View source for L-2024-093, Steam Generator Divider Plate Assemblies Bounding Analysis Evaluation for Aging Management Commitment 14 Revision

{{Adams
| number = ML24163A007
| issue date = 06/10/2024
| title = Steam Generator Divider Plate Assemblies Bounding Analysis Evaluation for Aging Management Commitment 14 Revision
| author name = Rasmus P
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person = 
| case reference number = L-2024-093
| package number = ML24163A006
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 1
}}

=Text=
{{#Wiki_filter:NEXTera                                                   Enclosure       1 to   this     Letter   Contains       Proprietary       Information Withhold        Enclosure       1 from      Public    Disclosure         in    Accordance       with     10  CFR   2.390 ENERGY             ~ ~

BEACH June     10,   2024 L-2024   -093

U.       S  . Nuclear    Regulatory    Commission ATTN    :            Document    Control    Desk Washington,         DC    20555-0001

RE:                                 Point   Beach    Nuclear    Plant,    Units   1 and   2 Docket    Nos. 50-266    and    50-301 Renewed    Facility   Operating      Licenses    DPR-24   and    DPR-27

Point  Beach    Unit   1 Steam    Generator      Divider   Plate Assemblies        Bounding   Analys   is  Evaluation     for Aging    Management     Commitment        14    Revision

References    :
: 1.                          Safety    Evaluation     Report,     Revision     1, "Related     to   the   Subsequent       License    Renewal   of Po  int Beach    Nuclear    Plant,    Units    1 and  2  ,"     May  2022   (ADAMS    Accession         No  . ML22140A127)
: 2.                              Westinghouse      LTR-CEC0         046   ,  Revision   2,     "Subsequent       License    Renewal    Bounding   Analysis Evaluation   for  the    Point   Beach    Unit   1 Steam    Generator     Divider    Plate  Assemblies   "
: 3.                          Electric   Power  and     Research     Institute    (EPRI)     Report  3002002850      , " Steam  Generator Management     Program   :  Investigation    of Crack   Initiation   and    Propagation       in     the   Steam   Generator Channel    Head  Assembly,"      October 2014

NextEra    Energy    Po   int   Beach,    LLC   (NextEra)     hereby   submits   this    notification     of a regulatory    commitment change     for   Point    Beach    Nuclear   Plant  (PBNP),     Units    1 and   2 .           Reference      1 documented    that   the   industry analyses     in      EPRI    Report   3002002850     (Reference      3)   are   assumed     to     not   be     bounding   for    PBNP,    Unit    1 steam   generators     (SGs)  .                    As  a  result,   Commitment     #14   of  Reference      1 included    a one-time     inspection     of the     PBNP,   Unit   1 SG    divider plate                                                                                                                   assemblies      using    qualified   techn   iques   capable    of detecting      primary water    stress   corrosion    cracking.       In     Reference    2 , Westinghouse       determined     that     EPRI   Report   3002002850 (Reference     3)     is    bounding   for    PBNP  ,  Unit  1  SG   divider     plate assemblies,       thereby     prompting      NextEra    to revise   Commitment    #14    to    no   longer   require   the   one-time     inspection    of the    SG    divider   plate   assemblies       .

Enclosure     1 contains     information    that  Westinghouse         Electric   Company        LLC   (Westinghouse)      considers       to be   proprietary      in      nature  . The    request   is   supported        by    an    affidavit    signed      by   Westinghouse,       the  owner    of the    information    . Pursuant  to     10  CFR  2 .390(a)(4)    ,  NextEra   requests    the    proprietary     information      be  withheld from    public disclosure     . Enclosure   2  provides    a  non-proprietary      version    of the   evaluation     provided      in Enclosure     1. Enclosure    3 provides    the Westinghouse        affidavit   supporting     the    proprietary  withholding request. The   affidavit   sets  forth    the   basis  on    which    the   information       may    be  withheld     from    public   disclosure by    the    Nuclear    Regulatory     Commission     ("Commission    ") and   addresses      with    specificity    the  considerat      ions listed    in     paragraph    (b)(4)  of Section   2 .390  of the   Commission's        regulat   ions  . Accordingly,       NextEra    requests that  the   information    which     is  proprietary     to    Westinghouse         be  withheld      from    public  disclosure       in     accordance with      10  CFR   Section   2 .390   of the   Commission    ' s  regulations. Correspondence        with    respect   to    the   copyright or  proprietary     aspects    of the   items   listed          above   or the    support  ing    Westinghouse        affidavit   should     reference CAW-24-026      and    be   addressed     to   Zachary      Harper,    Senior   Manager    , Licensing,    Westinghouse        Electric Company,       1000 Westinghouse        Drive,   Suite    165 , Cranberry    Township     ,  Pennsylvan    ia,        16066.

