ML25239A020
| ML25239A020 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/28/2025 |
| From: | Michele Sampson NRC/NRR/DNRL/NLRP |
| To: | Coffey R Florida Power & Light Co |
| Shared Package | |
| ML25239A019 | List: |
| References | |
| Download: ML25239A020 (1) | |
Text
Enclosure 1 Point Beach Nuclear Plant, Units 1 and 2 Supplement to the Safety Evaluation Revisions due to Annual Updates Table 3.3-1 Staff Evaluation for Auxiliary Systems Components in the GALL-SLR Report 3.31, 253 Consistent with the GALL-SLR Report (see SE Section 3.3.2.1.10)
SE Page 3-183 3.3.2.1.10 Loss of Material Due to Wear; Flow Blockage Due to Fouling (Raw Water Only)
As amended by Subsequent License Renewal Application - Third Annual Update|letter dated December 13, 2023]] (ML23347A094), SLRA Table 3.3-1, AMR item 3.3-1, 253 addresses loss of material due to wear and flow blockage due to fouling (raw water only) for PVC piping and piping components exposed to raw water, raw water (potable), treated water, and waste water. For the SLRA Table 2 AMR items that cite generic note E, the SLRA credits the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program to manage loss of material for PVC pump casings and valve bodies exposed to treated water. Based on its review of components associated with AMR items 3.3-1, 253 for which the applicant cited generic note E, the staff finds the applicants proposal to manage loss of material using the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program acceptable because: (a) flow blockage due to fouling is not an aging effect requiring management in a treated water environment; and (b) as documented in GALL-SLR Report item VII.C1.A-787c, this program is capable of detecting loss of material for PVC components exposed to a more aggressive environment (i.e., raw water).
SE Pages 3-248 and 3-249 3.5.2.3.2 Yard Structures - Summary of Aging Management Evaluation - SLRA Table 3.5.2-11 Earth Berm Exposed to Air-Outdoor.
SLRA Table 3.5.2-11 states that loss of form and loss of material for earthen berm structures exposed to an air-outdoor environment will be managed by the Structures Monitoring AMP. The AMR item cites generic note J. Also, the AMR item cites plant-specific note 4, which states that the berm surrounding the fuel oil storage tank serves a fire barrier function.
For the items in Table 3.5.2-11 stating that the loss of form and loss of material for earthen berm structures exposed to an air-outdoor environment will be managed by the Structures Monitoring AMP and citing generic note J, the NRC staff determined the need for additional information, which resulted in the issuance of an RAI. RAI 3.5.2.11-1 and the applicants response are documented in ADAMS Accession No. ML21223A308.
In its response, the applicant stated that the existing Structures Monitoring AMP only includes loss of material as an AERM for the earthen berm around the fuel tank.
Therefore, the applicant revised SLRA Section B.2.3.34 and SLRA Appendix A, Table 16-3 (items 38(d) and 38(j)), to include, as an enhancement to the AMP, loss of form as an AERM for the earthen berm surrounding the fuel oil storage tank.
SE Page 3-54 3.0.3.2.13 Steam Generators SLRA Section B.2.3.10 states that the Steam Generators AMP is an existing program with an enhancement that will be consistent with the program elements in the GALL-SLR Report AMP XI.M19, Steam Generators, except for the exception identified in the SLRA. The applicant amended this SLRA section by letters dated April 21, 2021, August 11, 2021, and November 25, 2024.
Staff Evaluation. During its audit, the NRC staff reviewed the applicants claim of consistency with the GALL-SLR Report. The staff compared the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA to the corresponding program elements of GALL-SLR Report AMP XI.M19.
For the scope of program and parameters monitored or inspected program elements, the NRC staff needed additional information on the programs that will manage loss of material for the carbon steel blowdown piping nozzles and secondary side shell penetrations exposed to treated water and the steam generator (SG) tube plugging material in the PBN SGs and issued RAIs B.2.3.10-1 and B.2.3.10-2, respectively. The staffs request and the applicants response are documented in ADAMS Accession No. ML21223A308.
In its response to RAI B.2.3.10-1, the applicant stated that loss of material for the carbon steel blowdown piping nozzles and secondary side shell penetrations exposed to treated water will be managed by the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, and Water Chemistry AMPs.
