March 15,201 3 NRC 201 3-0029 10 CFR 54

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

Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27

Reactor Vessel lnternals Inspection Plan Response to Request for Additional lnformation

References: (1) NextEra Energy Point Beach, LLC letter to NRC, dated December 19,201 1, License Renewal Commitment, Reactor Vessel lnternals Program Submittal (MLI 13540301)

(2) NRC electronic mail to NextEra Energy Point Beach, LLC, dated June 7, 2012, Point Beach Units 1 and 2 - Draft RAI on the Reactor Vessel lnternals lnspection Plan (TAC ME8235 and ME8236) (ML12159A113)

(3) NRC electronic mail to NextEra Energy Point Beach, LLC, dated July 10, 2012, Point Beach Nuclear Plant Units 1 and 2 - Draft Request for Additional lnformation re: Reactor Vessel lnternals lnspection Plan (TAC Nos. ME8235 and ME8236) (MLI 21 98A050)

(4) NextEra Energy Point Beach, LLC letter to NRC, dated August 16, 2012, Reactor Vessel lnternals lnspection Plan, Response to Request for Additional lnformation (MLI 2229A580)

(5) NRC electronic mail to NextEra Energy Point Beach, LLC, dated January 31, 2013, Point Beach Nuclear Plant, Units 1 and 2 - Draft Request for Additional lnformation (Second Round) re: Reactor Vessel lnternals lnspection Plan Review (TAC Nos. ME8235 and ME8236) (MLI 3036A300)

NextEra Energy Point Beach, LLC (NextEra) submitted the Point Beach Nuclear Plant (PBNP) program NP 7.7.30, Reactor Vessel lnternals Program, via Reference (1). The PBNP Reactor Vessel lnternals Program is based on Electric Power Research Institute (EPRI) Materials Reliability Program (MRP) Technical Report MRP-227, Pressurized Water Reactor (PWR) lnternals lnspection and Evaluation Guidelines, Revision 0.

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

Document Control Desk Page 2

Via References (2) and (3), the NRC determined additional information was required to enable the staff's continued review of the PBNP Reactor Vessel lnternals Program. NextEra responded to the request via Reference (4).

In Reference (5), the NRC requested a second round of additional information in order to enable the staff's continued review of the PBNP Reactor Vessel lnternals Program. Enclosure 1 contains the NextEra response to the NRC staff's request for additional information.

Summary of Regulatory Commitments:

This letter contains the following new commitments and no changes to existing commitments.

NextEra Energy Point Beach, LLC will contract with Westinghouse to determine which components are not bounded by the assumptions on stress, temperature, and fluence contained in MRP-191, MRP-232, and MRP-227-A. Westinghouse will complete the plant-specific evaluation to demonstrate that the MRP-227 recommended inspections will ensure functionality of these components until the next scheduled inspection. This information is expected to be available by January 31, 2014. This information will be provided to the NRC within 45 days of receipt from Westinghouse.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 15,201 3.

Very truly yours,

NextEra Energy Point Beach, LLC

Site Vice President

Enclosure

cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC

ENCLOSURE I

NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

REACTOR VESSEL INTERNALS INSPECTION PLAN RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

The NRC staff determined that additional information was required (Reference 1) to enable the continued review of the Point Beach Nuclear Plant (PBNP) Reactor Vessel lnternals (RVI) Program (Reference 2). The following information is provided by NextEra Energy Point Beach, LLC (NextEra) in response to the NRC staff's request.

RAI-I a

In response to RAI-I, ltem 4, the licensee stated:

"The PBNP RVI components are bounded by the typical Westinghouse PWR internals components outlined in MRP-227-A and the applicable referenced documents, including MRP-191 and MRP-232. The PBNP reactor vessel internals inspection program was written to comply with MRP-227-A. No changes in the inspection requirements are being proposed at this time in that the PBNP inspection program complies with MRP-227-A as indicated above."

The licensee did not mention that an exfended power uprate (EPU) for each unit was approved by the NRC on May 5, 201 1. The MRP has stated that the inspection recommendations are applicable to all U. S, PWR [pressurized water reactor] operating plants as of May 2007. In discussions with the MRP, the MRP indicated that EPUs after 2007 were not considered during the development of the MRP-227 recommendations.

