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| number = ML18165A412
| number = ML18165A412
| issue date = 06/22/2018
| issue date = 06/22/2018
| title = North Anna Power Station, Units 1 and 2 - Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1: Seismic (EPID L-2017-JLD-0059)
| title = Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1: Seismic
| author name = Vega F G
| author name = Vega F
| author affiliation = NRC/NRR/DLP/PBMB
| author affiliation = NRC/NRR/DLP/PBMB
| addressee name = Stoddard D G
| addressee name = Stoddard D
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| addressee affiliation = Virginia Electric & Power Co (VEPCO)
| docket = 05000338, 05000339
| docket = 05000338, 05000339
| license number =  
| license number =  
| contact person = Vega F G, NRR/DLP, 415-1617
| contact person = Vega F, NRR/DLP, 415-1617
| case reference number = EPID L-2017-JLD-0059
| case reference number = EPID L-2017-JLD-0059
| document type = Audit Report, Letter
| document type = Audit Report, Letter
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 22, 2018 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 22, 2018 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711


==SUBJECT:==
==SUBJECT:==
NORTH ANNA POWER STATION, UNITS 1 AND 2-STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID NO. L-2017-JLD-0059)  
NORTH ANNA POWER STATION, UNITS 1 AND 2- STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID NO. L-2017-JLD-0059)


==Dear Mr. Stoddard:==
==Dear Mr. Stoddard:==


The purpose of this letter is to inform Virginia Electric and Power Company (the licensee), of the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel pool (SFP) evaluation for North Anna Power Station, Units 1 and 2 (North Anna), which was submitted in response to Item 9 of Enclosure 1 of the NRC's March 12, 2012, request for information (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12053A340) issued under Title 10 of the Code of Federal Regulations, Section 50.54(f) (hereafter referred to as the 50.54(f) letter). The NRC staff concludes that the licensee's assessment was performed consistent with the NRG-endorsed SFP Evaluation Guidance Report and that the licensee has provided sufficient information to complete the response to Item (9) of the 50.54(f) letter. BACKGROUND On March 12, 2012, the NRC issued the 50.54(f) letter as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate seismic hazards at their sites using present-day methodologies and guidance.
The purpose of this letter is to inform Virginia Electric and Power Company (the licensee), of the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel pool (SFP) evaluation for North Anna Power Station, Units 1 and 2 (North Anna), which was submitted in response to Item 9 of Enclosure 1 of the NRC's March 12, 2012, request for information (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340) issued under Title 10 of the Code of Federal Regulations, Section 50.54(f)
Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) and the safe shutdown earthquake (SSE). The staff's assessment of the information provided in response to Items (1 )-(3) and (5)-(7) and the comparison portion of Item (4) of the 50.54(f) letter was provided by letter dated August 20, 2015 (ADAMS Accession No. ML 15057 A249). Enclosure 1, Item (9), of the 50.54(f) letter requested that, when the GMRS exceeds the SSE in the 1 to 10 Hertz frequency range, the licensee provide a seismic evaluation of the SFP. More specifically, licensees were asked to consider " ... all seismically induced failures that can lead to draining of the SFP."
(hereafter referred to as the 50.54(f) letter). The NRC staff concludes that the licensee's assessment was performed consistent with the NRG-endorsed SFP Evaluation Guidance Report and that the licensee has provided sufficient information to complete the response to Item (9) of the 50.54(f) letter.
D. Stoddard By letter dated January 31, 2017 (ADAMS Accession No. ML 17031A171), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance:
BACKGROUND On March 12, 2012, the NRC issued the 50.54(f) letter as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate seismic hazards at their sites using present-day methodologies and guidance. Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) and the safe shutdown earthquake (SSE). The staff's assessment of the information provided in response to Items (1 )-(3) and (5)-(7) and the comparison portion of Item (4) of the 50.54(f) letter was provided by letter dated August 20, 2015 (ADAMS Accession No. ML15057A249). Enclosure 1, Item (9), of the 50.54(f) letter requested that, when the GMRS exceeds the SSE in the 1 to 10 Hertz frequency range, the licensee provide a seismic evaluation of the SFP. More specifically, licensees were asked to consider " ... all seismically induced failures that can lead to draining of the SFP."
Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating the seismic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements the guidance in EPRI Report 1025287, "Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID)" (ADAMS Accession No. ML 12333A 170). The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML 17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter. By letter dated October 27, 2015 (ADAMS Accession No. ML 15194A015), the NRC staff stated that SFP evaluation submittals for sites with GMRS peak spectral accelerations above 0.8g were expected by December 31, 2017. By letter dated July 6, 2017 (ADAMS Accession No. ML 17177A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. The North Anna site was included in the list of applicable licensees.
 
