ET 16-0026, 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

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

ML16313A063
Person / Time
Site:	Wolf Creek
Issue date:	11/01/2016
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 16-0026
Download: ML16313A063 (10)

Text

Jaime H. McCoy Vice President Engineering November 1, 2016 ET 16-0026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter dated March 1?, 2012, from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident"

2) EPRI Report 1025287, "Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic"

3) Letter WO 14-0042 dated March 31, 2014, from R. A. Smith, WCNOC, to USNRC.

4) Letter dated August 12, 2015, from F. G. Vega, USNRC, to A. C. \

Heflin, WCNOC, "Wolf Creek Generating Station - 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"

5) Letter dated October 27, 2015, from W. M. Dean, USNRC, to A. C.

Heflin, WCNOC, "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"

6) EPRI Report 3002007148, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, February 2016

7) Letter dated February 23, 2016, from A. N. Mauer, NEI, to J. R. Davis, USNRC, "Request for Endorsement of Seismic Evaluation Guidance:

Spent Fuel Pool Integrity Evaluation (EPRI 3002007148)

P.O. Box 411 /Burlington, KS 66839 /Phone: (620) 364-8831

ro!D An Equal Opportunity Employer M/F/HCNET

Jf-K

ET 16-0026 Page 2 of 3

8) Letter dated March 18, 2016, from J. R. Davis, USNRC, to A N.

Mauer, NEI, "Endorsement of EPRI 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation"

Subject:

Docket No. 50-482: 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 Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to Wolf Creek Nuclear Operating Corporation (WCNOC). Enclosure 1, Item (9) of the 50.54(f) letter requested addressees to provide limited scope spent fuel pool (SFP) evaluations. By letter dated October 27, 2015 (Reference 5), the NRC transmitted final seismic information request tables which identified that WCNOC is to conduct a limited scope SFP Evaluation. By Reference 7, Nuclear Energy Institute (NEI) submitted an Electric Power Research Institute (EPRI) report entitled, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (EPRI 3002007148) (Reference 6) for NRC review and endorsement. NRC endorsement was provided by Reference 8.

EPRI 3002007148 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. This report supplements the guidance in the Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) (Reference 2), 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 WCNOC, and that the Wolf Creek Generating Station (WCGS) SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

The attachment to this letter provides the data for WCGS 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 contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine (620) 364-4204.

Sincerely, d~~/~/

~~i-me H. McC:y. * -/

JHM/rlt Attachment cc: K. M. Kennedy (NRC), w/a, B. K. Singal (NRC), w/a, N. H. Taylor (NRC), w/a, Senior Resident Inspector (NRC), w/a,

ET 16-0026

.* Page 3 of 3 STATE OF KANSAS SS COUNTY OF COFFEY Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

?/2{,___~~

By~-==--,4-~-=--:....._~~-L-~~'--1--~

Jaime . McCoy Vice resident Engineering SUBSCRIBED and sworn to before me this If° day of NOvember , 2016.

GAYLE SHEPHEARD My Appointment Expires July 24, 2019 Expiration Date ----'7/c-~_t/-_,_/_dJ._C)_/___

9___

Attachment to ET 16-0026

\/ Page 1 of 7 Site-Specific Spent Fuel Pool Criteria for Wolf Creek Generating Station The 10 CFR 50.54(f) letter (Reference 1) requested that, in conjunction with the response to Near-Term Task Force (NTTF) Recommendation 2.1, 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 Reference 2 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for Wolf Creek Generating Station (WCGS). By letter dated March 17, 2016 (Reference 3), the staff determined that EPRI 3002007148 (Reference 4) 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 WCGS 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.

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Site Parameters

1) The site-specific GMRS peak The GMRS peak spectral acceleration in the spectral acceleration at any Seismic Hazard Evaluation and Screening Report frequency should be less than or (Reference 5, Table 2.4-1 ), as accepted by the equal to 0.8g. NRC in Reference 6, is 0. 727g, which is less than 0.8g; therefore, this criterion is met.

Structural Parameters

2) The structure housing the SFP The SFP is housed in the Fuel Building (Reference should be designed using an SSE 7 Chapter 3, Section 3.8.4.1.2). Per USAR with a peak ground acceleration Chapter 9, Section 9.1 A.4.4 (Reference 7) the SFP (PGA) of at least 0.1g. has been designed in accordance with the criteria for Seismic Category 1 structures, and the Fuel Building is seismically designed to the site SSE with a PGA of 0.20g per Seismic Hazard Evaluation and Screening Report (Reference 5).

The WCGS PGA is greater than 0.1g; therefore, this criterion is met.

Attachment to ET 16-0026

" Page 2 of 7

3) The structural load path to the SFP The fuel building is supported on a two way should consist of some combination reinforced concrete base mat per Chapter 3, of reinforced concrete shear wall Section 3.8.4.1.2 of Reference 7, and the floors elements, reinforced concrete frame and roof are reinforced concrete slabs supported elements, post-tensioned concrete by structural steel beams and girders. The SFP elements and/or structural steel walls have been designed to resist SSE-induced frame elements. stresses per Reference 8, and the structural load path from the Fuel Building foundation to the SFP has been designed to resist SSE-induced stresses per Reference 9.

