ML16355A166

Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1

ML16355A166
Person / Time
Site:	Davis Besse
Issue date:	01/12/2017
From:	Frankie Vega Japan Lessons-Learned Division
To:	Boles B FirstEnergy Nuclear Operating Co
Vega F, NRR/JLD 415-1617
References
CAC MF3728
Download: ML16355A166 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 12, 2017 Mr. Brian D. Boles FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 (CAC NO. MF3728)

Dear Mr. Boles:

The purpose of this letter is to inform FirstEnergy Nuclear Operting Company (FENOC, the licensee) of the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel pool (SFP) evaluation for Davis-Besse Nuclear Power Station, Unit 1 (DBNPS), which was submitted in response to Item 9 of Enclosure 1 of the NRC's March 12, 2012, request for information (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340) issued under Title 1O of the Code of Federal Regulations Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter). The NRC staff concludes that the licensee's assessment was performed consistent with the NRG-endorsed SFP Evaluation Guidance Report and that the licensee has provided sufficient information to complete the response to Item 9 of the 50.54(f) letter.

BACKGROUND On March 12, 2012, the NRC issued a 50.54(f) letter as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate seismic hazards at their sites using present-day methodologies and guidance. Enclosure 1, Item 4, of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) and the safe shutdown earthquake (SSE). The staff's assessment of the information provided in response to Items 1-3 and 5-7 of the 50.54(f) letter is provided by letter dated August 25, 2015 (ADAMS Accession No. ML15230A289). Enclosure 1, Item 9, of the 50.54(f) letter requested that, when the GMRS exceeds the SSE in the 1 to 1O Hertz frequency range, 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."

B. Boles By letter dated February 23, 2016 (ADAMS Accession No. ML16055A021 ), the Nuclear Energy Institute (NEI) staff submitted Electric Power Research Institute (EPRI) Report No. 3002007148 entitled , "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating the seismic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements the guidance in EPRI Report 1025287, "Seismic Evaluation Guidance: Screening , Prioritization and Implementation Details (SPID)" (ADAMS Accession No. ML12333A170), for plants where the GMRS peak spectral acceleration is less than or equal to 0.8g (low GMRS sites). The NRC endorsed the SFP Evaluation Guidance Report by letter dated March 17, 2016 (ADAMS Accession No. ML15350A158), as an acceptable method for licensees to use when responding to Item 9 in Enclosure 1 of the 50.54(f) letter.

By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRC staff stated that SFP evaluation submittals for low GMRS sites are expected by December 31, 2016.

REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION By letter dated December 9, 2016 (ADAMS Accession No. ML16344A010), FE NOC submitted its SFP evaluation for DBNPS for NRC review. The NRC staff assessed the licensee's implementation of the SFP Evaluation Guidance Report through the completion of a reviewer checklist, which is included as an enclosure to this letter.

TECHNICAL EVALUATION Section 3.0 of the SFP Evaluation Guidance Report develops SFP evaluation criteria for plants with GMRS peak spectral acceleration less than or equal to 0.8g. These criteria address SFP structural elements (e.g. , floors, walls, and supports); non-structural elements (e.g. ,

penetrations) ; seismically-induced SFP sloshing ; and water losses due to heat-up and boil-off.

Section 3.0 also provides applicability criteria, which will enable licensees to determine if their site-specific conditions are within the bounds considered in developing the evaluation criteria for this report. The staff's review consists of confirming that these SFP site-specific conditions are within the bounds considered for the evaluation criteria specified in the SFP Evaluation Guidance Report.

1.1 Spent Fuel Pool Structural Evaluation Section 3.1 of the SFP Evaluation Guidance Report provides a SFP structural evaluation approach used to demonstrate that the SFP structure is sufficiently robust against the reevaluated seismic hazard . This approach supplements the guidance in Section 7 of the SPID and followed acceptable methods used to assess the seismic capacity of structures, systems, and components (SSCs) for nuclear power plants as documented in EPRI NP-6041 , "A Methodology for Assessment of Nuclear Plant Seismic Margin , Revision 1." Table 3-2 of the SFP Evaluation Guidance Report (reproduced from Table 2.3 of EPRI NP-6041) provides the structural screening criteria to assess the SFPs and their supporting structures.