The staff used the audit process as described below during the SFP evaluation review. REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION By letter dated December 14, 2017 (ADAMS Accession No. ML 17354A160), the licensee submitted its SFP evaluation for North Anna. The NRC staff assessed the licensee's implementation of the SFP Evaluation Guidance Report through the completion of a reviewer checklist, which is included as an enclosure to this letter. TECHNICAL EVALUATION Section 4.0 of the SFP Evaluation Guidance Report provides SFP evaluation criteria for plants with GMRS peak spectral accelerations greater than 0.8g. These criteria address SFP structural elements (e.g., floors, walls, and supports);
D. Stoddard                                       By letter dated January 31, 2017 (ADAMS Accession No. ML17031A171), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating the seismic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements the guidance in EPRI Report 1025287, "Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID)" (ADAMS Accession No. ML12333A170). The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter.
non-structural elements (e.g., penetrations);
By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRC staff stated that SFP evaluation submittals for sites with GMRS peak spectral accelerations above 0.8g were expected by December 31, 2017.
seismically-induced SFP sloshing; and water losses due to heat-up and boil-off.
By letter dated July 6, 2017 (ADAMS Accession No. ML17177A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. The North Anna site was included in the list of applicable licensees. The staff used the audit process as described below during the SFP evaluation review.
Section 4.0 also provides applicability criteria that enable licensees to determine if their specific conditions are within the bounds considered in developing some of the evaluation criteria in the guidance report. In its review, the staff confirmed that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. SPENT FUEL POOL STRUCTURAL EVALUATION Section 4.1 of the SFP Evaluation Guidance Report provides an SFP structural evaluation approach used to demonstrate that the SFP structure is sufficiently robust for the reevaluated seismic hazard. This approach supplements the guidance in Section 7 of the SPID and follows acceptable methods used to assess the seismic capacity of structures, systems, and components (SSCs) for nuclear power plants. In short, Sections 4.1.1 and 4.1.2 describe an acceptable method for licensees to use to calculate a site-specific seismic high confidence of D. Stoddard low probability of failure (HCLPF) value for the SFP that is then compared to the site-specific GMRS. The licensee stated that the SFP structural evaluation approach presented in the SFP Evaluation Guidance Report is applicable and, as a part of the audit process, provided site-specific data to the NRC staff to confirm the stated results for North Anna. As a part of the audit process, the NRC staff reviewed the information provided in calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1", Revision 0, and confirmed that the site-specific HCLPF value calculated for North Anna's SFP followed the methodology of the SFP Evaluation Guidance Report and that the HCLPF value is greater than the GMRS. The staff concludes that SFP SSCs were appropriately evaluated and that the licensee has demonstrated that there is high confidence that the SFP structure is sufficiently robust to withstand ground motions with peak spectral accelerations up to and including the peak spectral acceleration of North Anna's GMRS. SPENT FUEL POOL NON-STRUCTURAL EVALUATION Section 4.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the non-structural aspects of the SFP, such as piping connections, fuel gates, and anti-siphoning devices, as well as SFP sloshing and heat-up and boil-off of SFP water inventory.
REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION By letter dated December 14, 2017 (ADAMS Accession No. ML17354A160), the licensee submitted its SFP evaluation for North Anna. The NRC staff assessed the licensee's implementation of the SFP Evaluation Guidance Report through the completion of a reviewer checklist, which is included as an enclosure to this letter.
Additionally, page 4-11 of the SFP Evaluation Guidance Report provides a summary of the pertinent SFP non-structural parameters important to the methodology described in Section 4.2. The licensee provided a table in its letter dated December 14, 2017, demonstrating that it followed the SFP non-structural evaluation approach presented in the SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability.
TECHNICAL EVALUATION Section 4.0 of the SFP Evaluation Guidance Report provides SFP evaluation criteria for plants with GMRS peak spectral accelerations greater than 0.8g. These criteria address SFP structural elements (e.g., floors, walls, and supports); non-structural elements (e.g.,
The staff reviewed the structural information provided, which included North Anna's site-specific attributes, against the criteria described in the SFP Evaluation Guidance Report, and confirmed that the methods and conclusions are applicable to the North Anna site. Therefore, the staff concludes that the licensee adequately evaluated the non-structural considerations for SSCs whose failure could lead to potential drain-down of the SFP due to a seismic event. Further, the staff concludes that the licensee demonstrated that a potential drain-down of the SFP as a result of the reevaluated seismic hazard is unlikely.
penetrations); seismically-induced SFP sloshing; and water losses due to heat-up and boil-off.
AUDIT REPORT The July 6, 2017, generic audit plan describes the NRC staffs intention to issue an audit report that summarizes and documents the NRC's regulatory audit of licensee's submittals associated with reevaluated seismic hazard analyses.
Section 4.0 also provides applicability criteria that enable licensees to determine if their site-specific conditions are within the bounds considered in developing some of the evaluation criteria in the guidance report. In its review, the staff confirmed that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report.
The NRC staffs North Anna audit was limited to the review of the calculation discussed above. An audit summary document is included as Enclosure 2 to this letter. CONCLUSION The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria of the SFP Evaluation Guidance Report for North Anna and therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes D. Stoddard that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevaluated seismic hazard at North Anna. If you have any questions, please contact me at (301) 415-1617 or via e-mail at Frankie.Vega@nrc.gov.
SPENT FUEL POOL STRUCTURAL EVALUATION Section 4.1 of the SFP Evaluation Guidance Report provides an SFP structural evaluation approach used to demonstrate that the SFP structure is sufficiently robust for the reevaluated seismic hazard. This approach supplements the guidance in Section 7 of the SPID and follows acceptable methods used to assess the seismic capacity of structures, systems, and components (SSCs) for nuclear power plants. In short, Sections 4.1.1 and 4.1.2 describe an acceptable method for licensees to use to calculate a site-specific seismic high confidence of
Docket Nos. 50-338 and 50-339  
 
D. Stoddard                                     low probability of failure (HCLPF) value for the SFP that is then compared to the site-specific GMRS.
The licensee stated that the SFP structural evaluation approach presented in the SFP Evaluation Guidance Report is applicable and, as a part of the audit process, provided site-specific data to the NRC staff to confirm the stated results for North Anna.
As a part of the audit process, the NRC staff reviewed the information provided in calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1", Revision 0, and confirmed that the site-specific HCLPF value calculated for North Anna's SFP followed the methodology of the SFP Evaluation Guidance Report and that the HCLPF value is greater than the GMRS. The staff concludes that SFP SSCs were appropriately evaluated and that the licensee has demonstrated that there is high confidence that the SFP structure is sufficiently robust to withstand ground motions with peak spectral accelerations up to and including the peak spectral acceleration of North Anna's GMRS.
SPENT FUEL POOL NON-STRUCTURAL EVALUATION Section 4.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the non-structural aspects of the SFP, such as piping connections, fuel gates, and anti-siphoning devices, as well as SFP sloshing and heat-up and boil-off of SFP water inventory. Additionally, page 4-11 of the SFP Evaluation Guidance Report provides a summary of the pertinent SFP non-structural parameters important to the methodology described in Section 4.2.
The licensee provided a table in its letter dated December 14, 2017, demonstrating that it followed the SFP non-structural evaluation approach presented in the SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability. The staff reviewed the non-structural information provided, which included North Anna's site-specific attributes, against the criteria described in the SFP Evaluation Guidance Report, and confirmed that the methods and conclusions are applicable to the North Anna site. Therefore, the staff concludes that the licensee adequately evaluated the non-structural considerations for SSCs whose failure could lead to potential drain-down of the SFP due to a seismic event. Further, the staff concludes that the licensee demonstrated that a potential drain-down of the SFP as a result of the reevaluated seismic hazard is unlikely.
AUDIT REPORT The July 6, 2017, generic audit plan describes the NRC staffs intention to issue an audit report that summarizes and documents the NRC's regulatory audit of licensee's submittals associated with reevaluated seismic hazard analyses. The NRC staffs North Anna audit was limited to the review of the calculation discussed above. An audit summary document is included as to this letter.
CONCLUSION The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria of the SFP Evaluation Guidance Report for North Anna and therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes
 
D. Stoddard                                   that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevaluated seismic hazard at North Anna.
If you have any questions, please contact me at (301) 415-1617 or via e-mail at Frankie.Vega@nrc.gov.
Si:?
4 Frankie Vega, Project Manager Beyond-Design-Basis Management Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339


==Enclosures:==
==Enclosures:==
: 1. Technical Review Checklist  
: 1. Technical Review Checklist
: 2. NRC Staff Audit Summary cc w/encls: Distribution via Listserv Si:?4 Frankie Vega, Project Manager Beyond-Design-Basis Management Branch Division of Licensing Projects Office of Nuclear Reactor Regulation TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SPENT FUEL POOL EVALUATIONS FOR HIGH GROUND MOTION RESPONSE SPECTRUM SITES IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 SEISMIC NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339 BACKGROUND By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, under Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) (hereafter referred to as the "50.54(f) letter").
: 2. NRC Staff Audit Summary cc w/encls: Distribution via Listserv
Enclosure 1 of the 50.54(f) letter requests addressees to reevaluate the seismic hazard at their site using present-day methods and guidance for licensing new nuclear power plants, and identify actions to address or modify, as necessary, plant components affected by the reevaluated seismic hazards. Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) with the safe shutdown earthquake (SSE). Enclosure 1, Item (9), requests that, when the GMRS exceeds the SSE in the 1 to 10 Hertz (Hz) frequency range, a seismic evaluation be made of the spent fuel pool (SFP). More specifically, plants were asked to consider all seismically induced failures that can lead to draining of the SFP. Additionally, by letter dated January 31, 2017 (ADAMS Accession No. ML 17031 A 171 ), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance:
 
Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report supports the completion of SFP evaluations for sites with reevaluated seismic hazard exceedance in the 1 to 1 O Hz frequency range. The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML 17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter. Licensee deviations from the SFP Evaluation Guidance should be discussed in their SFP evaluation submittal.
TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SPENT FUEL POOL EVALUATIONS FOR HIGH GROUND MOTION RESPONSE SPECTRUM SITES IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 SEISMIC NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339 BACKGROUND By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, under Title 10 of the Code of Federal Regulations (10 CFR),
By letter dated December 14, 2017 (ADAMS Accession No. ML 17354A160), Virginia Electric and Power Company (the licensee), provided an SFP report in response to Enclosure 1, Item (9), of the 50.54(f) letter for North Anna Power Station, Units 1 and 2 (North Anna). The NRC staff performed its review of the licensee's submittal to assess whether the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff evaluated whether the SFP Evaluation Guidance Report methodology had been followed when calculating the specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. The NRC staff also confirmed that the requested information in response to Item (9) of the 50.54(f) letter was provided.
Section 50.54(f) (hereafter referred to as the "50.54(f) letter"). Enclosure 1 of the 50.54(f) letter requests addressees to reevaluate the seismic hazard at their site using present-day methods and guidance for licensing new nuclear power plants, and identify actions to address or modify, as necessary, plant components affected by the reevaluated seismic hazards. Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) with the safe shutdown earthquake (SSE). Enclosure 1, Item (9), requests that, when the GMRS exceeds the SSE in the 1 to 10 Hertz (Hz) frequency range, a seismic evaluation be made of the spent fuel pool (SFP). More specifically, plants were asked to consider all seismically induced failures that can lead to draining of the SFP.
A review checklist was used for consistency and efficiency.
Additionally, by letter dated January 31, 2017 (ADAMS Accession No. ML17031A171 ), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report supports the completion of SFP evaluations for sites with reevaluated seismic hazard exceedance in the 1 to 1O Hz frequency range. The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter. Licensee deviations from the SFP Evaluation Guidance should be discussed in their SFP evaluation submittal.
The application of this staff review is limited to the SFP evaluation as part of the seismic review as part of the Near-Term Task Force (NTTF) Recommendation 2.1. Enclosure 1
By letter dated December 14, 2017 (ADAMS Accession No. ML17354A160), Virginia Electric and Power Company (the licensee), provided an SFP report in response to Enclosure 1, Item (9), of the 50.54(f) letter for North Anna Power Station, Units 1 and 2 (North Anna). The NRC staff performed its review of the licensee's submittal to assess whether the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff evaluated whether the SFP Evaluation Guidance Report methodology had been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. The NRC staff also confirmed that the requested information in response to Item (9) of the 50.54(f) letter was provided.
NTTF Recommendation 2.1 Spent Fuel Pool Evaluations Technical Review Checklist for North Anna Power Station, Units 1 and 2 Site Parameters:  
A review checklist was used for consistency and efficiency. The application of this staff review is limited to the SFP evaluation as part of the seismic review as part of the Near-Term Task Force (NTTF) Recommendation 2.1.
/. Site-Specific GMRS The licensee:
Enclosure 1
* Used the site-specific GMRS hazard, consistent with the information in the Seismic Hazard and Screening Report (SHSR) or its update, that was evaluated and accepted in the NRC staff assessment when calculating the SFP high confidence of low probability of failure (HCLPF) value. Notes from the reviewer:
 
