RS-16-122, 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 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 Fukushima Dai-ichi Accident

ML16244A800
Person / Time
Site:	Byron
Issue date:	08/31/2016
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-16-122
Download: ML16244A800 (7)

Text

µ ExeLon Generation 10 CFR 50.54(f)

RS-16-122 August 31, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

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 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 (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 (ML15194A015)

3. NEI Letter, "Request for Endorsement of Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation (EPRI 3002007148)," dated February 23, 2016 (ML16055A017)

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

February 2016

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

6. Exelon Generation Company, LLC Letter to USNRC, "Seismic Hazard and Screening Report (Central and Eastern United States (CEUS) Sites), 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," dated March 31, 2014 (RS-14-065) (ML14091A010)

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 2

7. NRC Letter to Exelon Generation Company, LLC, "Byron Station, Units 1 and 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," dated February 17, 2016 (ML16027A045)

8. 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 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. Enclosure 1, Item (9) of the 50.54(f) letter requested addressees to provide spent fuel pool (SFP) integrity evaluations with any actions identified to address any discovered vulnerabilities. By letter dated October 27, 2015 (Reference 2), the NRC transmitted final seismic information request tables which identified that Byron Station, Units 1 and 2, is to conduct a limited scope SFP evaluation.

By Reference 3, Nuclear Energy Institute (NEI) submitted an Electric Power Research Institute (EPRI) report entitled, "Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation (EPRI 3002007148)," (Reference 4) for NRC review and endorsement. NRC endorsement was provided by Reference 5.

EPRI 3002007148 provides criteria for evaluating the seismic adequacy of a SFP to the reevaluated ground motion response spectrum (GMRS) hazard levels. The reevaluated GMRS, used for the SFP seismic demand, are documented in Reference 6 and endorsed by the NRC by Reference 7. This report supplements the guidance in the Seismic Evaluation Guidance, Screening, Prioritization and Implementation Details (SPID) (Reference 8), 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 Byron Station, Units 1 and 2, and that the Byron Station, Units 1 and 2, SFP is seismically adequate in accordance with Near Term Task Force (NTTF) 2.1 Seismic evaluation criteria.

The attachment to this letter provides the data for Byron Station, Units 1 and 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 associated with NTTF Recommendation 2.1 Seismic evaluation criteria.

This letter closes Commitment No. 2 of Reference 6.

This letter contains no new regulatory commitments or revisions to existing regulatory commitments.

If you have any questions regarding this report, please contact Ronald Gaston at 630-657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31"t day of August 2016.

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 3 Respectfully submitted,

/

Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Site-Specific Spent Fuel Pool Criteria for Byron Station, Units 1 and 2 cc: Regional Administrator - NRC Region III NRC Senior Resident Inspector Byron Station NRC Project Manager, NRR Byron Station Mr. Nicholas DiFrancesco, NRR/JLD/JHMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT Site-Specific Spent Fuel Pool Criteria for Byron Station, Units 1 and 2

Byron Station, Units 1 and 2 Seismic Spent Fuel Pool Evaluation Page 1 of 3 The 10 CFR 50.54(f) letter requested that, in conjunction with the response to Near Term Task Force (NTTF) Recommendation 2.1, a seismic evaluation be made of the Byron Station, Units 1

& 2 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 References G and K that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Byron Station, Units 1 and 2. By letter dated March 17, 2016 (Reference H) the NRC staff determined that EPRI 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 Byron Station, Units 1 and 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 3002007148 Site-Specific Data Site Parameters

1. The site-specific GMRS peak The GMRS peak spectral acceleration for Byron spectral acceleration at any Station, Units 1 & 2, in Reference J (Table 2.4-1) as frequency should be less than or accepted by the NRC in Reference K is 0.583g, equal to 0.8g. which is _< 0.8g; therefore, this criterion is met.

Structural Parameters

2. The structure housing the SFP The Byron Station, Units 1 and 2 SFP is housed in should be designed using an SSE the Fuel Handling Building, which is seismically with a peak ground acceleration designed to the site SSE with a PGA of 0.20g per (PGA) of at least 0.1 g. Reference J, Section 3.1. The PGA for Byron Station, Units 1 and 2, is greater than 0.1 g; therefore, this criterion is met.

3. The structural load path to the SFP The Byron Station Units 1 & 2, SFP is a should consist of some combination conventionally reinforced concrete structure. The of reinforced concrete shear wall load path from the foundation to the SFP consists of elements, reinforced concrete frame a 6-foot thick concrete slab founded on rock with 5-elements, post-tensioned concrete foot thick (minimum) wall thicknesses (References M elements and/or structural steel and N); therefore, this criterion is met.

frame elements.

4. The SFP structure should be The SFP structure is included in the Byron Station, included in the Civil Inspection Units 1 and 2, Structures Monitoring Program Program performed in accordance (Reference A) in accordance with 10 CFR 50.65, with Maintenance Rule. which monitors the performance or condition of structures, systems, and 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.

