RS-16-126, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 1O CFR 50.54(f) Regarding Recommendation 2.1 of Near-Term Task Force Review of Insights from Fukushima Dai-ichi Accident

Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 1O CFR 50.54(f) Regarding Recommendation 2.1 of Near-Term Task Force Review of Insights from Fukushima Dai-ichi Accident

ML16244A326
Person / Time
Site:	Three Mile Island
Issue date:	08/31/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-16-126, TMI-16-051
Download: ML16244A326 (8)

Text

Exelon Generation (~

10 CFR 50.54(f)

RS-16-126 TMl-16-051 August 31, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

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. NRC Letter, Request for Information Pursuant to Title 1O 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 (ML12053A340)

2. NRC Letter, Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 1O 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 (ML15194A015)

3. NEI Letter, Request for Endorsement of Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation (EPRI 3002007148), dated February 23, 2016 (ML16055A017)

4. EPRI 3002007148, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, February 2016

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

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 2

6. Exelon Generation Company, LLC Letter to USNRC, Seismic Hazard and Screening Report (Central and Eastern United States (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 (RS-14-073) (ML14090A271)

7. NRC Letter to Exelon Generation Company, LLC, Three Mile Island Nuclear Station, Unit 1, 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 August 14, 2015 (ML15223A215)

8. EPRI 1025287, Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details [SPID] for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic, February 2013 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information per 10 CFR 50.54(f) (Reference 1) to all power reactor licensees. Enclosure 1, Item (9) of the 50.54(f) letter requested addressees to provide spent fuel pool (SFP) integrity evaluations with any actions identified to address any discovered vulnerabilities. By letter dated October 27, 2015 (Reference 2), the NRC transmitted final seismic information request tables which identified that Three Mile Island Nuclear Station, Unit 1 is to conduct a limited scope SFP 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 3002007148) (Reference 4) for NRC review and endorsement. NRC endorsement was provided by Reference 5.

EPRI 3002007148 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. The reevaluated GMRS, used for the SFP seismic demand, are documented in Reference 6 and endorsed by the NRC by Reference 7. This report supplements the guidance in the Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) (Reference 8), for plants where the GMRS peak spectral acceleration is less than or equal to 0.8g. Section 3.3 of EPRI 3002007148 lists the parameters to be verified to confirm that the results of the report are applicable to Three Mile Island Nuclear Station, Unit 1, and that the Three Mile Island Nuclear Station, Unit 1, SFP is seismically adequate in accordance with Near Term Task Force (NTTF) 2.1 Seismic evaluation criteria.

The attachment to this letter provides the data for Three Mile Island Nuclear Station, Unit 1, that confirms applicability of the EPRI 3002007148 criteria, confirms that the SFP is seismically adequate, and provides the requested information in response to Item (9) of the 50.54 (f) letter associated with NTTF Recommendation 2.1 Seismic evaluation criteria.

This letter closes Regulatory Commitment No. 2 of Reference 6.

This letter contains no new regulatory commitments or revisions to existing regulatory commitments.

If you have any questions regarding this report, please contact Ronald Gaston at 630-657-3359.

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of August 2016.

Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Site-Specific Spent Fuel Pool Criteria for Three Mile Island Nuclear Station, Unit 1 cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector- Three Mile Island Nuclear Station NRC Project Manager, NRR - Three Mile Island Nuclear Station Mr. Nicholas DiFrancesco, NRR/JLD/JHMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

ATTACHMENT Site-Specific Spent Fuel Pool Criteria for Three Mile Island Nuclear Station, Unit 1

Three Mile Island Nuclear Station, Unit 1 Seismic Spent Fuel Pool Evaluation Page 1 of 4 The 10 CFR 50.54(f) letter requested that, in conjunction with the response to Near Term Task Force (NTTF) Recommendation 2.1, 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 1O Hz frequency range. The NRC staff confirmed through References A and D that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Three Mile Island Nuclear Station, Unit 1. By letter dated March 17, 2016 (Reference B) the NRC staff determined that EPRI 3002007148 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 Three Mile Island Nuclear Station, Unit 1 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 spectral acceleration at any Reference C Table 2.4-1, as accepted by the NRC frequency should be less than or in Reference D, is 0.465g, which is ::::; 0.8g; equal to 0.8g. therefore, this criterion is met.

Structural Parameters

2. The structure housing the SFP The SFP is housed in the Fuel Handling Building, should be designed using an SSE which is seismically designed to the site SSE with with a peak ground acceleration a PGA of 0.12g (Reference C, Section 3.1 ). The (PGA) of at least 0.1 g. Three Mile Island Nuclear Station, Unit 1 PGA is greater than 0.1 g; therefore, this criterion is met.

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 reinforced concrete boundary and of reinforced concrete shear wall intermediate bearing walls to its mat foundation on elements, reinforced concrete frame bedrock (Reference E, Sections 2.7.5.2 and elements, post-tensioned concrete 9.7.1.1 and Reference F); therefore, this criterion is elements and/or structural steel met for Three Mile Island Nuclear Station, Unit 1.

frame elements.

