ML17031A001

Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1 (CAC Nos. MF3824 and MF3825)

ML17031A001
Person / Time
Site:	Brunswick
Issue date:	02/02/2017
From:	Vega F G Japan Lessons-Learned Division
To:	Gideon W R Duke Energy Progress
Vega F G, NRR/JLD 415-1617
References
CAC MF3824, CAC MF3825
Download: ML17031A001 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. William R. Gideon Site Vice President Brunswick Steam Electric Plant Brunswick Steam Electric Plant 8470 River Rd. SE (M/C BNP001) Southport , NC 28461 February 2 , 2017

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT , UNITS 1AND2 -STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION 2.1 (CAC NOS. MF3824 AND MF3825)

Dear Mr. Gideon:

The purpose of this letter is to inform Duke Energy Progress , LLC (Duke , the licensee) of the results of the U.S. Nuclear Regulatory Commission (NRC) staff's review of the spent fuel pool (SFP) evaluation for Brunswick Steam Electric Plant , Units 1 and 2 (Brunswick), 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 1 O of the Code of Federal Regulations Part 50 , 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 a 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 of the 50.54(f) letter is provided by letter dated March 1 , 2016 (ADAMS Accession No. ML 16041 A435). Enclosure 1 , Item 9 , of the 50.54(f) letter requested that , when the GMRS exceeds the SSE in the 1 to 1 O Hertz frequency range , 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."

W. Gideon By letter dated February 23 , 2016 (ADAMS Accession No. ML 16055A021

), the Nuclear Energy Institute (NEI) staff submitted Electric Power Research Institute (EPRI) Report No. 3002007148 entitled , " Seismic Evaluation Gu i dance: Spent Fuel Pool Integrity Evaluation" (SFP Evaluation Guidance Report). The SFP Evaluation Guidance Report provides criteria for evaluating th.e se i smic adequacy of an SFP to the reevaluated GMRS hazard levels. This report supplements the gu i dance in EPRI Report 1025287 , " Seismic Evaluation Guidance: Screening , Prioritization and Implementation Details (SPID)" (ADAMS Accession No. ML 12333A 170), for plants where the GMRS peak spectral acceleration is less than or equal to 0.8g (low GMRS sites). The NRC endorsed the SFP Evaluat i on Guidance Report by letter dated March 17 , 2016 (ADAMS Accession No. ML 15350A 158), 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 low GMRS sites are expected by December 31 , 2016. REVIEW OF LICENSEE SPENT FUEL POOL EVALUATION By letter dated December 15 , 2016 (ADAMS Accession No. ML 16365A025), the licensee submitted its SFP evaluation for Brunswick for NRC review. 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 3.0 of the SFP Evaluation Guidance Report develops SFP evaluation criteria for plants with GMRS peak spectral acceleration less than or equal to 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 3.0 also provides applicability criteria , which will enable licensees to determine if their site-specific conditions are within the bounds considered in developing the evaluat i on criteria for this report. The staff's review consists of confirming that these SFP site-specific conditions are within the bounds considered for the evaluation criteria specified in the SFP Evaluation Guidance Report. 1.1 Spent Fuel Pool Structural Evaluation Section 3.1 of the SFP Evaluation Guidance Report provides a SFP structural evaluation approach used to demonstrate that the SFP structure is sufficiently robust against the reevaluated seismic hazard. This approach supplements the guidance in Section 7 of the SPID and followed acceptable methods used to assess the seismic capacity of structures , systems , and components (SSCs) for nuclear power plants as documented in EPRI NP-6041 , " A Methodology for Assessment of Nuclear Plant Seismic Margin , Revision 1." Table 3-2 of the SFP Evaluation Guidance Report (reproduced from Table 2.3 of EPRI NP-6041) provides the structural screening criteria to assess the SFPs and their supporting structures. The licensee stated that it followed the SFP structural evaluation approach presented in the SFP Evaluation Guidance Report and provided site-specific data to confirm its applicability.

