View source for RS-16-124, 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

{{Adams
| number = ML16244A801
| issue date = 08/31/2016
| title = 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
| author name = Kaegi G
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000237, 05000249
| license number = DPR-019, DPR-025
| contact person = 
| case reference number = RS-16-124
| document type = Letter type:RS, Report, Miscellaneous, Response to Request for Additional Information (RAI)
| page count = 10
| project = 
| stage = Supplement
}}

=Text=
{{#Wiki_filter:ExeLon Generation 10 CFR 50.54(f)
RS-16-124 August 31, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

==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 (ML1 5350Al 58)
: 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-14-067) (ML14091A012)

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 2
: 7. Exelon Generation Company, LLC Letter to USNRC, Supplemental Information Regarding Seismic Hazard Risk Evaluation and Seismic Hazard Prioritization Results 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 Dal-ichi Accident, dated July 22, 2015 (RS-15-185) (ML15204A088)
: 8. NRC Letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 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 Dai-ichi Accident, dated April 27, 2015 (ML15097A519)
: 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 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 Dresden Nuclear Power Station, Units 2 and 3, is to conduct limited scope SFP evaluations. 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, is documented in Reference 6 and endorsed by the NRC by Reference 8. This 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 Dresden Nuclear Power Station, Units 2 and 3, and that the Dresden Nuclear Power Station, Units 2 and 3, SFPs are seismically adequate in accordance with Near Term Task Force (NTTF) 2.1 Seismic evaluation criteria.
The attachment to this letter provides the data for Dresden Nuclear Power Station, Units 2 and 3, that confirms applicability of the EPRI 3002007148 criteria, confirms that the SFPs are 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.

U.S. Nuclear Regulatory Commission Seismic Hazard 2.1 Spent Fuel Pool Evaluation August 31, 2016 Page 3 declare under penalty of perjury that the foregoing is true and correct. Executed on the 31 s' day of August 2016.
Respectfully submitted, o
7 Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

==Attachment:==
Site-Specific Spent Fuel Pool Criteria for Dresden Nuclear Power Station, Units 2 and 3 cc:    Regional Administrator - NRC Region III NRC Senior Resident Inspector  Dresden Nuclear Power Station NRC Project Manager, NRR  Dresden Nuclear Power Station Mr. Nicholas DiFrancesco, NRR/JLD/JHMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT Site-Specific Spent Fuel Pool Criteria for Dresden Nuclear Power Station, Units 2 and 3

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Evaluation Page 1 of 6 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 Dresden Station, Units 2 &3 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 P and T that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for the Dresden Nuclear Power Station, Units 2 and 3. By letter dated March 17, 2016, (Reference R) 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 (Reference Q) along with data for Dresden Nuclear Power Station, Units 2 and 3, that confirms applicability of the EPRI 3002007148 (Reference Q) criteria and confirms that the SFP is seismically adequate and can retain adequate water inventory for 72 hours 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 Dresden spectral acceleration at any              Station, Units 2 & 3, in Reference S (Table 2.4-1) frequency should be less than or          as accepted by the NRC in Reference T is 0.59g, equal to 0.8g.                           which is s 0.8g; therefore, this criterion is met.
Structural Parameters
: 2. The structure housing the SFP             The Dresden Station, Units 2 & 3 SFP is housed in should be designed using an SSE           the Reactor Building, which is seismically designed with a peak ground acceleration           to the site SSE with a PGA of 0.20g per Reference (PGA) of at least 0.1 g.                  S, Section 3.1. The Dresden Nuclear Power Station, Units 2 and 3 PGA is greater than 0.1 g; therefore, this criterion is met.
: 3. The structural load path to the SFP       The Dresden Station, Units 2 & 3 structural load should consist of some combination        path from the foundation to the SFP consists of of reinforced concrete shear wall         reinforced concrete shear walls, slabs, and framing elements, reinforced concrete frame       members (References B-J); therefore, this criterion elements, post-tensioned concrete         is met.
elements and/or structural steel frame elements.

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Evaluation Page 2of6 SIP Criteria from EPRI 3002007148        1 Site-Specific Data
: 4. The SFP structure should be             The SFP structure is included in the Dresden included in the Structural Monitoring   Station, Units 2 and 3, Structures Monitoring Program performed in accordance         Program (References M & N) in accordance with with Maintenance Rule.                  10 CFR 50.65, 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.

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Fvaluation Page 3of6 SFP Criteria from EPRI 3002007148         Site-Specific Data Non-Structural Parameters
: 5. To confirm applicability of the piping Piping attached to the Dresden Station, Units 2 & 3 evaluation in Section 3.2 of EPRI      SFP are the fuel pool cooling system and the fuel 3002007148, piping attached to the     pool gates drain line, as shown in References K &
SFP up to the first valve should have  L. The fuel pool gates drain line are safety related been evaluated for the SSE.            up to the first isolation valves (References K & L) and have been evaluated for the SSE (References V & W and Dresden equipment database). The fuel pool cooling system is non-safety related (Note 2 on References K & L) but is seismically supported for 2 over 1 concern for the SSE (References V &
W and Dresden equipment database). The attached SFP piping meet the requirements of Regulatory Guide 1.29 (Reference X), as documented in References V and W, which requires seismic Category I requirements extend to the first seismic restraint beyond the defined boundaries (i.e. SFP). Interface between seismic Category I and non-seismic Category I features are designed to seismic Category I requirements to prevent potential damage to safety related components from breakage of the non-seismic piping or leakage of piping contents onto safety related components or impact damage to safety related components adjacent to it. This was evaluated under SEP Topic III-6 (References V &
W) which evaluated these piping systems as a whole including the piping attached to the SFP up to the first valve. Therefore, this criterion is met for Dresden Nuclear Power Station, Units 2 and 3.

