ML15196A020

NRR E-mail Capture - Point Beach Nuclear Plant - Technical Review Checklist Related to Interim ESEP Supporting Implementation of NTTF R2.1, Seismic (TAC No. MF5263 and MF5264)

ML15196A020
Person / Time
Site:	Point Beach
Issue date:	07/10/2015
From:	Diane Jackson Office of New Reactors
To:	Mohamed Shams Japan Lessons-Learned Division
References
TAC MF5263, TAC MF5264
Download: ML15196A020 (12)

Text

NRR-PMDAPEm Resource From: Jackson, Diane Sent: Friday, July 10, 2015 11:14 AM To: Shams, Mohamed Cc: DiFrancesco, Nicholas; Wyman, Stephen; Spence, Jane; Devlin-Gill, Stephanie; Roche, Kevin; Yee, On; Wang, Weijun; Gallucci, Ray; Patel, Pravin; Graizer, Vladimir; Pettis, Robert; 50.54f_Seismic Resource; RidsNroDsea Resource

Subject:

POINT BEACH NUCLEAR PLANT - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM ESEP SUPPORTING IMPLEMENTATION OF NTTF R2.1, SEISMIC (TAC NO.

MF5263 AND MF5264)

Attachments: Point Beach R2.1 seismic ESEP NRC review.docx July 10, 2015 MEMORANDUM TO: Mohamed K. Shams, Chief Hazards Management Branch (JHMB)

Japan Lessons-Learned Division Office of Nuclear Reactor Regulation FROM: Diane T. Jackson, Chief Geosciences and Geotechnical Engineering Branch 2 (RGS2)

Division of Site Safety and Environmental Analysis Office of New Reactors

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM EXPEDITED SEISMIC EVALUATION PROCESS SUPPORTING IMPLEMENTATION OF NTTF RECOMMENDATION 2.1, SEISMIC, RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF5263 AND MF5264)

The NRC technical staff working through the Geosciences and Geotechnical Engineering Branches 1 and 2 (RGS1 and RGS2) completed the Technical Review Checklist of the POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 response to Enclosure 1, Item (6) of the March 12, 2012, request for information letter issued per Title 10 of the Code of Federal Regulations, Subpart 50.54(f), to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staffs evaluation of regulatory actions to be taken in response to Fukushima Near-Term Task Force (NTTF)

Recommendation 2.1: Seismic which implements lessons learned from Japans March 11, 2011, Great Thoku Earthquake and subsequent tsunami. This addresses the staff review of the interim Expedited Seismic Evaluation Process (ESEP) report in response to Requested Item (6) of Enclosure 1, Recommendation 2.1:

Seismic, of the 50.54(f) letter. Attached is a file containing the technical review checklist to prepare a response letter to the licensee.

The NRC staff reviewed the information provided and, as documented in the enclosed staff checklist, determined that sufficient information was provided to be responsive to this portion of the Enclosure 1 of the 50.54(f) letter. The application of this staff review is limited to the interim ESEP as part of NTTF R2.1: Seismic activities.

This electronic memo constitutes the DSEA concurrence provided that only editorial changes are made to the staff assessment that would not affect the technical conclusions or technical context of the assessment.

1

This concludes the NRCs efforts associated with TAC NO. MF5263 and MF5264 for the review of the interim ESEP report for the POINT BEACH NUCLEAR PLANT, UNITS 1 and 2.

Docket No: 50-266 and 50-301 CONTACT: Stephanie Devlin-Gill Office of New Reactors 301-415-5301 Copy: Nicholas DiFrancesco, Steve Wyman, Jane Spence, Stephanie Devlin-Gill, Kevin Roche, On Yee, Weijun Wang, Ray Gallucci, Pravin Patel, Bob Pettis, Vladimir Graizer, 50.54f_Seismic Resource, RidsNroDsea Resource 2

Hearing Identifier: NRR_PMDA Email Number: 2228 Mail Envelope Properties (79bb1aa8b41145a8a96be2e1f59dbae8)

Subject:

POINT BEACH NUCLEAR PLANT - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM ESEP SUPPORTING IMPLEMENTATION OF NTTF R2.1, SEISMIC (TAC NO.

