ONS-2017-087, 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 ...

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 ...

ML17348A075
Person / Time
Site:	Oconee
Issue date:	12/04/2017
From:	Burchfield J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2017-087
Download: ML17348A075 (7)

Text

J. Ed Burchfield, Jr.

J_-,DUKE Vice President Oconee Nuclear Station

~ ENERGY Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 o: 864.873. 3478 ONS-2017-087 f. 864 .873. 4208 Ed.Burchfield@duke-energy.com December 4, 2017 ATTN: Document Control Desk 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolina, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55

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, ADAMS Accession No. ML12053A340

2. 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, ADAMS Accession Number ML15194A015

3. NEI Letter, transmits EPRI 3002009564 for NRC endorsement, dated January 31, 2017, ADAMS Accession Number ML17031A171

4. EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated January 2017

5. NRC Letter, Endorsement of EPRI 3002009564, dated February 28, 2017, ADAMS Accession Number ML17034A408 *

6. Duke Energy Letter, Seismic Hazard and Screening Report (CEUS Sites), Response to NRG 10 CFR 50.54(f) 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 31, 2014 ADAMS Accession No .. ML14092A024

7. NRC Letter, Oconee Nuclear Station, Units 1, 2, And 3 - 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 Dal-lchi Accident, dated July 22, 2015, ADAMS Accession Number ML15201A008

ONS-2017-087 December 4, 2017 Page 2 Ladies and Gentlemen, 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. By letter dated October 27, 2015 (Reference 2), the NRC transmitted final seismic information request tables which identified that Oconee Nuclear Station is to conduct a limited scope Spent Fuel Pool (SFP) Evaluation. By Reference 3, Nuclear Energy Institute (NEI) submitted Electric Power Research Institute (EPRI) report; EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (Reference 4) to the NRC for review and endorsement. NRC endorsement was provided by Reference 5.

EPRI 3002009564 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. Section 4.3, lists the parameters to be verified which confirm that the results of the report are applicable to Oconee Nuclear Station, and that the SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

The attachment to this letter provides the Oconee Nuclear Station data and, consistent with the EPRI 3002009564 criteria, confirms that the SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

There are no regulatory cbmmitments associated with this letter.

Should you have any questions regarding this submittal, please contact David Haile with Oconee Regulatory Affairs, at (864) 873-4742.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 4, 2017.

Sincerely,

)GI~/

J. Ed Burchfield, Jr.

Vice President Oconee Nuclear Station

Attachment:

NTTF 2.1 Seismic Recommendation:

Site-Specific Spent Fuel Pool Criteria for Oconee Nuclear Station

-ONS-20F-087 December 4, 2017 Page 3 cc:

Ms. Catherine Haney, Regional Administrator - Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atla~ta, Georgia 30303-1257 Mr. Brian Holian, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike M/S 0-13H 16 Rockville, MD 20852-2738 Ms. Audrey Klett, Project Manager (ONS)

(by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike M/S 0-08B 1A Rockville, Maryland 20852 Stephen Wyman (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 12 D20 Rockville, MD 20852 Brett A. Titus (by electronic mail only)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 12 D20 Rockville, MD 20852 Mr. Eddy Crowe (by electronic mail only)

NRC Senior Resident Inspector Oconee Nuclear Station

Attachment to Letter ONS-2017-087 ATTACHMENT Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55 NTTF 2.1 Seismic Recommendation:

Site-Specific Spent Fuel Pool Criteria for Oconee Nuclear Station Page 1 of 4

Attachment to Letter ONS-2017-087 The 50.54(f) Request for Information (Reference A-1) requested that, in response to 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 1Hz to 10 Hz frequency range.

The staff confirmed through References A-2 and A-7 that the Oconee Nuclear Station GMRS exceeds the SSE and thus a SFP evaluation is merited. By letter dated February 28, 2017 (Reference A-5), the staff determined that EPRI 3002009564 was an acceptable approach for performing SFP evaluations considering the GMRS hazard levels.

The table below lists the criteria from Section 4.3 of EPRI 3002009564 along with corresponding site-specific data for Oconee Nuclear Station which addresses the EPRI criteria and confirms the seismic adequacy of the SFP in accordance with the NTTF 2.1 Seismic recommendation.

SFf> Criteria from EPRI 3002009,564 Site-Specific Dc1ta ,

Site Parameters

1. The site-specific GMRS should be The Oconee Nuclear Station GMRS peak spectral the same as that submitted to the acceleration in Reference A-6 as accepted by the NRC NRC between March 2014 and in Reference A-7 is 0.874g.

July 2015, ,which the NRC has found acceptable for responding to the NRC 50.54(f) letter (Reference 7).

Structural Parameters

2. Site-specific calculations, performed A site-specific calculation (Reference A-8) performed in in accordance with Section 4.1 of accordance with Section 4.1 of EPRI 3002009564, EPRI 3002009564 should demonstrates that the limiting SFP HCLPF is 1.39g in demonstrate that the limiting SFP the frequency range of interest from 10 to 20 Hz, which HCLPF is greater than the site- exceeds the GMRS peak spectral acceleration of 0.86g specific GMRS in the frequency in that same frequency range.

range of interest (e.g., 10-20 Hz).

Therefore, this criterion is met for Oconee.