During its evaluation of the applicants response to RAI B.2.3.10-1, the NRC staff noted SLRA Table 3.1.2-5 was revised to remove AMR item 3.1-1, 072 to clarify that loss of material for the carbon steel blowdown piping nozzles and secondary side shell penetrations exposed to treated water will be managed by the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, and Water Chemistry AMPs. The staff finds the applicants response acceptable because the use of the Water Chemistry AMP to manage loss of material is consistent with the GALL-SLR Report, and the periodic inspections conducted as part of the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD AMP are capable of detecting whether loss of material is occurring.
In its response to RAI B.2.3.10-2, the applicant stated that the only Alloy 600 plugs installed in the PBN SGs are six Alloy 600 welded plugs installed in three tubes during manufacturing of the PBN Unit 1 SG A. In addition, the applicant stated that all Alloy 600 plugs in the PBN Unit 1 SG B have been replaced with Alloy 690 mechanical plugs.
During its evaluation of the applicants response to RAI B.2.3.10-2, the NRC staff noted that SLRA Section B.2.3.10 was revised to clarify that there are six Alloy 600 welded plugs in three tubes in the PBN Unit 1 SG A and that all plugs are inspected during SG tube inspections. The staff finds the applicants response acceptable because SLRA Section B.2.3.10 accurately reflects the materials of the plugs in the PBN SGs and the aging effects of the plugs, regardless of material, will be managed by the Steam Generators AMP.
The NRC staff also reviewed the portions of the scope of the program, and parameters monitored or inspected program elements associated with the exception to determine whether the program will be adequate to manage the aging effects for which it is credited. The staffs evaluation of the exception is as follows. By Subsequent License Renewal Application - Fourth Annual Update|letter dated November 25, 2024]], the applicant revised the SLRA to delete the enhancement referenced in prior versions of the SE.
Consequently, there are no enhancements to the program.
Exception. As amended by letter dated April 21, 2021, SLRA Section B.2.3.10 includes an exception to the scope of program program element to exclude the tube-to-tubesheet welds from inspection and monitoring. The tube-to-tubesheet joint consists of the tube, which is hydraulically expanded against the bore of the tubesheet, the tube-to-tubesheet weld located at the tube end, and the tubesheet. The applicants approved H* alternate repair criteria (ADAMS Accession No. ML17159A778) rely on the ability of the hydraulically expanded portion of the tube from the top of the tubesheet to 20.6 inches below the top of the tubesheet to resist tube end cap pressure loads. The alternate repair criteria take no credit for the portion of the tube more than 20.6 inches below the top of the tubesheet or the tube-to-tubesheet weld to maintain structural and leakage integrity, which removes the tube-to-tubesheet weld from a pressure boundary function. The NRC staff reviewed the exception against the corresponding program element in GALL-SLR Report AMP XI.M19 and finds it acceptable because the tube-to-tubesheet weld is no longer part of the reactor coolant pressure boundary consistent with item 2 in SRP-SLR Section 3.1.2.2.11.
Enhancement. As amended by Subsequent License Renewal Application - Fourth Annual Update|letter dated November 25, 2024]], the applicant deleted the enhancement to the parameters monitored or inspected program element from SLRA Section B.2.3.10. The enhancement would have conservatively assumed that the PBN Unit 1 SGs are not bounded by the industry analyses in EPRI 3002002850 and required performing a one-time inspection of the divider plate assemblies to confirm that the Water Chemistry and Steam Generators AMPs are mitigating primary water stress corrosion cracking (PWSCC). The applicant deleted the enhancement based on determining that the PBN Unit 1 SGs are bounded by the industry analyses. The staffs review of this change is in Section 3.1.2.2.11 of this SE.
The NRC staff conducted an audit to verify the applicants claim of consistency with the GALL-SLR Report. Based on a review of the SLRA, as amended, and the applicants responses to RAIs B.2.3.10-1 and B.2.3.10-2, the staff finds that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent with the corresponding program elements of GALL-SLR Report AMP XI.M19. The staff also reviewed the exception associated with the scope of the program program element, and the justification, and finds that the AMP, with the exception, is adequate to manage the applicable aging effects.