Ne x tEra    Energy      Point    Beach     , LLC

661 O Nuclear       Road   , Two     Rivers, 1w1     54241 Point    Beach    Nuclear    Plant                                                                                                      L- 2024-093 Docket    Nos  . 50-266;      50-301                                                                                                    Page  2 of 2

Should you  have any questions  regarding this submission,                                                                     please contact Mr. Kenneth  Mack  , Fleet Licensing Senior    Manager,    at  561-904-3635    .

Sincerely,

Paul   Rasmus General    Manager,      Regulatory   Affairs

==Enclosures:==
: 1.                          L TR-CEC0-21-046-P,                  Revision  2 , "Subsequent       License   Renewal    Bounding   Analysis      Evaluation   for the    Point    Beach    Unit  1 Steam   Generator      Divider    Plate  Assemblies"

2  .                        LTR-CEC0-21-046-NP                ,   Revision      2  ,  "Subsequent          License      Renewal       Bounding      Analysis         Evaluation for  the    Point   Beach    Unit  1 Steam   Generator       Divider   Plate  Assemblies"
: 3.                            AFFIDAVIT      CAW-24-026

cc  :                                                     USNRC     Regional   Administrator,       Region    Ill Project   Manager,      USNRC  , Point   Beach    Nuclear    Plant Resident    Inspector,      USNRC  , Point    Beach    Nuclear   Plant Mr. Mike Verhagan,        Department   of Commerce,       State  of Wisconsin Point    Beach    Nuclear    Plant                                                                                                L-2024-093 Docket    Nos  . 50 -266   ; 50 - 301                                                                                             Enclosure

Enclosure          2

LTR-CEC0-21-046-NP,                   Revision  2 , "Subsequent        License    Renewal     Bounding    Analysis      Evaluation for the                                                             Point   Beach   Unit   1 Steam   Generator     Divider    Plate  Assemblies"

NON  - PROPRIETARY

(9    Pages    Follow)
Westinghouse           Non-Proprietaiy             Class        3

Page     1 of9 LTR-CEC0-21-046               NP-Attachment,      Rev. 2 May 21,                                                                                  2024

Westinghouse                              Electric        Company

LTR-CEC0-21-046                          NP-Attachment Revision                 2

Subsequent         License       Renewal       Bounding        Analysis        Evaluation          for     the   Point    Beach     Unit     1 Steam       Generator        Divider Plate    Assemblies

May    2024

Author:
Michael          A. Roth*
Component             Engineering                 &   Chemistry             Operations

Verifier:
Joshua          R. Phillips*
Component            Engineering                 & Chemistty  Operations

Approved:
Monica          Copete       Montiel*,           Acting        Manager Component            Engineering                  & Chemistty  Operations

                                                &#xa9;   2024    Westinghouse       Electric        Company      LLC -All  Rights      Reserved
* Electro11ically  Approved       Records       are Authenticated              in   the Electro11ic Doc11111e11t ~Management      System

                *** This    record   was   final   approved      on  05/22/2024         14:57:19.     (This   statement     was   added     by the   PRIME  system       upon    its validation)
Westinghouse  Non-Proprietary      Class   3

Page 2 of9 LTR-CEC0-21-046              NP-Attachment,      Rev. 2 May    21, 2024

INTRODUCTION/BACKGROUND

Point    Beach    Unit         I       has    a   subsequent        license   renewal      (SLR)    commitment    for     steam     generators        to perf01m     a       one-time         inspection       of    the         steam      generator         divider       plate         assemblies.         This         document provides        a      bounding       analysis      relative          to        subsequent         license       renewal        for       the      Point      Beach      Unit             l steam            generator            divider         plate             assemblies              and          replaces                that         plant-specific             one-time             inspection commitment     as   allowed by LR-ISG-2016-01       (Reference    2).

LR-ISG-2016-01          (Reference     2),      describes      changes      to     the      aging    management      guidance      for     steam generator components in NUREG-1801   (GALL Report), Revision 2,  and NUREG-1800    (SRP-LR),
Revision       2,      including  guidance    for    managing    cracking    due     to   PWSCC       in    steam    generator    divider plate                  assemblies                   and                tube-to-tubesheet                     welds.                                 Specifically,                   it                revises                  GALL  Repo1t            aging management      program   (AMP)   XI.M19,     "Steam    Generators,"        and     SRP-LR  Sections      3.1.2.2.11     and
: 3. l.3 .2.11,    "Cracking        Due       to       Primary        Water        Stress C01rnsion Cracking."         The       revised        guidance reflects        the    NRC      Staffs             acceptance      of the     technical      conclusions      resulting      from       the    EPRI      Steam Generator           Management           Program             (SGMP)           investigation              into           the           initiation           and           propagation          of cracking  in the steam generator channel                                                                                                                                                                         head components,     as   documented  in   several EPRI reports, principally      including EPRI 3002002850     (Reference   3).