The licensee stated that it followed the SFP structural evaluation approach presented in the SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability.

B. Boles The NRC staff reviewed the structural information provided, which included the requested site-specific data in Section 3.3 of the SFP Evaluation Guidance Report, and confirmed that the evaluation criteria are applicable to the DBNPS site. The staff concludes that SFP SSCs were appropriately evaluated and screened based on the seismic capacity criteria in EPRI NP-6041 ,

and that the licensee has demonstrated that the SFP structure is sufficiently robust and can withstand ground motions with peak spectral acceleration less than or equal to 0.8g.

1.2 Spent Fuel Pool Non-Structural Evaluation Section 3.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the non-structural aspects of the SFP, such as piping connections , fuel gates, and anti-siphoning devices, as well as SFP sloshing and heat up and boil-off of SFP water inventory. Specifically, Table 3-4 of the SFP Evaluation Guidance Report provides a summary of the SFP non-structural evaluation criteria derived in Section 3.2, along with applicabil ity criteria to demonstrate that site-specific conditions are suitable for applying the evaluation criteria.

The licensee stated that it followed the SFP non-structural evaluation approach presented in the guidance report and provided site-specific data to confirm its applicability. The staff reviewed the non-structural information provided, which included the requested site-specific data in Table 3-4 of the SFP Evaluation Guidance Report, and confirmed that the evaluation criteria are applicable to the DBNPS site. Therefore, the staff concludes that the licensee adequately evaluated the non-structural considerations for SSCs whose failure could lead to potential drain-down of the SFP due to a seismic event.

CONCLUSION The NRC staff reviewed FENOC's SFP evaluation report. Based on its review, the NRC staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria of the SFP Evaluation Guidance Report for DBNPS and therefore , the licensee responded appropriately to Item 9 in Enclosure 1 of the NRC's 50.54(f) letter.

B. Boles If you have any questions, please contact me at (301) 415-1617 or via e-mail at Frankie.Vega@nrc.gov.

Fra kie Vega, Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Technical Review Checklist cc w/encl : Distribution via Listserv

TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SPENT FUEL POOL EVALUATIONS FOR LOW GROUND MOTION RESPONSE SPECTRUM SITES IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 SEISMIC DAVIS-BESSE NUCLEAR POWER STATION , UNIT 1 DOCKET NO. 50-346 BACKGROUND By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), 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 Licenses" (hereafter referred to as the "50.54(f) letter"). of the 50.54(f) letter requests addressees to reevaluate the seismic hazard at thei r 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 by the reevaluated seism ic hazards. Enclosure 1, Item 4, of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) with the safe shutdown earthquake (SSE). Enclosure 1, Item 9, requests that, when the GMRS exceeds the SSE in the 1 to 10 Hertz (Hz) frequency range, a seism ic 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."

Additionally, by letter dated February 23, 2016 (ADAMS Accession No. ML16055A021), the Nuclear Energy Institute (NEI) submitted Electric Power Research Institute (EPRI) Report No.

3002007148 entitled , "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report) . The SFP Evaluation Guidance Report supports the completion of SFP evaluations for sites with reevaluated seismic hazard exceedance in the 1 to 10 Hz frequency range. Specifically, the SFP Evaluation Guidance Report addressed those sites where the GMRS peak spectral acceleration (Sa) is less than or equal to 0.8g (low GMRS sites). The NRC endorsed the SFP Evaluation Guidance Report by letter dated March 17, 2016 (ADAMS Accession No. ML15350A158), as an acceptable method for licensees to use when responding to Item 9 in Enclosure 1 of the 50.54(f) letter. Licensee deviations from the SFP Evaluation Guidance should be discussed in their SFP evaluation submittal.

By letter dated December 9, 2016 (ADAMS Accession No. ML15230A289), FirstEnergy Nuclear Operting Company (FENOC, the licensee) , submitted its SFP report in a response to Enclosure 1, Item 9, of the 50.54(f) letter, for the Davis-Besse Nuclear Power Station , Unit 1 (DBNPS).

The NRC staff performed its review of FENOC's submittal to assess whether the licensee responded appropriately to Item 9 in Enclosure 1 of the 50.54(f) letter. The NRC staff checked whether the site-specific parameters are within the bounds of the criteria considered in the SFP Evaluation Guidance Report, verified the SFP's seismic adequacy to withstand the reevaluated GMRS hazard levels, and confirmed that the requested information in response to Item 9 of the 50.54(f) letter was provided .

