ML25239A021
| ML25239A021 | |
| 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: ML25239A021 (1) | |
Text
Enclosure 2 Point Beach Nuclear Plant, Units 1 and 2 Supplement to the Safety Evaluation Revisions to Appendix A, Subsequent License Renewal Commitments Table A-1 Point Beach Subsequent License Renewal Commitments Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source 14 Steam Generators XI.M19 Continue the existing PBN Steam Generators AMP No later than 6 months prior to the SPEO, i.e.:
PBN1: 04/05/2030 PBN2: 09/08/2032 SLRA, ML20329A292 SLRA Supplement 1, ML21111A155 Fourth Annual Update, ML24330A102 24 One-Time Inspection XI.M32 Continue the existing PBN One-Time Inspection AMP, including enhancement to:
a)
Perform visual exams or other appropriate NDE exams to verify the effectiveness of the PBN Lubricating Oil Analysis AMP for managing the effects of aging of various components in systems containing lubricating oil.
b)
For steel components exposed to water environments that do not include corrosion inhibitors as a preventive action (e.g., treated water, treated borated water, raw water, waste water), verify that long-term loss of material due to general corrosion will not cause a loss of intended function [e.g., pressure boundary, leakage boundary (spatial), structural integrity (attached)].
Long-term loss of material due to general corrosion for steel components need not be managed if one of the following two conditions is met: (i) the environment for the steel components includes corrosion inhibitors as a preventive action; or (ii) wall thickness measurements on a representative sample of each environment will be conducted between the 50th and 60th year of operation.
c)
Perform one-time volumetric inspections on each of the steam generator transition cone field welds on both units. This one-time volumetric inspection on each steam generator transition cone field weld is No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO, i.e.:
PBN1: 4/05/2030 PBN2: 09/08/2032 Perform the one time inspections no earlier than 10 years prior to the SPEO and no later than 6 months prior to the SPEO.
SLRA, ML20329A292 SLRA Supplement 1, ML21111A155 Fourth Annual Update, ML24330A102 Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source intended to cover essentially 100% of the total weld length.
d)
Inspect a representative sample of each population (defined as components having the same material, environment, and aging effect combination) and, where practical, focus on the bounding or lead components most susceptible to aging due to time in service, and severity of operating conditions. A representative sample size is 20% of the population or a maximum of 25 components at each unit. Otherwise, a technical justification of the methodology and sample size used for selecting components for one-time inspection is included as part of the program documentation. Factors that will be considered when choosing components for inspection are time in service, severity of operating conditions, and OE.
e)
Compare inspection results for each material, environment, and aging effect to those obtained during previous inspections, when available.
Where practical, these results are trended in order to project observe degradation to the end of the SPEO.
f)
Acceptance Criteria:
Consider 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 combinations.
Acceptance criteria may be based on applicable ASME Code or other appropriate standards, design basis information, or vendor-specified requirements and recommendations (e.g.,
ultrasonic thickness measurements are compared to predetermined limits); however, crack-like indications are not acceptable.
Where it is practical to project observed degradation to the end of the SPEO, the projected degradation will not: (a) affect the intended function of a system, structure, or component; (b) result in a potential leak; or (c) result in heat transfer rates below that required by Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source the CLB to meet design limits.
Enter inspection results into the corrective action plan for future monitoring and trending where measurable degradation has occurred, but acceptance criteria have been met.
g)
If the cause of the aging effect for each applicable material and environment is not corrected by repair of 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. The number of increased inspections is determined in accordance with the corrective action process; however, there will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material, environment, and aging effect combination is inspected, whichever is less. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of inspections.
Because PBN is a multi-unit site, the additional inspections include inspections at both units with the same material, environment, and aging effect combination.
h)
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 above acceptance criteria, a periodic inspection program is developed for the specific material, environment, and aging effect combination. The periodic inspection program is implemented at both units with the same combination(s) of material, environment, and aging effect.
Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source 27 External Surfaces Monitoring of Mechanical Components XI.M36 Continue the existing PBN External Surfaces Monitoring of Mechanical Components AMP, including enhancement to:
a)
Revise procedure(s) to inspect heat exchanger surfaces exposed to air for evidence of reduction of heat transfer due to fouling.
b)
Specify in procedure(s) that situations where the similarity of the internal and external environments are such that the external surface condition is representative of the internal surface condition, external inspections of components may be credited for managing:
loss of material and cracking of internal surfaces for metallic and cementitious components, loss of material, and cracking of internal surfaces for polymeric components, and hardening or loss of strength of internal surfaces for elastomeric components.