Operating Experience. SLRA Section B.2.3.10 summarizes operating experience related to the Steam Generators AMP. The NRC staff reviewed operating experience information in the application and during the audit. As discussed in the Audit Report, the staff reviewed the applicants plant operating experience information to, (a) identify examples of age-related degradation, as documented in the applicants corrective actions program database, and (b) provide a basis for the staffs conclusions on the ability of the applicants proposed AMP to manage the effects of aging in the subsequent period of extended operation.
The NRC staff did not identify any operating experience indicating that the applicant should modify its proposed program. Based on its audit and review of the application, the staff finds that the conditions and operating experience at the plant are bounded by those for which the Steam Generators AMP was evaluated.
UFSAR Supplement. SLRA Appendix A, Section 16.2.2.10, provides the UFSAR supplement for the Steam Generators AMP. The NRC staff reviewed this UFSAR supplement description of the program and noted that it is consistent with the recommended description in GALL-SLR Report Table XI-01. The staff also noted that the applicant committed to ongoing implementation of the existing Steam Generators program for managing the effects of aging for applicable components during the subsequent period of extended operation. The staff finds that the information in the UFSAR supplement is an adequate summary description of the program.
Conclusion. Based on its review of the applicants Steam Generators AMP, the NRC staff concludes that those program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent. The staff also reviewed the exception and finds that, with the exception, the AMP will be adequate to manage the applicable aging effects. The staff also reviewed the removal of the enhancement from the SLRA and found it acceptable based on the updated SLRA, without the enhancement, being consistent with the GALL-SLR Report. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the subsequent period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
SE Page 3-84 3.0.3.2.23 One-Time Inspection SLRA Section B.2.3.20 states that the One-Time Inspection AMP is an existing program with enhancements that will be consistent with the program elements in the GALL-SLR Report AMP XI.M32, One-Time Inspection. The applicant amended this SLRA section by letters dated April 21, 2021 and November 25, 2024.
Staff Evaluation. During its audit, the NRC staff reviewed the applicants claim of consistency with the GALL-SLR Report. The staff compared the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the applicants program in the SLRA to the corresponding program elements of GALL-SLR Report AMP XI.M32. The NRC staff also reviewed the portions of the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements associated with enhancements to determine whether the program will be adequate to manage the aging effects for which it is credited. The staffs evaluation of these six enhancements follows.
Enhancement 1. As amended by Subsequent License Renewal Application - Fourth Annual Update|letter dated November 25, 2024]], SLRA Section B.2.3.20 includes enhancements to the scope of program program element, which relates to verification of the effectiveness of the PBN Lubricating Oil Analysis AMP, steel components exposed to water environments that do not include corrosion inhibitors as a preventive action, and one-time volumetric inspections on each of the SG transition cone field welds on both units. The NRC staff reviewed these enhancements against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds them acceptable because, when implemented, this program element will be consistent with the GALL-SLR Report recommendations. In the Subsequent License Renewal Application - Fourth Annual Update|letter dated November 25, 2024]], the applicant deleted the one-time inspection of the PBN Unit 1 SG divider plate assemblies from this enhancement. The NRC staff finds this acceptable because the applicant determined that the industry analyses of divider plate assembly cracking are bounding for the PBN Unit 1 SG divider plate assemblies. Therefore, the one-time inspection is not needed to meet the SLR guidance for divider plate assemblies. This is discussed in more detail in Sections 3.0.3.2.13 and 3.1.2.2.11 of this SE.
Enhancement 2. SLRA Section B.2.3.20 includes an enhancement to the parameters monitored or inspected program element, which relates to verification of the effectiveness of the PBN Lubricating Oil Analysis AMP by performing a visual examination, or other appropriate nondestructive examination, to verify that degradation due to the applicable aging effects is not occurring. The NRC staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds it acceptable because, when implemented, it will be consistent with the GALL-SLR Report recommendations.
Enhancement 3. SLRA Section B.2.3.20 includes an enhancement to the detection of aging effects program element, which relates to including a representative sample of each component population and, where practical, focusing on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions. Additionally, the enhancement specifies that the sample size is 20 percent of the population or a maximum of 25 components at each unit. The NRC staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds it acceptable because, when implemented, it will be consistent with the GALL-SLR Report recommendations.
Enhancement 4. SLRA Section B.2.3.20 includes an enhancement to the monitoring and trending program element, which relates to inspection results for each material, environment, and aging effect and that the results are compared to those obtained during previous inspections, when available. The NRC staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds it acceptable because, when implemented, it will be consistent with the GALL-SLR Report recommendations.