Enclosure

A review checklist was used for consistency and scope. The application of this staff review is limited to the SFP evaluation as part of the seismic review of low GMRS sites as part of the Near-Term Task Force (NTTF) Recommendation 2.1.

NTTF Recommendation 2.1 Spent Fuel Pool Evaluations Technical Review Checklist for Davis-Besse Nuclear Power Station Site Parameters:

I. Site-Specific GMRS The licensee:

• Provided the site-specific GMRS consistent with the information Yes provided in the Seismic Hazard and Screening Report (SHSR), or its update, and evaluated by the staff in its staff assessment.

• Stated that the GMRS peak Sa is less than or equal to 0.8g for any Yes frequency.

Notes from the reviewer:

1. The NRC staff confirmed that the site-specific peak Sa= 0.54g (updated GMRS was provided in the Expedited Seismic Evaluation Process (ESEP) Report (ADAMS Accession No. ML14353A060)).

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

No deviations or deficiencies were identified.

The NRC staff concludes:

• The site-specific GMRS peak Sa at any frequency is less than 0.8g . Yes

• The licensee's GMRS used in this evaluation is consistent with the Yes information provided in the SHSR , or its update, and evaluated by the staff in its staff assessment.

Structural Parameters:

II. Seismic Design of the SFP Structure The licensee:

• Specified the building housing the SFP. Yes

• Specified the plant's peak ground acceleration (PGA). Yes

• Stated that the building housing the SFP was designed using an Yes SSE with a PGA of at least 0.1 g.

Notes from the reviewer:

1. The NRG staff confirmed that the SFP is housed in the auxiliary building, which is seismically designed to the site SSE with a PGA of 0.15g (SHSR Section 2.0 (ADAMS Accession No. ) and Updated Final Safety Analysis Report (UFSAR , Section 3.2.1 ).

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

No deviations or deficiencies were identified .

The NRC staff concludes that:

• The structure housing the SFP was designed using an SSE with a Yes PGA of at least 0.1g.

Ill. Structural Load Path to the SFP The licensee:

• Provided a description of the structural load path from the Yes foundation to the SFP.

• Performed screening based on EPRI NP-6041 Table 2-3 screening Yes criteria.

Notes from the reviewer:

1. The staff verified the structural load path to the SFP.

2. The staff confirmed that the SFP is located in the auxiliary building, which is constructed of steel framing and reinforced concrete walls, roofs and floors, founded on a 3 ft. thick reinforced concrete slab placed on bedrock. The SFP is constructed of reinforced concrete exterior walls and floor (UFSAR Section 3.8.1).

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

No deviations or deficiencies were identified.

The NRC staff concludes that:

• Licensee appropriately described the structural load path to the Yes SFP.

• Structures were appropriately screened based on the screening Yes criteria in EPRI NP-6041.

IV. SFP Structure Included in the Civil Inspection Program Performed in Accordance with Maintenance Rule The licensee:

• Stated that the SFP structure is included in the Civil Inspection Yes Program performed in accordance with Maintenance Rule (1 O CFR 50.65).

Notes from the reviewer:

None Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

• The SFP structure is included in the Civil Inspection Program Yes performed in accordance with Maintenance Rule (1 O CFR 50.65) .

Non-Structural Parameters:

V. Applicability of Piping Evaluation The licensee:

• Stated that piping attached to the SFP is evaluated to the SSE. No Notes from the reviewer:

1. The licensee stated that all piping attached to the SFP are seismically qualified (UFSAR Section 9.1.3) except five bore lines and an overfill line. These non-seismically-qualified lines are located approximately 20 ft. above the top of active fuel.

2. The licensee stated that any failure of these lines will provide sufficient water cover over the spent fuel elements and will provide approximately 178 hours0.00206 days <br />0.0494 hours <br />2.943122e-4 weeks <br />6.7729e-5 months <br /> before the top 1/3 of the SFP is uncovered.

3. Section 3.2 of the SFP Evaluation Guidance ensures that the SFP level is mantained above 2/3 of the height of the fuel for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. As stated above, this criterion would be met even if these non-seismically-qualified lines failed.