In          parallel             with            the         NRC          Staffs                    finalization           of     LR-ISG-2016-01,               EPRI          prepared             and           issued Information                 Letter                 SGMP-IL-16-02,                 "Changes                     to                 Aging                Management                  Guidance                   for                Steam Generator           Channel          Head         Components,"                (Reference            4).             The          purpose         of      SGMP-IL-16-02                  is              to inform                  the               industry                that              the               NRC                 LR-ISG-2016-01                   accepts                 the               conclusions              of           the                SGMP investigation        into     the    initiation      and    propagation     of cracking       in       the    steam    generator       channel     head components.      SGMP-IL-16-02      states   that     the  EPRI    2014   Report    (Reference     3)   and   LR-ISG-2016-0 l              may           be         used          as          a       basis         for        updating            aging        management           programs         for         Subsequent         License Renewal           for        plants         with       susceptible            materials.        Attachment               I             to           SGMP-IL-16-02             is          a       checklist entitled,    "Guidance      for  Addressing    Aging    Management     Plans  for    Steam  Generator     Channel  Head Components,"     (EPRI Checklist)   that reflects  the bounding    conditions  considered     in the EPRI 2014 Report         (Reference           3)         and      other        related       EPRI        technical          reports,       and       which        licensees        can       use        to document     that  the EPRI  2014 report   analysis  bounds    their plants'        steam generators.

The      EPRI       Checklist       states      that      if Alloy         600       or     Alloy       600      variations         were     used         in      fabricating        a plant's            steam    generator    divider      plate      assemblies     or   weld      materials,       then    the    reviewer       should     use the       checklist          to         verify        that      there        is        an        adequate        technical          basis       for       concluding         that       the      plant          is bounded                          by                         the                       analyses                    performed                              in                     EPRI                       Technical                          Rep01ts                 3002002850,                                   IO 14982 (Reference    5),      and         1020988    (Reference         6)   .               If all      responses         to        the      EPRI     Checklist          are    "Yes"          or other            appropriate            technical        justification                   is           provided,             then           the          plant             is            bounded                by            the           above referenced      EPRI     technical   reports      and    can    appropriately      rely    on      the     aging   management       guidance in LR-ISG-2016-01.

The Point Beach  Unit  1 steam generators   have divider plate  assemblies  fabricated   with  [
1*,c,e materials. Therefore,    the EPRI  Checklist   is used   to show  that  the pertinent  plant-specific     attributes   are   bounded  by   the EPRI  SGMP  analyses.

*** This    record   was   final  approved     on   05/22/2024       14:57  :19.  (This  statement    was   added    by the   PRIME  system     upon   its  validation)
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Page 3 of9 LTR-CEC0-21-046                        NP-Attachment,      Rev  . 2 May  21,  2024

EVALUATION

EPRI    Checklist     Evalu   a tion of the Point    Beach  Unit     1 Divider     Plate  Assemblies:
: 1.                        Divider    plate    thickn  ess                      is   greater     than   or equal     to       1.9 inches?

Respons       e:

Yes    . The  Point   Beach  Unit      1 steam    generators       have   a  divider  plate    thickness      that     is  greater    than   or equal     to         1.9  inches.            The   thiclmess     is    [                  ]     a,c ,c (References        8  and      13) .

2 .                            Channel   head   wall   thiclmess   at the    triple point     location       is   greater      than  or equal      to     5 .20              inches   ?

Respons      e :

Yes.        The     Point      Beach      Unit          1  steam       generators         have       a     channel         head        thickness        at     the       triple      point location         that       is       comparable             to        the      thiclmess        used       in      the      Reference           3    analysis     . The       channel       head thiclmess      varies       from        [
(Reference       9). 1
: 3.                               Tubesheet      is   greater  than   or equal     to    21        inches   thick?

Respons       e:

Yes.         The     Point      Beach     Unit          1  steam        generators        have        a    tubesheet           thiclmess       that        is       greater          than        or equal    to       21             inches  thick.      The    thickness   is      [                                   ]    a,c,c (Reference       10) .
: 4.                              The       steam        generator         that     was        modeled          included          a     stub mimer. The       stub mimer is        a      feature important           to      divider     plate        alignment         during       m anufacturing.           The      stub mimer facilitates         being able         to         adjust        the        divider       plate         position           and        still       make          the       weld       without           creating          excessive distortion       of the    divider      plate   . A     stub rnnner plate     3     inches      tall     is    typical       and   was    used      in    the analysis.      Other  designs      may  or may    not use   a  stub rnnner. Provide   justification          that    the plant's steam   generator    design    would      be   bounded    by  the   analysis     .

Respons     e :

Yes.         The       Point       Beach        Unit            1    steam          generators           utilize          a       stub        runner         design.         The         stub       runner            is
                                                    ]    a, c,e tall   (Reference            16).

1 Note      that     th e   Outside     Diamet   er  of the    Ch a nne l Head       is      [                                   r                ,c,e and     the   In side   Radiu   s  o f    the    Channel     Head       is

J  u,c,e .