Enhancement 5. SLRA Section B.2.3.20 includes enhancements to the acceptance criteria program element, which relate to considering both the results of observed degradation during current inspections and the results of projecting observed degradation of the inspections for each material, environment, and aging effect combination; basing acceptance criteria on applicable ASME Code or other appropriate standards, design basis information, or vendor-specified requirements and recommendations; projecting observed degradation to the end of the subsequent period of extended operation (when practical), to ensure that the projected degradation will not (a) affect the intended function of an SSC, (b) result in a potential leak, or (c) result in heat transfer rates below that required by the CLB to meet design limits; and entering inspection results into the corrective actions program for future monitoring and trending when measurable degradation has occurred but acceptance criteria have been met. The NRC staff reviewed these enhancements against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds them acceptable because, when implemented, this program element will be consistent with the GALL-SLR Report recommendations.
Enhancement 6. SLRA Section B.2.3.20 includes an enhancement to the corrective actions program element, which relates to ensuring that if the cause of the aging effect for each applicable material and environment is not corrected by repair or replacement for all components constructed of the same material and exposed to the same environment, additional inspections are conducted if one of the inspections does not meet acceptance criteria.
Additionally, where an aging effect identified during an inspection does not meet acceptance criteria or projected results of the inspections of a material, environment, and aging effect combination do not meet the acceptance criteria, a periodic inspection program is developed.
The NRC staff reviewed this enhancement against the corresponding program elements in GALL-SLR Report AMP XI.M32 and finds it acceptable because, when implemented, it will be consistent with the GALL-SLR Report recommendations.
The NRC staff conducted an audit to verify the applicants claim of consistency with the GALL-SLR Report. Based on a review of the SLRA, the staff finds that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent with the corresponding program elements of GALL-SLR Report AMP XI.M32. In addition, the staff reviewed the enhancements associated with the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements and finds that, when implemented, they will make the AMP adequate to manage the applicable aging effects.
Operating Experience. SLRA Section B.2.3.20 summarizes operating experience related to the One-Time Inspection AMP. The NRC staff reviewed operating experience information in the application and during the audit. As discussed in the Audit Report, the staff reviewed the applicants plant operating experience information to, (a) identify examples of age-related degradation, as documented in the applicants corrective actions program database, and (b) provide a basis for the staffs conclusions on the ability of the applicants proposed AMP to manage the effects of aging in the subsequent period of extended operation. The NRC staff did not identify any operating experience indicating that the applicant should modify its proposed program. Based on its audit and review of the application, the staff finds that the conditions and operating experience at the plant are bounded by those for which the One-Time Inspection AMP was evaluated.
UFSAR Supplement. SLRA Appendix A, Section 16.2.2.20, provides the UFSAR supplement for the One-Time Inspection AMP. The NRC staff reviewed this UFSAR supplement description of the program and noted that it is consistent with the recommended description in GALL-SLR Report Table XI-01. The staff also noted that the applicant committed to implementing the One-Time Inspection AMP no later than 6 months before the subsequent period of extended operation, or no later than the last refueling outage before the subsequent period of extended operation for managing the effects of aging for applicable components. The staff also noted that the applicant committed to continuing the existing One-Time Inspection AMP, including the enhancements for managing the effects of aging for applicable components during the subsequent period of extended operation. The staff finds that the information in the UFSAR supplement is an adequate summary description of the program.
Conclusion. Based on its review of the applicants One-Time Inspection AMP, the NRC staff concludes that those program elements for which the applicant claimed consistency with the GALL-SLR Report are consistent. The staff also reviewed the enhancements and finds that, when the enhancements are implemented, the AMP will be adequate to manage the applicable aging effects. The staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the subsequent period of extended operation, as required by 10 CFR 54.21(a)(3).
The staff also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).
