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| #REDIRECT [[JAFP-16-0182, James A. Fitzpatrick Nuclear Power Plant - Spent Fuel Pool Evaluation, 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 Da]] | | {{Adams |
| | | number = ML16357A786 |
| | | issue date = 12/22/2016 |
| | | title = James A. Fitzpatrick Nuclear Power Plant - Spent Fuel Pool Evaluation, 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-ic |
| | | author name = Sullivan B R |
| | | author affiliation = Entergy Nuclear Northeast, Entergy Nuclear Operations, Inc |
| | | addressee name = |
| | | addressee affiliation = NRC/Document Control Desk, NRC/NRR |
| | | docket = 05000333 |
| | | license number = DPR-059 |
| | | contact person = |
| | | case reference number = JAFP-16-0182 |
| | | document type = Letter, Response to Request for Additional Information (RAI) |
| | | page count = 6 |
| | | project = |
| | | stage = Response to RAI |
| | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:JAFP-16-0182 December 22, 2016 |
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| | U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
| | |
| | ==Subject:== |
| | Spent Fuel Pool Evaluation, 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 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059 |
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| | ==Reference:== |
| | : 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, ML12053A340, dated March 12, 2012 2. NEI letter, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, ML13101A379, dated April 9, 2013 3. NRC Letter, Electric Power Research Institute Final Draft Report XXXXXX, "Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations, ML13106A331, dated May 7, 2013 4. ENOI letter, Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, JAFP-13-0056, dated April 29, 2013 5. NRC letter, Final Determination of Licensee Seismic Probabilistic Risk Assessments Under the Request for Information Pursuant to Title 10 of the |
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| | Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 "Seismic" of the Near-Term Task Force Review of Insights from the |
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| | Fukushima Dai-ichi Accident, ML15194A015, dated October 27, 2015 6. EPRI guidance, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, EPRI 3002007148, dated February 2016 7. NRC letter, Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation," ML15350A158, dated March 17, 2016 Entergy Nuclear NortheastEntergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF |
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| | ==Dear Sir or Madam:== |
| | JAFP-16-0182 Page 2 of 2 On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued a Request for Information per 10 CFR 50.54(f) [Reference 1] in regard to Recommendation 2.1: Seismic. In Reference 2, the Nuclear Energy Institute (NEI) requested a Proposed Path Forward for Recommendation 2.1: Seismic, that the NRG agreed with in Reference 3, and James A. FitzPatrick Nuclear Power Plant (JAF) committed to this schedule in Reference |
| | : 4. This letter addresses the 50.54(f) Enclosure Recommendation 2.1: Seismic requested information item (9) and the portion of the Proposed Path Forward first group of risk evaluations, to perform a Spent Fuel Pool (SFP) evaluation. |
| | The SFP evaluation is one of the risk evaluations determined to be required for JAF through the screening and prioritization process [Reference 5]. The seismic adequacy of the SFP is reevaluated against the new ground motion response spectrum (GMRS) hazard levels in accordance with the criteria provided in EPRI 3002007148 |
| | [Reference 6] as endorsed by the NRG [Reference 7]. EPRI 3002007148 Section 3.3 lists the parameters to be verified to confirm that the results of the report are applicable to JAF, and that the JAF SFP is seismically adequate. |
| | The Attachment provides JAF's SFP evaluation as described in Section 3.3 of Reference 6 in accordance with the schedule identified in Reference 2 and committed to in Reference |
| | : 4. This letter contains no new regulatory commitments. |
| | If you have any questions regarding this submittal, please contact William C. Drews, Regulatory Assurance Manager, at 315-349-6562. |
| | I declare under penalty of perjury that the foregoing is true and correct; executed on December 22, 2016. Respectfully, |
| | |
| | ==Attachment:== |
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| | Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant cc: Director, Office of Nuclear Reactor Regulat i on NRG Region I Administrator NRG Resident Inspector NRG Project Manager NYSPSC President NYSERDA |
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| | JAFP-16-0182 ATTACHMENT Spent Fuel Pool Criteria for James A. |
| | FitzPatrick Nuclear Power Plant (3 Pages) |