                  ... This  record was   final approved     on  05/22/2024       14 :57  :19.  (This statement      was    added        by   the   PRIME   system        upon    its validation)
Westinghouse Non-Proprietary       Class   3

Page   4  of9 LTR-CEC0-21-046             NP-Attachment,       Rev   . 2 May   21,  2024
: 5.                            The         bottom          head            is            a         carbon         steel           casting           SA-216           WCC           or        material          of    similar           chemical composition              and          mechanical            properties.               Material             Specification              SA-508            Grade               3,             Class               1 (formerly      SA-508     Class    3)     forging      is      one   material     that    has      been   evaluated       as      similar      and    the analysis     is    bound by   the properties   of the  casting.

===Response===

Yes.        The    Point      Beach    Unit        1 steam      generators'             channel       head    (bottom      head)      are      fabricated       from
[                                                                ]a,c,e (Reference        11 ).
: 6.                                 The      upper        vessel      wall       is        SA-533        Type      A       Class          1    carbon      steel       or      a    material         having       similar prope1ties. All  Types  and Classes   specified  in  SA-533    are considered  similar   as   the  analysis   is bound  by   the properties  of the  SA-533  Type  A  Class       1 material.

===Response===

The  Point Beach   Unit    1 steam  generators   upper  vessel   walls   are fabricated   from     [
y,c,c low  alloy plate   (Reference       11 )  .
: 7.                            The        tubesheet            is          SA-508        Grade         2       Class            1    (formerly          SA-508        Class        2)        or       a       low        alloy         steel material     having     similar  properties.       SA-508    Grade    2,     Class   2    (formerly     SA-508    Class     2a)     and SA-508    Grade     3,    Class       1 (formerly      SA-508     Class     3)     are   considered    similar       as       the    analysis       is bound   by   the properties  of the  SA-508   Grade  2  Class        l    (formerly  SA-508    Class  2)    material.

===Response===

Yes.            The        Point         Beach        Unit             1      steam          generator          tubesheets             are          [             ]a,c,e forgings   (Reference       11 ).
: 8.                                 The           channel             head             is             clad           with            stainless            steel           weld            material           having            properties              similar               to Type  304  stainless  steel.

===Response===

Yes. All     internal     surfaces    of the   Point    Beach     Unit       1 steam     generator chaimel heads      are     clad   with austenitic        stainless        steel       [                                                     ]"*c,e (Reference              11,     Reference               13,     and Reference        17) .

... This    record   was  final   approved    on   05/22/2024       14  :57:19.    (This  statement    was   added   by the   PRIME   system     upon   its  validation)
Westinghouse      Non-Proprietary           Class   3

Page  5 of9 LTR -CEC0-21          -046 NP -Attachm  ent,  Rev . 2 M ay 21,  2024

9 .                        Both          the      stub       runner         and        the       divider         plate         are       Alloy         600         plate       materials           and         the       welds         are nickel-based             Inconel         ERNiCr-3            or       ENiCrFe-3            (commonly             referred            to             as         FM82         or      FM182, respectively).

===Response===

Yes    . The    Point      Beach     Unit           1 steam       generator         channel       heads        are     partitioned             into       inlet      and     outlet chambers    by a by a stub rnnner and a divider plate [
                                           ]a,c,e (Reference          11       and      16).

Yes. The Point   Beach   Unit     1 steam  generators      stub runner  to  divider plate   welds    and  stub  runner    to Tubesheet               welds                are              [                                                                                         ]     a, c,e material (References              12  and      13).
: 10.        The   design    and   transient     loads  used     in   the report    bound   the   similar    loads    in  the plant    SG   .

Response        :

Yes    . The     design      and    transient       loads       used       in     the    EPRI     rep01t  bound      the    similar        loads      in   the    Point Beach    Unit      1 SGs.

A      comparison          of the     Point       Beach        Unit           1  steam      generators          against        the     parameters            and       transients used     as      the   basis    for   the   EPRI     rep01t (Reference        5)    must     look    at    both   the    operating        conditions      for the         plant           and          those         transients             that          are         relevant              to          the        Point          Beach          Unit             1        SG         design           basis              to determine        if the  EPRI     report    applies    .

Stress   levels   in   the prima1y chamber    of the Point  Beach  Unit     1 SGs result   primarily     due   to   pressure differences            across         the      component           surfaces.          Thermal          considerations            play       a      much         smaller        role         in defining      the  primaty       side   stress     levels    , and                           in    the  case   of the   divider   plate  , induce      a  bending    stress in    the     divider plate                                                                                                                                              due     to      the    approximate            70&deg;F temperature         difference       between        the     SG    inlet    and outlet        temperature           (69.1&deg;F   for        the     EPRI      report        and       [          ]",c,e2    for     Point      Beach       Unit       1)      and       a compressive          stress       in   the   divider plate                                                                                                                                     resulting       from   the     differential         thermal      growth       between      the divider     plate     [                      ]    a,c,e material      and   the  SG  carbon    steel   primary     chamber       ( enveloped       in   the EPRI   analysis    for Models    51      and 44F steam  generators)      . The  thermal    transients    between  plants will differ      due    to   power      levels     and     SG     design,      however,        the    temperature          difference         across       the    divider plate     would     not  differ    significantly         and  would,      therefore,      not be   significant.       Since      the  EPRI    report uses  a higher  temperature     difference      across   the divider  plate,   the Point Beach Unit    1 analysis  would be    enveloped     for   these   conditions.

