ML25125A116

Issuance of Amendment Nos. 279 and 281 Regarding License Amendment Request to Adopt an Alternative Seismic Method for Categorization of Structures, Systems, and Components

ML25125A116
Person / Time
Site:	Point Beach
Issue date:	07/08/2025
From:	Scott Wall Plant Licensing Branch III
To:	Coffey R Point Beach
Wall, S P
References
EPID L-2024-LLA-0104
Download: ML25125A116 (1)

Text

July 8, 2025 Mr. Robert Coffey Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd Juno Beach, FL 33408

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 279 AND 281 REGARDING LICENSE AMENDMENT REQUEST TO ADOPT AN ALTERNATIVE SEISMIC METHOD FOR CATEGORIZATION OF STRUCTURES, SYSTEMS, AND COMPONENTS (EPID L-2024-LLA-0104)

Dear Mr. Coffey:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 279 and 281 to Renewed Facility Operating License (RFOL) Nos. DPR-24 and DPR-27, for the Point Beach Nuclear Plant (Point Beach), Units 1 and 2, respectively, in response to your application dated October 8, 2024.

The amendments are related to Point Beachs adoption of Title 10 of the Code of Federal Regulations (10 CFR) 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. Specifically, the amendments modify Point Beach, Unit 1, RFOL License Condition 4.E and Point Beach, Unit 2, RFOL License Condition 4.E to allow the use of an alternative approach for evaluating seismic risk for categorization of structures, systems, and components under Point Beachs approved 10 CFR 50.69 program, and removes certain pre-program implementation items that have been completed. Additionally, the proposed amendments would make editorial corrections to Unit 1 License Condition 4.M and Unit 2 License Condition 4.L, Additional Conditions, Functions 5 and 6 on technical specification (TS) Table 3.3.1-1, and TS 5.5.18.h.

A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

1. Amendment No. 279 to DPR-24

2. Amendment No. 281 to DPR-27

3. Safety Evaluation

4. Notice and Environmental Finding cc: Listserv

NEXTERA ENERGY POINT BEACH, LLC DOCKET NO. 50-266 POINT BEACH NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 279 License No. DPR-24

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by NextEra Energy Point Beach, LLC (the licensee), dated October 8, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment, and paragraph 4.B, 4.E and 4.M of Renewed Facility Operating License No. DPR-24 are hereby amended to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 279, are hereby incorporated in the renewed operating license. NextEra Energy Point Beach shall operate the facility in accordance with Technical Specifications.

E.

Adoption of 10 CFR 50.69, Risk-Informed categorization and treatment of structures, systems, and components for nuclear power plants NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. 262 dated November 26, 2018.

In addition, NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the alternative seismic approach described in NextEra Energy Point Beach letter L-2024-120, dated October 8, 2024, for categorization of RISC-1, RISC-2, RISC 3, and RISC-4 SSCs, as specified in License Amendment No. 279 dated July 8, 2025.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

M.

Additional Conditions The additional conditions contained in Appendix C, as revised through Amendment No. 258, are hereby incorporated into this license. NextEra Energy Point Beach shall operate the facility in accordance with the additional conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Ilka Berrios, Acting Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: July 8, 2025 ILKA BERRIOS Digitally signed by ILKA BERRIOS Date: 2025.07.08 13:32:18 -04'00'

NEXTERA ENERGY POINT BEACH, LLC DOCKET NO. 50-301 POINT BEACH NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 281 License No. DPR-27

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by NextEra Energy Point Beach, LLC (the licensee), dated October 8, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment, and paragraph 4.B, 4.E and 4.L of Renewed Facility Operating License No. DPR-27 are hereby amended to read as follows:

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 281, are hereby incorporated in the renewed operating license. NextEra Energy Point Beach shall operate the facility in accordance with Technical Specifications.

E.

Adoption of 10 CFR 50.69, Risk-Informed categorization and treatment of structures, systems, and components for nuclear power plants NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. 265 dated November 26, 2018.

In addition, NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the alternative seismic approach described in NextEra Energy Point Beach letter L-2024-120, dated October 8 2024, for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs, as specified in License Amendment No. 281 dated July 8, 2025.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

L.

Additional Conditions The additional conditions contained in Appendix C, as revised through Amendment No. 262, are hereby incorporated into this license. NextEra Energy Point Beach shall operate the facility in accordance with the additional conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Ilka Berrios, Acting Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Renewed Facility Operating License Date of Issuance: July 8, 2025 ILKA BERRIOS Digitally signed by ILKA BERRIOS Date: 2025.07.08 13:32:45 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 279 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-24 AND LICENSE AMENDMENT NO. 281 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-27 DOCKET NOS. 50-266 AND 50-301 Replace the following pages of Renewed Facility Operating License Nos. DPR-24 and DPR-27 and Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. DPR-24 REMOVE INSERT Renewed Facility Operating License No. DPR-27 REMOVE INSERT Appendix A, Technical Specifications REMOVE INSERT 3.3.1-15 3.3.1-15 5.5-20 5.5-20 Renewed License No. DPR-24 Amendment No. 279 D. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NextEra Energy Point Beach to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E.

Pursuant to the Act and 10 CFR Parts 30 and 70, NextEra Energy Point Beach to possess such byproduct and special nuclear materials as may be produced by the operation of the facility, but not to separate such materials retained within the fuel cladding.

4.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A.

Maximum Power Levels NextEra Energy Point Beach is authorized to operate the facility at reactor core power levels not in excess of 1800 megawatts thermal.

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 279, are hereby incorporated in the renewed operating license.

NextEra Energy Point Beach shall operate the facility in accordance with Technical Specifications.

