ULNRC-06381, 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

ML17276B201
Person / Time
Site:	Callaway
Issue date:	10/03/2017
From:	Herrmann T Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06381
Download: ML17276B201 (8)

Text

Timothy E. Herrmann, RE.

a ;ie Site Vice President Ameren Missouri Aiiieren MISSOURI Callaway Energy Center October 3, 2017 ULNRC-063 81 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 50.4 10 CFR 50.54 (f)

Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 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 1 0 of the Code of Federal Regulations 50.54(1) Regarding Recommendations 2.1 2.3, and 9.3, ofthe Near-Term Task Force Review oflnsights from the Fukushima Dai-ichi Accident, dated March 12, 2012, ADAMS Accession Number ML12053A340

2. NRC Letter, Final Determination ofLicensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 ofthe Code ofFederal Regulations 50.54(1)

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. NET Letter, transmits EPRI 3002009564 for NRC endorsement, dated 1/3 1/2017, ADAMS Accession Number ML17031A171

4. EPRI 3002009564, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated January2017

5. NRC Letter, provides endorsement ofEPRI 3002009564, dated 2/8/2017, ADAMS Accession Number ML17034A408 Junction CC & Hwy 0 P0 Box 620, MC CA460 Futon, MO 65257 : AmerenMissouricorn STARS Afliance

ULNRC-063 81 October 3, 2017 Page 2

6. ULNRC-06030, Arneren Missouri Response to NRC Request for Information Pursuant to 10CFR5O.54(f) Regarding the Seismic Aspects ofRecommendation 2.1 ofthe Near-Term Task Force Review of Insights From the Fukushima Dal-ichi Accident- 1 .5 Year Responses for CEUS Sites, dated September 12, 2013

7. ULNRC-06095, Correction to Ameren Missouri Response to NRC Request for Information Pursuant to 10CFR5O.54(f) Regarding the Seismic Aspects ofRecommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident- 1 .5 Year Responses for CEUS Sites, dated March 04, 2014

8. ULNRC-06102, Arneren Missouri Seismic Hazard and Screening (CEUS Sites) Response to NRC Request for Information Pursuant to 10CFR5O.54(f) Regarding the Seismic Aspects of Recommendation 2 1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident- 1 .5 Year Responses for CEUS Sites, dated March 28, 2014

9. NRC Letter, Callaway Plant, Unit 1 Staff Assessment of Information provided Pursuant to Title 10 ofthe Code ofFederal 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 Fukushirna Dai-ichi Accident, dated April 2 1 201 5, ADAMS Accession Number ML15063A517 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a Request for Information per 10CFR 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 Ameren Missouri Callaway Energy Center was to conduct a limited scope Spent Fuel Pool 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 3002009564)

(Reference 4) for NRC review and endorsement. NRC endorsement was provided by Reference 5.

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

The attachment to this letter provides the data for Callaway that confirms applicability of the EPRI 3002009564 criteria and confirms that the SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

Should you have any questions regarding this submittal, please contact Bruce Huhmann, Supervising Engineer, Regulatory Projects, at 573-694-6741.

ULNRC-063 81 October 3, 2017 Page 3 I declare under penalty ofperjury that the foregoing is true and correct Sincerely, Executed on: /Ø3/ei

• Timothy Herrmann Site Vice President

Enclosure:

Site-Specific Spent Fuel Pool Criteria for Callaway

ULNRC-06381 October 3, 2017 Page 4 cc: Mr. Kriss M. Kennedy Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. L. John Klos Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8H4 Washington, DC 20555-0001

ULNRC-06381 October 3, 2017 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 Fort Worth, TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

F. M. Diya T. E. Herrmann B. L. Cox R. C. Wink T. B. Elwood B. E. Huhmann Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Enclosure To ULNRC-06381 Page 1 of 3 Ameren Missouri Callaway Energy Center Site-Specific Spent Fuel Pool Criteria for Callaway

Enclosure To ULNRC-06381 Page 2 of 3 The 50.54(f) letter (Reference 1) requested that, in conjunction with the response to NTTF Recommendation 2.1, a seismic evaluation be performed for 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 1 to 10 Hz frequency range. The staff confirmed through References 2 and 9 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Callaway Energy Center. By letter dated 02/08/2017 (Reference 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 data for Callaway that confirms applicability of the EPRI 3002009564 criteria and confirms that the SFP is seismically adequate in accordance with NTTF 2.1 Seismic evaluation criteria.