When credited, the program provides the basis to establish that the external and internal surface condition and environment are sufficiently similar.
c)
Clarify in procedure(s) that aging effects associated with below grade components that are accessible during normal operations or refueling outages, for which access is not restricted are managed by the PBN External Surfaces Monitoring of Mechanical Components AMP.
d)
Revise procedure(s) to include an item in the walkdown checklist to inspect insulation metallic jacketing for any damage that would permit in-leakage of moisture.
e)
Revise procedure(s) to clarify visual inspection of cementitious components for indications [of] loss of material and cracking. Examples of inspection parameters for cementitious materials include spalling, scaling, and cracking.
No later than 6 months prior to the SPEO, i.e.:
PBN1: 04/05/2030 PBN2:
09/08/2032 SLRA, ML20329A292 SLRA Supplement 1, ML21111A155 RAI Set 1 -
Supplement 1, ML21253A138 Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source f)
Revise procedure(s) to clarify periodic visual or surface examinations are utilized to manage cracking in stainless steel or aluminum components.
g)
Revise procedure(s) to add the following inspection parameters for metallic components:
Surface imperfections, loss of wall thickness, oxide coated surfaces Corrosion stains on thermal insulation Blistering of protective coating Evidence of leakage (for detection of cracks) on the surfaces of stainless steel and aluminum components Accumulation of debris on heat exchanger tube surfaces and air-side heat exchanger surfaces h)
Revise procedure(s) to include inspection for elastomeric and polymeric components and its methodology. Elastomeric and flexible polymeric components are monitored through a combination of visual inspection and manual or physical manipulation of the material. Visual inspections cover 100% of accessible component surfaces. Manual or physical manipulation of the material includes touching, pressing on, flexing, bending, or otherwise manually interacting with the material in order to reveal changes in material properties, such as hardness, and to make the visual examination process more effective in identifying aging effects such as cracking. The sample size for manipulation is at least 10% of available surface area. The inspection parameters for elastomers polymers shall include the following:
Surface cracking, crazing, scuffing, and dimensional change (e.g., ballooning and necking)
Loss of thickness Discoloration (evidence of a potential change in material properties that could be indicative of polymeric degradation)
Exposure of internal reinforcement for reinforced elastomers Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source Hardening as evidenced by a loss of suppleness during manipulation where the component and material are appropriate to manipulation i)
Revise procedure(s) to include that flexing of polyvinyl chloride piping exposed directly to sunlight (i.e., not located in a structure restricting access to sunlight such as manholes, enclosures, and vaults or isolated from the environment by coatings) is conducted to detect potential reduction in impact strength as indicated by a crackling sound or surface cracks when flexed.
j)
Revise procedure(s) to include accumulation of debris on in-scope components is monitored.
k)
Revise procedure(s) to inspect a sample of HVAC closure bolting in reach to ensure that it is not loose.
l)
Revise procedure(s) to specify that inspections are to be performed by personnel qualified in accordance with site procedures and programs to perform the specified task, and when required by the ASME Code, inspections are conducted in accordance with the applicable code requirements.
m) Revise procedure(s) to include inspections for loss of material, cracking, changes in material properties, hardening or loss of strength (of elastomeric components), reduced thermal insulation resistance, loss of preload for ducting closure bolting, and reduction of heat transfer due to fouling at an inspection frequency of every refueling outage for all in-scope non-stainless steel and non-aluminum components, which include metallic, polymeric, insulation jacketing (insulation when not jacketed).
Non-ASME Code inspections and tests should include inspection parameters for items such as lighting, distance offset, surface coverage, and presence of protective coatings. Surfaces that are not readily visible during plant operations and refueling outages should be inspected when they are made accessible and at such intervals that would ensure the components intended functions are maintained.
n)
Revise procedure(s) to specify that surface Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source examinations, or ASME Code Section XI VT-1 examinations (including those inspections conducted on non-ASME Code components) are conducted every 10 years to detect cracking of stainless steel (SS) and aluminum components.
o)
Revise procedure(s) to specify that surface examinations, or ASME Code Section XI VT-1 examinations, are conducted on 20% of the surface area unless the component is measured in linear feet, such as piping. Alternatively, any combination of 1-foot length sections and components can be used to meet the recommended extent of 25 inspections.