C. Spent Fuel Pool Modification The licensee is authorized to modify the spent fuel storage pool to increase its storage capacity from 351 to 1502 assemblies as described in licensees application dated March 21, 1978, as supplemented and amended. In the event that the on-site verification check for poison material in the poison assemblies discloses any missing boron plates, the NRC shall be notified and an on-site test on every poison assembly shall be performed.

Renewed License No. DPR-24 Amendment No. 279 D. Physical Protection NextEra Energy Point Beach shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Point Beach Nuclear Plant Physical Security Plan, (Revision 4)," submitted by letter dated May 10, 2006. NextEra Energy Point Beach, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Point Beach Nuclear Plant Cyber Security Plan (CSP),

including changes made pursuant to the authority of 1 O CFR 50.90 and 10 CFR 50.54(p). The NextEra Energy Point Beach CSP was approved by License Amendment No. 243 as supplemented by a change approved by License Amendment No. 247 and License Amendment No. 252.

E.

Adoption of 10 CFR 50.69, Risk-Informed categorization and treatment of structures, systems, and components for nuclear power plants NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using:

Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. 262 dated November 26, 2018.

In addition, NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the alternative seismic approach described in NextEra Energy Point Beach letter L-2024-120, dated October 8, 2024, for categorization of RISC-1, RISC-2, RISC 3, and RISC-4 SSCs, as specified in License Amendment No. 279 dated July 8, 2025.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

Renewed License No. DPR-24 Amendment No. 279 F.

NextEra Energy Point Beach Unit 1 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated June 26, 2013, and supplements dated September 16, 2013, July 29, 2014, August 28, 2014, September 25, 2014, November 14, 2014, December 19, 2014, January 16, 2015, May 12, 2015, August 26, 2015, February 22, 2016, April 07, 2016, and May 3, 2016, and as approved in the safety evaluation report dated September 8, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or license condition, and the criteria listed below are satisfied.

1. Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

b. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7 /year (yr) for CDF and less than 1 x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-24 Amendment No. 279

1. Fire fighting response strategy with the following elements:

a.

Pre-defined coordinated fire response strategy and guidance

b.

Assessment of mutual aid fire fighting assets

c.

Designated staging areas for equipment and materials

d.

Command and control

e.

Training of response personnel

2. Operations to mitigate fuel damage considering the following:

a.

Protection and use of personnel assets

b.

Communications

c.

Minimizing fire spread

d.

Procedures for implementing integrated fire response strategy

e.

Identification of readily-available pre-staged equipment

f.

Training on integrated fire response strategy

g.

Spent fuel pool mitigation measures

3. Actions to minimize release to include consideration of:

a.

Water spray scrubbing

b.

Dose to onsite responders M. Additional Conditions The additional conditions contained in Appendix C, as revised through Amendment No. 258, are hereby incorporated into this license. NextEra Energy Point Beach shall operate the facility in accordance with the additional conditions.

5.

The issuance of this renewed operating license is without prejudice to subsequent licensing action which may be taken by the Commission with regard to the ongoing rulemaking hearing on the Interim Acceptance Criteria for Emergency Core Cooling Systems (Docket No. RM 50-1).

6.

This renewed operating license is effective as of the date of issuance, and shall expire at midnight on October 5, 2030.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By R. W. Borchardt, Director Office of Nuclear Reactor Regulation Attachments:

1.

Appendix A - Technical Specifications

2.

Appendix B - Environmental Technical Specifications

3.

Appendix C - Additional Conditions Date of Issuance: December 22, 2005 Renewed License No. DPR-27 Amendment No. 281 C. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NextEra Energy Point Beach to receive, possess and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed source for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; D. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NextEra Energy Point Beach to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E.

Pursuant to the Act and 10 CFR Parts 30 and 70, NextEra Energy Point Beach to possess such byproduct and special nuclear materials as may be produced by the operation of the facility, but not to separate such materials retained within the fuel cladding.

4.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Sections 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A.

Maximum Power Levels NextEra Energy Point Beach is authorized to operate the facility at reactor core power levels not in excess of 1800 megawatts thermal.

B.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 281, are hereby incorporated in the renewed operating license.

NextEra Energy Point Beach shall operate the facility in accordance with Technical Specifications.

C. Spent Fuel Pool Modification The licensee is authorized to modify the spent fuel storage pool to increase its storage capacity from 351 to 1502 assemblies as described in licensees application dated March 21, 1978, as supplemented and amended. In the event that the on-site verification check for poison material in the poison assemblies discloses any missing boron plates, the NRC shall be notified and an on-site test on every poison assembly shall be performed.

Renewed License No. DPR-27 Amendment No. 281 D. Physical Protection NextEra Energy Point Beach shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Point Beach Nuclear Plant Physical Security Plan, (Revision 4)," submitted by letter dated May 10, 2006. NextEra Energy Point Beach, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Point Beach Nuclear Plant Cyber Security Plan (CSP),

including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NextEra Energy Point Beach CSP was approved by License Amendment No. 247 as supplemented by a change approved by License Amendment No. 251 and License Amendment No. 256.

E.

Adoption of 10 CFR 50.69, Risk-Informed categorization and treatment of structures, systems, and components for nuclear power plants NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using:

Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. 265 dated November 26, 2018.

In addition, NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the alternative seismic approach described in NextEra Energy Point Beach letter L-2024-120, dated October 8, 2024, for categorization of RISC-1, RISC-2, RISC 3, and RISC-4 SSCs, as specified in License Amendment No. 281 dated July 8, 2025.

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

Renewed License No. DPR-27 Amendment No. 281 F.

NextEra Energy Point Beach Unit 2 shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated June 26, 2013, and supplements dated September 16, 2013, July 29, 2014, August 28, 2014, September 25, 2014, November 14, 2014, December 19, 2014, January 16, 2015, May 12, 2015, August 26, 2015, February 22, 2016, April 07, 2016, and May 3, 2016, and as approved in the safety evaluation report dated September 8, 2016. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or license condition, and the criteria listed below are satisfied.

1. Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

a. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

b. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7 /year (yr) for CDF and less than 1 x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins.

The change may be implemented following completion of the plant change evaluation.

Renewed License No. DPR-27 Amendment No. 281 L.

Additional Conditions The additional conditions contained in Appendix C, as revised through Amendment No. 262, are hereby incorporated into this license. NextEra Energy Point Beach shall operate the facility in accordance with the additional conditions.

5.

The issuance of this renewed operating license is without prejudice to subsequent licensing action which may be taken by the Commission with regard to the ongoing rulemaking hearing on the Interim Acceptance Criteria for Emergency Core Cooling Systems (Docket No. RM 50-1).

6.

This renewed operating license is effective as of the date of issuance, and shall expire at midnight on March 8, 2033.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By R. W. Borchardt, Director Office of Nuclear Reactor Regulation Attachments:

1.

Appendix A - Technical Specifications

2.

Appendix B - Environmental Technical Specifications

3.

Appendix C - Additional Conditions Date of Issuance: December 22, 2005

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 279 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-24 AND AMENDMENT NO. 281 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-27 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301

1.0 INTRODUCTION

By application dated October 8, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24282A760), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for the Point Beach Nuclear Plant (Point Beach), Units 1 and 2, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit or early site permit. The LAR is related to Point Beachs adoption of 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. Specifically, the amendments modify Point Beach, Unit 1, Renewed Facility Operating License (RFOL) License Condition E and Point Beach, Unit 2, RFOL License Condition E to allow the use of an alternative approach for evaluating seismic risk for categorization of structures, systems, and components (SSCs) under Point Beachs approved 10 CFR 50.69 program and removes certain pre-program implementation items that have been completed. Additionally, the proposed amendments would make editorial corrections to Unit 1 License Condition 4.M and Unit 2 License Condition 4.L, Additional Conditions, Functions 5 and 6 on technical specification (TS) Table 3.3.1-1, and TS 5.5.18.h.

1.1 Background

In the safety evaluation (SE) for Point Beach, Units 1 and 2, License Amendment Nos. 262 and 265 to RFOL Nos. DPR-24 and DPR-27, respectively, dated November 26, 2018 (ML18289A378), the NRC staff concluded that the licensees 10 CFR 50.69 program was consistent with the NRC-endorsed guidance in the Nuclear Energy Institute (NEI) 00-04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline (ML052910035), and thus satisfied the requirements of 10 CFR 50.69(c). A license condition incorporated into the license as part of the NRC staffs decision to approve the licensees original 10 CFR 50.69 LAR stated that, Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

In its submittal dated October 8, 2024, the licensee proposed to modify the license conditions to the Point Beach RFOLs to allow the use of an alternative seismic approach for evaluating seismic risk in addition to the use of its seismic margin analysis (SMA) described in the licensees previously approved 10 CFR 50.69 program.

1.2 Description of Proposed Changes 1.2.1 Revision to 10 CFR 50.69 License Condition A license condition was added to the Point Beach RFOLs when the NRC approved the licensees use of its 10 CFR 50.69 program on November 26, 2018. As discussed in 10 CFR 50.69(b), a licensee may voluntarily comply with 10 CFR 50.69 as an alternative to compliance with the following requirements for Risk Informed Safety Class (RISC)-3 and RISC-4 SSCs after it submits, and the NRC approves, an application for a license amendment:

(i) 10 CFR Part 21, Reporting of Defects and Noncompliance; (ii)

The portion of 10 CFR 50.46a, Acceptance criteria for reactor coolant system venting systems, paragraph (b), that imposes requirements to conform to 10 CFR Part 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants; (iii) 10 CFR 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants; (iv) 10 CFR 50.55, Conditions of construction permits, early site permits, combined licenses and manufacturing licenses, paragraph (e);

(v)

Certain requirements of 10 CFR 50.55a, Codes and standards; (vi) 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, except for paragraph (a)(4);

(vii) 10 CFR 50.72, Immediate notification requirements for operating nuclear power reactors; (viii) 10 CFR 50.73, Licensee event report system; (ix) 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants; (x)

Certain containment leakage testing requirements in 10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors; and (xi)

Certain requirements of 10 CFR Part 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants.

The current RFOL license conditions for Point Beach, Units 1 and 2 (added by License Amendment Nos. 262 and 265, respectively), state the following [bracketed text denotes unit-specific license amendment numbers]:

1. NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. [262/265] dated November 26, 2018.

2. Prior to implementation of the provisions of 10 CFR 50.69, NextEra Energy Point Beach shall complete the items below:

a. Item A in Attachment 1, List of Categorization Prerequisites, to NextEra Energy Point Beach letter NRC 2017-0043, License Amendment Request 287, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Plants, dated August 31, 2017; and

b. Attachment 1, Point Beach 10 CFR 50.69 PRA Implementation Items, in NextEra Energy Point Beach letter NRC 2018-0044, Supplement to Response to Request for Additional Information Regarding License Amendment Request 287, Application to Adopt 10 CFR 50.69, Risk informed Categorization and Treatment of Structures, System, and Components (SSCs) for Nuclear Power Plants, dated September 28, 2018.

3. Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

The licensee proposed in the subject LAR to amend the above license condition for Units 1 and 2 to read as follows:

NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using:

Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. [262/265] dated November 26, 2018.

In addition, NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the alternative seismic approach described in NextEra Energy Point Beach letter L-2024-120, dated October 8, 2024, for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs, as specified in License Amendment No. [XXX/YYY]

dated [DATE].

Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

2.0 REGULATORY EVALUATION

2.1 Applicable Regulations The regulations in 10 CFR 50.90 state that whenever a holder of an operating license desires to amend the license, including TSs in the license, an application for amendment must be filed with the Commission fully describing the changes desired. The regulations at 10 CFR 50.92(a) state that determinations on whether to grant an applied-for license amendment are guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a) (regarding, among other things, consideration of the operating procedures, the facility and equipment, the use of the facility, and other TSs, or the proposals) and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.

The regulations in 10 CFR 50.69 allow a licensee voluntarily to comply with the requirements in 10 CFR 50.69 as an alternative to compliance with specific requirements for RISC-3 SSCs (i.e., safety-related SSCs that perform low safety significant (LSS) functions) and RISC-4 SSCs (i.e., non-safety-related SSCs that perform LSS functions). The approval standards are set forth in 10 CFR 50.69(b)(3) and 50.69(b)(4) and state:

(3) The Commission will approve a licensee's implementation of this section if it determines that the process for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs satisfies the requirements of § 50.69(c) by issuing a license amendment approving the licensee's use of this section.

(4) An applicant choosing to implement this section shall include the information in § 50.69(b)(2) as part of application. The Commission will approve an applicant's implementation of this section if it determines that the process for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs satisfies the requirements of § 50.69(c).

Section 50.69(c) of 10 CFR Part 50 requires licensees to use an integrated decision-making process to categorize safety-related and non-safety-related SSCs according to the safety significance of the functions they perform, into one of the following four RISC categories, which are defined in 10 CFR 50.69(a), as follows:

RISC-1:

Safety-related SSCs that perform safety significant functions RISC-2:

Non-safety-related SSCs that perform safety significant functions RISC-3:

Safety-related SSCs that perform low safety significant functions RISC-4:

Non-safety-related SSCs that perform low safety significant functions The SSCs are classified as having either high safety significant (HSS) functions (i.e., RISC-1 and RISC-2 categories) or LSS functions (i.e., RISC-3 and RISC-4 categories). For HSS SSCs, 10 CFR 50.69 preserves current regulatory requirements for special treatment (i.e., it does not remove any requirements from these SSCs). For LSS SSCs, licensees can implement alternative treatment requirements in accordance with 10 CFR 50.69(b)(1) and 50.69(d). For RISC-3 SSCs, licensees can replace special treatment with an alternative treatment. For RISC-4 SSCs, 10 CFR 50.69 does not impose new treatment requirements.

In addition, the regulations in 10 CFR 50.69 contain requirements regarding how a licensee categorizes SSCs using a risk-informed process, adjusts treatment requirements consistent with the relative significance of the SSC, and manages the process over the lifetime of the plant. A risk-informed categorization process is employed to determine the safety significance of SSCs and place the SSCs into one of four RISC categories.

Categorization of SSCs does not allow for the elimination of SSC functional requirements, nor does it allow for equipment that is required by the deterministic design basis to be removed from the facility. Instead, 10 CFR 50.69 enables licensees to focus their resources on SSCs that make a significant contribution to plant safety. For SSCs that are categorized as HSS, existing treatment requirements are maintained or potentially enhanced. Conversely, for SSCs categorized as LSS that do not significantly contribute to plant safety on an individual basis, the regulation allows for an alternative risk-informed approach to treatment that provides a reasonable level of confidence that these SSCs will satisfy functional requirements.

Implementation of 10 CFR 50.69 allows licensees to improve focus on equipment that is HSS.

Section 50.36, Technical specifications, of 10 CFR establishes the regulatory requirements related to the content of TS. The five categories of items required to be in the TS are listed in 10 CFR 50.36(c) and include (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs);

(4) design features; and (5) administrative controls.

2.2 Applicable Regulatory Guidance The NRC staff considered the following regulatory guidance during its review of the proposed changes:

Regulatory Guide (RG) 1.201, Revision 1, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance (ML061090627);

RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (ML090410014);

RG 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (ML17317A256); and NUREG-1855, Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk Informed Decisionmaking (ML17062A466).

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the proposed changes with respect to the previously approved Point Beach 10 CFR 50.69 program. In its submittal, the licensee stated, in part, that the proposed amendment to Point Beach RFOLs would allow the use of an alternative approach (in addition to the current use of an SMA for evaluating seismic risk) and that previously approved 10 CFR 50.69 categorization methods would not be impacted. The NRC staff confirmed that the LAR did not impact or change any other aspect of the licensees categorization process except for the addition of the alternative seismic approach as a categorization method to consider the seismic risk. Therefore, the NRC staffs determinations in the letter dated November 26, 2018, concerning the licensees categorization process, other than the addition of the alternative seismic approach related to the consideration of the seismic risk, remain unchanged and valid.

Further, in Section 3 of the enclosure to the LAR, the licensee stated that it would use a single approach (i.e., either SMA or the proposed alternative seismic approach) for the categorization of an entire system. Consequently, the NRC staff did not review the licensees categorization process other than the change requested in the subject LAR.

As stated in RG 1.201, if a licensee wishes to change its categorization approach, the NRC staffs review of the resulting LAR will focus on the acceptability of the methodology and analyses relied upon in the application. Section 3.1 below summarizes the NRC staffs review of the acceptability of the proposed alternative seismic approach as described in the licensees submittal.

In Section 2.3, Description of the Proposed License Condition Change, of the LAR enclosure, the licensee stated that the implementation items in the previously approved amendment were completed. Section 3.2 below summarizes the NRC staffs review of the PRA implementation items in the previously approved amendment that would be removed from the license condition as described in the LAR.

