  • Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25)
  • One-Time Inspection (B.2.3.20)
  • Selective Leaching (B.2.3.21)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 10 of 13 Table 3.3.2-12: Circulating Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Type Function Requiring Program Item Item Management Bolting Mechanical Carbon Raw water Loss of Bolting Integrity VII.I.A-423 3.3-1, A closure steel (ext) material (B.2.3.9) 142 Bolting Mechanical Carbon Raw water Loss of Bolting Integrity VII.I.AP-124 3.3-1, A closure steel (ext) preload (B.2.3.9) 015

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 11 of 13 Table 3.3.2-12: Circulating Water System - Summary of Aging Management Evaluation Component Type Intended Function Material Environment Aging Effect Aging Management NUREG-2191 Table 1 Notes Requiring Program Item Item Management Valve body Pressure Carbon Raw water Long-term One-Time Inspection VII.C1.A-532 3.3-1, A boundary steel (ext) loss of (B.2.3.20) 193 material Valve body Pressure Carbon Raw water Loss of External Surfaces VII.C1.A-727 3.3-1, E, 2 boundary steel (ext) material Monitoring of 134 Mechanical Components (B.2.3.23)

Valve body Pressure Carbon Raw water Long-term One-Time Inspection VII.C1.A-532 3.3-1, A boundary steel (int) loss of (B.2.3.20) 193 material Valve body Pressure Carbon Raw water Loss of Inspection of Internal VII.C1.A-727 3.3-1, A boundary steel (int) material Surfaces in 134 Flow Miscellaneous Piping blockage and Ducting Components (B.2.3.25)

Valve body Pressure Carbon Raw water Wall thinning Inspection of Internal VII.C1.A-409 3.3-1, E, 1 boundary steel (int) - erosion Surfaces in 126 Miscellaneous Piping and Ducting Components (B.2.3.25)

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 12 of 13 Generic Notes A. Consistent with component, material, environment, aging effect and aging management program listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

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

Plant Specific Notes

1. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.3.25) AMP is enhanced to manage the wall thinning due to erosion aging effect.
2. The External Surfaces Monitoring of Mechanical Components (B.2.3.23) AMP used to manage loss of material of the submerged forebay inlet motor operated valves.

Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Affected SLRA Content Revisions L-2021-224 Attachment 2 Page 13 of 13

[Change 3]

Table 3.3.2-15: Plant Air - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging Management NUREG-2191 Table Notes Type Function Requiring Program Item 1 Item Management Valve body Pressure Aluminum Air - dry (int) Loss of Compressed Air VII.D.A-764 3.3-1, A boundary material Monitoring (B.2.3.14) 235 Valve body Pressure Aluminum Air - indoor Loss of External Surfaces VII.I.A-774c 3.3-1, A (insulated) boundary uncontrolled material Monitoring of 245 (ext) Mechanical Components (B.2.3.23)

Valve body Pressure Aluminum Air - indoor Cracking External Surfaces VII.I.A-762c 3.3-1, A (insulated) boundary uncontrolled Monitoring of 233 (ext) Mechanical Components

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