NRC 2017-0052, Supplement to LAR 287, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Plants

Supplement to LAR 287, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Plants

ML17299A012
Person / Time
Site:	Point Beach
Issue date:	10/26/2017
From:	Coffey R Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MG0196, CAC MG0197, NRC 2017-0052
Download: ML17299A012 (5)

Text

NRC 2017-0052 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Supplement toLAR 287, Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures. Systems. and Components for Nuclear Power Plants"

References:

1. NextEra Energy Point Beach, LLC letter NRC 2017-0043, "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,"

August 31, 2017 (ML17243A201)"

2. NRC e-mail "LIC-1 09 Acceptance Review Supplement Request- Point Beach Units 1 and 2 LAR 287 -Application to adopt 10 CFR 50.69, "Risk Informed Categorization and Treatment of Structures (SSCs) for Nuclear Power Plants,"- MG0196/MG0197,"

October 4, 2017 In Reference 1, NextEra Energy Point Beach, LLC submitted a license amendment request for the Point Beach Nuclear Plant, Units 1 and 2. The proposed amendment would revise the licensing basis by adding a license condition to allow for implementation of the provisions of Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors."

In Reference 2, the NRC staff requested supplemental information to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request.

The enclosure to this letter provides the requested information.

This supplement does not alter the conclusions in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.

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

Document Control Desk Page 2 This letter contains no new or revised regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Eric Schultz, Licensing Manager, at 920-755-7854.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 26, 2017 Sincerely, NextEra Energy Point Beach, LLC Robert Coffey Site Vice President NextEra Energy Point Beach, LLC Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Public Service Commission of Wisconsin

NRC 2017-0052 Enclosure Page 1 of 3 Response to Supplemental Information Request

a. Clarify whether a high winds hazard screening evaluation or the high winds PRA will be used during the safety significance categorization process consistent with Section 5.4 of NEI 00-04, as endorsed by RG 1.201, Revision 1.

Response

NextEra Energy Point Beach, LLC (NextEra) will use the high winds hazard screening evaluation for the safety significance categorization process consistent with section 5.4 of NEI 00-04 as endorsed by RG 1.201, Revision 1.

b. If the high winds PRA will be used during the safety significance categorization process, describe the peer review process applied to the high winds PRA, indicate whether it was a full-scope peer review and identify the guidance used to perform this peer review (e.g.,

ASME/ANS RA-Sa 2009, RG 1.200, Revision 2). Include any necessary gap or self-assessments if current guidance/standards were not used in the peer review. In addition, provide all F&Os characterized as findings from the peer review of the high winds PRA. For each F&O, include details of its disposition or why not meeting the corresponding Capability Category II requirements has no impact on the application.

Response

NextEra will not use a high winds PRA for the safety significance categorization process.

c. If a high winds hazard screening evaluation will be used during the safety significance categorization process, describe this screening evaluation. Also, discuss how this evaluation is consistent with the screening criteria in Section 6-2 of ASME/ANS RA-Sa 2009, as qualified by RG 1.200, Revision 2, and reflects the current as-built, as-operated plant.

Response

The high winds screening hazard evaluation was initially screened from the IPEEE based on CDF < 1E-06. This conclusion is consistent with the screening criteria in section 6-2 of the ASME/ANS RA-Sa 2009. There have been a significant number of modifications completed since the IPEEE that will lower the high winds risk. Therefore, continuing to screen the high winds hazard is judged to be conservative and bounds the as-built, as-operated plant risk.

NRC 2017-0052 Enclosure Page 2 of 3 This supplement modifies three sections (Section 3.2.4, Attachment 2, and Attachment 4) of the license amendment request (Reference 1 in the cover letter) as shown below. Deleted information is indicated with a double strikeout and new information is shown in italics.

• 3.2.4 Other External Hazards The PBNP, Units 1 and 2 categorization process will use screening results from the Individual Plant Evaluation-External Events (IPEEE) in response to GL 88-20 (Reference 6) for evaluation of safety significance. TAe Hi~A 'A'iR1s AazaF1 was lFi~iRally semeRe1 fFlFR al@l@lieal3ility iR tAe IPEEE. A Hi~ A 'JViR1s PRA was St;~l3sejt;~eRtly 1evelll@e1 aR1 is 13eiR~ mvise1 tl FRlm malistieally Fefleet tAe as l3t;~ilt, as li@8Fate1 l@laRt.

All ~external hazards were screened from applicability to PBNP, Units 1 and 2 per a plant-specific evaluation in accordance with GL 88-20 and updated to use the criteria in ASME PRA Standard RA-Sa-2009. Attachment 4 provides a summary of the other external hazards screening results. Attachment 5 provides a summary of the progressive screening approach for external hazards.

• Attachment 2: Description of PRA Models Used in Categorization Unit Model Baseline CDF Baseline LERF Comments 1 Internal Events 5.1E-06 3.7E-08 Will be used for 1 Internal Flood 3E-07 2E-08 categorization 3 1 Internal Fire 5.9E-05 9.0E-07 1 Seismic 6.24E-06 1.21 E-06 Not used for categorization Other External 1 <1E-06 <1E-07 Hazards 7.3E 054 1 Total 2.3E-06 2 7.2£-05 1

NRC 2017-0052 Enclosure Page 3 of 3 Unit Model Baseline CDF Baseline LERF Comments 2 Internal Events 5.1 E-06 3.6E-08 Will be used for 2 Internal Flood 3E-07 2E-08 categorization 3

~ '

2 Internal Fire 6.9E-05 1.1 E-06 2 Seismic 6.24E-06 1.21 E-06 Not used for categorization Other External 2 <1E-06 <1 E-07 Hazards S.3E 954 2 Total 2.5E-06 2 8.2£-051 Notes

1. Total CDF meets the RG 1.174 acceptance guideline of <1 E-4 per year.

2. Total LERF meets the RG 1.174 acceptance guideline of <1 E-5 per year.

3. Models to be used for categorization were previously submitted in Reference 15.

• Attachment 4: External Hazards Screening The High Winds hazard was eri~iAally screened from applicability in the IPEEE.=A This conclusion is consistent with the screening criteria in Section 6-2 of the ASMEIANS RA-Sa 2009.

Significant plant modifications Extreme Wind or Y (see installed since the IPEEE will PS4 Tornado comments) lower the High Winds PRA was SY9SeeteteAtly 1evele!§le1 aA1 is eeiA~ revise! CDF; therefore, screening this hazard from applicability based on the IPEEE is judged to mere malistieally mfleet tAe as eetilt, as e!§lerate1

~ be conservative.