MF5263 AND MF5264)

Sent Date: 7/10/2015 11:14:06 AM Received Date: 7/10/2015 11:14:07 AM From: Jackson, Diane Created By: Diane.Jackson@nrc.gov Recipients:

"DiFrancesco, Nicholas" <Nicholas.DiFrancesco@nrc.gov>

Tracking Status: None "Wyman, Stephen" <Stephen.Wyman@nrc.gov>

Tracking Status: None "Spence, Jane" <Jane.Spence@nrc.gov>

Tracking Status: None "Devlin-Gill, Stephanie" <Stephanie.Devlin-Gill@nrc.gov>

Tracking Status: None "Roche, Kevin" <Kevin.Roche@nrc.gov>

Tracking Status: None "Yee, On" <On.Yee@nrc.gov>

Tracking Status: None "Wang, Weijun" <Weijun.Wang@nrc.gov>

Tracking Status: None "Gallucci, Ray" <Ray.Gallucci@nrc.gov>

Tracking Status: None "Patel, Pravin" <Pravin.Patel@nrc.gov>

Tracking Status: None "Graizer, Vladimir" <Vladimir.Graizer@nrc.gov>

Tracking Status: None "Pettis, Robert" <Robert.Pettis@nrc.gov>

Tracking Status: None "50.54f_Seismic Resource" <50.54f_Seismic.Resource@nrc.gov>

Tracking Status: None "RidsNroDsea Resource" <RidsNroDsea.Resource@nrc.gov>

Tracking Status: None "Shams, Mohamed" <Mohamed.Shams@nrc.gov>

Tracking Status: None Post Office: HQPWMSMRS04.nrc.gov Files Size Date & Time MESSAGE 3201 7/10/2015 11:14:07 AM Point Beach R2.1 seismic ESEP NRC review.docx 47649 Options Priority: Standard Return Notification: No Reply Requested: No

Sensitivity: Normal Expiration Date:

Recipients Received:

TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXPEDITED SEISMIC EVALUATION PROCESS INTERIM EVALUATION IMPLEMENTING NTTF RECOMMENDATION 2.1 SEISMIC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 By letter dated March 12, 2012 (USNRC, 2012a), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) Conditions of License (hereafter referred to as the 50.54(f) letter). Enclosure 1 of the 50.54(f) letter requests addressees to reevaluate the seismic hazard at their site using present-day methods and guidance for licensing new nuclear power plants, and identify actions to address or modify, as necessary, plant components affected with the reevaluated seismic hazards. Requested Information Item (6) in Enclosure 1 to the 50.54(f) letter requests addressees to provide an interim evaluation and actions taken or planned to address a higher seismic hazard relative to the design basis, as appropriate, prior to completion and submission of the seismic risk evaluation.

Additionally, by letter dated April 12, 20131, the Electric Power Research Institute (EPRI) staff submitted EPRI TR 3002000704 Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force (NTTF) Recommendation 2.1: Seismic (hereafter referred to as the guidance). The Augmented Approach proposed that licensees would use an Expedited Seismic Evaluation Process (ESEP) to address the interim actions as requested by Information Item (6) in the 50.54(f) letter. The ESEP is a simplified seismic capacity evaluation with a focused scope of certain key installed Mitigating Strategies equipment that is used for core cooling and containment functions to cope with scenarios that involve a loss of all AC power and loss of access to the ultimate heat sink to withstand the Review Level Ground Motion, which is up to two times the safe shutdown earthquake (SSE).

Due to the expedited and interim nature of the ESEP, the assessment does not include many considerations that are part of a normal risk evaluation. These deferred items, include but are not limited to, structures, piping, non-seismic failures, and operator actions, as well scenarios such as addressing loss of coolant accidents. By letter dated May 7, 20132, the NRC staff endorsed the guidance. Central and eastern United States licensees with a reevaluated seismic hazard exceeding the SSE submitted an ESEP interim evaluation in December 2014 Consistent with the interim nature of this activity, the staff performed the review of the licensees submittal to assess whether the intent of the guidance was implemented. A multi-disciplined team checked whether the identified methods were consistent with the guidance. A senior expert panel reviewed the teams questions, if any, and checklist for consistency and scope.