'              Pe  r Table A . 1-   1 o  f Refer                  e nce      14:  At    Hi g h T"." Reactor  Ves sel   Outlet   temperature          =  [ )'*'*' and  SG   Outlet Temperature          =   [ )'*'*'.

                  *** This    record    was   final   approved     on   05/22/2024        14 :57:19   . (This   statement      was   added     by the   PRIME    system      upon    its validation)
Westinghouse             Non-Proprietary                 Class      3

Page 6 of9 LTR-CEC0-21-046              NP-Attachment       , Rev. 2 May  21,  2024

Differences                  in        design           parameters                  affecting               the         qualification                 of  the         divider             plate           are         due            to          the pressure          differential          across     the   tubesheet.                   The  EPRI     report,      Table     3-12   of Reference            5,   considered a Design,     Upset   and Faulted      pressure       differential       of 1,515 psi,      1,836 psi,  and 2,650   psi,  respectively.
Review       of the pressure         differentials            for    the  Point     Beach     Unit           I Station     SG   transients         show    that   the pressure              differentials              in       the      EPRI         Report           envelope             those          for         the     Point        Beach          Unit             l           plant.          The Design,       Upset      and   Faulted         (Loss      of Secondaiy                  Pressure)         pressure          differentials           for    the  Point    Beach Unit         1 Station      steam    generators           are      [             ]",c   ,e3 , [            ]a,c,e4  and    [              ]",c,  es psi,   respectively              .

The     Point        Beach       Unit           1  SG      transients              are     defined          in    the      Design          Specification,              Reference                     14      and ve1y       similar               to          the         transients                 listed             in         the        Table            4-6        of  EPRI            report          (Reference                    5)        except           Hot Standby        transient        (See     Table            1).           In  Table       4-1     of Reference               14,  several      transient         occunences               were adjusted             based           on          the        plant           operating                histo1y       data          analysis.                              The          lifetime            occurrences                of Plant Loading/Plant                  Unloading                 (5%/Min),                 Unit          Loading/Unit                  Unloading                 and         of  other            corresponding transients          are    adjusted for                                                                                                                                     in  Table           1.

The   Point   Beach    Unit        1 RS Gs  were    replaced       and   operated       on  April    7 of 1984   and   the    license   of the Unit         1 Plant     will    be  expired        on  October            5,   2030      (Section          3.5.1      of Reference            7). Most     recent,     Point Beach         Unit             I       has       filed         the      Subsequent              License          Renewal             from          its      cmTent     60-year          end-of-license period              to        80-year         end-of-subsequent-license                           renewal            period.           Because          of this      renewal,              its      license would        not    be   expired        until       October           5,     2050   (Reference               15). Due       to    these       facts,       the     actual       years      of operation         for     the  RSGs       of Point     Beach        Unit      1 will       be   66.49     years     until       the    end    of its    80-year       end-of-subsequent              license     renewal        period.       Table    4.3.1-1       ofReference                          15   provides         the  results      of the   80-year     transient        cycle   projections            for   Point    Beach     Nuclear        (PBN)       Unit        1. As   it is   stated      in Reference 15,        "Most  nuclear power  plants,        including   PBN. have experienced       a significant      declining     trend    in accumulation      of transients      over     time. As   shown        in      Table      4.3.1-1,      the projected          cycles for        the    80-year       subsequent    period       of extended        operation        (SPEO)       are      less      than       the     original        40-year      design cycles  (Current Licensing   Base  cycles). "For   the remaining          lifetime     of 66.49    years,      the occurrences of all  transients      are  adjusted      by multiplying           ( 66.49/80)          to  the  lifetime     occurrences           for  each   transient of 80-year      projection           (see    Table          1 for    more     details).

In   Table       4.3.1-1       of Reference                 15,  the     Feedwater           Cycling       at  Hot     Standby        for     PBN     Unit         1 has    been defined            as   "NIA"         (Not      applicable      -  there         is      no     basis        for      computing            the     upper         bound)          for      80-year projection             cycle     count.              For   conservatism,                 [   ]a ,c,e design       allowable        cycles       are  used      in  Table          1.

The     total     transient      occurrences             for   40  years     considered          in Table     4-6   of the  EPRI     report       (Reference 5),     including     Normal,       Upset,        and   Faulted       conditions,              is   60,111        cycles.      Similarly,           the    total     transient occurrences              for      the     next  66.49-year                 of operation           for   Point       Beach       Unit          1  Station,            is    projected             to      a

3   At 300  second   of l 0%  Step     Load   Increase=  [                                     ]'*c,c press ure differenti    a  l.

