NRC-16-0067, 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

ML16344A257
Person / Time
Site:	Fermi
Issue date:	12/09/2016
From:	Polson K DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-16-0067
Download: ML16344A257 (7)

Text

Keith J. Polson Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.4172 Email: keith.polson@dteenergy.com

.7DTE Energy-10 CFR 50.54(f)

December 9, 2016 NRC-16-0067 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) 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 Number ML12053A340)

3) 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)

4) NEI Letter, Request for Endorsement of Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation (EPRI 3002007148),

dated February 23, 2016 (ADAMS Accession Number ML16055A017)

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

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

7) DTE Electric Company (DTE) Letter NRC-14-0017, DTE Electric Company's Seismic Hazard and Screening 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 Fukushimi Dai-ichi Accident, dated March 31, 2014 (ADAMS Accession Number ML14090A326)

USNRC NRC-16-0067 Page 2

8) NRC Letter, Fermi, Unit 2 - 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 (TAC No.

MF3861), dated October 5, 2015 (ADAMS Accession Number ML15077A028)

9) 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

10) DTE Report, Fermi 2 Updated Final Safety Analysis Report, Revision 20, May 2016 (ADAMS Accession Number ML16165A442)

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 On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a Request for Information per 10 CFR 50.54(f) (Reference 2) to all power reactor licensees. 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 3), the NRC transmitted final seismic information request tables, which identified that DTE Electric Company (DTE) is to conduct a limited scope SFP Evaluation. By Reference 4, the Nuclear Energy Institute (NEI) submitted an Electric Power Research Institute (EPRI) report entitled "Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (EPRI 3002007148)" (Reference 5) for NRC review and endorsement. NRC endorsement was provided by Reference 6.

EPRI 3002007148 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. The report supplements the guidance in the Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) (Reference 9), 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 DTE, and that the Fermi, Unit 2 (Fermi 2) SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

The enclosure to this letter provides the data for Fermi 2 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

USNRC NRC-16-0067 Page 3 associated with Near-Term Task Force (NTTF) Recommendation 2.1 Seismic evaluation criteria.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr. Scott A. Maglio, Manager - Nuclear Licensing, at (734) 586-5076.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on December 9, 2016 Keith J. Polson Site Vice President

Enclosure:

Site-Specific Spent Fuel Pool Criteria for Fermi 2 cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-16-0067 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Site-Specific Spent Fuel Pool Criteria for Fermi 2

Enclosure to NRC-16-0067 Page 1 Site-Specific Spent Fuel Pool Criteria for Fermi 2 The U.S. Nuclear Regulatory Commission (NRC) requested that, in conjunction with the response to Near-Term Task Force (NTTF) Recommendation 2.1 (Reference 2), a seismic evaluation be made of the spent fuel pool (SFP). Plants were asked to consider "all seismically induced failures that can lead to draining of the SFP." This evaluation is required for any plant in which the ground motion response spectrum (GMRS) exceeds the safe shutdown earthquake (SSE) in the 1 to 10 Hertz (Hz) frequency range. The NRC confirmed that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Fermi 2 site (References 3 and 8).

By letter dated March 17, 2016 (Reference 6), the NRC determined that Electric Power Research Institute (EPRI) report 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 Fermi 2 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 Site-Specific Data 3002007148 Site Parameters

1. The site-specific GMRS peak The GMRS peak spectral acceleration in the NTTF spectral acceleration at any 2.1 Seismic Hazard and Screening Report for Fermi 2 frequency should be less than or (Reference 7), as accepted by the NRC in NRC letter equal to 0.8g. dated October 5, 2015 (Reference 8), is 0.32g, 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 Reactor Building, which is should be designed using an SSE seismically designed to the site SSE with a PGA of with a peak ground acceleration 0.15g. The Fermi 2 PGA is greater than 0.1g.