New or updated parameters (e.g., In-Structure Response Spectra, High Confidence of Low Probability of Failure calculations) presented by the licensees were assessed only based on licensee statements for acceptability for the Item (6) response. The application of this staff review is limited to the ESEP interim evaluation as part of NTTF R2.1: Seismic activities.

1 ADAMS Accession No. ML13102A142 2 ADAMS Accession No. ML13106A331

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 By letter dated December 22, 2014,3NextEra Energy Point Beach, LLC (the licensee), provided an Expedited Seismic Evaluation Process (ESEP) report in a response to Enclosure 1, Requested Information Item (6) of the 50.54(f) letter, for the Point Beach Nuclear Plant (Point Beach), Units 1 and 2.

I. Review Level Ground Motion The licensee:

• described the determination of the review level ground motion Yes (RLGM) using one of the means acceptable by the guidance

• identified location of the control point and is consistent with March Yes submittal

• compared the site ground motion response spectra used to select Yes the ESEP RLGM to the SSE.

Point Beach Units 1 and 2 used a scaled SSE at a ratio of __1.91_

Notes from the Reviewer:

1. Typo/error in Table 4-2 (page 10 of report) but correct values were used in calculation.

Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

The NRC staff concludes:

• the licensees RLGM meets the intent of the guidance Yes

• the RLGM is reasonable for use in the interim evaluation Yes II. Selection of the Success Path The licensee:

• described the success path Yes

• described normal and desired state of the equipment for the success Yes path

• ensured that the success path is consistent with the plants overall Yes mitigating strategies approach or provided a justification for an alternate path

• stated that the selection process was in accordance with the Yes guidance or meets the intent of the guidance

• used installed FLEX Phase 1 equipment as part of the success path Yes

• included FLEX Phase 2 and/or 3 connections

• considered installed FLEX Phase 2 and/or 3 equipment Yes Yes 3 ADAMS Accession No ML14356A426 2

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 Notes from the Reviewer:

1. The licensee relies on a diesel driven fire pump in Phase 1 Core Cooling strategies to provide service water as a suction to the turbine drive auxiliary feedwater pump.

2. The safety-related fuel oil storage tank is not included in the ESEL and not credited for Phase 1, however, the day tank for the diesel driven fire pump (DDFP) is included.

Based on the capacity of the fuel oil day tank and the consumption rate of the pump, and availability of fuel oil in refueling trailers, there is greater than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of run time for the DDFP. For the interim evaluation, this is acceptable to the staff.

Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

The NRC staff concludes that:

• the selected success path is reasonable for use in the interim Yes evaluation

• the licensee considered installed Phase 2 and 3 connections or Yes equipment in the interim evaluation.

III. Selection of the Equipment List The licensee:

• developed and provided the ESEL by applying the ESEP Yes

• identified equipment considering the following functions:

o Core cooling (with focus on Mode 1) function Yes o Available, sustainable water source Yes o Containment function and integrity Yes Notes from the Reviewer:

1. The staff verified that the licensee identified major components in direct flow path (use system notebooks).

2. Typo in Table A, page 41 of 66: 1B42-3212H should be 1B32-3212H.

Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

For PWR Plants Only The licensee included indicators / instrumentation for the following functions:

level, pressure, temperature, that would be indicative of (but not explicitly Yes identified to specific instruments): water level of the steam generator(SG),

pressure of SG, containment, and reactor coolant system (RCS); and temperature of the RCS.

For BWR Plants Only The licensee considered indicators for the following functions:

level, pressure, temperature that would be indicative of (but not explicitly N/A identified to specific instruments): Temperature of suppression pool, RCS, containment); Pressure of suppression pool, RCS, and drywell; water level of the suppression pool.

3

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 Notes from the Reviewer: None Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

Through a sampling of the ESEP key components, the NRC staff concludes that:

• the licensees process to develop the ESEL meets the intent of the Yes guidance for the interim evaluation

• the desired equipment state for the success path were identified Yes

• the licensee considered the support equipment for the ESEL Yes

• both front-line and support systems appeared to be included in the Yes ESEL as evidenced by inclusion of SSCs on the success path and of support systems (e.g., batteries, motor control center, inverters).

