ML20233B015
| ML20233B015 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/20/2020 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Gaston R Entergy Nuclear Operations |
| Guzman R | |
| References | |
| EPID L-2020-LLA-0051 | |
| Download: ML20233B015 (5) | |
Text
{{#Wiki_filter:1 Guzman, Richard From: Guzman, Richard Sent: Thursday, August 20, 2020 8:47 AM To: Gaston, Ronald William Cc: Schrage, John; Mirzai, Mahvash
Subject:
Indian Point Unit No. 3 - REQUEST FOR ADDITIONAL INFORMATION: LAR to Revise Licensing Basis for New Auxiliary Lifting Device [EPID L-2020-LLA-0051] Mr. Gaston, On August 7, 2020, the NRC staff sent Entergy Nuclear Operations, Inc. (Entergy, the licensee) the subject Request for Additional Information (RAI) as a draft. This RAI relates to the license amendment request submitted by Entergy dated March 24, 2020 (ADAMS Accession No. ML20084U773), proposing to incorporate, into the Indian Point Unit 3 (IP3) Licensing Basis, the installation and use of a new single failure proof auxiliary lifting device (i.e., the Holtec International HI-LIFT) to handle a dry cask storage transfer cask in the IP3 Fuel Storage Building. On August 18, 2020, the NRC staff conducted a conference call with the licensee staff to clarify the request. Following the discussion, you indicated that Entergy will provide a response to this RAI within 45 days from the issuance of the RAI; therefore, the NRC staff expects Entergys formal response by October 5, 2020. Updated below is the official (final) RAI. A publicly available version of this e-mail and RAI will be made an official agency record and placed in ADAMS, the NRCs official recordkeeping system. Please contact me should you have any questions in regard to this request. Sincerely, Richard V. Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov
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REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE STRUCTURAL REVIEW (ESEB) OF THE PROPOSED LICENSE AMENDMENT REQUEST TO REVISE THE LICENSING BASIS FOR INSTALLATION AND USE OF A NEW AUXILIARY LIFTING DEVICE INDIAN POINT NUCLEAR GENERATING STATION, UNIT NO. 3 DOCKET NO. 50-286 EPID L-2020-LLA-0051
2 By letter dated March 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20084U773), Entergy Nuclear Operations, Inc. (the licensee) submitted a license amendment request (LAR) for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment would incorporate, into the IP3 Licensing Basis, the installation and use of a new single failure proof auxiliary lifting device (i.e., the Holtec International HI-LIFT) to handle a dry cask storage transfer cask in the IP3 Fuel Storage Building. The change to the IP3 licensing basis would be documented via revision to the IP3 Updated Final Safety Analysis Report (UFSAR). The Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete its review, as described in the request for additional information (RAI) shown below. RAI-1 (ESEB-Structural)
Background:
The licensee described the applicable regulatory requirements and criteria in Section 4.0 Regulatory Evaluation, in Enclosure NL-20-021 Evaluations of the Proposed Change, (Agencywide Documents Access and Management System (ADAMS) Accession No ML20084U773), which includes protecting the IP3 spent fuel pool (SFP) and the IP3 fuel storage building (FSB) truck bay walls from the effects of natural phenomena such as earthquake as required in General Design Criterion (GDC) 2, "Design Bases for Protection Against Natural Phenomena," of Appendix A to 10 CFR Part 50. a) In Section 3.0 Methodology and Analysis, HOLTEC Report, HI-2188625, Revision 1, (ADAMS Accession No ML20084U778), the licensee stated the load combinations listed in Section 2.0 Acceptance Criteria and Load Combinations, were considered under the three loading orientations, CASE A, CASE B, and CASE C. b) Based on HOLTEC Drawing No. 11654, HI-LIFT Ancillary Lift Device, Revision 1, Sheet 11 of 12 in HOLTEC Report HI-2188549, Revision 1, (ADAMS No ML20084U778), the NRC staff determined an operational luffing-motion angle of the HI-LIFT lifting device support-arm. Issues: a) The NRC staff was not able to determine in the UFSAR whether the licensee described the operating range (luffing-motion angle) of the HI-LIFT lifting device support-arm loading orientations from CASE B to CASE C of the HI-LIFT lifting device. b) The NRC staff determined the HI-LIFT lifting device support-arm luffing-motion angle by taking the angular difference of the loading orientations of CASE C and CASE B. However, the luffing-motion angle of the HI-LIFT lifting device support-arm in drawing No. 11654 does not reflect the same angle. Request: a) The NRC staff is requesting the licensee to augment the proposed UFSAR as appropriate to specifically reflect the operating range of the HI-LIFT lifting device support-arm by providing the luffing-motion angle. b) The NRC staff is requesting the licensee to address this discrepancy of HI-LIFT lifting device support-arm luffing-motion angle. The staff also requested the licensee to check whether this discrepancy would affect the loading conditions (CASE B and CASE C) and would adversely affect the results of the analyses.