Yes 1. The NRC staff reviewed the licensee's calculation 1 BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTIF Recommendation 2.1," Revision 0, as a part of the audit process for North Anna. The staff notes that the calculation derives seismic input values for the Fuel Building from other seismic input values that were ultimately generated by the NRG-accepted GMRS. Deviation(s) or Deficiency(ies), and Resolution:
NTTF Recommendation 2.1 Spent Fuel Pool Evaluations Technical Review Checklist for North Anna Power Station, Units 1 and 2 Site Parameters:
    /.       Site-Specific GMRS The licensee:
* Used the site-specific GMRS hazard, consistent with the                       Yes information in the Seismic Hazard and Screening Report (SHSR) or its update, that was evaluated and accepted in the NRC staff assessment when calculating the SFP high confidence of low probability of failure (HCLPF) value.
Notes from the reviewer:
: 1. The NRC staff reviewed the licensee's calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTIF Recommendation 2.1," Revision 0, as a part of the audit process for North Anna. The staff notes that the calculation derives seismic input values for the Fuel Building from other seismic input values that were ultimately generated by the NRG-accepted GMRS.
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
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Structural Parameters:
Structural Parameters:
II. Seismic Design of the SFP Structure The licensee:
II. Seismic Design of the SFP Structure The licensee:
* Performed site-specific calculations to demonstrate that the limiting SFP HCLPF capacity value is greater than the peak spectral acceleration of the site-specific GMRS. Notes from the reviewer:
* Performed site-specific calculations to demonstrate that the limiting       Yes SFP HCLPF capacity value is greater than the peak spectral acceleration of the site-specific GMRS.
Yes 1. The NRC staff confirmed that the licensee followed the methodology described in the SFP Evaluation Guidance Report in calculation 1 BAT35013-AQ-CAL-001, Revision 0, to calculate an SFP HCLPF capacity.
Notes from the reviewer:
The resulting HCLPF value is greater than the site-specific GMRS; therefore, it is reasonable to conclude that the SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.
: 1. The NRC staff confirmed that the licensee followed the methodology described in the SFP Evaluation Guidance Report in calculation 1BAT35013-AQ-CAL-001, Revision 0, to calculate an SFP HCLPF capacity. The resulting HCLPF value is greater than the site-specific GMRS; therefore, it is reasonable to conclude that the SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.
Deviation(s) or Deficiency(ies), and Resolution:
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
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* The SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.
* The SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.
Ill. SFP Structure Included in the Civil Inspection Program Performed in Accordance with Maintenance Rule The licensee:
Ill. SFP Structure Included in the Civil Inspection Program Performed in Accordance with Maintenance Rule The licensee:
* Stated that the SFP structure is included in the Civil Inspection Program performed in accordance with Maintenance Rule (10 CFR 50.65). Notes from the reviewer:
* Stated that the SFP structure is included in the Civil Inspection           Yes Program performed in accordance with Maintenance Rule (10 CFR 50.65).
Yes 1. The licensee stated that the Fuel Building, which contains the SFP structure, is included in the North Anna Civil Inspection Program. Final Safety Analysis Report (FSAR) Section 18.2.6 "Civil Engineering Structural Inspection" describes this program. Deviation(s) or Deficiency(ies), and Resolution:
Notes from the reviewer:
: 1. The licensee stated that the Fuel Building, which contains the SFP structure, is included in the North Anna Civil Inspection Program. Final Safety Analysis Report (FSAR) Section 18.2.6 "Civil Engineering Structural Inspection" describes this program.
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
* The SFP structure is included in the Civil Inspection Program performed in accordance with Maintenance Rule (10 CFR 50.65). Non-Structural Parameters:
* The SFP structure is included in the Civil Inspection Program performed in accordance with Maintenance Rule (10 CFR 50.65).
IV. Applicability of Piping Evaluation The licensee:
Non-Structural Parameters:
* Stated that there are no penetrations attached to the SFP more than 6 feet (ft.) below the normal level water surface. Notes from the reviewer:
IV.     Applicability of Piping Evaluation The licensee:
Yes 1. The licensee stated that the SFP water level is elevation 289 ft. 10 in. and that the lowest penetration through the SFP liner is approximately 285 ft. 9in. The staff reviewed FSAR Section 9.1.3.3.3 "Spent-Fuel Pit Water Leakage Control" and confirmed that there are no piping penetrations attached to the SFP pool more than 6 ft. below the normal level water surface. Deviation(s}
* Stated that there are no penetrations attached to the SFP more                 Yes than 6 feet (ft.) below the normal level water surface.
or Deficiency(ies}, and Resolution:
Notes from the reviewer:
: 1. The licensee stated that the SFP water level is elevation 289 ft. 10 in. and that the lowest penetration through the SFP liner is approximately 285 ft. 9in. The staff reviewed FSAR Section 9.1.3.3.3 "Spent-Fuel Pit Water Leakage Control" and confirmed that there are no piping penetrations attached to the SFP pool more than 6 ft. below the normal level water surface.
Deviation(s} or Deficiency(ies}, and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
* There are no piping penetrations attached to the SFP more than 6 ft. below the surface of the water. V. Ductile Behavior of SFP Gates The licensee:
* There are no piping penetrations attached to the SFP more than 6 ft. below the surface of the water.
* Stated that the SFP gate is constructed from a ductile material (e.g . aluminum or stainless steel alloys). Notes from the reviewer:
V.       Ductile Behavior of SFP Gates The licensee:
Yes 1. The licensee stated that the SFP gates are constructed of Type 304 stainless steel material.
* Stated that the SFP gate is constructed from a ductile material (e.g .         Yes aluminum or stainless steel alloys).
This is consistent with the materials specified in the SFP Evaluation Guidance Report to ensure ductile behavior of the gates. Deviation(s) or Deficiency(ies), and Resolution:
Notes from the reviewer:
: 1. The licensee stated that the SFP gates are constructed of Type 304 stainless steel material. This is consistent with the materials specified in the SFP Evaluation Guidance Report to ensure ductile behavior of the gates.
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
* The SFP gates are constructed from a material expected to exhibit ductile behavior under higher seismic demands. VI. Siphoning Evaluation The licensee:
* The SFP gates are constructed from a material expected to exhibit ductile behavior under higher seismic demands.
* Stated that anti-siphoning devices are installed on piping systems Yes that could lead to siphoning inventory from the SFP.
VI. Siphoning Evaluation The licensee:
* In cases where anti-siphoning devices were not included on the N/A applicable piping, a description documenting the evaluation performed to determine the seismic adequacy of the piping is provided.
* Stated that anti-siphoning devices are installed on piping systems           Yes that could lead to siphoning inventory from the SFP.
* Stated that the piping of the SFP cooling system cannot lead to rapid Yes drain down due to siphoning.
* In cases where anti-siphoning devices were not included on the               N/A applicable piping, a description documenting the evaluation performed to determine the seismic adequacy of the piping is provided.
* Stated that no anti-siphoning devices are attached to 2" or smaller piping with extremely large extended operators.
* Stated that the piping of the SFP cooling system cannot lead to rapid         Yes drain down due to siphoning.
Yes
* Stated that no anti-siphoning devices are attached to 2" or smaller Yes piping with extremely large extended operators.
* Provided a seismic adequacy evaluation, in accordance with NP-6041, for cases where active siphoning devices are attached to N/A 2" or smaller piping with extremely large extended operators.
* Provided a seismic adequacy evaluation, in accordance with N/A NP-6041, for cases where active siphoning devices are attached to 2" or smaller piping with extremely large extended operators.
Notes from the reviewer:  
Notes from the reviewer:
: 1. The licensee stated that siphoning of significant amounts of water is prevented by either passive anti-siphoning devices or the elevation of the piping open ends within the pool. The staff verified that the FSAR supports this statement (FSAR Section 9.1.3.3).
: 1. The licensee stated that siphoning of significant amounts of water is prevented by either passive anti-siphoning devices or the elevation of the piping open ends within the pool. The staff verified that the FSAR supports this statement (FSAR Section 9.1.3.3).
Deviation(s) or Deficiency(ies), and Resolution:
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
* Anti-siphoning devices exist in applicable piping systems that could Yes lead to siphoning water from the SFP.
* Anti-siphoning devices exist in applicable piping systems that could         Yes lead to siphoning water from the SFP.
* Piping of the SFP cooling system is not likely to lead to rapid Yes draindown due to siphoning.
* Piping of the SFP cooling system is not likely to lead to rapid               Yes draindown due to siphoning.
* No active anti-siphoning devices are attached to 2" or smaller piping Yes with extremely large extended operators.
* No active anti-siphoning devices are attached to 2" or smaller piping         Yes with extremely large extended operators.
VII. Sloshing Evaluation The licensee:
VII. Sloshing Evaluation The licensee:
* Specified the SFP dimensions (length, width, and depth) . Yes
* Specified the SFP dimensions (length, width, and depth) .         Yes
* Specified that the SFP dimensions are bounded by the dimensions Yes specified in the report (i.e., SFP length and width <125ft.; SFP depth >36ft. ). Notes from the reviewer:  
* Specified that the SFP dimensions are bounded by the dimensions   Yes specified in the report (i.e., SFP length and width <125ft.; SFP depth >36ft. ).
: 1. SFP dimensions (FSAR Section 3.8.1.1.4)  
Notes from the reviewer:
-SFP Length -60 ft. -SFP Width -29 ft. -SFP Depth -40 ft. 6 in. Deviation(s) or Deficiency(ies), and Resolution:
: 1. SFP dimensions (FSAR Section 3.8.1.1.4)
        - SFP Length - 60 ft.
        - SFP Width - 29 ft.
        - SFP Depth - 40 ft. 6 in.
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes that:
The NRC staff concludes that:
* SFP dimensions are bounded by the dimensions specified in the Yes report (i.e., SFP length and width <125 ft.; SFP depth >36ft.). VIII. Evaporation Evaluation The licensee:
* SFP dimensions are bounded by the dimensions specified in the     Yes report (i.e., SFP length and width <125 ft.; SFP depth >36ft.).
* Provided the surface area of the plant's SFP . Yes
VIII. Evaporation Evaluation The licensee:
* Stated that the surface area of the plant's SFP is greater than Yes 500 ft 2.
* Provided the surface area of the plant's SFP .                   Yes
* Provided the licensed reactor core thermal power . Yes
* Stated that the surface area of the plant's SFP is greater than Yes 500 ft 2.
* Stated that the reactor core thermal power is less than 4,000 Yes megawatt thermal (MW1) per unit. Notes from the reviewer:  
* Provided the licensed reactor core thermal power.               Yes
: 1. Surface area of pool = 1,740 ft 2 2. Reactor thermal power = 2,940 MW1 (FSAR Section 1.1) Deviation(s) or Deficiency(ies), and Resolution:
* Stated that the reactor core thermal power is less than 4,000   Yes megawatt thermal (MW1) per unit.
Notes from the reviewer:
                                  =
: 1. Surface area of pool 1,740 ft2
                                      =
: 2. Reactor thermal power 2,940 MW1 (FSAR Section 1.1)
Deviation(s) or Deficiency(ies), and Resolution:
No deviations or deficiencies were identified.
No deviations or deficiencies were identified.
The NRC staff concludes:
The NRC staff concludes:
* The surface area of the plant's SFP is greater than 500 ft 2. Yes
* The surface area of the plant's SFP is greater than 500 ft2 . Yes
* The reactor core thermal power is less than 4,000 MW1 per unit. Yes
* The reactor core thermal power is less than 4,000 MW1 per unit.             Yes