IV. Walkdown Approach The licensee:

• described the walkdown screening approach, including walkbys and Yes walkdowns performed exclusively for the ESEP, in accordance with the guidance

• credited previous walkdown results, including a description of current Yes action(s) to verify the present equipment condition and/or configuration (e.g., walk-bys), in accordance with the guidance

• stated that the walkdown was performed by seismically trained Yes personnel Notes from the Reviewer: None Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

The licensee:

• described, if needed, adverse material condition of the equipment Yes (e.g. material degradation)

• credited previous walkdown results, included a description of current Yes action(s) to verify the present equipment condition (e.g., walk-bys),

meeting the intent of the guidance The licensee:

• described the conditions of structural items considered for the interim evaluation, including:

o spatial interactions (i.e. interaction between block walls and Yes other items/components) o anchorage Yes o piping connected to tanks (i.e. differential movement between Yes pipes and tanks at connections)

Notes from the Reviewer:

1. Although a statement was not explicit in the submittal, the day tank for the DDFP was included and evaluated as part of the ESEL, in accordance with the guidance, connections were also included in the evaluation.

Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

4

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 The licensee reported deviations for Point Beach, Units 1 and 2. No If deviations were identified, there is a discussion of how the deficiencies N/A were or will be addressed in the ESEP submittal report.

The NRC staff concludes that:

• the licensee described the performed walkdown approach, including Yes any credited previous efforts (e.g., Individual Plant Examination of External Events(IPEEE)) consistent with the guidance

• the licensee addressed identified deviations consistent with the Yes guidance, if any V. Capacity Screening Approach and HCLPF Calculation Results The licensee:

• described the capacity screening process for the ESEL items, Yes consistent with the guidance (e.g., use of EPRI NP-6041 screening table).

• presented the results of the screened-out ESEL items in the ESEP Yes report

• described the development of in-structure response spectra(ISRS) Yes based on scaling N/A

• described the development of ISRS based on new analysis consistent with the guidance Yes

• described the method for estimating HCLPF capacity of screened-in ESEL items, including both structural and functional failure modes consistent with the guidance: Yes o use of Conservative Deterministic Failure Margin (CDFM) N/A o use of fragility analysis (FA) Yes o use of experience data or generic information

• credited IPEEE spectral shape for HCLPF capacity estimates is N/A similar to or envelopes the RLGM, and anchored at the same control point

• presented the results of HCLPF capacities including associated Yes failure modes for screened-in ESEL items Yes

• reviewed the ESEL items with the lowest HCLPF values to ensure that their capacities are equal or greater than the RLGM 5

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 Notes from the Reviewer:

1. Licensee identified 4 items where the HCLPF is below the RLGM; plant modifications will be made in accordance with EPRI 3002000704 to enhance the seismic capacity of the plant (Section 8.2). Two masonry walls, one block wall, and anchorage for condensate storage tank (CST) T-24A and T-24B. CST modifications (EC279034) to be completed prior to U2 Outage Fall 2015, however the CST mod is not listed as an item in Section 8.4,Summary of Regulatory Commitments. The masonry and block walls are listed in Section 8.4 under Items 4, 5, and 6.

2. Although the CST modification is not included in the Summary of Commitments, CST modifications are related to Work Control Center block wall modification and listed in Attachment B. Level transmitters LT-4038 and LT-4041 are also affected by the WCC modification. HCLPF value for CSTs and LTs is 0.158 prior to completion of WCC block wall modifications.

Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

The NRC staff concludes that:

• the licensee described the implementation of the capacity screening Yes process consistent with the intent of the guidance

• the licensee presented capacity screening and calculation results, as Yes appropriate, in the ESEP report

• the method used to develop the ISRS is consistent with guidance for Yes use in the ESEP

• for HCLPF calculations, the licensee used HCLPF calculation Yes methods as endorsed in the guidance

• no anomalies were noted in the reported HCLPF Yes VI. Inaccessible Items The licensee:

• provided a list of inaccessible items Yes

• provided a schedule of the planned walkdown and evaluation for all Yes inaccessible items

• provided Regulatory Commitment to complete walkdowns. Yes Point Beach Units 1 and 2 will complete walkdowns and provide the results within120 days following the restart from the Unit 2 Fall 2015 outage.