Byron Station, Units 1 and 2 Seismic Spent Fuel Pool Evaluation Page 2of3 SFP Criteria from EPRI 3002007148 Site-Specific Data Non-Structural Parameters

5. To confirm applicability of the piping Piping attached to the Byron Station, Units 1 and 2, evaluation in Section 3.2 of EPRI SFP is evaluated to the SSE in accordance with 3002007148, piping attached to the Reference B; therefore, this criterion is met.

SFP up to the first valve should have been evaluated for the SSE.

6. Anti-siphoning devices should be There are no anti-siphoning devices attached to any installed on any piping that could piping that enters the Byron Station, Units 1 and 2 lead to siphoning water from the SFP. Anti-siphoning features associated with SFP SFP. In addition, for any cases piping consists of vent holes provided just below the where active anti-siphoning devices water level in the 14-inch SFP cooling system return are attached to 2-inch or smaller line and the 2-inch piping from each of the two SFP piping and have extremely large skimmers (Reference C). Thus, failure of these extended operators, the valves pipes will not result in any loss of SFP inventory due should be walked down to confirm to siphoning.

adequate lateral support.

The two 12-inch SFP cooling system suction lines, two 2-inch SFP skimmer pump return lines and one 2-inch cask area fill line are not provided with anti-siphoning features, however, these pipes extend to a maximum distance approximately 8-feet below the normal SFP water level (References D, P and Q).

Should failure of these lines external to the SFP result in siphoning of the SFP water, there would still be greater than 15-feet of water remaining above the top of the Spent Fuel Storage Racks. Thus failure of these pipes outside the SFP would not lead to uncovering the spent fuel.

Since there are no anti-siphoning devices attached to any piping that enters the Byron Station, Units 1 and 2 SFP, there are no active anti-siphoning devices are attached to 2-inch or smaller piping and have extremely large extended operators.

Therefore, these criteria are met.

7. To confirm applicability of the The Byron Station, Units 1 and 2, SFP has a length sloshing evaluation in Section 3.2 of of 62.0 ft., a width of 33.1 ft. and a depth of 41.33 ft.

EPRI 3002007148, the maximum (References E and F); therefore, this criterion is met.

SFP horizontal dimension (length or The Byron Station, Units 1 and 2, GMRS maximum width) should be less than 125 ft, the spectral acceleration in the frequency range equal to SFP depth should be greater than or less than 0.3 Hz is 0.03g from Reference J, 36 ft, and the GMRS peak Sa should Section 2.4, which is less than 0.1g; therefore, this be <0.1 g at frequencies equal to or criterion is met.

less than 0.3 Hz.

Byron Station, Units 1 and 2 Seismic Spent Fuel Pool Evaluation Page 3of3 SFP Criteria from EPRI 3002007148 Site-Specific Data

8. To confirm applicability of the The surface area of the Byron Station, Units 1 and 2, evaporation loss evaluation in SFP is 1870 fV (Reference E), which is greater than Section 3.2 of EPRI 3002007148, 500 ft 2 ; and licensed reactor thermal power for Byron the SFP surface area should be Station, Units 1 and 2 is 3645 MWt per unit greater than 500 ft2 and the licensed (Reference L), which is less than 4,000 MWt per unit; reactor core thermal power should therefore, these criteria are met.

be less than 4,000 MWt per unit.

Attachment

References:

A. ER-BY-450, Byron Structures Monitoring Program, Revision 0 B. Document No. 01-10-52. Byron Piping Design Specification Units 1 & 2 , Revision 2 C. Drawing M-63, Sheet 1 A, Diagram of Fuel Pool Cooling and Clean-Up, Revision BI D. Drawing M-377, Sheet 1, Fuel Handling Building Misc. Plans and Sections, Revision C E. Drawing S-827, Spent Fuel Pool Liner Plan El. 426'-0", Revision Y F. Drawing S-830, Spent Fuel Pool Liner Sections 15-15, 16-16 & 17-17, Revision J G. 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 (ML15194A015)

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

J. Exelon Generation Company, LLC Letter to USNRC, Seismic Hazard and Screening Report (Central and Eastern United States (CEUS) Sites), 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, dated March 31, 2014 (RS-14-065) (ML14091A010)

K. NRC Letter to Exelon Generation Company, LLC, Byron Station, Units 1 and 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, dated February 17, 2016 (ML16027A045)

L. Byron Station Units 1 and 2, Renewed Facility Operating License Nos. NPF-37 and NPF-66 M. Drawing S-816, Fuel Handling Building Foundation Section 1-1, Revision V N. Drawing S-820, Fuel Handling Building Foundation Section 5-5, Revision AH P. Drawing S-FC-100-63, 2-Inch and Under Piping Isometric, Revision 5 Q. Drawing S-FC-100-52, 2-Inch and Under Piping Isometric, Revision 5