4 At  7 sec ond  of Lo  ss of Load=       [                                  ]'*c,c pre ss ure  differenti   a  l.

5    At      l 00   second   of Loss of Secondaty       Pressure        =   [                    ]'*c,, pressure  differential.

                   *** This   record    was  final   approved      on  05/22/2024         14:57:19.     (This    statement     was    added    by the   PRIME    system      upon    its  validation)
Westinghouse        Non-Proprietary             Class     3

Page   7 of9 LTR-CEC0-21-046              NP-Attachment,      Rev. 2 May  21,  2024

total   of [               ]    a,c,e cycles,     which    is  exhibiting      a significant       declining in                                                                                                                                                          accumulation         of transients (See   Table         l       for   more   details).

To       conclude,         comparison         of the     Point      Beach     Unit           l         steam       generators        against          the   parameters            and transients      used    as    the b asis  for    the EPRI   report   (Reference           5)   confirms     that  the   design    and  transient load      inputs    for    the Point    Beach    Unit          I     SGs   are    bounded       by   the     loads  used       in   the    report.      The   EPRI report         uses        a      larger         temperature            difference           across          the       divider        plate         than       the      Point       Beach       Unit            l analysis. Finally,            the  projected        cycles       for    the    80-year      subsequent       period     of extended        operation        are bounded      by the original   40-year    design    cycles  in the EPRI  Report    (Reference        5). The EPRI   limiting model      and    results   are   applicable         to  Point    Beach    Unit          1.

*** This    record   was   final  approved     on   05/22/2024      14:57:19.    {This   statement    was   added    by the   PRIME   system      upon   its  validation)
Westinghouse        Non-Propri      etary   Class    3

Page   8 of9 LTR-CEC0-21-046             NP-Attachment,        Rev. 2 May  2   1, 2024

Table      1:     Transient        Occurrences EPRI                                                                                                                                                                                                            Po  int  Beach                                                                                                                                                                                                           Point     Beach                                                                                                                                                                                                                    Point    Beach Total     Years   = 40                                                                           Total    Years=60        (Design)                                                                                                                   80 -Y ear  Projection                                                                                                       66.49-Y ear  Projection <3l Lifetime                                    Frequency                                            Lifetime      (  I  )                                          F  reque    ncy                                                      Lifetime <2> Freque      ncy                                           Lifetime Frequency a                       ,e

                                                                                                                                                                                                         ~                                                                                                                                                                                                                                                           -
Norma       l                                                Heat-Up                                                                                                                                                                                   200                                                                                                         5.00 Normal                                                  Cool    Down                                                                                                                                                                       200                                                                                                      5.00 Normal                              Plant    Loading      (5%  / Min)                                                                     18,300                                                                    457    .5  0 Nonna!                           P lant    Unloading (5%                                                                                                                                                           / Min)                                                      18,300                                                                457    .5  0 Norma       l                                Small     Step    Increase                                                                                                     2,000                                                                                     50.00 Normal                                    Small Step                                                                                    Decrease                                                                                              2,000                                                                                50  .00 N01mal                                    La  rge   Step    Decrease                                                                                                        200                                                                                                                 5 .00 Normal                                                Hot   Standby                                                                                                                                                         18,300                                                                457    .5  0 Nonna!                                         Turbine       Roll     Test                                                                                                                                                                      10                                                                                                                 0.25 Upset                                              Loss    of Load                                                                                                                                                                     80                                                                                                              2.00 Upset                                            Loss   of Power                                                                                                                                                        40                                                                                                                           1.00 Upset                                              Loss    of F low                                                                                                                                                                  80                                                                                                              2.00 Upset                                              Reactor        Trip                                                                                                                                                       400                                                                                                       10.00 Fau    lt ed                              Feed    line Break,       SLB                                                                                                                                   1                                                                                                                               0 .03 Tota    l                                                                                                                                                                                                  60,111                                                                                           1,503

                                                                                                                                                                                                          ~

Note:
: l. Ex  tracted    from   Table    2-    1 of Refere   nce     14.
: 2. Extracted     from   Tab  le 4.3    .1    -   1 of Reference        15.
: 3. Adjusted     year s  of opera   ti  on    fo   r Point   Beach   Un   it     I    is    based   on   Section   3.5. I  of Reference      7.

CONCLUSION

As               demonstrated                    above,                the               industry                  analyses                  documented                   in              the               EPRI                Technical                  Reports 3002002850,              1014982,  and         1020988     are     bounding       for     the    Point    Beach     Unit          1 Station       SG    divider plate        assemb  lie s.      Therefore     ,  Next  Era   E nergy    Point    Beach    Unit         1 may     m anage     the    aging     effect    of primary               water              stress              corrosion                  cracking               (PWSCC)                in               tho se            steam               genera  tor             components                     in accordance          with        the       guidance          contained            in       LR-ISG-2016-01                which        follows.          The       primary         water chemistiy                             program is                                                                                                                                                    supplemented          with    a   genera   l  visual      inspection      of the     SG   channel      head.      The purpo    se  of the vis ual    inspection         is   to     ide ntify  rnst   s tains  or other   abnormal     conditions      which     could indicate                the           presence              of        cracking                 (e.g.,              distortion             of       the             divider              plates).               The              general                 vi sua l inspection      is  performed     on  each   SG  at least every                                                                                                       72   effective    full power    months     or every   three  (3) refueling      outages,   whichever       results       in   more   freq  uent    inspections     .