The provisions of GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, to conduct inspections in a more severe environment and combination of air environments may be incorporated for these inspections.
p)
Revise procedure(s) to specify alternative methods for detecting moisture inside piping insulation (such as thermography, neutron backscatter devices, and moisture meters) are to be used for inspecting piping jacketing that is not installed in accordance with plant-specific procedures (such as no minimum overlap, wrong location of seams, etc.).
q)
Revise procedure(s) to include the following information:
Component surfaces that are insulated and exposed to condensation (because the in-scope component is operated below the dew point),
and insulated outdoor components, are periodically inspected every 10 years during the SPEO.
For all outdoor components and any indoor components exposed to periodic submergence or condensation (because the in-scope component is operated below the dew point),
inspections are conducted of each material type (e.g., steel, SS, copper alloy, aluminum) and environment (e.g., raw water, air outdoor, air accompanied by leakage) where periodic Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source submergence, condensation or moisture on the surfaces of the component could occur routinely or seasonally. In some instances, significant moisture can accumulate under insulation during high humidity seasons, even in conditioned air.
A minimum of 20% of the in-scope piping length, or 20% of the surface area for components whose configuration does not conform to a 1-foot axial length determination (e.g., valve, accumulator, tank) is inspected after the insulation is removed. Alternatively, any combination of a minimum of 25 1-foot axial length sections and components for each material type is inspected. Inspection locations should focus on the bounding or lead components most susceptible to aging because of time in service, severity of operating conditions (e.g., amount of time that condensate would be present on the external surfaces of the component), and lowest design margin.
Inspections for cracking due to SCC in aluminum components need not be conducted if it has been determined that SCC is not an applicable aging effect.
r)
Revise procedure(s) to specify that:
Visual inspection will identify direct indicators of loss of material due to wear to include dimension change, scuffing, and, for flexible polymeric materials with internal reinforcement, the exposure of reinforcing fibers, mesh, or underlying metal.
Visual inspection of elastomers and flexible polymers will identify indirect indicators of elastomer and flexible polymer hardening or loss of strength, including the presence of surface cracking, crazing, discoloration, and, for elastomers with internal reinforcement, the exposure of reinforcing fibers, mesh, or underlying metal.
Visual inspections will cover 100% of accessible component surfaces.
Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source Manual or physical manipulation can be used to augment visual inspection to confirm the absence of hardening or loss of strength for elastomers and flexible polymeric materials (e.g., heating, ventilation, and air conditioning flexible connectors) where appropriate, and the sample size for manipulation is at least 10% of available surface area.
s)
Revise procedure(s) to formalize sampling-based inspections. The results of sampling-based inspections will be evaluated against acceptance criteria to confirm that the sampling bases (e.g.,
selection, size, frequency) will maintain intended functions of the components throughout the SPEO based on the projected rate and extent of degradation.
t)
The AMP owner will interface with the fleet corrosion monitoring action program to identify problem areas and track resolution of deficiencies.
u)
Revise procedure(s) to add an evaluation to project the degree of observed degradation to the end of the SPEO or the next scheduled inspection, whichever is shorter.
v)
Revise procedure(s) to specify where practical, acceptance criteria are quantitative (e.g., minimum wall thickness, percent shrinkage allowed in an elastomeric seal). For quantitative analyses, the required minimum wall thickness to meet applicable design standards will be used. Where qualitative acceptance criteria are used, the criteria are clear enough to reasonably ensure that a singular decision is derived based on the observed condition of the systems, structures, and components (e.g. cracks are absent in rigid polymers, the flexibility of an elastomeric sealant is sufficient to ensure that it will properly adhere to surface).
w)
Revise procedure(s) to include guidance from EPRI TR-1007933 Aging Assessment Field Guide and TR-1009743 Aging Identification and Assessment Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source Checklist on the evaluation of materials and criteria for their acceptance when performing visual/tactile inspections.
x)
Revise procedure(s) to specify that additional inspections will be performed if any sampling-based inspections to detect cracking in aluminum and stainless steel components do not meet the acceptance criteria, unless the cause of the aging effect for each applicable material and environment is corrected by repair or replacement. There will be no fewer than five additional inspections for each inspection that did not meet acceptance criteria, or 20% of each applicable material, environment, and aging effect combination inspected, whichever is less.