== Conclusions:==
==
Conclusions:==


The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the structural evaluation criteria specified in the SFP Evaluation Guidance Report. Therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevalutaed seismic hazard at North Anna.
The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. Therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevalutaed seismic hazard at North Anna.
AUDIT  
AUDIT  


==SUMMARY==
==SUMMARY==
BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO NORTH ANNA POWER STATION, UNITS 1 AND 2 SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID L-2017-JLD-0059)
BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO NORTH ANNA POWER STATION, UNITS 1 AND 2 SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID L-2017-JLD-0059)
BACKGROUND AND AUDIT BASIS By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information under Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(f) (hereafter referred to as the 50.54(f) letter). Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate the seismic hazards for their sites using present-day methods and regulatory guidance used by the NRC staff when reviewing applications for early site permits and combined licenses.
BACKGROUND AND AUDIT BASIS By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information under Title 10 of the Code of Federal Regulations (10 CFR),
By letter dated October 27, 2015 (ADAMS Accession No. ML 15194A015), the NRC made a determination of which licensees were to perform: ( 1) a seismic probabilistic risk assessment (SPRA), (2) limited scope evaluations, or (3) no further actions based on a comparison of the reevaluated seismic hazard and the site's design-basis earthquake.  
Section 50.54(f) (hereafter referred to as the 50.54(f) letter). Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate the seismic hazards for their sites using present-day methods and regulatory guidance used by the NRC staff when reviewing applications for early site permits and combined licenses.
{Note: Some plant-specific changes regarding whether an SPRA was needed or limited scope evaluations were needed at certain sites have occurred since the issuance of the October 27, 2015, letter.) By letter dated July 6, 2017 {ADAMS Accession No. ML 17177 A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. North Anna Power Station, Units 1 and 2 {North Anna) was included in the list of applicable licensees.
By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRC made a determination of which licensees were to perform: ( 1) a seismic probabilistic risk assessment (SPRA), (2) limited scope evaluations, or (3) no further actions based on a comparison of the reevaluated seismic hazard and the site's design-basis earthquake. {Note: Some plant-specific changes regarding whether an SPRA was needed or limited scope evaluations were needed at certain sites have occurred since the issuance of the October 27, 2015, letter.)
REGULATORY AUDIT SCOPE AND METHODOLOGY The areas of focus for the regulatory audit are the information contained in the spent fuel pool (SFP) evaluation submittal and all associated and relevant supporting documentation used in the development of the SFP evaluation including, but not limited to, methodology, process information, calculations, computer models, etc. AUDIT ACTIVITIES The North Anna audit took place at the NRC Headquarters in Rockville, MD, beginning on July 6, 2017 and ending in June 15, 2018. Licensee personnel participated remotely, via email, from their respective offices. A list of the licensee staff and NRC staff that participated in the audit is contained in Table 1. Enclosure 2
By letter dated July 6, 2017 {ADAMS Accession No. ML17177A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. North Anna Power Station, Units 1 and 2 {North Anna) was included in the list of applicable licensees.
Table 1 NRC Staff Licensee Staff Name Title Name Title Brett Titus Sr. Project Manager Diane Aitken Nuclear Regulatory Affairs Frankie Vega Project Manager On April 26, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to determine the high confidence low probability of failure (HCLPF) value for the SFP onto the licensee's ePortal (electronic reading room). The licensee uploaded calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, onto the ePortal on April 30, 2018. On June 13, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to develop the ISRS at various locations on the SFP. The licensee uploaded Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0, onto the ePortal on June 15, 2018, as requested by the NRC staff. DOCUMENTS AUDITED 1 BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision O Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0 OPEN ITEMS AND REQUEST FOR INFORMATION Following the review of the SFP ISRS and HCLPF calculations, there were no open items identified by the NRC staff that required proposed closure paths, and there were no requests for information discussed or planned to be issued. DEVIATIONS FROM AUDIT PLAN There were no deviations from the July 6, 2017, generic audit plan. AUDIT CONCLUSION The issuance of this document, containing the staff's review of the SFP evaluation submittal, concludes the SFP audit process for North Anna.
REGULATORY AUDIT SCOPE AND METHODOLOGY The areas of focus for the regulatory audit are the information contained in the spent fuel pool (SFP) evaluation submittal and all associated and relevant supporting documentation used in the development of the SFP evaluation including, but not limited to, methodology, process information, calculations, computer models, etc.
D. Stoddard
AUDIT ACTIVITIES The North Anna audit took place at the NRC Headquarters in Rockville, MD, beginning on July 6, 2017 and ending in June 15, 2018. Licensee personnel participated remotely, via email, from their respective offices. A list of the licensee staff and NRC staff that participated in the audit is contained in Table 1.
Enclosure 2


