GO2-17-204, Energy Northwest Submittal of the Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 Crf 50.54(F) Regarding Recommendation 2.1 of the Near-Term Task Force Review ...

Energy Northwest Submittal of the Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 Crf 50.54(F) Regarding Recommendation 2.1 of the Near-Term Task Force Review ...

ML18002A424
Person / Time
Site:	Columbia
Issue date:	12/28/2017
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF5274, GO2-17-204
Download: ML18002A424 (7)

Text

Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509-377-8555 l F. 509-377-4150 aljavorik@energy-northwest.com December 28, 2017 GO2-17-204 10 CFR 50.54(f)

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

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ENERGY NORTHWEST'S SUBMITTAL OF THE SPENT FUEL POOL EVALUATION SUPPLEMENTAL REPORT, RESPONSE TO NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(F)

REGARDING RECOMMENDATION 2.1 OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT References 1. Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS No.

ML12053A340)

2. Letter from W. M. Dean (NRC) to the Power Reactor Licensees on the Enclosed List, "Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 Seismic of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated October 27, 2015 (ADAMS No. ML15194A015)

3. Letter from A. N. Mauer (NEI) to M. X. Franovich (NRC), "Request for Endorsement of Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation (EPRI 3002009564)," dated January 31, 2017 (ADAMS No.

ML17031A171)

4. EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated January 2017

5. Letter from M. X. Franovich (NRC) to A. N. Mauer (NEI) "Endorsement of EPRI Report 3002009564, 'Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation'," dated February 28, 2017 (ADAMS No.

ML17034A408)

GO2-17-204 Page 2 of 3

6. Letter GO2-15-045 from D. A. Swank (Energy Northwest) to the NRC, "Seismic Hazard and Screening Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(F) Regarding Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2015 (ADAMS No.

ML16204A060)

7. Letter from F. Vega (NRC) to M. E. Reddemann (Energy Northwest),

"Columbia Generating Station - Staff Assessment of Information provided under Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima DAI-ICHI Accident (CAC No. MF5274)," dated November 4, 2016 (ADAMS No. ML16285A410)

Dear Sir or Madam,

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information per 10CFR 50.54(f) (Reference 1) to all power reactor licensees. By letter dated October 27, 2015 (Reference 2), the NRC transmitted final seismic information request tables which identified that Columbia Generating Station (Columbia) is to conduct a limited scope Spent Fuel Pool Evaluation. By Reference 3, Nuclear Energy Institute (NEI) submitted an Electric Power Research Institute (EPRI) report entitled, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (EPRI 3002009564)

(Reference 4) for NRC review and endorsement. NRC endorsement was provided by Reference 5.

Reference 4 provides criteria for evaluating the seismic adequacy of a spent fuel pool (SFP) to the reevaluated ground motion response spectrum (GMRS) hazard levels.

Section 4.3 of Reference 4 lists the parameters to be verified to confirm that the results of the report are applicable to Columbia, and that Columbia's SFP is seismically adequate in accordance with the Near Term Task Force (NTTF) seismic evaluation criteria.

The attachment to this letter provides the data for Columbia that confirms applicability of the EPRI 3002009564 criteria and confirms that the SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

No new commitments are identified in this letter.

If you have any questions or require additional information, please contact Ms. L. L.

Williams at (509) 377-8148.

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

G02-17-204 Page 2 of 3 Executed on the A. L. Javorik Vice President, Engineering Attachments As stated cc: NRC RIV Regional Administrator CD Sonoda - BPA/1399 (email)

NRC NRR Project Manager WA Horin - Winston & Strawn NRC Senior Resident lnspector/988C

GO2-17-204 Attachment Energy Northwest Columbia Generating Station Docket No. 50-397 Renewed License Number NPF-21 Site-Specific Spent Fuel Pool Criteria for Columbia Generating Station

GO2-17-204 Attachment Page 1 of 3 The 50.54(f) letter requested that, in conjunction with the response to Near Term Task Force (NTTF) Recommendation 2.1 (Reference 1), a seismic evaluation be made of the spent fuel pool (SFP). More specifically, plants were asked to consider all seismically induced failures that can lead to draining of the SFP. Such an evaluation would be needed for any plant in which the ground motion response spectrum (GMRS) exceeds the safe shutdown earthquake (SSE) in the 1 to 10 Hz frequency range. The staff confirmed through References 2 and 7 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Columbia Generating Station (Columbia). By Reference 5, the NRC staff determined that EPRI 3002009564 (Reference 4) was an acceptable approach for performing SFP evaluations considering the GMRS hazard levels.

The table below lists the criteria from Section 4.3 of EPRI 3002009564 along with data for Columbia that confirms applicability of the EPRI 3002009564 criteria and confirms that the SFP is seismically adequate in accordance with the NTTF 2.1 seismic evaluation criteria.

SFP Criteria from EPRI 3002009564 Site-Specific Data Site Parameters

1. The site-specific GMRS should be The Columbia GMRS peak of 1.45g spectral the same as that submitted to the acceleration is the same as that submitted in in NRC between March 2014 and July Reference 6 and accepted by the NRC in 2015, which the NRC has found Reference 7.

acceptable for responding to the NRC 50.54(f) letter (Reference 7).