3.1 Alternative Seismic Approach As part of its proposed process to categorize SSCs according to safety significance, the licensee proposed to use a non-PRA method to consider seismic hazards. The licensee provided a description of its proposed alternative seismic approach for considering seismic risk in the categorization process and described how the proposed alternative seismic approach would be used in the categorization process in Section 3.1 of the enclosure to the LAR. In Section 3.1, Categorization Process Description (10 CFR 50.69(b)(2)(i)), of the Enclosure to the LAR, the licensee stated that the proposed approach for Tier 2 sites is documented in Electric Power Research Institute (EPRI) Report 3002017583, Alternative Approaches for Addressing Seismic Risk in 10 CFR 50.69 Risk-Informed Categorization (ML21082A170), with the EPRI markups provided by Exelon Generation Company, LLC concerning LaSalle County Station, Units 1 and 2 (ADAMS Accession Nos. ML20290A791 and ML21022A130. The NRC staff notes that licensees proposed alternative seismic approach was not endorsed by the NRC in approving NEI 00-04. Therefore, a detailed NRC staff review of the licensees proposed plant-specific alternative seismic approach is provided below.

The licensee based its plant specific evaluation, in part, on the test cases described in EPRI Report 3002017583 to determine the extent and type of unique HSS SSCs from SPRAs. The licensee stated that the test cases are applicable to Point Beach and demonstrated that there are very few, if any, SSCs that would be designated HSS for seismic unique purposes.

Furthermore, the test cases identified that the unique seismic insights were typically associated with seismically correlated failures and led to unique HSS SSCs. The licensee further stated that the categorization team will evaluate correlated seismic failures and seismic interactions between SSCs as described in EPRI Report 3002017583 and the referenced markups. The licensee stated that the determination of seismic insights will make use of the full power internal events PRA model supplemented by focused seismic walkdowns, and the licensee described the steps of the process used to determine the importance of SSCs for mitigating seismic events on a system basis. Based on the above, the NRC staff finds that the requirements in 10 CFR 50.69(b)(2)(ii) for the proposed plant-specific alternative seismic approach are met because the licensee sufficiently described the measures taken to assure the quality and level of detail of the proposed alternative seismic approach to evaluate the plant for the categorization of SSCs.

In Section 3.1 of the enclosure to the LAR, the licensee cited a precedent for its proposed alternative seismic approach. The precedent, the LaSalle alternative seismic approach, as described in Exelons letter dated January 31, 2020, and all its subsequent associated supplements, as specified in License Amendment No. 249 dated May 27, 2021 (ML21082A422), includes a combination of qualitative and quantitative considerations of the mitigation capabilities as well as seismic failure modes of SSCs in the categorization process.

These considerations are based on plant-specific walkdowns for the SSCs undergoing categorization, quantification of the impact of seismic failure of SSCs subject to correlated or interaction failures, and insights obtained from prior seismic evaluations performed at LaSalle.

The licensee identified differences between Point Beach and the NRC staffs approval of the precedent as documented in the LaSalle SE. The licensee described that, aside from three exceptions (i.e., the use of EPRI Report 3002017583 rather than EPRI Report 3002012988, Alternative Approaches for Addressing Seismic Risk in 10 CFR 50.69 Risk-Informed Categorization (not publicly available), the use of site-specific LaSalle information, and the LaSalle request for additional information responses that are outside the scope of the LAR), the licensee would follow the same alternative seismic approach in its proposed 10 CFR 50.69 categorization process as the approved plant-specific LaSalle 10 CFR 50.69 license amendment.

Based on information provided by the licensee in the LAR enclosure, the NRC staff understands that the technical criteria in EPRI Report 3002017583 are unchanged from its predecessor EPRI Report 3002012988, and that the test cases are applicable to Point Beach and are, therefore, justified for use in the licensees proposed plant-specific alternative seismic approach. The NRC staff confirmed that the test cases in EPRI Report 3002017583 used by the licensee to support its proposed alternative seismic approach provided a sufficient plant-specific evaluation of the applicability and differences for Point Beach as compared to the plant-specific approach approved by the NRC staff for LaSalle. The NRC staff reviewed the information presented in the licensees LAR and licensees analysis for items referenced in EPRI Report 3002017583 and finds that it provides a sufficient description of, and basis for, acceptability of the evaluations to be conducted to satisfy 10 CFR 50.69(c)(1)(iv) for the Point Beach plant-specific alternative seismic approach. The NRC staff determined that there is reasonable confidence that the evaluated LSS safety-related SSCs would have sufficient safety margins maintained, and that any potential increases in core damage frequency and large early release frequency resulting from the changes in SSC treatment are small. Based on the above, the NRC staff finds that the requirements in 10 CFR 50.69(b)(2)(iv) are met for the proposed plant-specific alternative seismic approach.

Based on the information provided in the licensees submittal, the NRC staff finds that the licensee provided acceptable bridging analysis for the Point Beach plant-specific alternative seismic approach, in part, based on its analysis of LaSalles approved plant-specific alternative seismic approach because: (1) the differences between the licensees proposed alternative seismic approach and the alternative seismic approach previously approved for LaSalle are satisfactorily addressed; (2) there are no differences in the technical criteria used in EPRI Report 3002017583 and its predecessor, EPRI Report 3002012988, for use in this application; and (3) all references needed to support the proposed alternate seismic approach have been cited by the LAR.

3.1.1 Evaluation of Technical Acceptability of the PRAs Used for Test Cases Supporting the Proposed Alternative Seismic Approach In Section 3.1 of the enclosure to the LAR, the licensee discussed the LaSalle precedent, including the test cases (also referred to as case studies in the LAR), mapping approach, and conclusions on the determination of unique HSS SSCs from the test cases, which were used by the licensee to support its proposed plant-specific alternative seismic approach. The licensee stated that Point Beach is using test case information from EPRI Report 3002017583 which demonstrated that seismic risk is adequately addressed for Tier 2 sites. The licensee stated that Tier 2 seismic demand sites have a lower likelihood of seismically induced failures and fewer challenges to plant systems than test case plants. Section 3.1.2 below provides the NRC staffs evaluation of the Tier 2 criteria for Point Beach. The NRC staff reviewed and evaluated the technical acceptability of the PRAs used in the test cases for Plants A, C, and D in EPRI Report 3002017583, as well as the applicability of these test cases to Point Beach. The NRC staff also evaluated the peer review process, resolution of peer review findings, and key assumptions and sources of uncertainty for Plants A, C, and D.