The additional inspections will be completed within the interval (e.g., 10-year inspection interval) in which the original inspection was conducted. If any subsequent inspections do not meet the acceptance criteria, an extent of condition and extent-of-cause analysis will be conducted to determine the further extent of inspections required. Additional samples will be inspected for any recurring degradation to ensure corrective actions appropriately address the associated causes. The additional inspections will include inspections of components with the same material, environment, and aging effect combination at both Unit 1 and Unit 2.
y)
Revise procedure(s) to specify that visual inspections for loss of material (every refueling outage) and cracking (every ten years) on accessible portions of the RC piping RMI insulation and insulation jacketing within the PSW will be performed.
35 ASME Section XI, Subsection IWF XI.S3 Continue the existing PBN ASME Section XI, Subsection IWF AMP, including enhancement to:
a)
Augment existing procedures to evaluate the acceptability of inaccessible areas (e.g., portions of supports encased in concrete, buried underground, or encapsulated by guard pipe) when conditions in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas.
No later than 6 months prior to the SPEO, or no later than the last refueling outage prior to the SPEO, i.e.:
PBN1: 04/05/30 PBN2: 09/08/32 Start the one-time SLRA, ML20329A292 SLRA Supplement 1, ML21111A155 RAI Responses Set 2, ML21223A308 Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source b)
Augment existing procedures to include vibration isolation elements of ASME Section XI Class 1, 2, and 3 supports within the ISI Program scope.
c)
Augment existing procedures to specify that whenever replacement of bolting is required, bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, EPRI TR-104213, Bolted Joint Maintenance & Application Guide, and the additional recommendations of NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation of Failure in Nuclear Power Plants.
d)
Augment existing procedures to specify that for structural bolting consisting of ASTM A325, ASTM F1852, ASTM F2280, and/or ASTM A490 bolts, the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC publication Specification for Structural Joints Using ASTM A325 or A490 Bolts, will be used.
Additionally, molybdenum disulfide and other lubricants containing sulfur will not be used.
e)
Augment existing procedures to specify that bolting within the scope of this program is inspected for loss of integrity of bolted connections due to self-loosening.
f)
Augment existing procedures to specify that elastomeric or polymeric vibration isolation elements are monitored for cracking, loss of material, and hardening.
g)
Perform and document a one-time inspection of an additional 5% of the sample populations for Class 1, 2, and 3 piping supports. The additional supports will be selected from the remaining population of IWF piping supports and will include components that are most susceptible to age-related degradation.
h)
Augment existing procedures to include tactile inspection (feeling, prodding) of elastomeric vibration isolation elements to detect hardening if the vibration isolation function is suspect.
inspections no earlier than five years prior to the SPEO.
Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source i)
Augment existing procedures to specify that, for ASME Class 1, 2, or 3 component supports, high-strength bolting greater than one inch nominal diameter, volumetric examination comparable to that of ASME Code,Section XI, Table IWB2500-1, Examination Category B-G-1 will be performed to detect cracking in addition to the VT3 examination. A representative sample of bolts will be inspected during the inspection interval prior to the start of the SPEO and in each 10-year period during the SPEO. The sample will be 20% of the population (for a material /
environment combination) up to a maximum of 25 bolts.
j)
Augment existing procedures to increase or modify the component support inspection population when a component is repaired to as-new condition by including another support that is representative of the remaining population of supports that were not repaired.
k)
Augment existing procedures to specify that the following conditions are also unacceptable: loss of material due to corrosion or wear; debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support; cracking or sheared bolts, including high strength bolts, and anchors; loss of material, cracking, and hardening of elastomeric or polymeric vibration isolation elements that could reduce the vibration isolation function; and cracks.
38 Structures Monitoring XI.S6 Continue the existing PBN Structures Monitoring AMP, including enhancement to:
a)
Revise inspection procedures to include guidance and acceptance criteria on inspections of stainless steel and aluminum components for pitting and crevice corrosion, and evidence of cracking due to SCC.
Perform an evaluation if stainless steel or aluminum surfaces exhibit evidence of SCC, pitting, or crevice corrosion.
b)
Revise inspection procedure scope to include polystyrene foam that is mounted to the underside of No later than 6 months prior to the SPEO, i.e.:
PBN1: 04/05/30 PBN2: 09/08/32 Perform the first inspection for tightness (torque check) of all anchors within the scope of license renewal that are embedded in epoxy resin-based grout no SLRA, ML20329A292 RAI Responses Set 1, 7/8/21, ML21189A173 SLRA Supplement 1, ML21111A155 RAI Responses Set 2, ML21223A308 Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source manhole covers as an elastomer material.
c)
Revise implementing procedures to include preventive actions to ensure bolting integrity for replacement and maintenance activities by specifying proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high strength bolting. Also, ensure proper selection and storage of high strength bolting in accordance with Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts. Additionally, molybdenum disulfide and other lubricants containing sulfur will not be used.
d)
Revise inspection procedures to additionally inspect for the following items:
Increase in porosity and permeability, loss of strength, and reduction in anchor capacity due to local concrete and grout (including epoxy resin-based grout) degradation in concrete and grout (including epoxy resin-based grout) structures.