SFP Criteria from EPRI 3002009564 Site-Specific Data Site Parameters

1. The site-specific GMRS should be The Callaway GMRS developed by EPRI and the same as that submitted to the submitted to the NRC in Reference 6 is accepted NRC between March 2014 and July by the NRC in Reference 7. The peak spectral 2015, which the NRC has found acceleration of the GMRS is 1.35g.

acceptable for responding to the NRC 50.54(f) letter (Reference 7).

Structural Parameters

2. Site-specific calculations, performed Site-specific calculations (AMN-12-CALC-001, Rev in accordance with Section 4.1 of 0), performed in accordance with Section 4.1 of EPRI 3002009564 should EPRI 3002009564, demonstrate that the limiting demonstrate that the limiting SFP SFP HCLPF is 1.4g, which exceeds the GMRS HCLPF is greater than the site- 1.35g. Therefore, this criterion is met for Callaway.

specific GMRS in the frequency range of interest (e.g., 10-20 Hz).

3. The SFP structure should be The SFP structure is included in the Callaway Civil included in the Civil Inspection Inspection Program in accordance with 10 CFR Program performed in accordance 50.65 [procedure ESP-ZZ-01013 and its with Maintenance Rule. associated Appendix A, B, and C], therefore, this criterion is met for Callaway.

Non-Structural Parameters

4. To confirm applicability of the piping The maximum depth of piping below the water evaluation in Section 4.2 of EPRI surface is less than 6 ft as documented on 3002009564, piping attached to the drawings M-23EC04, M-23EC06, and M-23EF12, SFP should have penetrations no therefore, this criterion is met for Callaway.

more than 6 ft below water surface.

Enclosure To ULNRC-06381 Page 3 of 3 SFP Criteria from EPRI 3002009564 Site-Specific Data

5. To confirm ductile behavior under The SFP gate is constructed from an ASTM A240, increased seismic demands, SFP Type 304L alloy as documented on drawing C-174-gates should be constructed from 00001, therefore, this criterion is met for Callaway.

either aluminum or stainless steel alloys.

6. Anti-siphoning devices should be For pool skimmers FEC04A, FEC04B, and installed on any piping that could FEC04C, 1/4 diameter vent holes are located on lead to siphoning water from the top of the pipes for anti-siphoning. Fuel Pool SFP. In addition, for any cases Cooling A and B to the Sparging Header have 3 where active anti-siphoning devices diameter vent holes are located at EL. 2043-2 to are attached to 2-inch or smaller provide anti-siphoning.

piping and have extremely large As described, no anti-siphoning devices can lead extended operators, the valves to siphoning, therefore, this criterion is met for should be walked down to confirm Callaway.

adequate lateral support.

As described, no anti-siphoning devices are attached to 2-inch or smaller piping with extremely large extended operators, therefore, this criterion is met for Callaway.

Further, to ensure that there are no potential adverse seismic conditions or interactions, all piping that penetrates the walls of the SFP were walked down by a team consisting of two Seismic Capability Engineers. No adverse seismic interactions were identified and all piping and valves have adequate lateral support.

7. To confirm applicability of the The Callaway SFP has a length of 50 ft, a width of sloshing evaluation in Section 4.2 of 28 ft and a depth of 40 ft based on drawings C-EPRI 3002009564, the maximum 2C6111 and C-2C6311, therefore, this criterion is SFP horizontal dimension (length or met for Callaway.

width) should be less than 125 ft and the SFP depth should be greater than 36 ft.

8. To confirm applicability of the The Callaway SFP has a surface area of 1425 ft2, evaporation loss evaluation in which is greater than 500 ft2 and the licensed Section 4.2 of EPRI 3002009564, reactor thermal power for Callaway is 3565 MWt the SFP surface area should be per unit which is less than 4,000 MWt per unit, greater than 500 ft2 and the licensed therefore, this criterion is met for Callaway.

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