(PGA) of at least 0.1g. 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 SFP consists of reinforced concrete shear wall combination of reinforced concrete elements. The pool walls themselves are reinforced shear wall elements, reinforced concrete shear walls as described in Section 9.1.2.2.1 concrete frame elements, post- of the Updated Final Safety Analysis Report tensioned concrete elements and/or (UFSAR) (Reference 10). Load is transferred to the structural steel frame elements. foundation via the multiple supporting reinforced concrete shear walls. The full load path can be traced in UFSAR Figures 3.7-12, 3.8-27, 3.8-28, and 3.8-40 (Reference 10). Therefore, this criterion is met.

Enclosure to NRC-16-0067 Page 2 SFP Criteria from EPRI Site-Specific Data 3002007148 Structural Parameters (cont.)

4. The SFP structure should be The SFP structure is included in the Fermi 2 Civil included in the Civil Inspection Inspection Program in accordance with 10 CFR 50.65, Program performed in accordance which monitors the performance or condition of with Maintenance Rule. 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.

Non-Structural Parameters

5. To confirm applicability of the Piping attached to the SFP is evaluated to the SSE in piping evaluation in Section 3.2 of accordance with the Fuel Pool Cooling and Cleanup EPRI 3002007148, piping attached System (FPCCS) Design Specification and UFSAR to the SFP up to the first valve Section 3.7 (Reference 10). All lines that penetrate should have been evaluated for the the pool are Seismic Category I or Seismic Category SSE. II/I, which is part of the SSE piping analysis. This piping qualification extends at least up to the first isolation valve for all piping penetrating the pool.

Therefore, this criterion is met.

6. Anti-siphoning devices should be Two 6 inch (in) lines penetrate the pool liner and installed on any piping that could discharge into the pool as part of the Pool Clean-Up lead to siphoning water from the Supply. Each line enters the pool 1 foot (ft) below the SFP. In addition, for any cases water surface and terminates 8 ft 6 in below the water where active anti-siphoning surface. Each of these lines has passive siphon devices are attached to 2-inch or breakers at a depth of 1 ft below the normal water smaller piping and have extremely level. It is therefore not possible to siphon more than large extended operators, the 1 ft of the pool inventory. There is 21 ft-6 in of water valves should be walked down to between the elevation of the siphon breakers and the confirm adequate lateral support. top of the fuel (reference plant drawings C-2419, M-3356, M-3357, and UFSAR Figures 9.1-3, 9.1-23).

No other lines penetrate the pool or the liner. A weir at the top of pool water level serves as the outlet for the FPCCS. No lines penetrate into the water from here, so siphoning from the weir is not possible.

Anti-siphoning devices are installed on all SFP piping that could lead to siphoning. Additionally, all anti-siphoning devices are passive. There are no active anti-siphoning devices necessary for the Fermi 2 SFP.

No anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators. Therefore, this criterion is met.

Enclosure to NRC-16-0067 Page 3 SFP Criteria from EPRI Site-Specific Data 3002007148 Non-Structural Parameters (cont.)

7. To confirm applicability of the The Fermi 2 SFP has a length of 40 ft, a width of 34 ft sloshing evaluation in Section 3.2 and a depth of 38 ft 9 in based on the UFSAR Section of EPRI 3002007148, the 9.1.2.2.1 (Reference 10).

maximum SFP horizontal dimension (length or width) The Fermi 2 GMRS maximum spectral acceleration in should be less than 125 ft, the SFP the frequency range equal to or less than 0.3 Hz is depth should be greater than 36 ft, 0.025g from the Seismic Hazard and Screening and the GMRS peak spectral Report (Reference 7), which is less than 0.1g.

acceleration (Sa) should be <0.lg at frequencies equal to or less than Therefore, this criterion is met.

0.3 Hz.

8. To confirm applicability of the The surface area of the Fermi 2 SFP is 1,360 ft2 ,

evaporation loss evaluation in which is greater than 500 ft2 ; and licensed reactor Section 3.2 of EPRI 3002007148, thermal power for Fermi 2 is 3,486 MWt, which is the SFP surface area should be less than 4,000 MWt per unit.

greater than 500 ft2 and the licensed reactor core thermal Therefore, this criterion is met.

power should be less than 4,000 MWt per unit.