JAFP-16-0182, Spent Fuel Pool Evaluation, 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

Spent Fuel Pool Evaluation, 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

ML16357A786
Person / Time
Site:	FitzPatrick
Issue date:	12/22/2016
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-16-0182
Download: ML16357A786 (6)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-16-0182 December 22, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Spent Fuel Pool Evaluation, 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 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC letter, 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, ML12053A340, dated March 12, 2012

2. NEI letter, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, ML13101A379, dated April 9, 2013

3. NRC Letter, Electric Power Research Institute Final Draft Report XXXXXX, Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations, ML13106A331, dated May 7, 2013

4. ENOI letter, Entergys Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, JAFP-13-0056, dated April 29, 2013

5. NRC letter, 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, ML15194A015, dated October 27, 2015

6. EPRI guidance, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, EPRI 3002007148, dated February 2016

7. NRC letter, Endorsement of Electric Power Research Institute Report 3002007148, Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation, ML15350A158, dated March 17, 2016

JAFP-16-0182 Page 2 of 2

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued a Request for Information per 10 CFR 50.54(f) [Reference 1] in regard to Recommendation 2.1: Seismic.

In Reference 2, the Nuclear Energy Institute (NEI) requested a Proposed Path Forward for Recommendation 2.1: Seismic, that the NRG agreed with in Reference 3, and James A.

FitzPatrick Nuclear Power Plant (JAF) committed to this schedule in Reference 4. This letter addresses the 50.54(f) Enclosure Recommendation 2.1: Seismic requested information item (9) and the portion of the Proposed Path Forward first group of risk evaluations, to perform a Spent Fuel Pool (SFP) evaluation. The SFP evaluation is one of the risk evaluations determined to be required for JAF through the screening and prioritization process [Reference 5].

The seismic adequacy of the SFP is reevaluated against the new ground motion response spectrum (GMRS) hazard levels in accordance with the criteria provided in EPRI 3002007148

[Reference 6] as endorsed by the NRG [Reference 7]. EPRI 3002007148 Section 3.3 lists the parameters to be verified to confirm that the results of the report are applicable to JAF, and that the JAF SFP is seismically adequate.

The Attachment provides JAF's SFP evaluation as described in Section 3.3 of Reference 6 in accordance with the schedule identified in Reference 2 and committed to in Reference 4.

This letter contains no new regulatory commitments. If you have any questions regarding this submittal, please contact William C. Drews, Regulatory Assurance Manager, at 315-349-6562.

I declare under penalty of perjury that the foregoing is true and correct; executed on December 22, 2016.

Respectfully,

Attachment:

Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant cc: Director, Office of Nuclear Reactor Regulation NRG Region I Administrator NRG Resident Inspector NRG Project Manager NYSPSC President NYSERDA

JAFP-16-0182 ATTACHMENT Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant (3 Pages)

JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant On March 12, 2012, the NRC Request for Information per 10 CFR 50.54(f) (Reference 1) in regard to Near Term Task Force (NTTF) Recommendation 2.1, requested a seismic evaluation be made of the 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 Reference 2 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for James A.

FitzPatrick Nuclear Power Plant (JAF).

By letter dated March 17, 2016 (Reference 5) the staff determined that EPRI 3002007148 (Reference 6) was an acceptable approach for performing SFP evaluations for plants where the peak spectral acceleration is less than or equal to 0.8g. The table below lists the criteria from Section 3.3 of EPRI 3002007148 along with data for JAF that confirms applicability of the EPRI 3002007148 criteria and confirms that the SFP is seismically adequate and can retain adequate water inventory for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in accordance with NTTF 2.1 Seismic evaluation criteria.

SFP Criteria from EPRI 3002007148 Site-Specific Data Site Parameters

1. The site-specific GMRS peak The GMRS peak spectral acceleration in JAF spectral acceleration at any GMRS submittal (Reference 3) as accepted by the frequency should be less than or NRC (Reference 4) is 0.241g, which is 0.8g.

equal to 0.8g.

Therefore, this criterion is met for JAF.

Structural Parameters

2. The structure housing the SFP The SFP is housed in the Reactor Building, which should be designed using an SSE is seismically designed to the site SSE with a PGA with a peak ground acceleration of 0.15g. JAF PGA is greater than 0.1g.

(PGA) of at least 0.1g.

Therefore, this criterion is met for JAF.

3. The structural load path to the SFP The structural load path from the foundation to the should consist of some combination SFP consists of a combination of reinforced of reinforced concrete shear wall concrete shear wall elements, reinforced concrete elements, reinforced concrete frame frame elements and structural steel elements (Ref.

elements, post-tensioned concrete JAF Drawings FC-27A, FC-27B, FC-30A thru 30E, elements and/or structural steel FC-30L, and FC-30M).

frame elements.