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| | JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 1 of 3 On March 12, 2012, the NRC Request for Information per 10 CFR 50.54(f) (Reference 1) in regard to Near Term Task Force (NTTF) Recommendation 2.1, requested a seismic evaluation be made of 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 Reference 2 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for James A. FitzPatrick Nuclear Power Plant (JAF). By letter dated March 17, 2016 (Reference 5) the staff determined that EPRI 3002007148 (Reference 6) 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 JAF that confirms applicability of the EPRI 3002007148 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 spectral acceleration at any |
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| | frequency should be less than or equal to 0.8g. The GMRS peak spectral acceleration in JAF GMRS submittal (Reference 3) as accepted by the NRC (Reference 4) is 0.241g, which is 0.8g. Therefore, this criterion is met for JAF. Structural Parameters |
| | : 2. The structure housing the SFP should be designed using an SSE with a peak ground acceleration (PGA) of at least 0.1g. The SFP is housed in the Reactor Building, which is seismically designed to the site SSE with a PGA of 0.15g. JAF PGA is greater than 0.1g. Therefore, this criterion is met for JAF. 3. The structural load path to the SFP should consist of some combination of reinforced concrete shear wall elements, reinforced concrete frame elements, post-tensioned concrete elements and/or structural steel frame elements. The structural load path from the foundation to the SFP consists of a combination of reinforced concrete shear wall elements, reinforced concrete frame elements and structural steel elements (Ref. |
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| | JAF Drawings FC-27A, FC-27B, FC-30A thru 30E, FC-30L, and FC-30M). Therefore, this criterion is met for JAF. 4. The SFP structure should be included in the Civil Inspection |
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| | Program performed in accordance with Maintenance Rule. The SFP concrete walls and slab are included in the James A. FitzPatrick Nuclear Power Plant Civil Inspection Program per EN-DC-150 Attachment 9.16 under Reactor Building General Areas. The four steel columns underneath the SFP slab are also included in inspections for EL 326'-9". These inspections are performed every 5 to 10 years. Therefore, this criterion is met for JAF. |
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| | JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 2 of 3 SFP Criteria from EPRI 3002007148 Site-Specific Data Non-Structural Parameters |
| | : 5. To confirm applicability of the piping evaluation in Section 3.2 of EPRI 3002007148, piping attached to the |
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| | SFP up to the first valve should have been evaluated for the SSE. Piping connections (penetrations) attached to the SFP that could lead to rapid drain-down was addressed within the scope of NTTF Recommendation 2.3: Seismic walkdowns in JAF-RPT-12-00015. Section 6.2.2 of this report states, "-the Equipment Selection Personnel-identified SSCs that could cause the SFP to drain rapidly by |
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| | first reviewing the SFP documentation to identify |
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| | penetrations below about 10 ft above the top of fuel assemblies. Because this review found no such SFP penetrations, there is no potential for rapid drain-down." In addition, a review has been performed to identify all piping attached to the SFP |
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| | as documented in JAF-RPT-16-00004. The review shows that all of the piping lines that could lead to rapid drawdown have been seismically designed to SSE levels up to the first valve. The Piping lines which are not seismically designed to SSE levels are drain lines for the skimmer surge tanks located |
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| | at a level above the required minimum water elevation. Therefore, this criterion is met for JAF. 6. Anti-siphoning devices should be installed on any piping that could lead to siphoning water from the |
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| | SFP. In addition, for any cases where active anti-siphoning devices are attached to 2-inch or smaller piping and have extremely large extended operators, the valves should be walked down to confirm adequate lateral support. Anti-siphoning devices have been installed on four piping lines as documented on Attachment 9.2 of JAF-RPT-16-00004. These are the only lines that can lead to siphoning of the water from the SFP to an elevation below the required minimum water elevation of 363'-9". These lines have nominal piping diameters of 6" and 10". As described, anti-siphoning devices are installed on all SFP piping that could lead to siphoning; therefore, this criterion is met for JAF. 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 JAF. |
| | JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 3 of 3 SFP Criteria from EPRI 3002007148 Site-Specific Data 7. To confirm applicability of the sloshing evaluation in Section 3.2 of EPRI 3002007148, the maximum SFP horizontal dimension (length or width) should be less than 125 ft, the SFP depth should be greater than 36 ft, and the GMRS peak Sa should be <0.1g at frequencies equal to or less than 0.3 Hz. JAF SFP structure has a length of 40.0 ft, a width of 31.0 ft and a depth of 38.75ft based on JAF |
| | |
| | drawings FV-9A, FC-30E, and FM-1H. The normal water depth is 37.75 ft. Therefore, the SFP dimensional criterion is met. The JAF GMRS maximum spectral acceleration in the frequency range of 0.3 Hz is 0.0225g as documented in JAF-RPT-14-00004. Since this acceleration is less than 0.1g, this criterion is met. 8. To confirm applicability of the evaporation loss evaluation in Section 3.2 of EPRI 3002007148, the SFP surface area should be |
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| | greater than 500 ft 2 and the licensed reactor core thermal power should be less than 4,000 MWt per unit. The surface area of JAF SFP is 1,240 ft 2 , which is greater than 500 ft |
| | : 2. The licensed reactor thermal power for the single unit JAF is 2,536 MWt which is less than 4,000 MWt. The SFP surface area and licensed reactor core thermal power values are |
| | |
| | bounded by the EPRI criteria. Therefore, this criterion is met for JAF. |
| | |
| | ==References:== |
| | : 1) NRC letter, ML12053A340 - Request for Informati on 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 |
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| | March 12, 2012 2) NRC letter, ML15194A015 - 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 |
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| | October 27, 2015 3) ENOI letter, JAFP-14-0039 - Entergy Seismic and Screening Hazard Report (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 4) NRC letter, ML16043A411 - James A. FitzPatrick Nuclear Power Plant - 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 18, 2016 5) NRC letter, ML15350A158 - Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation," |
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| | dated March 17, 2016 6) EPRI guidance, EPRI 3002007148 - Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated February 2016}} |
Letter Sequence Response to RAI |
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Category:Letter
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[Table view] Category:Response to Request for Additional Information (RAI)
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RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P NMP1L3447, Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs2022-02-0202 February 2022 Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs JAFP-22-0008, Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary2022-01-14014 January 2022 Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Eliminate Selected Response Time Testing for Reactor Protection System and Primary JAFP-21-0087, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-09-16016 September 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0073, Response to Request for Additional Information Regarding Application to Revise the James A. FitzPatrick Nuclear Power Plant Limiting Condition for Operation (LCO) 3.5.1, ECCS - Operating Surveillance.2021-08-0909 August 2021 Response to Request for Additional Information Regarding Application to Revise the James A. FitzPatrick Nuclear Power Plant Limiting Condition for Operation (LCO) 3.5.1, ECCS - Operating Surveillance. JAFP-21-0044, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-06-11011 June 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments ML21138A0132021-05-18018 May 2021 NRC Response to Request for Additional Time to Respond to James A. Fitzpatrick Nuclear Power Plant: Final Significance Determination of a White Finding with Assessment Follow Up and Notice of Violation-Inspection No. 05000333/2021090 JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting2021-04-20020 April 2021 Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting JAFP-21-0008, Supplement to Application to Revise Surveillance Requirement (SR) 3.5.1.62021-02-18018 February 2021 Supplement to Application to Revise Surveillance Requirement (SR) 3.5.1.6 JAFP-21-0005, Response to Request for Additional Information to Support Review of License Amendment Request - Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves2021-01-26026 January 2021 Response to Request for Additional Information to Support Review of License Amendment Request - Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves ML20315A2452020-11-10010 November 2020 Response to Request for Additional Information to Support Review of License Amendment Request - Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves JAFP-20-0030, Response to Request for Additional Information in Support of License Amendment Request - Proposed Changes to the Technical Specifications to