4. Based on the review of the justification provided by the licensee regarding the design and configuration of piping attached to the SFP and its rapid drain-down analysis, NRC staff concludes that the information provided was sufficient to confirm aoolicability of the pipinQ evaluation in Section 3.2 of the SFP evaluation quidance.

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

No deviations or deficiencies were identified.

The NRC staff concludes that:

• The piping attached to the SFP is evaluated to the SSE . No

• Failure of piping attached to the SFP is not likely to result in rapid Yes drain-down as defined in the SFP evaluation guidance.

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

VI. Siphoning Evaluation The licensee:

• Stated that anti-siphoning devices are installed on piping systems No that could lead to siphoning inventory from the SFP.

• In cases where anti-siphoning devices were not included on the applicable piping, a description documenting the evaluation Yes performed to determine the seismic adequacy of the piping is provided.

• Stated that the piping of the SFP cooling system cannot lead to rapid Yes drain down due to siphoning.

• Provided a seismic adequacy evaluation, in accordance with NP-N/A 6041 , for cases where active siphoning devices are attached to 2" or smaller piping with extremely large extended operators.

• Stated that no anti-siphoning devices are attached to 2" or smaller Yes piping with extremely large extended operators.

Notes from the reviewer:

1. The licensee stated that no anti-siphoning devices are used because SFP piping is designed to prevent siphoning of water to a water level below approximately 1O feet above the top of the spent fuel rack (UFSAR Section 9.1.2.3) .

2. Licensee stated that no active anti-siphoning devices are attached to 2" or smaller piping with extremely large extended operator.

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

No deviations or deficiencies were identified.

The NRC staff concludes:

• Anti-siphoning devices exist in applicable piping systems that could No lead to siphoning water from the SFP.

• Given the SFP piping design , piping of the SFP cooling system is not Yes likely to lead to rapid draindown due to siphoning .

• No active anti-siphoning devices are attached to 2" or smaller piping Yes with extremely large extended operators.

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

VII. Sloshing Evaluation The licensee:

• Specified the SFP dimensions (length, width , and depth). Yes

• Specified that the SFP dimensions are bounded by the dimensions Yes specified in the report (i.e. SFP length and width <125ft. ; SFP depth >36ft.).

• Stated that the peak Sa in the frequency range less than 0.3 Hz is Yes less than 0.1g.

Notes from the reviewer:

1. SFP dimensions:

- SFP Length - 20 ft.

- SFP Width - 53 ft.

- SFP Depth - 39 ft. 6 in.

2. The staff confirmed in the ESEP report that the peak Sa in the frequency range less than 0.3 Hz is less than 0.1 g (SHSR).

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

No deviations or deficiencies were identified.

The NRC staff concludes:

• SFP dimensions are bounded by the dimensions specified in the Yes report (i.e. SFP length and width <125ft. ; SFP depth >36ft.).

• The peak Sa in the frequency range less than 0.3 Hz is less than Yes 0.1g.

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

VIII. Evaporation Evaluation The licensee:

• Provided the surface area of the plant's SFP . Yes

• Stated that the surface area of the plant's SFP is greater than Yes 500 ft2 .

• Provided the licensed reactor core thermal power . Yes

• Stated that the reactor core thermal power is less than 4,000 Yes MW1per unit.

Notes from the reviewer:

1. Surface area of pool = 1056.96 ft 2 (UFSAR Section 9.1.3.3)

2. Reactor thermal power= 2,817 MW1(UFSAR Section 1.0)

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

No deviations or deficiencies were identified.

The NRC staff concludes:

• The surface area of the plant's SFP is greater than 500 ft 2. Yes

• The reactor core thermal power is less than 4,000 MW1per unit. Yes

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

==

Conclusions:==

The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the FENOC's implementation of the SFP integrity evaluation met the criteria of the SFP Evaluation Guidance Report for DBNPS and therefore the licensee responded appropriately to Item 9 in Enclosure 1 of the 50.54(f) letter.

ML16355A166 *via e-mail OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRR/JLD/JHMB/BC(A)

NAME FVega SLent GBowman DATE 01/09/2017 12/21/2016 01/12/2017 OFFICE NRR/JLD/JHMB/PM NAME FVega DATE 01/12/2017