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Evaluation Page 4of6 SFP Criteria from EPRI 3002007148         Site-Specific Data
: 6. Anti-siphoning devices should be       All penetrations into the pool are located above a installed on any piping that could     fixed height from the bottom such that there must lead to siphoning water from the       always be a safe level of water above the fuel SFP. In addition, for any cases        (Section 9.1.3.3 of Reference A).
where active anti-siphoning devices    Two 6-inch diameter spent fuel pool cooling are attached to 2-inch or smaller      system return lines to the spent fuel pool each piping and have extremely large        have openings in the pipe about 6 inches below extended operators, the valves         the pool surface to act as anti-syphon devices should be walked down to confirm       (Section 9.1.3.3 of Reference A and References K adequate lateral support.              &Q As described, anti-siphoning devices are installed on all SFP piping that could lead to siphoning; therefore, this criterion is met for Dresden Nuclear Power Station, Units 2 and 3.
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 Dresden Nuclear Power Station, Units 2 and 3 (References K & Q.
: 7. To confirm applicability of the        The Dresden Nuclear Power Station, Units 2 and sloshing evaluation in Section 3.2 of  3, SFP has a length of approximately 41 ft, a width EPRI 3002007148, the maximum           of approximately 33 ft and a depth of SFP horizontal dimension (length or    approximately 39 ft based on Section 9.1.2.2.3 of width) should be less than 125 ft, the Reference A and References D & J; therefore, this SFP depth should be greater than       criterion is met.
36 ft, and the GMRS peak Sa should     The Dresden Nuclear Power Station, Units 2 and be <0.1 g at frequencies equal to or   3, GMRS maximum spectral acceleration in the less than 0.3 Hz.                      frequency range equal to or less than 0.3 Hz is 0.0412 g from Reference S (Table 2.4-1), which is less than 0.1 g; therefore, this criterion is met.
: 8. To confirm applicability of the        The surface area of the Dresden Nuclear Power evaporation loss evaluation in         Station, Units 2 and 3, SFP is approximately 1,353 Section 3.2 of EPRI 3002007148,        ft (41 ft length x 33 ft width) per unit (References the SFP surface area should be         D & J), which is greater than 500 ft2; and licensed greater than 500 ft2 and the licensed  reactor thermal power for Dresden Nuclear Power reactor core thermal power should      Station, Units 2 and 3 is 2957 MWt per unit be less than 4,000 MWt per unit.       (Reference U) which is less than 4,000 MWt per unit; therefore, these criteria are met.

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Evaluation Page 5 of 6 Attachment 

==References:==

A. Dresden Nuclear Power Station Updated Final Safety Analysis Report (UFSAR),
Revision 11.
B. Dresden Unit 2 Drawing B-208, Revision S, Reactor Building Framing Plan EL 613'-0" South Area.
C. Dresden Unit 2 Drawing B-209, Revision N, Reactor Building Framing Plan EL 613'-0" North Area.
D. Dresden Unit 2 Drawing B-218, Revision P, Reactor Building Framing Section D-D Upper Area.
E. Dresden Unit 2 Drawing B-224, Revision M, Reactor Building Framing Section G-G Upper Area.
F. Dresden Unit 3 Drawing B-638, Revision H, Reactor Building Framing Plan EL 613'-0" South Area.
G. Dresden Unit 3 Drawing B-639, Revision D, Reactor Building Framing Plan EL 613'-0" North Area.
H. Dresden Unit 3 Drawing B-648, Revision 0, Reactor Building Framing Section D-D Upper Area.
J. Dresden Unit 3 Drawing B-654, Revision E, Reactor Building Framing Section G-G Upper Area.
K. Dresden Unit 2 Drawing M-31, Revision BQ, Diagram of Fuel Pool Cooling Piping.
L. Dresden Unit 3 Drawing M-362, Revision BF, Diagram of Fuel Pool Cooling Piping.
M. Exelon Procedure ER-AA-450, Revision 5, Structures Monitoring.
N. Exelon Procedure ER-DR-450-1001, Revision 0, Dresden Structures Monitoring Instructions.
P. 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)
Q. EPRI 3002007148, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, February 2016 R. NRC Letter, Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation", dated March 17, 2016 (ML15350A158)
S. 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-14-067) (ML14091A012)

Dresden Nuclear Power Station, Units 2 and 3 Seismic Spent Fuel Pool Evaluation Page 6of6 T. NRC Letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 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 Dai-ichi Accident, dated April 27, 2015 (ML15097A519)
U. Dresden Nuclear Power Station, Units 2 and 3, Renewed Facility Operating License Nos. DPR-19 and DPR-25 V. SEP Safety Topic 111-6, Seismic Design Consideration and III-11, Component Integrity Dresden Nuclear Power Station Unit No. 2, Letter to Mr. L. DelGeorge, dated June 30, 1982 W. Systematic Evaluation Program, Topic III-6, Structural Integrity of Reactor Pressure Vessel  Dresden Nuclear Power Station, Unit 2 (TAC No. M72906), Letter to Mr. D. L.
Farrar, dated September 10, 1993 X. Regulatory Guide 1.29, Revision 3, Seismic Design Classification (ML003739983)}}