SE Pages 3-160 and 3-161 3.1.2.2.11 Cracking Due to Primary Water Stress Corrosion Cracking SLRA Table 3.1-1, AMR item 3.1-1, 025 addresses cracking due to PWSCC for steel (with nickel-alloy cladding) or nickel-alloy SG primary side components: divider plate and tube-to-tube sheet welds exposed to reactor coolant. For the SLRA Table 2 AMR item that cites generic note E, the SLRA credits the Steam Generators, Water Chemistry, and One-Time Inspection AMPs to manage cracking due to PWSCC of the PBN Unit 1 SG nickel-alloy divider plate exposed to reactor coolant. The AMR item cites plant-specific note 1, which states, Per Section 3.1.2.2.11, the Unit 1 divider plate aging effect of cracking is managed by the Steam Generators (B.2.3.10), Water Chemistry (B.2.3.2), and One-Time Inspection (B.2.3.20) AMPs.
SLRA Section 3.1.2.2.11, associated with SLRA Table 3.11, AMR item 3.11, 025, addresses cracking for Alloy 600 material exposed to reactor coolant, which will be managed by the Steam Generators and Water Chemistry AMPs. The NRC staff reviewed the applicants proposal against the criteria in SRP-SLR Section 3.1.2.2.11. The review includes the applicants Subsequent License Renewal Application - Fourth Annual Update|November 25, 2024 letter]], which deleted the One-Time Inspection program as an AMP needed for aging management of the PBN Unit 1 divider plate.
Item 1. The PBN Unit 1 steam generators are Westinghouse Model 44F and have Alloy 600 divider plate assemblies. The PBN Unit 2 steam generators are Westinghouse Model Delta 47F and have Alloy 690 divider plates and associated welds. As amended by Subsequent License Renewal Application - Fourth Annual Update|letter dated November 25, 2024]], SLRA Section 3.1.2.2.11 states that the industry analysis in EPRI 3002002850 was determined by Westinghouse to be bounding for the PBN Unit 1 steam generator divider plate assemblies. The applicant submitted the Westinghouse evaluation by letter dated June 10, 2024, and incorporated it into the SLRA as new references 1.6.72 and 1.6.73 in the Subsequent License Renewal Application - Fourth Annual Update|November 25, 2024, letter]]. The applicant also deleted a commitment to perform a one-time inspection of the PBN Unit 1 steam generator divider plate assemblies to verify the effectiveness of the Water Chemistry and Steam Generators AMPs and to verify the absence of PWSCC. Deleting the plant-specific AMP (One-Time Inspection) means PWSCC of the PBN Unit 1 divider plate assemblies will be managed by the Water Chemistry and Steam Generators AMPs. The Subsequent License Renewal Application - Fourth Annual Update|November 25, 2024 letter]] proposed corresponding revisions to SLRA Section 1.6, Section 3.1.2.2.11, Table 3.1-1, Table 3.1.2-5, Appendix A Section 16.2.2.20 and Table 16-3, and Appendix B Sections B.2.3.10 and B.2.3.20.
Item 1 of SRP-SLR Section 3.1.2.2.11 states that a plant-specific AMP is not necessary for plants with divider plate assemblies fabricated of Alloy 690 and Alloy 690-type weld materials.
The SRP-SLR states that for plants with divider plate assemblies fabricated of Alloy 600 or Alloy 600-type weld materials, a plant-specific AMP is necessary if the industry analysis in EPRI 3002002850 is not bounding. In addition, the SRP-SLR states that the plant-specific AMP may include a one-time inspection capable of detecting cracking to verify the effectiveness of the Water Chemistry and Steam Generators AMPs and the absence of PWSCC in the divider plate assemblies.
For PBN Unit 1, the NRC staff reviewed the changes in the Subsequent License Renewal Application - Fourth Annual Update|November 25, 2024, letter]] and finds that the applicant has met the further evaluation criteria because for Alloy 600-type divider plate assemblies bounded by the industry analyses in EPRI 3002002850, managing PWSCC of divider plate assemblies using the Water Chemistry and Steam Generator AMPs is consistent with the guidance in item 1 of SRP-SLR Section 3.1.2.2.11. The staff finds that the applicant has met the further evaluation criteria for PBN Unit 2 because the divider plate assemblies are fabricated of Alloy 690 and Alloy 690-type weld materials and, therefore, a plant-specific AMP is not required.
Based on the programs identified, the NRC staff concludes that the applicants programs meet the criteria for item 1 in SRP-SLR Section 3.1.2.2.11. For the AMR item associated with SLRA Section 3.1.2.2.11, the staff concludes that the SLRA is consistent with the GALL-SLR Report and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB during the subsequent period of extended operation, as required by 10 CFR 54.21(a)(3).