Therefore, this criterion is met for JAF.

4. The SFP structure should be The SFP concrete walls and slab are included in included in the Civil Inspection the James A. FitzPatrick Nuclear Power Plant Civil Program performed in accordance Inspection Program per EN-DC-150 Attachment with Maintenance Rule. 9.16 under Reactor Building General Areas. The four steel columns underneath the SFP slab are also included in inspections for EL 326-9. These inspections are performed every 5 to 10 years.

Therefore, this criterion is met for JAF.

Page 1 of 3

JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant SFP Criteria from EPRI 3002007148 Site-Specific Data Non-Structural Parameters

5. To confirm applicability of the piping Piping connections (penetrations) attached to the evaluation in Section 3.2 of EPRI SFP that could lead to rapid drain-down was 3002007148, piping attached to the addressed within the scope of NTTF SFP up to the first valve should have Recommendation 2.3: Seismic walkdowns in JAF-been evaluated for the SSE. RPT-12-00015. Section 6.2.2 of this report states, the Equipment Selection Personnelidentified SSCs that could cause the SFP to drain rapidly by first reviewing the SFP documentation to identify penetrations below about 10 ft above the top of fuel assemblies. Because this review found no such SFP penetrations, there is no potential for rapid drain-down. In addition, a review has been performed to identify all piping attached to the SFP as documented in JAF-RPT-16-00004. The review shows that all of the piping lines that could lead to rapid drawdown have been seismically designed to SSE levels up to the first valve. The Piping lines which are not seismically designed to SSE levels are drain lines for the skimmer surge tanks located at a level above the required minimum water elevation.

Therefore, this criterion is met for JAF.

6. Anti-siphoning devices should be Anti-siphoning devices have been installed on four installed on any piping that could piping lines as documented on Attachment 9.2 of lead to siphoning water from the JAF-RPT-16-00004. These are the only lines that SFP. In addition, for any cases can lead to siphoning of the water from the SFP to where active anti-siphoning devices an elevation below the required minimum water are attached to 2-inch or smaller elevation of 363-9. These lines have nominal piping and have extremely large piping diameters of 6 and 10.

extended operators, the valves As described, anti-siphoning devices are installed should be walked down to confirm on all SFP piping that could lead to siphoning; adequate lateral support.

therefore, this criterion is met for JAF.

As described, no anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators.

Therefore, this criterion is met for JAF.

Page 2 of 3

JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant SFP Criteria from EPRI 3002007148 Site-Specific Data

7. To confirm applicability of the JAF SFP structure has a length of 40.0 ft, a width sloshing evaluation in Section 3.2 of of 31.0 ft and a depth of 38.75ft based on JAF EPRI 3002007148, the maximum drawings FV-9A, FC-30E, and FM-1H. The normal SFP horizontal dimension (length or water depth is 37.75 ft. Therefore, the SFP width) should be less than 125 ft, the dimensional criterion is met.

SFP depth should be greater than The JAF GMRS maximum spectral acceleration in 36 ft, and the GMRS peak Sa should the frequency range of 0.3 Hz is 0.0225g as be <0.1g at frequencies equal to or documented in JAF-RPT-14-00004. Since this less than 0.3 Hz.

acceleration is less than 0.1g, this criterion is met.

8. To confirm applicability of the The surface area of JAF SFP is 1,240 ft2, which is evaporation loss evaluation in greater than 500 ft2. The licensed reactor thermal Section 3.2 of EPRI 3002007148, power for the single unit JAF is 2,536 MWt which is the SFP surface area should be less than 4,000 MWt. The SFP surface area and greater than 500 ft2 and the licensed licensed reactor core thermal power values are reactor core thermal power should bounded by the EPRI criteria.

be less than 4,000 MWt per unit.

Therefore, this criterion is met for JAF.

References:

1) NRC letter, ML12053A340 - 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

2) NRC letter, ML15194A015 - 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

3) ENOI letter, JAFP-14-0039 - Entergy Seismic and Screening Hazard Report (CEUS Sites), 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 31, 2014

4) NRC letter, ML16043A411 - James A. FitzPatrick Nuclear Power Plant - Staff Assessment of Information Provided Pursuant to 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, dated February 18, 2016

5) NRC letter, ML15350A158 - Endorsement of Electric Power Research Institute Report 3002007148, Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation, dated March 17, 2016

6) EPRI guidance, EPRI 3002007148 - Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated February 2016 Page 3 of 3