==SUBJECT:==
Table 1 NRC Staff                                      Licensee Staff Name                    Title                      Name                Title Brett Titus            Sr. Project Manager        Diane Aitken        Nuclear Regulatory Affairs Frankie Vega            Project Manager On April 26, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to determine the high confidence low probability of failure (HCLPF) value for the SFP onto the licensee's ePortal (electronic reading room). The licensee uploaded calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, onto the ePortal on April 30, 2018.
NORTH ANNA POWER STATION, UNITS 1 AND 2 -STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC DATED June 22, 2018 DISTRIBUTION:
On June 13, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to develop the ISRS at various locations on the SFP. The licensee uploaded Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0, onto the ePortal on June 15, 2018, as requested by the NRC staff.
PUBLIC RidsNrrDlpPbmbResource BTitus, NRR RidsNrrDorlLpl2-1 Resource RidsNrrLASLent Resource RidsACRS_MailCTR Resource PBMB R/F FVega, NRR RidsNrrPMNorthAnnaResource RidsRgn2MailCenter Resource ADAMS Accession No.: ML 18165A412
DOCUMENTS AUDITED 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision O Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0 OPEN ITEMS AND REQUEST FOR INFORMATION Following the review of the SFP ISRS and HCLPF calculations, there were no open items identified by the NRC staff that required proposed closure paths, and there were no requests for information discussed or planned to be issued.
* via e-mail OFFICE NRR/DLP/PBMB/PM NRR/DLP/PBMB/LA NRR/DLP/PBMB/BC NAME FVega SLent BTitus DATE 06/20/2018 06/14/2018 06/21/2018 OFFICE NRR/DLP/PBMB/PM NAME FVega DATE 06/22/2018 OFFICIAL RECORD COPY}}
DEVIATIONS FROM AUDIT PLAN There were no deviations from the July 6, 2017, generic audit plan.
AUDIT CONCLUSION The issuance of this document, containing the staff's review of the SFP evaluation submittal, concludes the SFP audit process for North Anna.
 
ML18165A412
* via e-mail OFFICE NRR/DLP/PBMB/PM NRR/DLP/PBMB/LA             NRR/DLP/PBMB/BC NAME     FVega               SLent               BTitus DATE     06/20/2018           06/14/2018         06/21/2018 OFFICE NRR/DLP/PBMB/PM NAME     FVega DATE     06/22/2018}}

Latest revision as of 21:09, 2 February 2020

Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1: Seismic
ML18165A412
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 06/22/2018
From: Frankie Vega
Beyond-Design-Basis Management Branch
To: Stoddard D
Virginia Electric & Power Co (VEPCO)
Vega F, NRR/DLP, 415-1617
References
EPID L-2017-JLD-0059
Download: ML18165A412 (14)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 22, 2018 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2- STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID NO. L-2017-JLD-0059)

Dear Mr. Stoddard:

The purpose of this letter is to inform Virginia Electric and Power Company (the licensee), of the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel pool (SFP) evaluation for North Anna Power Station, Units 1 and 2 (North Anna), which was submitted in response to Item 9 of Enclosure 1 of the NRC's March 12, 2012, request for information (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340) issued under Title 10 of the Code of Federal Regulations, Section 50.54(f)

(hereafter referred to as the 50.54(f) letter). The NRC staff concludes that the licensee's assessment was performed consistent with the NRG-endorsed SFP Evaluation Guidance Report and that the licensee has provided sufficient information to complete the response to Item (9) of the 50.54(f) letter.

BACKGROUND On March 12, 2012, the NRC issued the 50.54(f) letter as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate seismic hazards at their sites using present-day methodologies and guidance. Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) and the safe shutdown earthquake (SSE). The staff's assessment of the information provided in response to Items (1 )-(3) and (5)-(7) and the comparison portion of Item (4) of the 50.54(f) letter was provided by letter dated August 20, 2015 (ADAMS Accession No. ML15057A249). Enclosure 1, Item (9), of the 50.54(f) letter requested that, when the GMRS exceeds the SSE in the 1 to 10 Hertz frequency range, the licensee provide a seismic evaluation of the SFP. More specifically, licensees were asked to consider " ... all seismically induced failures that can lead to draining of the SFP."

D. Stoddard By letter dated January 31, 2017 (ADAMS Accession No. ML17031A171), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating the seismic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements the guidance in EPRI Report 1025287, "Seismic Evaluation Guidance: Screening, Prioritization and Implementation Details (SPID)" (ADAMS Accession No. ML12333A170). The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter.

By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRC staff stated that SFP evaluation submittals for sites with GMRS peak spectral accelerations above 0.8g were expected by December 31, 2017.

By letter dated July 6, 2017 (ADAMS Accession No. ML17177A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. The North Anna site was included in the list of applicable licensees. The staff used the audit process as described below during the SFP evaluation review.

REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION By letter dated December 14, 2017 (ADAMS Accession No. ML17354A160), the licensee submitted its SFP evaluation for North Anna. The NRC staff assessed the licensee's implementation of the SFP Evaluation Guidance Report through the completion of a reviewer checklist, which is included as an enclosure to this letter.

TECHNICAL EVALUATION Section 4.0 of the SFP Evaluation Guidance Report provides SFP evaluation criteria for plants with GMRS peak spectral accelerations greater than 0.8g. These criteria address SFP structural elements (e.g., floors, walls, and supports); non-structural elements (e.g.,

penetrations); seismically-induced SFP sloshing; and water losses due to heat-up and boil-off.

Section 4.0 also provides applicability criteria that enable licensees to determine if their site-specific conditions are within the bounds considered in developing some of the evaluation criteria in the guidance report. In its review, the staff confirmed that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report.

SPENT FUEL POOL STRUCTURAL EVALUATION Section 4.1 of the SFP Evaluation Guidance Report provides an SFP structural evaluation approach used to demonstrate that the SFP structure is sufficiently robust for the reevaluated seismic hazard. This approach supplements the guidance in Section 7 of the SPID and follows acceptable methods used to assess the seismic capacity of structures, systems, and components (SSCs) for nuclear power plants. In short, Sections 4.1.1 and 4.1.2 describe an acceptable method for licensees to use to calculate a site-specific seismic high confidence of

D. Stoddard low probability of failure (HCLPF) value for the SFP that is then compared to the site-specific GMRS.

The licensee stated that the SFP structural evaluation approach presented in the SFP Evaluation Guidance Report is applicable and, as a part of the audit process, provided site-specific data to the NRC staff to confirm the stated results for North Anna.

As a part of the audit process, the NRC staff reviewed the information provided in calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1", Revision 0, and confirmed that the site-specific HCLPF value calculated for North Anna's SFP followed the methodology of the SFP Evaluation Guidance Report and that the HCLPF value is greater than the GMRS. The staff concludes that SFP SSCs were appropriately evaluated and that the licensee has demonstrated that there is high confidence that the SFP structure is sufficiently robust to withstand ground motions with peak spectral accelerations up to and including the peak spectral acceleration of North Anna's GMRS.

SPENT FUEL POOL NON-STRUCTURAL EVALUATION Section 4.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the non-structural aspects of the SFP, such as piping connections, fuel gates, and anti-siphoning devices, as well as SFP sloshing and heat-up and boil-off of SFP water inventory. Additionally, page 4-11 of the SFP Evaluation Guidance Report provides a summary of the pertinent SFP non-structural parameters important to the methodology described in Section 4.2.