                                         *** This   record    was   final  approved     on   05/22/2024         14 :57: 19 . (This   statement    was   added    by the   PRIME   system     upon   its  validation)
Westinghouse      Non-Proprietary          Class    3

Page   9 of9 LTR-CEC0-21-046              NP-Attachment       , Rev. 2 May   21,  2024

REFERENCES
: 1.                            Not   used.
: 2.                             NRC        LR-ISG-2016-01,                "Changes              to        Aging         Management              Guidance           for        Various           SteamGenerator Components,"       December        2016.
: 3.                              EPRI      3002002850,         "   Steam      Generator      Management          Program     : Investigation         of Crack    Initiation         and Propagation        in   the  Steam    Generator     Channel    Head  Assembly,"         October    2014.
4  .                          EPRI         Information             Letter           SGMP-IL-16-02,              "Changes                 to         Aging        Management                Guidance            forStearn Generator     Channel     Head   Components,"          October    2016.
5  .                          EPRI      l O 14982, "Divider    Plate   Cracking    in  Steam  Generators   Results   of Phase      1 : Analysis   ofPrirnaty Water     Stress    Corrosion      Cracking       and  Mechanical         Fatigue       in    the  Alloy      600    Stub    Runner        to   Divider Plate   Weld  Material,"        June    2007.
: 6.                              EPRI                         I 020988,                     "Stearn                    Generator                    Management                         Program:                    Phase                      2               Divider                      Plate                   Cracking Engineering      Study,"     November        2010.
: 7.                               Westinghouse              Report             WCAP-17905-P,                Revision                  3,          "Model             44F         Replacement                Steam           Generator Stress          Report            Addendum                 3          for        Point           Beach           Unit               1      Channel            Head           Bowl            Drain           Modification,"
December      2020.
: 8.                               Westinghouse      Drawing       No. 650B029,    Revision       5,  "Vertical       Steam   Generator     Partition     Plate."
: 9.                                Westinghouse           Drawing            No.           6524D18,           Revision               2,        "Steam            Generator            (44          Series)          Channel            Head Casting."
10  . Westinghouse       Drawing    No   . l 184J73, Revision           1, "Tube     Plate  Cladding   & Mach-               Steam   Generator Model   44-F."
: 11.        Westinghouse        Design       Specification           955381,      Revision          5,     "NextEra        Point    Beach        Unit       1 Model      44F Replacement       Generators,"          September     2021.
: 12.         Westinghouse         Drawing        No   .      1184J66,     Revision          2    "Tube         Bundle        and      Chamber         Assembly         -                      Steam Generator    Model    44-F    ."
: 13.         Westinghouse      Process      Specification         82121XF,     Revision           13, "Welding      Nuclear     Power     Components to       ASME       Section        III     Manual         (SMAW)      Method         With      Inconel      Electrode           and      Semi-Automatic             Gas Metal   Arc   (GMA W)   Method     With  Inconel     Type   Filler   Metal,"      October        1980.
14  .      CN-CPS-08-4,          Revision                 1,      "Summaty            of NSSS       Design         Transients         for      Point      Beach       Units            1  and       2 EPU  Program,"        October     2014   .

15   . ML29329A247,       NRC   2020-0032     Enclosure       3 "Point     Beach Nuclear    Plant  Units         I   and  2 Subsequent License    Renewal      Application         (Public   Version),"        Attachment             1, November         2020.
: 16.        Westinghouse           Drawing         No.       PL2499B40000,                      Revision                 12,    "Steam         Generator          Model           51          Partition Stub,"    June        1979.
: 17.       Westinghouse       Drawing    No.          l 184J63, Revision       4,  "Channel      Head    Clad    and  Machine,"        July         1983 .

*** This   record    was   final   approved      on   05/22/2024         14 :57  :19 . (This   statement     was   added     by the   PRIME    system      upon     its validation)
Point    Beach    Nuclear    Plant                                                                               L-2024  -093 Docket    Nos  . 50-266    ; 50-301                                                                               Enclosure

Enclosure         3

AFFIDAVIT       CAW-24-026

(3    Pages    Follow)
Westinghouse                Non-Proprieta1y               Class      3 AFFIDAVIT CA W-24-026 Page          1 of3

Commonwealth         of Pennsylvania:
County     of Butler:

( 1)                                                                                           I, Zachaty Harper,     Senior   Manager,        Licensing,      have  been   specifically       delegated       and authorized         to    apply   for   withholding        and  execute     this  Affidavit    on behalf   of Westinghouse Electric     Company    LLC   (Westinghouse).