4. The SFP structure should be The SFP structure is included in the Three Mile included in the Civil Inspection Island Nuclear Station, Unit 1 Structures Program performed in accordance Monitoring Program (Reference G) in accordance with Maintenance Rule. with 10 CFR 50.65, which monitors the performance or condition of structures, systems, or components (SSCs) in a manner sufficient to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions.

Therefore, this criterion is met for Three Mile Island Nuclear Station, Unit 1.

Three Mile Island Nuclear Station, Unit 1 Seismic Spent Fuel Pool Evaluation Page 2 of 4 SFP Criteria from EPRI 3002007148 Site-Specific Data Non-Structural Parameters

5. To confirm applicability of the piping Piping attached to the SFP is evaluated to the SSE evaluation in Section 3.2 of EPRI as documented in Reference E, Section 5.1.1.1.f; 3002007148, piping attached to the therefore, this criterion is met for Three Mile Island SFP up to the first valve should have Nuclear Station, Unit 1.

been evaluated for the SSE.

6. Anti-siphoning devices should be Reference E, Section 9.4 states: "The most serious installed on any piping that could failure of the Spent Fuel Cooling System would be lead to siphoning water from the complete loss of water from both spent fuel storage SFP. In addition, for any cases pools. To protect against this possibility, the where active anti-siphoning devices cooling water inlet and outlet connections to spent are attached to 2-inch or smaller fuel pool B all enter slightly below, or at, the normal piping and have extremely large water level in the pool. Fuel pool A has a drain extended operators, the valves connection from the spent fuel cooling system should be walked down to confirm extending downward from elevation 330 ft (10 ft adequate lateral support. above the top of fuel stored in this pool) to 2 inches above the bottom of the pool. This line has a siphon breaker with a normally locked open valve to prevent water from siphoning from the pool below elevation 330 ft in the highly unlikely event that the line should break outside the pool."

As described, anti-siphoning devices are installed on all SFP piping that could lead to siphoning; therefore, this criterion is met for Three Mile Island Nuclear Station, Unit 1.

The normally locked-open anti-siphon valve (SF-V-

48) was walked down as documented in Reference J. SF-V-48 is a 1-inch manual diaphragm valve confirmed to have adequate lateral support and seismic capacity for the GMRS spectral acceleration of Reference C in accordance with NP-6041, Table 2-4.

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 Three Mile Island Nuclear Station, Unit 1.

Three Mile Island Nuclear Station, Unit 1 Seismic Spent Fuel Pool Evaluation Page 3 of 4 SFP Criteria from EPRI 3002007148 Site-Specific Data

7. To confirm applicability of the The Three Mile Island Nuclear Station, Unit 1 SFP sloshing evaluation in Section 3.2 of has a length of 102.25-ft, a width of 24-ft and a EPRI 3002007148, the maximum depth of 43-ft as documented in Reference F; SFP horizontal dimension (length or therefore, this criterion is met.

width) should be less than 125 ft, the SFP depth should be greater than The Three Mile Island Nuclear Station, Unit 1 36 ft, and the GMRS peak Sa should GMRS maximum spectral acceleration in the be <0.1 g at frequencies equal to or frequency range less than 0.3 Hz is 0.0241 g from less than 0.3 Hz.

Reference C (Table 2.4-1 ), which is less than 0.1 g; therefore, this criterion is met.

8. To confirm applicability of the The surface area of the Three Mile Island Nuclear evaporation loss evaluation in Station, Unit 1 SFP is 2,354-ft2 [(102.25-ft x 24-ft) -

Section 3.2 of EPRI 3002007148, ((24-ft ft) x 5-ft)] (Reference F), which is greater the SFP surface area should be than 500 ft2; and licensed reactor thermal power for greater than 500 ft2 and the licensed Three Mile Island Nuclear Station, Unit 1 is 2,568 reactor core thermal power should MWt (Reference H) which is less than 4,000 MWt be less than 4,000 MWt per unit. per unit; therefore, these criteria are met.

Attachment

References:

A. 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, dated October 27, 2015 (ML15194A015)

B. NRC Letter, Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation", dated March 17, 2016 (ML15350A158)

C. Exelon Generation Company, LLC Letter to USNRC, Seismic Hazard and Screening Report (Central and Eastern United States (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 (RS-14-073) (ML14090A271)

D. NRC Letter to Exelon Generation Company, LLC, Three Mile Island Nuclear Station, Unit 1, Staff Assessment of Information Provided Pursuant to Title 1O 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 August 14, 2015 (ML15223A215)

E. Three Mile Island Unit 1, Updated Final Safety Analysis Report (UFSAR), Revision 23, April 2016 F. Three Mile Island Unit 1, Drawing 421-117, "Fuel Storage Building - Concrete Walls -

Elev. 329'-0" to Elev. 348'-0" and Floor Slab Elev. 348'-0", Revision 7

Three Mile Island Nuclear Station, Unit 1 Seismic Spent Fuel Pool Evaluation Page 4 of 4 G. Three Mile Island Unit 1, Procedure ER-TM-450,"TMI Structures Monitoring Program",

Revision 3 H. Three Mile Island Nuclear Station, Unit 1, Renewed Facility Operating License No.

DPR-50 J. Exelon Generation Company, LLC's 180-day Response to NRG Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated November 19, 2012 (ML12362A044)