The licensee provided a table in its letter dated December 14, 2017, demonstrating that it followed the SFP non-structural evaluation approach presented in the SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability. The staff reviewed the non-structural information provided, which included North Anna's site-specific attributes, against the criteria described in the SFP Evaluation Guidance Report, and confirmed that the methods and conclusions are applicable to the North Anna site. Therefore, the staff concludes that the licensee adequately evaluated the non-structural considerations for SSCs whose failure could lead to potential drain-down of the SFP due to a seismic event. Further, the staff concludes that the licensee demonstrated that a potential drain-down of the SFP as a result of the reevaluated seismic hazard is unlikely.

AUDIT REPORT The July 6, 2017, generic audit plan describes the NRC staffs intention to issue an audit report that summarizes and documents the NRC's regulatory audit of licensee's submittals associated with reevaluated seismic hazard analyses. The NRC staffs North Anna audit was limited to the review of the calculation discussed above. An audit summary document is included as to this letter.

CONCLUSION The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteria of the SFP Evaluation Guidance Report for North Anna and therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes

D. Stoddard that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevaluated seismic hazard at North Anna.

If you have any questions, please contact me at (301) 415-1617 or via e-mail at Frankie.Vega@nrc.gov.

Si:?

4 Frankie Vega, Project Manager Beyond-Design-Basis Management Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosures:

1. Technical Review Checklist
2. NRC Staff Audit Summary cc w/encls: Distribution via Listserv

TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SPENT FUEL POOL EVALUATIONS FOR HIGH GROUND MOTION RESPONSE SPECTRUM SITES IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 SEISMIC NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339 BACKGROUND By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, under Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.54(f) (hereafter referred to as the "50.54(f) letter"). Enclosure 1 of the 50.54(f) letter requests addressees to reevaluate the seismic hazard at their site using present-day methods and guidance for licensing new nuclear power plants, and identify actions to address or modify, as necessary, plant components affected by the reevaluated seismic hazards. Enclosure 1, Item (4), of the 50.54(f) letter requested that licensees perform a comparison of the ground motion response spectrum (GMRS) with the safe shutdown earthquake (SSE). Enclosure 1, Item (9), requests that, when the GMRS exceeds the SSE in the 1 to 10 Hertz (Hz) frequency range, a seismic evaluation be made of the spent fuel pool (SFP). More specifically, plants were asked to consider all seismically induced failures that can lead to draining of the SFP.

Additionally, by letter dated January 31, 2017 (ADAMS Accession No. ML17031A171 ), the Nuclear Energy Institute (NEI) submitted the Electric Power Research Institute (EPRI) Report No. 3002009564 entitled, "Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report supports the completion of SFP evaluations for sites with reevaluated seismic hazard exceedance in the 1 to 1O Hz frequency range. The NRC endorsed the SFP Evaluation Guidance Report by letter dated February 28, 2017 (ADAMS Accession No. ML17034A408), as an acceptable method for licensees to use when responding to Item (9) in Enclosure 1 of the 50.54(f) letter. Licensee deviations from the SFP Evaluation Guidance should be discussed in their SFP evaluation submittal.

By letter dated December 14, 2017 (ADAMS Accession No. ML17354A160), Virginia Electric and Power Company (the licensee), provided an SFP report in response to Enclosure 1, Item (9), of the 50.54(f) letter for North Anna Power Station, Units 1 and 2 (North Anna). The NRC staff performed its review of the licensee's submittal to assess whether the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff evaluated whether the SFP Evaluation Guidance Report methodology had been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. The NRC staff also confirmed that the requested information in response to Item (9) of the 50.54(f) letter was provided.

A review checklist was used for consistency and efficiency. The application of this staff review is limited to the SFP evaluation as part of the seismic review as part of the Near-Term Task Force (NTTF) Recommendation 2.1.

Enclosure 1

NTTF Recommendation 2.1 Spent Fuel Pool Evaluations Technical Review Checklist for North Anna Power Station, Units 1 and 2 Site Parameters:

/. Site-Specific GMRS The licensee:

  • Used the site-specific GMRS hazard, consistent with the Yes information in the Seismic Hazard and Screening Report (SHSR) or its update, that was evaluated and accepted in the NRC staff assessment when calculating the SFP high confidence of low probability of failure (HCLPF) value.

Notes from the reviewer:

1. The NRC staff reviewed the licensee's calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, and Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTIF Recommendation 2.1," Revision 0, as a part of the audit process for North Anna. The staff notes that the calculation derives seismic input values for the Fuel Building from other seismic input values that were ultimately generated by the NRG-accepted GMRS.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • The licensee's derivation of the Fuel Building In-Structure Response Spectra (ISRS) was generated using input motions based on GMRS demands. The staff considers this as reasonable for the purposes of this calculation.

Structural Parameters:

II. Seismic Design of the SFP Structure The licensee:

  • Performed site-specific calculations to demonstrate that the limiting Yes SFP HCLPF capacity value is greater than the peak spectral acceleration of the site-specific GMRS.

Notes from the reviewer:

1. The NRC staff confirmed that the licensee followed the methodology described in the SFP Evaluation Guidance Report in calculation 1BAT35013-AQ-CAL-001, Revision 0, to calculate an SFP HCLPF capacity. The resulting HCLPF value is greater than the site-specific GMRS; therefore, it is reasonable to conclude that the SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • The SFP has sufficient capacity to withstand a seismic event at least up to the GMRS without failure that would lead to a rapid draindown.

Ill. SFP Structure Included in the Civil Inspection Program Performed in Accordance with Maintenance Rule The licensee:

  • Stated that the SFP structure is included in the Civil Inspection Yes Program performed in accordance with Maintenance Rule (10 CFR 50.65).

Notes from the reviewer:

1. The licensee stated that the Fuel Building, which contains the SFP structure, is included in the North Anna Civil Inspection Program. Final Safety Analysis Report (FSAR) Section 18.2.6 "Civil Engineering Structural Inspection" describes this program.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • The SFP structure is included in the Civil Inspection Program performed in accordance with Maintenance Rule (10 CFR 50.65).

Non-Structural Parameters:

IV. Applicability of Piping Evaluation The licensee:

  • Stated that there are no penetrations attached to the SFP more Yes than 6 feet (ft.) below the normal level water surface.

Notes from the reviewer:

1. The licensee stated that the SFP water level is elevation 289 ft. 10 in. and that the lowest penetration through the SFP liner is approximately 285 ft. 9in. The staff reviewed FSAR Section 9.1.3.3.3 "Spent-Fuel Pit Water Leakage Control" and confirmed that there are no piping penetrations attached to the SFP pool more than 6 ft. below the normal level water surface.

Deviation(s} or Deficiency(ies}, and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • There are no piping penetrations attached to the SFP more than 6 ft. below the surface of the water.

V. Ductile Behavior of SFP Gates The licensee:

  • Stated that the SFP gate is constructed from a ductile material (e.g . Yes aluminum or stainless steel alloys).

Notes from the reviewer:

1. The licensee stated that the SFP gates are constructed of Type 304 stainless steel material. This is consistent with the materials specified in the SFP Evaluation Guidance Report to ensure ductile behavior of the gates.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • The SFP gates are constructed from a material expected to exhibit ductile behavior under higher seismic demands.