Loss of material, blistering, and loss of strength for elastomers/polymers (including polystyrene inserts for manhole covers)
Pitting and crevice corrosion, and evidence of cracking due to SCC for stainless steel and aluminum components Confirmation of the absence of water in-leakage through concrete.
Localized distortion of the biological shield wall liner as a leading indicator of radiation induced volumetric expansion of the underlying concrete.
Loss of form of the earthen berm surrounding the fuel oil storage tank.
e)
Revise inspection procedures to include guidance on MEB inspection for loss of material (external bus duct enclosure surfaces and structural supports) and elastomer degradation (exterior housing gaskets, boots, and sealants).
later than the last refueling outage prior to the SPEO.
RAI Responses Set 10, ML21308A282 Third Annual Update, (ML23347A094)
Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source f)
Clarify that if ground water leakage is identified then engineering evaluation, more frequent inspections, or destructive testing of affected concrete (to validate properties and determine pH) are required.
When leakage volumes allow, assessments may include analysis of the leakage pH, along with mineral, chloride, sulfate, and iron content in the water.
g)
Update the governing AMP procedure and other applicable procedures to specify inspection of structural support applications employing epoxy (adhesive) anchors and epoxy resin-based grout for degradation that could cause a loss of anchor capacity.
h)
Revise inspection procedure to specify that the responsible engineer (RE) shall be a registered professional engineer with knowledge in the design, evaluation, and in-service inspection of concrete structures and performance requirements of nuclear safety-related structures; or a degreed civil or structural engineer with at least ten years' experience in the design, construction, and inspection of concrete structures, with knowledge of the performance requirements of nuclear safety-related structures and potential degradation processes.
i)
Update the governing procedure to specify that, for non-ASME high-strength bolting in scope for SLR and greater than one inch nominal diameter, volumetric examination capable of detecting cracking will be performed in addition to the VT-3 examination. Within 10 years prior to entering the SPEO, and in each 10-year period during the SPEO, a representative sample of bolts will be inspected. The sample will be 20% of the population (for a material / environment combination) up to a maximum of 25 bolts.
j)
Revise inspection procedure to specify that accessible areas subject to similar conditions (material, environment, etc.) may be inspected in lieu of inaccessible areas, and include guidance for evaluating the acceptability of inaccessible areas Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to the inaccessible areas.
k)
Ensure quantitative baselines have been established for all structures within the scope of SLR prior to entering the SPEO.
l)
Revise inspection procedure to include the following acceptance criteria:
For Elastomers/polymers (including polystyrene inserts for manhole covers): No loss of material, no blistering, and no indications of loss of strength such as unacceptable surface cracking, crazing, scuffing, dimensional change (e.g., ballooning and necking), shrinkage, discoloration, or hardening.
For Bolting and Fasteners: Loose bolts and nuts are not acceptable unless accepted by engineering evaluation.
For Structural Sealants: Observed loss of material, cracking, and hardening will not result in loss of sealing For earthen berm: No evidence of:
o Settlement - unusual localized or overall settlement, depressions, sinkholes, o
Slope instability - variance from originally constructed slopes, unusual changes from original crest alignment and elevation, evidence of movement o
Erosion - gullies or notches in slope m)
Revise the implementing procedure to include periodic inspections for tightness (e.g., torque checks, as applicable) of all anchors within the scope of license renewal that are embedded in epoxy resin based grout during normally scheduled walkdowns to ensure that proper installation is maintained and verify that preload has not been lost due to creep. To ensure proper installation of the anchors embedded in epoxy resin-based grout has been maintained, the first inspection for tightness will be performed no later than the last RFO prior to the SPEO.
Item No.
Program/Topic NUREG-2192 Section Commitment Implementation Schedule Source n)
Revise implementing documents to prohibit the use of epoxy resin based grout in safety-related applications in locations where normal temperatures exceed 120°F, or in posted high radiation areas as defined in 10 CFR Part 20.