Primary Containment Hydrodynamic Loads2020-04-0606 April 2020 Response to Request for Additional Information in Support of License Amendment Request - Proposed Changes to the Technical Specifications to Primary Containment Hydrodynamic Loads JAFP-20-0026, Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation2020-03-31031 March 2020 Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation JAFP-20-0020, Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation2020-02-21021 February 2020 Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation JAFP-20-0008, Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences2020-01-16016 January 2020 Response to Request for Additional Information Associated with the License Amendment Request for Application of the Alternative Source Term for Calculating Loss-of-Coolant Accident Dose Consequences JAFP-19-0105, Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (Rwcu)...2019-11-0606 November 2019 Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (Rwcu)... ML19279A0012019-10-0606 October 2019 Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of an Emergency License Amendment Request for One Time Extension to the TS 3.8.1 Action ... JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-06-0404 June 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants2019-05-0101 May 2019 Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants JAFP-19-0009, End of Interval Relief Request Associated with the Fourth Ten-Year Inservice Inspection (ISI) Interval2019-01-15015 January 2019 End of Interval Relief Request Associated with the Fourth Ten-Year Inservice Inspection (ISI) Interval JAFP-19-0006, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-01-0808 January 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 JAFP-18-0068, Response to Request for Additional Information: License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors2018-07-12012 July 2018 Response to Request for Additional Information: License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors RS-18-067, Response to Request for Additional Information Regarding Generic Letter 2016-012018-05-29029 May 2018 Response to Request for Additional Information Regarding Generic Letter 2016-01 JAFP-18-0038, Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 22018-04-19019 April 2018 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 JAFP-18-0029, Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of James A. FitzPatrick Nuclear Power Plant to Address Secondary Containment Personnel Access Door Openings2018-03-15015 March 2018 Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to Support Review of James A. FitzPatrick Nuclear Power Plant to Address Secondary Containment Personnel Access Door Openings JAFP-18-0014, Response to Request for Additional Information on Submittal of Relief Request JAF-15R-05 Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702)2018-03-0202 March 2018 Response to Request for Additional Information on Submittal of Relief Request JAF-15R-05 Concerning Nozzle-to-Vessel Weld and Inner Radii Examinations (Use of Code Case N-702) ML18025A7992018-01-25025 January 2018 Response to Request for Additional Information Regarding Generic Letter 2016-01 JAFP-18-0012, Supplemental Response Concerning License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 22018-01-22022 January 2018 Supplemental Response Concerning License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 ML17346A1532017-12-11011 December 2017 Submittal of Response to Request for Additional Information on Relief Requests Associated with the Fifth Inservice Inspection (ISI) Interval JAFP-17-0029, Revision to Entergy'S Expedited Seismic Evaluation Process Report (CEUS Sites) Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of Near-Term Task Force Review of Insights...2017-04-27027 April 2017 Revision to Entergy'S Expedited Seismic Evaluation Process Report (CEUS Sites) Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of Near-Term Task Force Review of Insights... JAFP-17-0005, Response to 03/12/2012 Request for Information Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, Recommendation 9.3 for Emergency Preparedness2017-01-23023 January 2017 Response to 03/12/2012 Request for Information Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, Recommendation 9.3 for Emergency Preparedness JAFP-16-0182, Spent Fuel Pool Evaluation, 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 Accident2016-12-22022 December 2016 Spent Fuel Pool Evaluation, 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 ML16335A1042016-11-29029 November 2016 Independent Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Transfer F Renewed Facility Operating License and Proposed Conforming License Amendment JAFP-16-0170, Response to Request for Additional Information (RAI) Regarding License Amendment Request to Revise Technical Specifications Section 5.5.6 for Extension of Type a and Type C Leak Rate Test Frequencies - Supplement 12016-11-21021 November 2016 Response to