VI. Siphoning Evaluation The licensee:

  • Stated that anti-siphoning devices are installed on piping systems Yes that could lead to siphoning inventory from the SFP.
  • In cases where anti-siphoning devices were not included on the N/A applicable piping, a description documenting the evaluation performed to determine the seismic adequacy of the piping is provided.
  • Stated that the piping of the SFP cooling system cannot lead to rapid Yes drain down due to siphoning.
  • Stated that no anti-siphoning devices are attached to 2" or smaller Yes piping with extremely large extended operators.
  • Provided a seismic adequacy evaluation, in accordance with N/A NP-6041, for cases where active siphoning devices are attached to 2" or smaller piping with extremely large extended operators.

Notes from the reviewer:

1. The licensee stated that siphoning of significant amounts of water is prevented by either passive anti-siphoning devices or the elevation of the piping open ends within the pool. The staff verified that the FSAR supports this statement (FSAR Section 9.1.3.3).

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • Anti-siphoning devices exist in applicable piping systems that could Yes lead to siphoning water from the SFP.
  • Piping of the SFP cooling system is not likely to lead to rapid Yes draindown due to siphoning.
  • No active anti-siphoning devices are attached to 2" or smaller piping Yes with extremely large extended operators.

VII. Sloshing Evaluation The licensee:

  • Specified the SFP dimensions (length, width, and depth) . Yes
  • Specified that the SFP dimensions are bounded by the dimensions Yes specified in the report (i.e., SFP length and width <125ft.; SFP depth >36ft. ).

Notes from the reviewer:

1. SFP dimensions (FSAR Section 3.8.1.1.4)

- SFP Length - 60 ft.

- SFP Width - 29 ft.

- SFP Depth - 40 ft. 6 in.

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

  • SFP dimensions are bounded by the dimensions specified in the Yes report (i.e., SFP length and width <125 ft.; SFP depth >36ft.).

VIII. Evaporation Evaluation The licensee:

  • Provided the surface area of the plant's SFP . Yes
  • Stated that the surface area of the plant's SFP is greater than Yes 500 ft 2.
  • Provided the licensed reactor core thermal power. Yes
  • Stated that the reactor core thermal power is less than 4,000 Yes megawatt thermal (MW1) per unit.

Notes from the reviewer:

=

1. Surface area of pool 1,740 ft2

=

2. Reactor thermal power 2,940 MW1 (FSAR Section 1.1)

Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes:

  • The surface area of the plant's SFP is greater than 500 ft2 . Yes
  • The reactor core thermal power is less than 4,000 MW1 per unit. Yes

==

Conclusions:==

The NRC staff reviewed the licensee's SFP evaluation report. Based on its review, the NRC staff concludes that the SFP Evaluation Guidance Report methodology has been followed when calculating the site-specific seismic capacity of the SFP, and that North Anna's site-specific values and conditions are within the acceptable limits and bounds considered for the non-structural evaluation criteria specified in the SFP Evaluation Guidance Report. Therefore, the licensee responded appropriately to Item (9) in Enclosure 1 of the 50.54(f) letter. The NRC staff further concludes that the licensee has demonstrated an adequate margin to preclude a potential drain-down of the SFP as a result of the reevalutaed seismic hazard at North Anna.

AUDIT

SUMMARY

BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO NORTH ANNA POWER STATION, UNITS 1 AND 2 SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1: SEISMIC (EPID L-2017-JLD-0059)

BACKGROUND AND AUDIT BASIS By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information under Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.54(f) (hereafter referred to as the 50.54(f) letter). Enclosure 1 to the 50.54(f) letter requested that licensees reevaluate the seismic hazards for their sites using present-day methods and regulatory guidance used by the NRC staff when reviewing applications for early site permits and combined licenses.

By letter dated October 27, 2015 (ADAMS Accession No. ML15194A015), the NRC made a determination of which licensees were to perform: ( 1) a seismic probabilistic risk assessment (SPRA), (2) limited scope evaluations, or (3) no further actions based on a comparison of the reevaluated seismic hazard and the site's design-basis earthquake. {Note: Some plant-specific changes regarding whether an SPRA was needed or limited scope evaluations were needed at certain sites have occurred since the issuance of the October 27, 2015, letter.)

By letter dated July 6, 2017 {ADAMS Accession No. ML17177A446), the NRC issued a generic audit plan and entered into the audit process described in Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195), to assist in the timely and efficient closure of activities associated with the 50.54(f) letter. North Anna Power Station, Units 1 and 2 {North Anna) was included in the list of applicable licensees.

REGULATORY AUDIT SCOPE AND METHODOLOGY The areas of focus for the regulatory audit are the information contained in the spent fuel pool (SFP) evaluation submittal and all associated and relevant supporting documentation used in the development of the SFP evaluation including, but not limited to, methodology, process information, calculations, computer models, etc.

AUDIT ACTIVITIES The North Anna audit took place at the NRC Headquarters in Rockville, MD, beginning on July 6, 2017 and ending in June 15, 2018. Licensee personnel participated remotely, via email, from their respective offices. A list of the licensee staff and NRC staff that participated in the audit is contained in Table 1.

Enclosure 2

Table 1 NRC Staff Licensee Staff Name Title Name Title Brett Titus Sr. Project Manager Diane Aitken Nuclear Regulatory Affairs Frankie Vega Project Manager On April 26, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to determine the high confidence low probability of failure (HCLPF) value for the SFP onto the licensee's ePortal (electronic reading room). The licensee uploaded calculation 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision 0, onto the ePortal on April 30, 2018.

On June 13, 2018, the NRC staff requested, via email, that the licensee upload the calculation that was performed to develop the ISRS at various locations on the SFP. The licensee uploaded Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0, onto the ePortal on June 15, 2018, as requested by the NRC staff.

DOCUMENTS AUDITED 1BAT35013-AQ-CAL-001, "Spent Fuel Pool Assessment," Revision O Engineering Technical Evaluation ETE-CEM-20160002, "Seismic Response Spectra at Spent Fuel Pool (SFP) Locations in Fuel Building for NRC Fukushima NTTF Recommendation 2.1, Revision 0 OPEN ITEMS AND REQUEST FOR INFORMATION Following the review of the SFP ISRS and HCLPF calculations, there were no open items identified by the NRC staff that required proposed closure paths, and there were no requests for information discussed or planned to be issued.

DEVIATIONS FROM AUDIT PLAN There were no deviations from the July 6, 2017, generic audit plan.

AUDIT CONCLUSION The issuance of this document, containing the staff's review of the SFP evaluation submittal, concludes the SFP audit process for North Anna.

ML18165A412

  • via e-mail OFFICE NRR/DLP/PBMB/PM NRR/DLP/PBMB/LA NRR/DLP/PBMB/BC NAME FVega SLent BTitus DATE 06/20/2018 06/14/2018 06/21/2018 OFFICE NRR/DLP/PBMB/PM NAME FVega DATE 06/22/2018
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