Structural Parameters

2. Site-specific calculations, performed Site-specific calculations (Reference 9), performed in accordance with Section 4.1 of in accordance with Section 4.1 of EPRI EPRI 3002009564 should 3002009564, demonstrate that the limiting SFP demonstrate that the limiting SFP HCLPF is 0.28g, which exceeds the GMRS 0.25g.

high confidence of low probability of Therefore, this criterion is met for Columbia.

failure (HCLPF) is greater than the site-specific GMRS in the frequency range of interest (e.g., 10-20 Hz).

3. The SFP structure should be Energy Northwest currently performs structural included in the Civil Inspection inspections of the accessible exterior concrete Program performed in accordance surfaces of the spent fuel pool every four years as with Maintenance Rule. part of the maintenance rule structural inspections required under 10 CFR 50.65. Energy Northwest has committed to continue these inspections as part of the Structures Monitoring Program through the period of extended operation under Columbias renewed license (NUREG-2123, Appendix A, item 50)

GO2-17-204 Attachment Page 2 of 3 SFP Criteria from EPRI 3002009564 Site-Specific Data Non-Structural Parameters

4. To confirm applicability of the piping There are no piping penetrations or connections evaluation in Section 4.2 of EPRI that allow the SFP water to be drained, as 3002009564, piping attached to the documented in Sections 3.8.4.1.1.6 and 9.1.2.3.3 of SFP should have penetrations no the FSAR (Reference 8); therefore, this criterion is more than 6 ft below water surface. met for Columbia.

5. To confirm ductile behavior under The SFP gate is constructed from an aluminum increased seismic demands, SFP alloy as documented on plant drawings. Therefore, gates should be constructed from this criterion is met for Columbia.

either aluminum or stainless steel alloys.

6. Anti-siphoning devices should be Only two 8-inch discharge lines enter the SFP from installed on any piping that could the top and extend below the design water level.

lead to siphoning water from the Each pipe is equipped with a check valve designed SFP. In addition, for any cases to prevent siphoning backflow, as documented in where active anti-siphoning devices Sections 9.1.2.3.3 and 9.1.2.3.5 of the FSAR are attached to 2-inch or smaller (Reference 8). As described, anti-siphoning piping and have extremely large devices are installed on all SFP piping that can lead extended operators, the valves to siphoning; therefore, this criterion is met for should be walked down to confirm Columbia.

adequate lateral support. Based on review of Figures 9.1-6.1 and 9.1-6.2 of the FSAR (Reference 8), no 2-inch or smaller piping exits the SFP, i.e., no active anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators; therefore, this criterion is met for Columbia.

7. To confirm applicability of the The Columbia Generating Station SFP has a length sloshing evaluation in Section 4.2 of of 40 ft, a width of 34 ft, and a depth of 38.75 ft EPRI 3002009564, the maximum based on Figure 3.8-31 of the FSAR (Reference 8);

SFP horizontal dimension (length or therefore, this criterion is met for Columbia width) should be less than 125 ft Generating Station.

and the SFP depth should be greater than 36 ft.

8. To confirm applicability of the The Columbia SFP has a surface area of 1,360 ft2, evaporation loss evaluation in which is greater than 500 ft2 and the licensed Section 4.2 of EPRI 3002009564, reactor thermal power for Columbia is 3,544 MWt the SFP surface area should be which is less than 4,000 MWt ; therefore, this greater than 500 ft2 and the licensed criterion is met for Columbia.

reactor core thermal power should be less than 4,000 MWt per unit.

References 1. Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the

GO2-17-204 Attachment Page 3 of 3 Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ADAMS No.

ML12053A340)

2. Letter from W. M. Dean (NRC) to the Power Reactor Licensees on the Enclosed List, "Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 Seismic of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated October 27, 2015 (ADAMS No. ML15194A015)

3. Letter from A. N. Mauer (NEI) to M. X. Franovich (NRC), "Request for Endorsement of Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation (EPRI 3002009564)," dated January 31, 2017 (ADAMS No.

ML17031A171)

4. EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated January 2017

5. Letter from M. X. Franovich (NRC) to A. N. Mauer (NEI) "Endorsement of EPRI Report 3002009564, 'Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation'," dated February 28, 2017 (ADAMS No.

ML17034A408)

6. Letter GO2-15-045 from D. A. Swank (Energy Northwest) to the NRC, "Seismic Hazard and Screening Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(F) Regarding Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident," dated March 12, 2015 (ADAMS No.

ML16204A060)

7. Letter from F. Vega (NRC) to M. E. Reddemann (Energy Northwest),

"Columbia Generating Station - Staff Assessment of Information provided under Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima DAI-ICHI Accident (CAC No. MF5274)," dated November 4, 2016 (ADAMS No. ML16285A410)

8. Energy Northwest's Columbia Generating Station Final Safety Analysis Report, Amendment 63, dated December 2015.

9. CVI 1266-00,1, Columbia Generating Station Spent Fuel Pool Seismic Integrity Evaluation