Request for Additional Information (RAI) Regarding License Amendment Request to Revise Technical Specifications Section 5.5.6 for Extension of Type a and Type C Leak Rate Test Frequencies - Supplement 1 JAFP-16-0165, Response to Generic Letter 2016-01 - Monitoring of Neutron Absorbing Materials in Spent Fuel Pools2016-11-0303 November 2016 Response to Generic Letter 2016-01 - Monitoring of Neutron Absorbing Materials in Spent Fuel Pools JAFP-16-0142, Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 22016-09-19019 September 2016 Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 2 JAFP-16-0131, Response to Request for Additional Information Regarding Request for Approval of a Certified Fuel Handler Training and Retraining Program2016-08-18018 August 2016 Response to Request for Additional Information Regarding Request for Approval of a Certified Fuel Handler Training and Retraining Program JAFP-16-0130, License Amendment Request to Revise the Emergency Plan to Address the Permanently Defueled Condition - Supplement 22016-08-10010 August 2016 License Amendment Request to Revise the Emergency Plan to Address the Permanently Defueled Condition - Supplement 2 JAFP-16-0113, License Amendment Request to Revise the Emergency Plan to Address the Permanently Defueled Condition - Supplement 12016-07-0606 July 2016 License Amendment Request to Revise the Emergency Plan to Address the Permanently Defueled Condition - Supplement 1 JAFP-16-0114, Response to Request for Additional Information for Proposed Inservice Inspection Program Alternative in Accordance with 10 CFR 50.55a(z)(2), RR-202016-06-27027 June 2016 Response to Request for Additional Information for Proposed Inservice Inspection Program Alternative in Accordance with 10 CFR 50.55a(z)(2), RR-20 JAFP-16-0077, Response to Request for Additional Information (RAI) Regarding Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 12016-06-0303 June 2016 Response to Request for Additional Information (RAI) Regarding Revision to Technical Specification (TS) Administrative Controls for Staffing and Training Upon Permanent Cessation of Operation (CAC No. MF7280) - Supplement 1 JAFP-16-0078, Response to Request for Additional Information (RAI) Regarding Request for Approval of Certified Fuel Handler Training and Retaining Program2016-06-0303 June 2016 Response to Request for Additional Information (RAI) Regarding Request for Approval of Certified Fuel Handler Training and Retaining Program CNRO-2016-00016, Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated)2016-06-0202 June 2016 Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated) ML16071A4412016-03-0707 March 2016 Entergy Fleet Relief Request No. RR-EN-15-1-Proposed Alternative to Use ASME Code Case N-789-1 - E-mail from G.Davant to R.Guzman - Response to Second RAI (MF6340 - MF6349) CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) 2024-08-09
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JAFP-16-0182 December 22, 2016
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Spent Fuel Pool Evaluation, 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 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059
Reference:
- 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, ML12053A340, dated March 12, 2012 2. NEI letter, Proposed Path Forward for NTTF Recommendation 2.1: Seismic Reevaluations, ML13101A379, dated April 9, 2013 3. NRC Letter, Electric Power Research Institute Final Draft Report XXXXXX, "Seismic Evaluation Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force Recommendation 2.1: Seismic," as an Acceptable Alternative to the March 12, 2012, Information Request for Seismic Reevaluations, ML13106A331, dated May 7, 2013 4. ENOI letter, Entergy's Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Seismic Aspects of Recommendation 2.1 of the Near Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, JAFP-13-0056, dated April 29, 2013 5. 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, ML15194A015, dated October 27, 2015 6. EPRI guidance, Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, EPRI 3002007148, dated February 2016 7. NRC letter, Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation," ML15350A158, dated March 17, 2016 Entergy Nuclear NortheastEntergy Nuclear Operations, Inc. James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF
Dear Sir or Madam:
JAFP-16-0182 Page 2 of 2 On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued a Request for Information per 10 CFR 50.54(f) [Reference 1] in regard to Recommendation 2.1: Seismic. In Reference 2, the Nuclear Energy Institute (NEI) requested a Proposed Path Forward for Recommendation 2.1: Seismic, that the NRG agreed with in Reference 3, and James A. FitzPatrick Nuclear Power Plant (JAF) committed to this schedule in Reference
- 4. This letter addresses the 50.54(f) Enclosure Recommendation 2.1: Seismic requested information item (9) and the portion of the Proposed Path Forward first group of risk evaluations, to perform a Spent Fuel Pool (SFP) evaluation.