Notes from the Reviewer:

1. No walkdown planned for some inaccessible items that are either located in high radiation area and not easily accessible, or inherently rugged and judged adequate by the licensees SRT, in accordance with guidance. Other inaccessible items in Unit 2 are scheduled to be walked down during Unit 2 outage in Fall 2015.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that the licensee:

• listed inaccessible items Yes

• committed to provide the results (e.g. walkdowns, walkbys, etc) of Yes the remaining inaccessible items consistent with the guidance

• substitutions, if needed, were appropriately justified Yes 6

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 VII. Modifications to Plant Equipment The licensee:

• identified modifications for ESEL items necessary to achieve HCLPF Yes values that bound the RLGM (excluding mitigative strategies equipment (FLEX)), as specified in the guidance

• provided a schedule to implement such modifications (if any), Yes consistent with the intent of the guidance

• provided Regulatory Commitment to complete modifications Yes

• provided Regulatory Commitment to report completion of Yes modifications.

Point Beach Units 1 and 2 will:

• complete modifications by Fall of 2017 or earlier.

• report completion of modifications by 60 days following completion of all modifications Notes from the Reviewer: None Deviation(s) or Deficiency(ies), and Resolution:

• No deviations or deficiencies were identified.

The NRC staff concludes that the licensee:

• identified plant modifications necessary to achieve the target seismic Yes capacity

• provided a schedule to implement the modifications (if any) Yes consistent with the guidance VIII. Conclusions Based on its review, the NRC staff concludes that the licensees implementation of the interim evaluation meets the intent of the guidance. The staff concludes that, through the implementation of the ESEP guidance, the licensee identified and evaluated the seismic capacity of key components that are used for core cooling and containment functions to cope with scenarios that involve a loss of all AC power and loss of access to the ultimate heat sink to withstand a seismic event up to the Review Level Ground Motion (RLGM) and thus, provides additional assurance while the plant seismic risk evaluation is being conducted. The NRC staff concludes that the licensee responded appropriately to Enclosure 1, Item (6) of the 50.54(f) letter, dated March 12, 2012 for Point Beach Nuclear Plant Units 1 and 2.

The NRC staff assessed the licensees implementation of the ESEP guidance. Due to the interim applicability of the ESEP evaluations, use of the information for another application would require a separate NRC review and approval. Based on its review, the NRC staff concludes that the licensees implementation of the interim evaluation meets the intent of the guidance. The staff concludes that, through the implementation of the ESEP guidance, the licensee identified and evaluated the seismic capacity of certain key installed Mitigating Strategies equipment that is used for core cooling and containment functions to cope with scenarios that involve a loss of all AC power and loss of access to the ultimate heat sink to withstand a seismic event up to the Review Level Ground Motion (RLGM). In the case of Point Beach, in accordance with the guidance, the RLGM used a scaled SSE at the ratio of 1.91. The staff did not identify deviations or exceptions taken from the guidance. The application of this staff review is limited to the ESEP interim evaluation as part of NTTF R2.1: Seismic activities.

7

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for Point Beach Nuclear Plant, Units 1 and 2 The licensee identified safety enhancing modifications based on the evaluation and committed to complete modifications by Fall of 2017 or earlier and report completion of modifications by 60 days following completion of all modifications.

In summary, the licensee, by implementing the ESEP interim evaluation, has demonstrated additional assurance which supports continued plant safety while the longer-term seismic evaluation is completed to support regulatory decision making. The NRC staff concludes that the licensee responded appropriately to Enclosure 1, Item (6) of the 50.54(f) letter, dated March 12, 2012, for Point Beach Nuclear Plant, Units 1 and 2.

Principle Contributors: Ray Gallucci, Kevin Roche, On Yee, Pravin Patel, Robert Pettis, Vladimir Graizer, Weijun Wang, Thomas Houston (NRC Consultant) 8