3. The SFP structure should be The SFP structure is included in the Oconee Nuclear included in the Civil Inspection Station Civil Inspection Program in accordance with Program performed in accordance 10 CFR 50.65. Oconee Procedure AD-EG-ONS-1214 with Maintenance Rule. Attachment 1 lists structures included in the civil inspection program and it includes the Auxiliary Building, Units 1, 2, and 3. The SFP structures are part of the Units 1, 2, and 3 Auxiliary Building. This inspection is performed in accordance with Maintenance Rule Functions ON-O-SFP2 and ON SFP3.

Therefore, this criterion is met for the Oconee Nuclear Station.

Page 2 of 4

Attachment to Letter ONS-2017-087 SFP Criteria from tEPRI 3002009.564 ~i-te"-Specific [fata Non-Structural Parameters 4.To confirm applicability of the piping The maximum depth of piping penetrations below the evaluation in Section 4.2 of EPRI water surface is less than 6 ft.

3002009564, piping attached to the Per Oconee Site Drawings 0-443 & 0-2443, there are SFP should have penetrations no 4 direct penetrations to the Unit 1 & 2 SFP and the Unit more than 6 ft below water surface.

3 SFP. All 8 penetrations are located between 840'-9" and 841 '-0" which is above the SFP Normal Water Level of Elev. 840'-0" as shown on Oconee Site Drawings OFD-104A-1.1 & OFD-104A-3.1.

Therefore, this criterion is met for the Oconee Nuclear Station.

5. To confirm ductile behavior under Oconee does not have SFP gates.

increased seismic demands, SFP Oconee does have fuel transfer tubes. The transfer gates should be constructed from tubes are sealed closed with a bolted steel flanged either aluminum or stainless steel cover and are constructed from a stainless steel alloy alloys.

as documented on Oconee Site Drawing OM-271-0235-001 Therefore, this criterion is met for the Oconee Nuclear Station.

6.Anti-siphoning devices should be The Oconee Unit 1& 2 SFP and Unit 3 SFP relies on installed on any piping that could passive design features to limit the amount of inventory lead to siphoning water from the which could be inadvertently drained. In general, the SFP. In addition, for any cases mechanical piping interfaces below the SFP normal where active anti-siphoning devices water level are either equipped with siphon breakers, are attached to 2-inch or smaller and/or the pipe elevation does not extend more than piping and have extremely large 4 ft below the normal SFP water level (Ref. DBD extended operators, the valves OSS-0254.00-00-1006, Sect. 4.1.1) should be walked down to confirm As described, no anti-siphoning devices can lead to adequate lateral support.

siphoning. In addition, no anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators (Ref. Duke drawings 0-443

&. 0-2443).

Therefore, this criterion is met for the Oconee Nuclear Station.

7. To confirm applicability of the The Oconee Nuclear Station Unit 1 & 2 SFP has a sloshing evaluation in Section 4.2 of length of 84 ft-3 in, a width of 24 ft and a depth of 38 ft EPRI 3002009564, the maximum at normal SFP level of 840 ft msl (Ref. Oconee Site SFP horizontal dimension (length or Drawing 0-18C and OFD-104A-1.1 ).

width) should be less than 125 ft The Oconee Nuclear Station Unit 3 SFP has a length and the SFP depth should be of 58 ft, a width of 24 ft and a depth of 38 ft at normal greater than 36 ft.

SFP level of 840 ft msl (Ref. Oconee Site Drawing 0-2154-S and OFD-104A-3.1 ).

Therefore, this criterion is met for the Oconee Nuclear Station.

Page 3 of 4

Attachment to Letter ONS-2017-087 SFP Criteria from EPRI 3002009564 Site-Specific Data

8. To confirm applicability of the The Oconee Nuclear Station Unit 1 & 2 SFP has a evaporation loss evaluation in surface area of 2022 ft 2 (Ref. Oconee Site Drawing Section 4.2 of EPRI 3002009564, 0-18C) and Unit 3 SFP has a surface area of 1392 ft 2 the SFP surface area should be (Oconee Site Drawing 0-2154-S ) which are both greater than 500 ft2 and the licensed greater.than 500 ft2. The licensed reactor thermal reactor core thermal power should power for Oconee is 2568 MWt per unit (Ref. UFSAR be less than 4,000 MWt per unit. Sect. 1.1) which is less than 4,000 MWt per unit.

Therefore, this criterion is met for the Oconee Nuclear Station.

References:

A-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, dated March 12, 2012, ADAMS Accession No. ML12053A340 A-2. 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, ADAMS Accession Number ML15194A015 A-3. NEI Letter, transmits EPRI 3002009564 for NRC endorsement, dated January 31, 2017, ADAMS Accession Number ML17031A171 A-4. EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated January 2017 A-5. NRC Letter, Endorsement of EPRI 3002009564, dated February 28, 2017, ADAMS Accession Number ML17034A408 A-6. Duke Energy Letter, Seismic Hazard and Screening Report (CEUS Sites), Response to NRC 10 CFR 50.54(f) 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 31, 2014 ADAMS Accession No. ML14092A024 A-7. NRG Letter, Oconee Nuclear Station, Units 1, 2, And 3 - 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 Dal-lchi Accident, dated July 22, 2015, ADAMS Accession Number ML15201A008 A-8. Jenson Hughes calculation No. 1PJA25021-AQ-CAL-001 (ONS SFP Structural Calculation)

Rev. 0, dated October 27, 2017 Page 4 of 4