The SFP evaluation is one of the risk evaluations determined to be required for JAF through the screening and prioritization process [Reference 5]. The seismic adequacy of the SFP is reevaluated against the new ground motion response spectrum (GMRS) hazard levels in accordance with the criteria provided in EPRI 3002007148
[Reference 6] as endorsed by the NRG [Reference 7]. EPRI 3002007148 Section 3.3 lists the parameters to be verified to confirm that the results of the report are applicable to JAF, and that the JAF SFP is seismically adequate.
The Attachment provides JAF's SFP evaluation as described in Section 3.3 of Reference 6 in accordance with the schedule identified in Reference 2 and committed to in Reference
- 4. This letter contains no new regulatory commitments.
If you have any questions regarding this submittal, please contact William C. Drews, Regulatory Assurance Manager, at 315-349-6562.
I declare under penalty of perjury that the foregoing is true and correct; executed on December 22, 2016. Respectfully,
Attachment:
Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant cc: Director, Office of Nuclear Reactor Regulat i on NRG Region I Administrator NRG Resident Inspector NRG Project Manager NYSPSC President NYSERDA
JAFP-16-0182 ATTACHMENT Spent Fuel Pool Criteria for James A.
FitzPatrick Nuclear Power Plant (3 Pages)
JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 1 of 3 On March 12, 2012, the NRC Request for Information per 10 CFR 50.54(f) (Reference 1) in regard to Near Term Task Force (NTTF) Recommendation 2.1, requested a seismic evaluation be made of 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 Reference 2 that the GMRS exceeds the SSE and concluded that a SFP evaluation is merited for James A. FitzPatrick Nuclear Power Plant (JAF). By letter dated March 17, 2016 (Reference 5) the staff determined that EPRI 3002007148 (Reference 6) 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 JAF 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 spectral acceleration at any
frequency should be less than or equal to 0.8g. The GMRS peak spectral acceleration in JAF GMRS submittal (Reference 3) as accepted by the NRC (Reference 4) is 0.241g, which is 0.8g. Therefore, this criterion is met for JAF. Structural Parameters
- 2. The structure housing the SFP should be designed using an SSE with a peak ground acceleration (PGA) of at least 0.1g. The SFP is housed in the Reactor Building, which is seismically designed to the site SSE with a PGA of 0.15g. JAF PGA is greater than 0.1g. Therefore, this criterion is met for JAF. 3. The structural load path to the SFP should consist of some combination of reinforced concrete shear wall elements, reinforced concrete frame elements, post-tensioned concrete elements and/or structural steel frame elements. The structural load path from the foundation to the SFP consists of a combination of reinforced concrete shear wall elements, reinforced concrete frame elements and structural steel elements (Ref.
JAF Drawings FC-27A, FC-27B, FC-30A thru 30E, FC-30L, and FC-30M). Therefore, this criterion is met for JAF. 4. The SFP structure should be included in the Civil Inspection
Program performed in accordance with Maintenance Rule. The SFP concrete walls and slab are included in the James A. FitzPatrick Nuclear Power Plant Civil Inspection Program per EN-DC-150 Attachment 9.16 under Reactor Building General Areas. The four steel columns underneath the SFP slab are also included in inspections for EL 326'-9". These inspections are performed every 5 to 10 years. Therefore, this criterion is met for JAF.
JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 2 of 3 SFP Criteria from EPRI 3002007148 Site-Specific Data Non-Structural Parameters
- 5. To confirm applicability of the piping evaluation in Section 3.2 of EPRI 3002007148, piping attached to the
SFP up to the first valve should have been evaluated for the SSE. Piping connections (penetrations) attached to the SFP that could lead to rapid drain-down was addressed within the scope of NTTF Recommendation 2.3: Seismic walkdowns in JAF-RPT-12-00015. Section 6.2.2 of this report states, "-the Equipment Selection Personnel-identified SSCs that could cause the SFP to drain rapidly by
first reviewing the SFP documentation to identify
penetrations below about 10 ft above the top of fuel assemblies. Because this review found no such SFP penetrations, there is no potential for rapid drain-down." In addition, a review has been performed to identify all piping attached to the SFP
as documented in JAF-RPT-16-00004. The review shows that all of the piping lines that could lead to rapid drawdown have been seismically designed to SSE levels up to the first valve. The Piping lines which are not seismically designed to SSE levels are drain lines for the skimmer surge tanks located
at a level above the required minimum water elevation. Therefore, this criterion is met for JAF. 6. Anti-siphoning devices should be installed on any piping that could lead to siphoning water from the
SFP. In addition, for any cases where active anti-siphoning devices are attached to 2-inch or smaller piping and have extremely large extended operators, the valves should be walked down to confirm adequate lateral support. Anti-siphoning devices have been installed on four piping lines as documented on Attachment 9.2 of JAF-RPT-16-00004. These are the only lines that can lead to siphoning of the water from the SFP to an elevation below the required minimum water elevation of 363'-9". These lines have nominal piping diameters of 6" and 10". As described, anti-siphoning devices are installed on all SFP piping that could lead to siphoning; therefore, this criterion is met for JAF. 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 JAF.
JAFP-16-0182 Attachment Spent Fuel Pool Criteria for James A. FitzPatrick Nuclear Power Plant Page 3 of 3 SFP Criteria from EPRI 3002007148 Site-Specific Data 7. To confirm applicability of the sloshing evaluation in Section 3.2 of EPRI 3002007148, the maximum SFP horizontal dimension (length or width) should be less than 125 ft, the SFP depth should be greater than 36 ft, and the GMRS peak Sa should be <0.1g at frequencies equal to or less than 0.3 Hz. JAF SFP structure has a length of 40.0 ft, a width of 31.0 ft and a depth of 38.75ft based on JAF
drawings FV-9A, FC-30E, and FM-1H. The normal water depth is 37.75 ft. Therefore, the SFP dimensional criterion is met. The JAF GMRS maximum spectral acceleration in the frequency range of 0.3 Hz is 0.0225g as documented in JAF-RPT-14-00004. Since this acceleration is less than 0.1g, this criterion is met. 8. To confirm applicability of the evaporation loss evaluation in Section 3.2 of EPRI 3002007148, the SFP surface area should be
greater than 500 ft 2 and the licensed reactor core thermal power should be less than 4,000 MWt per unit. The surface area of JAF SFP is 1,240 ft 2 , which is greater than 500 ft
- 2. The licensed reactor thermal power for the single unit JAF is 2,536 MWt which is less than 4,000 MWt. The SFP surface area and licensed reactor core thermal power values are
bounded by the EPRI criteria. Therefore, this criterion is met for JAF.
References:
- 1) NRC letter, ML12053A340 - Request for Informati on 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 2) NRC letter, ML15194A015 - 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 3) ENOI letter, JAFP-14-0039 - Entergy Seismic and Screening Hazard Report (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 4) NRC letter, ML16043A411 - James A. FitzPatrick Nuclear Power Plant - 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 18, 2016 5) NRC letter, ML15350A158 - Endorsement of Electric Power Research Institute Report 3002007148, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation,"
dated March 17, 2016 6) EPRI guidance, EPRI 3002007148 - Seismic Evaluation Guidance Spent Fuel Pool Integrity Evaluation, dated February 2016