Based on the NRC staffs independent review, as described above, the staff finds that the technical acceptability of PRAs used for the Plant A, C, and D test cases in EPRI Report 3002017583, the mapping approach used in those test cases, and the conclusions on the determination of unique HSS SSCs from the test cases in the LaSalle precedent are applicable to Point Beachs proposed plant-specific alternative seismic approach. Therefore, the NRC staff concludes that the Plant A, C, and D PRAs were technically acceptable and applicable for use in support of the licensees proposed alternative seismic approach, the mapping of SSCs between the SPRA, the full power internal events PRA, and, as applicable, the fire PRA (FPRA) for the Plant A, C, and D test cases. The NRC staff further finds that the licensees plant-specific evaluation is technically justified to support conclusions on the determination of unique HSS SSCs from SPRAs in the Plant A, C, and D test cases in EPRI Report 3002017583, and that the licensees proposed plant-specific alternative seismic approach is applicable to Point Beach.

3.1.2 Evaluation of the Criteria for the Proposed Alternative Seismic Approach In Section 3.1 of the enclosure to the LAR, the licensee provided the basis for Point Beach being a Tier 2 plant. The licensee referred to the following criteria provided in EPRI Report 3002017583:

Tier 1: Plants where the ground motion response spectrum (GMRS) peak acceleration is at or below approximately 0.2g or where the GMRS is below or approximately equal to the safe shutdown earthquake (SSE) between 1.0 Hertz (Hz) and 10 Hz.

Tier 2: Plants where the GMRS to SSE comparison between 1.0 Hz and 10 Hz is greater than in Tier 1 but not high enough to be treated as Tier 3. At these sites, the unique seismic categorization insights are expected to be limited.

Tier 3: Plants where the GMRS to SSE comparison between 1.0 Hz and 10 Hz is high enough that the NRC required the plant to perform an SPRA to respond to the 10 CFR 50.54(f) letter regarding the Fukushima Dai-Ichi Accident (ML12053A340).

The licensee compared the GMRS to the SSE and explained that the GMRS to SSE comparison is above the Tier 1 threshold under criteria in the EPRI Report but is not high enough for the NRC to require the plant to perform an SPRA to respond to NTTF recommendation 2.1. This determination on the licensees plant-specific evaluation is supported by its response to NTTF recommendation 2.1 (ML14090A275). The NRC staff reviewed the plant-specific evaluation and concludes that the proposed Tier 2 criteria to determine the applicability and use of the proposed alternative seismic approach is acceptable. Based on its review of the GMRS to SSE comparison, the NRC staff finds that the licensees seismic hazard assessment meets the criteria for its proposed alternative seismic approach.

3.1.3 Evaluation of the Implementation of Conclusions The categorization conclusions supporting the request for Point Beach indicated that seismic specific failure modes resulted in HSS categorization uniquely from SPRAs. Seismic specific failure modes, such as correlated failures, relay chatter, and passive component structural failure modes, can influence the categorization process. The NRC staff reviewed the proposed alternative seismic approach for Point Beach to evaluate whether the categorization-related conclusions were assessed appropriately and provisions for implementation were sufficient.

In Section 3.1 of the enclosure to the LAR, the licensee described the implementation of the proposed alternative seismic approach. For HSS SSCs uniquely identified by the PRA models but having design-basis functions during seismic events or functions credited for mitigation and prevention of severe accidents caused by seismic events, the licensee stated that it will address these SSCs using non-PRA based qualitative assessments in conjunction with any seismic insights provided by the PRA. For components that are HSS due to the FPRA, but not HSS due to the full power internal events PRA, the licensee stated that the categorization team will review design-basis functions during seismic events or functions credited for mitigation and prevention of severe accidents caused by seismic events and characterize these as additional qualitative inputs to the Integrated Decision-making Panel (IDP).

The licensee stated that the categorization team will evaluate plant-specific seismic reviews.

The licensee stated that the objective of the seismic reviews is to identify plant-specific seismic insights that might include potentially important impacts such as:

Impact of relay chatter Implications related to potential seismic interactions such as with block walls Seismic failures of passive SSCs such as tanks and heat exchangers Any known structural or anchorage issues with a particular SSC Components implicitly part of PRA-modeled functions (including relays)

The licensee stated that it will follow the same categorization process that the NRC staff approved for LaSalle, and it incorporated the LaSalle RAI responses in the Point Beach LAR.

The licensee described its exceptions to the LaSalle precedent, including LaSalle site-specific information, as evaluated above. The NRC staff reviewed the licensees proposed alternative seismic approach and determined that the NRC-approved precedent is applicable to the proposed alternative seismic approach and that the plant-specific evaluation of the alternative seismic approach is acceptable. Based on its independent review of the licensees proposed alternative seismic approach, in conjunction with the requirements in 10 CFR 50.69, the NRC staff finds that the proposed alternative seismic approach, as described in the proposed license condition, provides reasonable confidence in the evaluations required by 10 CFR 50.69(c)(1)(ii) as well as 10 CFR 50.69(c)(1)(iv) because:

The proposed alternative seismic approach includes qualitative consideration of seismic events at several steps of the categorization process, including documentation of the information for presentation to the IDP as part of the integrated, systematic process for categorization.