The NRC staff reviewed the licensee's 2009 submittal for the EPU (ADAMS Accession No. ML091250566) and noted several instances for which the stress, fatigue usage, and neutron fluence values provided in the EPU evaluation appear to exceed the screening values of MRP-191 and, therefore, may not be bounded by the assumptions made in development of MRP-227-A. The following examples are noted:

I. Table 2.2.3-3 of the 2009 EPU submittal lists the stresses and fatigue usage factors (CUF) of different core support structures. For the upper core plate alignment pins, the document includes values of 51.48 ksi for stress and 0.30 for the CUF before the EPU, and 38,507 ksi for stress and 0.583 for the CUF after the EPU with an ASME Code-allowable stress intensity of 34.44 ksi,

The licensee's August 16, 2012, response to RAI-I, ltem 2, lists that component as having an effective stress < 30 ksi, matching the stress for that component in MRP-191.

2. Section 2.1.4.2.2 of the 2009 EPU submittal lists the maximum fast neutron fluence (E > 1.0 MeV) for 54 EFPY as 8.83E+22 n/cm2 for Unit I and 8.77E+22 n/cm2 for Unit 2, whereas MRP-191 states that the maximum fluence values for any internal component is 5E+22 n/cm2.

Reuuested Information

The NRC staff requests the licensee review its current licensing basis (CLB), including the 2009 EPU submittal, and list all components that are not bounded by the assumptions on stress, temperature, and fluence contained in MRP-191, MRP-232, and MRP-227-A. Evaluate the need for changes to the

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inspection requirements and/or inspection frequency for any components that are not bounded by the screening values of fluence, temperature, and stress. Describe the process used to perform these evaluations. Provide a technical justification for either changing or not changing the inspection requirements and/or inspection frequency.

NextEra Response

NextEra will contract with Westinghouse to supply the requested information for components that are not bounded by the assumptions on stress, temperature, and fluence contained in MRP-191, MRP-232, and MRP-227-A.

In the December 19, 201 1, submittal, there is no discussion of Action ltem 7 from MRP-227-A. In Section 3.3.7 of the SE for MRP-227, the NRC staff stated that the licensee shall develop a plant-specific analysis to demonstrate that components manufactured from CASS materials will maintain their functions during the period of extended operation. This requirement applies to all susceptible components for which the licensee has determined aging management is required, which includes components designated as expansion and existing as well as the primary category.

Reauested Information

The NRC staff requests that the licensee provide a list of all reactor vessel internal components manufactured from CASS materials for Point Beach, Units I and 2, along with the plant-specific analysis required by Action ltem 7. Provide plant-specific aging management requirements for any components that are not already covered by the "Primary'; "Expansion'; or "Existing Programs'; categories under MRP-227-A.

NextEra Response:

The following five PBNP RVI components within the scope of license renewal are constructed of CASS:

1) Flow Mixers (Upper Core Plate);

2) Upper Support Column Bases;

3) Bottom Mounted Instrumentation (BMI) Column Cruciforms;

4) Secondary Core Support (SCS) Guide Posts (Unit 2); and

5) Secondary Core Support (SCS) Housings (Unit 2).

The first three of these components screened in for thermal embrittlement (TE) and irradiation embrittlement (IE) during the initial screening process for MRP-227-A, as documented in Table 5-1 of MRP- 191. This screening was based only on the temperature (500°F) and fluence (6.7 x lo2' n/cm2, EN.0 MeV) thresholds for TE and IE, respectively, without consideration of the components' delta ferrite contents. The last two of these components did not screen in for any of the failure mechanisms since MRP-191 considered them to be constructed only of wrought 304 SS. Given their CASS construction, PBNP also considers them susceptible to TE and IE.

Two of these components, Flow Mixers (Upper Core Plate) and Upper Support Column Bases, were screened as Category A - No Adverse Effects in Table 7-2 of MRP-191. BMI Column Cruciforms were placed in the No Additional Measures Group by the FMECA, categorization and rankings described in MRP-I 91 and MRP-232. The last two components, SCS Guide Posts and SCS Housings, were not considered to be made from CASS during screening in MRP-191. As part of the effort to respond to RAI-I a, Westinghouse will complete the plant-specific analysis or evaluation to demonstrate that the MRP-227 recommended inspections will ensure functionality of these components until the next scheduled inspection.

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References

(1) NRC electronic mail to NextEra Energy Point Beach, LLC dated January 31, 2013, Point Beach Nuclear Plant, Units 1 and 2 - Draft Request for Additional Information (Second Round) re: Reactor Vessel lnternals Inspection Plan Review (TAC ME8235 and ME8236)

(2) NextEra Energy Point Beach, LLC letter to NRC, dated December 19, 201 1, License Renewal Commitment, Reactor Vessel lnternals Program Submittal (MLI 13540301)

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