(2)                                                                                  I  am   requesting     the  proprietary       portions     ofLTR-CEC0-21-046                           P-Attachment,          Revision      2   be withheld       from public    disclosure      under       10 CFR  2.390.

(3)                                                                                  I have   personal    knowledge      of the  criteria     and  procedures       utilized    by  Westinghouse            in designating       info1mation as   a   trade    secret,   privileged,      or as  confidential      commercial          or financial      information.

(4)                                                                            Pursuant       to       10  CFR  2.390,    the   following        is   furnished      for   consideration        by  the    Commission in determining      whether     the  infmmation          sought     to   be  withheld     from   public    disclosure         should  be withheld      .
(i)                                                                                       The   info1mation sought     to   be withheld      from   public    disclosure        is  owned      and   has   been held   in confidence      by  Westinghouse        and  is  not customaiily                          disclosed        to    the  public.
(ii)                                                                            The   information      sought       to   be withheld      is being    transmitted       to   the   Commission         in confidence      and,     to  Westinghouse's               knowledge,          is  not  available     in public       sources.
(iii)                                                               Westinghouse       notes    that    a showing    of substantial      harm   is no  longer     an   applicable criterion    for   analyzing      whether     a  document     should   be  withheld      from    public disclosure.               Neve1iheless,    public     disclosure    of this  proprietary       infonnation                 is   likely     to cause   substantial      hann      to    the competitive     position     of Westinghouse         because       it would enhance    the  ability    of competitors         to  provide     similar    technical     evaluation justifications          and    licensing    defense     services      for  commercial     power    reactors       without commensurate        expenses.                Also,    public    disclosure      of the    information       would     enable others   to   use   the   information        to  meet  NRC   requirements       for    licensing     documentation without    purchasing      the   right    to   use   the  infonnation.

    *** This    record     was  final   approved     on  05/23/2024         08  :50:25.     (This   statement     was   added    by the   PRIME    system      upon   its  validation)
Westinghouse         Non-Proprietary               Class    3 AFFIDAVIT        CA W-24-026 Page    2  of3

(5)                                                                             Westinghouse       has   policies      in place      to   identify   proprietary         information.              Under     that   system, inf01mation is   held    in  confidence      if it falls    in one  or more   of several      types,   the release                                                        of

which    might  result    in  the     loss  of an   existing    or potential      competitive       advantage,        as   follows:
( a)                                                                              The   information       reveals    the distinguishing          aspects   of a process                                   ( or component,       structure,      tool,   method,      etc.)    where   prevention      of its use   by  any of Westinghouse's         competitors      without      license    from   Westinghouse constitutes      a   competitive     economic      advantage     over   other  companies.
(b)                                                            It consists    of suppo11ing data,   including     test   data,  relative      to    a process                                  ( or

component,       strncture,      tool,   method,      etc  .),   the  application     of which     data secures    a competitive       economic      advantage       ( e.g  ., by  optimization       or improved marketability).
(c)                                                                                       Its  use    by  a  competitor     would    reduce      his   expenditure      ofresources                or improve his  competitive       position    in   the  design,      manufacture,        shipment,       installation, assurance     of quality,     or licensing      a similar    product.
(d)                                                            It reveals     cost   or price    information,      production      capacities,        budget     levels,   or commercial       strategies    of Westinghouse,          its  customers     or suppliers.
(e)                                                                                      It reveals    aspects     of past  , present,     or future    Westinghouse       or customer      funded development      plans     and programs       of potential commercial                                                                                                                                                          value     to Westinghouse         .
(f)                                                                                  It contains    patentable       ideas,   for  which    patent   protection      may    be  desirable.

(6)                                                                       The   attached    documents       are   bracketed     and  marked      to   indicate    the  bases     for  withholding.                   The justification          for   withholding         is   indicated     in both  versions      by   means   oflower-case                   letters    (a) through      (f)   located    as  a  superscript       immediately       following       the  brackets     enclosing       each    item  of info1mation being    identified       as  proprietary       or in the  margin      opposite     such   information       .           These lower-case       letters   refer    to    the   types   of inf01mation Westinghouse        customarily        holds     in confidence       identified     in  Sections       (S)(a)  through     (f)  of this  Affidavit.

     *** This   record   was final                                                        approved      on  05/23/2024      08:50:25   . (This   statement     was  added   by the  PRIME    system     upon   its  validation)
Westinghouse      Non-Proprietary         Class   3 AFFIDAVIT CA W-24-026 Page   3 of3

I  declare       that     the  averments       of fact   set  forth       in  this  Affidavit         are   true    and   correct       to    the   best    of my knowledge,             information,         and  belief.                  I  declare      under    penalty      of perjury       that   the   foregoing             is hue and

correct.

Executed         on:    5/23/2024

Zachaty       Harper

   *** This   record    was  final   approved   on  05/23/2024      08:50:25.     (This   statement    was  added   by the    PRIME   system     upon   its validation)}}