The proposed alternative seismic approach presents system specific seismic insights to the IDP for consideration as part of the IDP review process as each system is categorized, thereby providing the IDP a means to consider potential impacts of seismic events in the categorization process.

The insights presented to the IDP include potentially important seismically induced failure modes, as well as mitigation capabilities of SSCs during seismically induced design basis and severe accident events consistent with the conclusions on the determination of unique HSS SSCs from SPRAs in EPRI Report 3002017583. The insights will use prior plant-specific seismic evaluations, and therefore, in conjunction with performance monitoring for the proposed alternative seismic approach, reasonably reflect the current plant configuration. Further, the recommendation for categorizing civil structures in the alternative seismic approach provides appropriate consideration of such failures from a seismic event.

The proposed alternative seismic approach includes qualitative considerations and insights related to the impact of a seismic event on SSCs for each SSC that is categorized and does not limit the scope to SSCs from the test cases supporting this application.

3.1.4 Consideration of Changes to Seismic Hazard An important input to the NRC staffs evaluation of the proposed alternative seismic approach is the current knowledge of the seismic hazard at Point Beach. The possibility exists for the seismic hazard at the site to increase or decrease such that the criteria for use of the proposed alternative seismic approach are challenged. In such a situation, the categorization process may be impacted from a seismic risk perspective either solely due to the seismic risk or by the integrated importance measure determination.

In Section 3.1 of the enclosure to the LAR, the licensee stated, in part, that:

If the [Point Beach] seismic hazard changes from medium risk (i.e., Tier 2) at some future time and the feedback process determines that a process different from the proposed alternative seismic approach is warranted for seismic risk consideration in categorization under 10 CFR 50.69, prior NRC approval, pursuant to 10 CFR 50.90, will be requested.

The licensee also stated that it will follow its categorization review and adjustment process to review the changes to the plant and update, as appropriate, the SSC categorization in accordance with 10 CFR 50.69(e) and the EPRI Report 3002017583 SSC categorization criteria for the updated tier, and that this includes use of the licensees corrective action process. The licensee described the processes it will follow if the seismic hazard is reduced such that it meets the criteria for Tier 1 in EPRI Report 3002017583 or is increased to a degree that an SPRA becomes necessary to demonstrate adequate seismic safety.

Based on its independent review, the NRC staff finds that the consideration of changes to the seismic hazard in the licensees proposed alternative seismic approach is consistent with the applicable regulations and the precedent approved by NRC staff for LaSalle. Therefore, the NRC staffs evaluation of the proposed changes to Point Beachs seismic hazard against the requirements in 10 CFR 50.69(e)(1) and 10 CFR 50.69(e)(3), as well as the resulting conclusion on consideration of changes to the seismic hazard for the NRC approved precedent is applicable to this licensees proposed alternative seismic approach. Consequently, the NRC staff finds that the consideration of changes to the seismic hazard at Point Beach is acceptable because: (1) the criteria for use of the proposed alternative seismic approach are clear and traceable, (2) the proposed alternative seismic approach includes periodic reconsideration of the seismic hazard as new information becomes available, (3) the proposed alternative seismic approach satisfies the requirements in 10 CFR 50.69 as discussed above, and (4) the licensee has included a proposed license condition in the LAR to require NRC approval for a change to the specified seismic categorization approach.

3.1.5 Monitoring of Inputs to and Outcome of Proposed Alternative Seismic Approach In Section 3.5, Feedback and Adjustment Process, of the enclosure to the LAR, the licensee described its feedback and adjustment (i.e., performance monitoring) process. The licensee described its performance monitoring process, configuration control process, and problem identification and resolution process. In the LAR, the licensee stated, in part, that:

To more specifically address the feedback and adjustment (i.e., performance monitoring) process as it pertains to the proposed alternative seismic method for Tier 2 sites [], implementation of the NextEra design control and corrective action programs provide assurance that the inputs for the qualitative determinations for seismic continue to remain valid to maintain compliance with the requirements of 10 CFR 50.69(e).

Further, the licensee stated, in part, that:

Scheduled periodic reviews no more frequent than once every two refueling outages will evaluate new insights resulting from available risk information (i.e.,

PRA model or other analysis used in the categorization) changes, design changes, operational changes, and SSC performance. If it is determined that these changes have affected the risk information or other elements of the categorization process such that the categorization results are more than minimally affected, then the risk information and the categorization process will be updated.

Based on its independent review, the NRC staff finds that consideration of the feedback and adjustment process in the licensees proposed alternative seismic approach is acceptable because: (1) the licensees programs provide reasonable assurance that the existing seismic capacity of LSS components would not be significantly impacted, and (2) the monitoring and configuration control program ensures that potential degradation of seismic capacity would be detected and addressed before significantly impacting the plants risk profile. Therefore, the NRC staff finds that the potential impact of the seismic hazard on the categorization of RISC-3 SSCs is maintained acceptably low and the requirements in 10 CFR 50.69(c)(1)(iv) are met for the proposed alternative seismic approach.

3.2 PRA Implementation Items As described in Section 1.2 of this SE, the current license condition for Point Beach, Units 1 and 2, (added by License Amendment Nos. 262 and 265, respectively) states the following

[bracketed text denotes unit-specific license amendment numbers]:

1. NextEra Energy Point Beach is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in License Amendment No. [262/265] dated November 26, 2018.

2. Prior to implementation of the provisions of 10 CFR 50.69, NextEra Energy Point Beach shall complete the items below:

a. Item A in Attachment 1, List of Categorization Prerequisites, to NextEra Energy Point Beach letter NRC 2017-0043, License Amendment Request 287, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Plants, dated August 31, 2017; and

b. Attachment 1, Point Beach 10 CFR 50.69 PRA Implementation Items, in NextEra Energy Point Beach letter NRC 2018-0044, Supplement to Response to Request for Additional Information Regarding License Amendment Request 287, Application to Adopt 10 CFR 50.69, Risk informed Categorization and Treatment of Structures, System, and Components (SSCs) for Nuclear Power Plants, dated September 28, 2018.

3. Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).

In Section 2.3 of the enclosure to the LAR, the licensee stated that the implementation items identified in the last paragraph of the license condition were completed as required prior to the implementation of the 10 CFR 50.69 categorization process. The licensee proposed deleting the paragraph specific to the implementation items in the revised license condition because the paragraph is no longer applicable. Inasmuch as the previous implementation items have been completed, the NRC staff finds this change acceptable.

3.3 Editorial Changes 3.3.1 Corrections to Additional Conditions Currently, Point Beach Unit 1 License Condition 4.M reads:

The additional conditions contained in Appendix C, as revised through Amendment No. 241, are hereby incorporated into this license The licensee proposed License Condition 4.M to read:

The additional conditions contained in Appendix C, as revised through Amendment No. 258, are hereby incorporated into this license Currently, Point Beach Unit 2 License Condition 4.L reads:

The additional conditions contained in Appendix C, as revised through Amendment No. 245, are hereby incorporated into this license The licensee proposed License Condition 4.L to read:

The additional conditions contained in Appendix C, as revised through Amendment No. 262, are hereby incorporated into this license On February 22, 2017, the NRC issued Amendment Nos. 258 and 262 to RFOL Nos. DPR-24 and DPR-27 for Point Beach, Units 1 and 2, respectively (ML17039A300). In part, these amendments removed several additional conditions of the Appendix C, Additional Conditions, of the RFOLs that were completed and were no longer in effect. However, the amendments erroneously did not update License Condition 4.M (Unit 1) and License Condition 4.L (Unit 2) to reflect the proper amendment numbers. The NRC staff confirmed that the proposed editorial changes do not materially change License Condition or TS requirements and, therefore, the proposed changes are acceptable.

3.3.2 Corrections to TS Table 3.3.1-1 Currently, the Allowable Value for Function 5 on TS Table 3.3.1-1 reads Refer to Note 1 (Page 3.3.1-18) The licensee proposed the Allowable Value for Function 5 on TS Table 3.3.1-1 to read Refer to Note 1 (Page 3.3.1-20).

Similarly, the Allowable Value for Function 6 on TS Table 3.3.1-1 currently reads Refer to Note 2 (Page 3.3.1-19) The licensee proposed the Allowable Value for Function 6 on TS Table 3.3.1-1 to read Refer to Note 2 (Page 3.3.1-21).

On June 1, 2023, the NRC issued Amendment Nos. 271 and 273 to RFOL Nos. DPR-24 and DPR-27 for Point Beach, Units 1 and 2, respectively (ML23103A133). In part, these amendments added additional pages to TS 3.3.1, Reactor Protection System (RPS)

Instrumentation, that resulted in moving Note 1 and Note 2 from Page 3.3.1-18 and Page 3.3.1-19, respectively, to Page 3.3.1-20 and Page 3.3.1-21, respectively. However, the amendments erroneously did not update TS Table 3.3.1-1 to reflect the proper page numbers for the notes. The NRC staff confirmed that the proposed editorial changes do not materially change TS requirements and, therefore, the proposed changes are acceptable.

3.3.3 Corrections to TS 5.5.18.h Currently, TS 5.5.18.h reads:

Portable smoke ejection equipment per the Fire Protection Evaluation Report and Safe Shutdown Analysis Report to address a potential smoke challenge The licensee proposed revising TS 5.5.18.h to read:

Portable smoke ejection equipment per the Fire Protection Evaluation Program Design Document to address a potential smoke challenge.

On September 8, 2016, the NRC issued Amendment Nos. 256 and 260 to RFOL Nos. DPR-24 and DPR-27 for Point Beach, Units 1 and 2, respectively (ML16196A093). These amendments authorized the transition of the Point Beach fire protection program to a risk-informed, performance-based program based on National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, in accordance with 10 CFR 50.48(c). The licensee indicates that changing TS 5.5.18.h to use Fire Protection Evaluation Program Design Document will better align the wording with License Condition 4.F. The NRC staff confirmed that the proposed editorial changes do not materially change License Condition or TS requirements and, therefore, the proposed changes are acceptable.

3.4 Technical Conclusion Based on the NRC staffs independent review, the staff finds the licensees non-PRA methods for assessing risk for seismic hazards (a deviation from NEI 00-04), are acceptable and that the licensees proposed 10 CFR 50.69 program, with the proposed license conditions, will continue to meet the requirements in 10 CFR 50.69. Based on the NRC staffs review of the editorial changes to the TS in Table 3.3.1-1 and TS 5.5.18.h, the staff finds that the revisions are editorial and do not alter the TS requirements. Based on these findings, the NRC staff concludes that there is reasonable assurance that the requirements of 10 CFR 50.36(c)(2) and (c)(5) will continue to be met and therefore finds the proposed changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, on April 28, 2025, the Wisconsin State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

These amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding in the Federal Register on November 26, 2024 (89 FR 93361), that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: D. Silverstein, NRR K. Tetter, NRR Date: July 8, 2025

ML25125A116 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRA/APLC/BC NAME SWall SLent SAlferink DATE 05/02/2025 05/05/2025 05/09/2025 OFFICE NRR/DEX/EXHB NRR/DEX/EMIB NRR/DSS/STSB/BC NAME BHayes SBailey SMehta DATE 05/15/2025 05/06/2025 05/12/2025 OFFICE OGC - NLO NRR/DORL/LPL3/BC (A)

NRR/DORL/LPL3/PM NAME STurk IBerrios SWall DATE 06/04/2025 07/08/2025 07/08/2025