Based on the above discussion the load path criterion is met for WCGS.

4) The SFP structure should be The Fuel Building, which houses the SFP, is included in the Civil Inspection included in the WCGS Structural Monitoring Program performed in accordance Program, per Attachment B of Reference 10. This with Maintenance Rule. program includes regular inspections in accordance 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 Wolf Creek Generating Station.

Attachment to ET 16-0026 Page 3 of 7

c;i"\ i SFP Criteria from EPRl3002007148 Site'"SPe,C?ific Data; Non-Structural Parameters

5) To confirm applicability of the piping Piping & Instrumentation Diagram M-12EC01 evaluation in Section 3.2 of EPRI (Reference 11) shows 11 piping lines attached to 3002007148, piping attached to the the SFP, which are:

SFP up to the first valve should have been evaluated for the SSE. Isometric Drawing Line Function (Reference 11)

Essential Service M-13EF12 012-HCC-2 Water Essential Service M-13EF12 013-HCC-2 Water Suction of Fuel Pool Cooling (FPC) Pump M-13EC04 001-HCC-12 "A" Suction of FPC Pump M-13EC04 009-HCC-12 "B" SFP HX (Heat M-13EC04 011-HCC-10 Exchanaer) Return 003-HCC-10 SFP HX Return M-13EC04 Fuel Pool Clean-Up M-13EC04 094-HCC-6 Demineralizers 083-HCD- 2 M-13EC06 1/2 Pool Skimmer 086-HCD-2 M-13EC06 1/2 Pool Skimmer 084-HCD-2 M-13EC06 1/2 Pool Skimmer Recycle Evaporator M-13EC06 Feed Pumps to Fuel 079-HCD-3 Transfer Canal Per Wolf Creek's Piping Class Summary (Reference 12), lines 012-HCC-2, 013-HCC-2, 001-HCC-12, 009-HCC-12, 011-HCC-10, 003-HCC-10, and 094-HCC-6 are all Class 1 piping and as such have been designed for the SSE.

Attachment to ET 16-0026

'i Page 4 of 7 Upon review of the discussion provided on page 3-13 of Reference 4, the intent of the seismic evaluation criterion is to prevent rapid drain-down of the SFP inventory via a break in piping attached to the SFP below the surface of the water. Per Note 8 of M-12EC01 (Reference 11 ), lines 083-HCD- 2 /'2, 086-HCD-2 /'2, and 084-HCD-2 'Y2 penetrate the pool boundary 6 inches below normal pool water level. Per M-13EC06 (Reference 11 ), these lines do not route any further below this elevation inside the pool boundary. Additionally, each line has a %"

diameter vent hole located on top of the pipe. This shallow depth and vent holes preclude these lines as being a source of rapid drain-down and the intent of this criterion has been met for these lines.

Per Note 11 of M-12EC01 (Reference 11 ), line 079-HCD-3 penetrates the fuel transfer canal wall 12 inches above normal water level. Per M-13EC06 (Reference 11 ), this line does not route any further below this elevation inside the pool boundary. This line is not a possible source of drain-down and the intent of this criterion has been met for this line.

As discussed previously, piping attached to the SFP and capable of draining the SFP is evaluated to the SSE; therefore, this criterion is met for WCGS.

6) Anti-siphoning devices should be Per M-12ECO 1 (Reference 11) the termination for installed on any piping that could the Fuel Pool Cooling (FPC) pump suction lines lead to siphoning water from the 009-HCC-12 and 001-HCC-12 is at Elevation SFP. In addition, for any cases 2040'-0" (6'-0" below the normal water). Per where active anti-siphoning devices Section 9.1.3.2.1.1 of Reference 7, the top of the are attached to 2-inch or smaller fuel racks is at approximately Elevation 2021'. No piping and have extremely large anti-siphoning devices are present on the SFP HX extended operators, the valves suction lines. However, these lines are acceptable should be walked down to confirm because of the shallow elevation of the line adequate lateral support. termination. Additionally, these lines have been evaluated for the SSE, as discussed previously.

Attachment to ET 16-0026 Page 5 of 7 Per Section 9.1.3.2.1.1 of Reference 7, M-13EC04 (Reference 11 ), and Note 7 of M-12ECO 1 (Reference 11 ), a 3" siphon break is present on the SFP HX return lines 011-HCC-10 and 003-HCC-10 at Elevation 2043'-2". This siphon break precludes these lines as being a source of rapid drain-down.

As stated above, Lines 083-HCD- 2Yz, 086-HCD-2Yz, and 084-HCD-2Yz are SFP skimmers and located near the top of the pool, with the bottom of the skimmer weir located six inches below the water surface. Per M-12EC01 (Reference 11 ),

each line contains a %" siphon hole; therefore, no rapid drain-down is possible.

Line 094-HCC-6 flows into line 003-HCC-10 and does not penetrate the pool; therefore, it cannot directly siphon water from the SFP per M-12EC01 (Reference 11 ).