3 RAI-2 (ESEB-Structural)
Background:
GDC 1, Quality Standards and Records, of Appendix A to 10 CFR Part 50, specifies, in part, that structures, systems, and components (SSCs) important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. Where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability. In HOLTEC Report, HI-2188625, Revision 1 (ADAMS Accession No. ML20084U778), the licensee submitted Subsections D4.2 Truckbay Wall ANSYS Model Description, and D.5.2 Spent Fuel Pool Wall ANSYS Model Description. Issue: Based on the review, it is not clear to the NRC staff whether effects of potential concrete cracking can be represented using the specified ANSYS model element under postulated loading conditions. The specified ANSYS model elements can be extremely stiff in bending and it is generally recommended that at least three elements be used through the thickness for reasonable results. Furthermore, the boundary conditions have to be applied to all the nodes of the specified elements to achieve the correct deformation behavior. Request: a) The NRC staff is requesting the licensee to describe the capabilities of the specified element in use of reinforced concrete structures. It is not clear to the staff how the existing reinforcement in the SFP and truck bay walls were considered in the ANSYS model. b) The NRC staff is requesting the licensee to justify the use of its proposed layer of elements through the thicknesses of the SFP and truck bay walls in the ANSYS models.
4 RAI-3 (ESEB-Structural)
Background:
GDC 1, Quality Standards and Records, and GDC 2 "Design Bases for Protection Against Natural Phenomena," of Appendix A to 10 CFR Part 50, specifies, in part, that SSCs important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed using generally recognized codes and standards under the effects of natural phenomena such as earthquake. In HOLTEC Report, HI-2188625, Revision 1, the licensee provided Appendix E, Structural Qualification of Concrete Anchoring System. Issue: While reviewing the sample calculation provided in Appendix E, the NRC staff was unable to determine whether or not the licensee considered anchor behavior effects under loads such as embedment size (overlapping), edge distance, prying, etc., per the requirements of ACI 349-85 standard in the calculations. Otherwise, the load-carrying capacity of anchors may be overestimated without the consideration of these anchor behavior effects under loading. Request: The NRC staff is requesting the licensee to describe whether the anchor behavior effects under loads, per the requirements of ACI 349-85, were considered in the calculations. If not, the licensee is requested to either provide justification for not considering anchor behavior effects or to revise the anchor calculations as necessary.
5 RAI-4 (ESEB-Structural)
Background:
GDC 1, Quality Standards and Records, of Appendix A to 10 CFR Part 50, specifies, in part, that SSCs important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. Where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability. In Section 3.5 Testing, of Enclosure NL-20-021 dated March 24, 2020, the licensee stated, The complete HI-LIFT will be load tested in the exact configuration that will be used to lift the loaded HI-TRAC. In Section E.6 Conclusions, of Appendix E in HOLTEC Report, HI-2188625, Revision 1, the licensee also provided statements regarding anchor testing for design adequacy verification. However, there was no discussion of if, or how, the truck bay wall through bolts will be tested. Issue: Based on the review, the NRC staff was not able to determine which ACI Code and its provision(s) the licensee will be implementing to test the grouted anchors. It is not clear to the staff whether the licensee will also test the truck bay wall through bolts. Request: The NRC staff is requesting the licensee to provide the applicable ACI code and its associated provision(s) for testing the grouted anchors and through bolts (if applicable). The staff is also requesting the licensee augment the UFSAR as appropriate to reflect the applicable standards for testing of anchors/bolts.
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