ML23136A280

SLRA Second Annual Update RAI Set 1

ML23136A280
Person / Time
Site:	Point Beach
Issue date:	05/05/2023
From:	Tyree C NRC/NRR/DNRL/NLRP
To:	Coffey R Nextera Energy
References
Download: ML23136A280 (1)

Text

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

Subsequent License Renewal Application (SLRA)

Second Annual Update Request for Additional Information (RAI)

Safety - Set #1 RAI NUMBER 3.2.2.2.2-1 Application Section 3.2.2.2.2 and 3.2.2.2.4 Regulatory Basis 10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background

In the Second Annual Update (2022) of the Point Beach Subsequent License Renewal Application (ML22332A491), Change 2 added eight AMR items to SLRA Table 3.2.2-2, Containment Spray - Summary of Aging Management Evaluation. Four of the new items are related to loss of material and four are related to stress corrosion cracking, corresponding to Further Evaluation Sections 3.2.2.2.2 and 3.2.2.2.4, respectively. All of the items are for stainless steel or stainless steel cladding in an environment of Air - indoor uncontrolled (int),

all specify the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Aging Management Program (AMP), and all use Note A regarding consistency with NUREG-2191. The two items for the spray additive tank refer to NUREG-2191 Items V.A.EP-81d for loss of material and V.A.EP-103e for cracking. The other six items added to the table refer to NUREG-2191 items V.A.EP-81c (loss of material) or V.A.EP-103d (cracking).

Issue The two items added to SLRA Table 3.2.2-2 for the spray additive tank refer to NUREG-2191 Items V.A.EP-81d and V.A.EP-103e. In NUREG-2191, the corresponding AMP for V.A.EP-81d and V.A.EP-103e is XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. SLRA Table 3.2.2-2 lists the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components for these items and is therefore not consistent with the AMP used in the referenced NUREG-2191 items. As a result, the Note A indicating consistency with NUREG-2191 is incorrect.

NRC Request Please clarify the aging management program for the loss of material and cracking entries added to SLRA Table 3.2.2-2 for the spray additive tank exposed to indoor uncontrolled air and describe how the table will be revised to accurately reflect consistency with NUREG-2191.