Line 079-HCD-3, as stated above, is located 12 inches above the water line and therefore cannot siphon water from the SFP.

Per M-12EC01(Reference11) and M-13EF12 (Reference 11 ), the termination for the Essential Service Water lines 012-HCC-2 and 013-HCC-2 is at Elevation 2044'-6" ( 1'-6" below the normal water). Per Section 9.1.3.2.1.1 of Reference 7, the top of the fuel racks is at approximately Elevation 2021 '. No anti-siphoning devices are present on these Essential Service Water lines; however, these lines are acceptable because the shallow elevation of the line termination precludes the possibility of drain-down. Additionally, these lines have been evaluated for the SSE, as discussed previously.

As described, all SFP piping that could lead to siphoning either has anti-siphoning devices installed or has been documented to be seismically adequate. There are no anti-siphoning devices attached to 2-inch or smaller piping with extremely large extended operators. This anti-siphoning criterion is therefore met for WCGS.

Attachment to ET 16-0026 Page 6 of 7

7) To confirm applicability of the The WCGS SFP has a length of 50'-0" and a width sloshing evaluation in Section 3.2 of of 28'-6" based on drawing C-1 C6211 (Reference EPRI 3002007148, the maximum 11 ). The bottom of the SFP liner is Elevation SFP horizontal dimension (length or 2006'-6" (Reference 11). Per Note 1 of M-12EC01 width) should be less than 125 ft, (Reference 11), lines 009-HCC-12" and 001-HCC-the SFP depth should be greater 12 penetrate the pool boundary 3'-0" below the than 36 ft, and the GMRS peak Sa normal water level of the pool. Per M-13EC04 should be <0.1 g at frequencies (Reference 11 ), these lines penetrate the pool equal to or less than 0.3 Hz. boundary at Elevation 2043'-0". Consequently, the normal water level is 2046'-0" and the total SFP depth is 39'-6".

Considering a nominal water depth to be 1'-6" from top of the pool, per Table 9.1-4 of Reference 7, the minimum water depth is 38'. All SFP dimensions are within the allowable dimensions; therefore, this criterion is met.

The Wolf Creek Generating Station GMRS maximum spectral acceleration in the frequency range less than 0.3 Hz is 0.0386 g from the Seismic Hazard Evaluation and Screening Report (Reference 5) which is less than 0.1g; therefore, this criterion is met.

8) To confirm applicability of the The surface area of the WCGS SFP is 1,425 ft 2 evaporation loss evaluation in based on drawing C-1 C6211 (Reference 11 ),

Section 3.2 of EPRI 3002007148, the which is greater than 500 ft2 ; and licensed reactor SFP surface area should be greater thermal power for WCGS is 3565 MWt per unit than 500 ft2 and the licensed reactor (Reference 7, Chapter 1, Section 1.1.5) which is core thermal power should be less less than 4,000 MWt per unit; therefore, these than 4,000 MWt per unit. criteria are met.

References:

1. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Request for Information Pursuant to Title 10 of the Code of Federal Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident," March 12, 2012. ADAMS Accession No. ML12053A340 (Letter), ML12056A046 (Pkg).

2. Letter from W. M. Dean, USNRC, to A C. Heflin, "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," October 27, 2015. ADAMS Accession No. ML15194A015.

Attachment to ET 16-0026 Page 7 of 7

3. Letter from J. R. Davis, USNRC, to A. N. Mauer, NEI, "Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation," March 17, 2016. ADAMS Accession No. ML15350A158.

4. EPRI 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation",

February 2016.

5. WCNOC Letter WO 14-0042, "Wolf Creek Nuclear Operating Corporation's Seismic Hazard and Screening Report (CEUS Sites), Response 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," March 31, 2014.

ADAMS Accession No. ML14097A020.

6. Letter from F. G. Vega, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station - 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-lchi Accident (TAC No. MF3755)", August 12, 2015. ADAMS Accession No. ML15216A320.

7. Wolf Creek Updated Safety Analysis Report (USAR), Rev 29

8. Wolf Creek Calculation 05-80-F, Rev. 1, "Fuel Building Spent Fuel Pool Walls Design"

9. Wolf Creek Calculation 05-82-F, Rev. 0, "Fuel Building Exterior Walls & Pilasters"

10. Wolf Creek Procedure, Al 23M-007, Rev. 5, "Structures Monitoring Program"

11. Wolf Creek Generating Station drawings:

i. C-1 C6211, Rev. 1, "Fuel Building Cone. Neat Line and Reinforcing Plan Floor EL 2026'-0" ii. M-13EC04, Rev. 6, "Piping Isometric of Fuel Pool Cooling & Clean-Up System Fuel Building" iii. M-13EF12, Rev. 8, "Essential Service Water Fuel Building" iv. M-13EC06, Rev. 2, "Piping Isometric of Fuel Pool Cooling & Clean-Up System Fuel Building"

v. M-12EC01, Rev. 21, "Piping & Instrumentation Diagram Fuel Pool Cooling and Clean-Up System

12. Wolf Creek MS-01, Rev. 76, "Piping Class Summary"