W. Gideon The NRC staff reviewed the structural information provided, which included the requested specific data in Section 3.3 of the SFP Evaluation Guidance Report, and confirmed that the evaluation criteria are applicable to the Brunswick site. The staff concludes that SFP SSCs were appropriately evaluated and screened based on the seismic capacity criteria in EPRI NP-6041 , and that the licensee has demonstrated that the SFP structure is sufficiently robust and can withstand ground motions with peak spectral acceleration less than or equal to O.Bg. 1.2 Spent Fuel Pool Non-Structural Evaluation Section 3.2 of the SFP Evaluation Guidance Report provides criteria for evaluating the 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.

Specifically, Table 3-4 of the SFP Evaluation Guidance Report provides a summary of the SFP structural evaluation criteria derived in Section 3.2, along with applicability criteria to demonstrate that site-specific conditions are suitable for applying the evaluation criteria. The licensee stated that it followed the SFP non-structural evaluation approach presented in the guidance report and provided site-specific data to confirm its applicability.

The staff reviewed the non-structural information provided, which included the requested site-specific data in Table 3-4 of the SFP Evaluation Guidance Report, and confirmed that the evaluation criteria are applicable to the Brunswick site. Therefore, the staff concludes that the licensee adequately evaluated the non-structural considerations for SSCs whose failure could lead to potential down of the SFP due to a seismic event. 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 Brunswick and therefore , the licensee responded appropriately to Item 9 in Enclosure 1 of the NRC's 50.54(f) letter.

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

Docket Nos. 50-325 and 50-324

Enclosure:

Technical Review Checklist cc w/encl: Distribution via Listserv Sincerely , Frankie Vega , Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SPENT FUEL POOL EVALUATIONS FOR LOW GROUND MOTION RESPONSE SPECTRUM SITES IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION

2.1 SEISMIC

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 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, pursuant to Title 10 of the Code of Federal Regulations (1 O 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 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 February 23, 2016 (ADAMS Accession No. ML 16055A021

), the Nuclear Energy Institute (NEI) submitted Electric Power Research Institute (EPRI) Report No. 3002007148 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. Specifically, the SFP Evaluation Guidance Report addressed those sites where the GMRS peak spectral acceleration (Sa) is less than or equal to 0.8g (low GMRS sites). The NRC endorsed the SFP Evaluation Guidance Report by letter dated March 17, 2016 (ADAMS Accession No. ML 15350A 158), 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 15, 2016 (ADAMS Accession No. ML 16365A025), Duke Energy Progress , LLC (Duke, the licensee), provided a SFP report in a response to Enclosure 1, Item 9 , of the 50.54(f) letter for Brunswick Steam Electric Plant , Units 1 and 2 (Brunswick).

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 checked whether the site-specific parameters are within the bounds of the criteria considered in the SFP Evaluation Guidance Report, verified the SFP's seismic adequacy to withstand the reevaluated GMRS hazard levels, and confirmed that the requested information in response to Item 9 of th e 50.54(f) letter was provided.

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

NTTF Recommendation

2.1 Spent

Fuel Pool Evaluations Technical Review Checklist for Brunswick Steam Electric P_lant, Units 1 and 2 Site Parameters:

I. Site-Specific GMRS The licensee:

• Provided the site-specific GMRS consistent with the information Yes provided in the Seismic Hazard and Screening Report (SHSR), or its update , and evaluated by the staff in its staff assessment.

• Stated that the GMRS peak S a is less than or equal to 0.8g for any Yes frequency. Notes from the reviewer:

1. The NRC staff confirmed that the site-specific peak S a= 0.563g (SHSR -ADAMS Accession No. ML 14106A461

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

No deviations or deficiencies were identified.

The NRC staff concludes:

• The site-specific GMRS peak S a at any frequency i s less than 0.8g .

• The licensee's GMRS used in this evaluation is consistent with the information provided in the SHSR. Structural Parameters:

II. Seismic Design of the SFP Structure The licensee:

• Specified the building housing the SFP.

• Specified the plant's peak ground acceleration (PGA).

• Stated th a t the building housing the SFP w a s designed u s ing a n SSE with a PGA of at least 0.1 g. Yes Yes Yes Y e s Y e s Notes from the reviewer:

1. The NRC staff confirmed that the SFP is housed in the reactor building which is seismically designed to the site SSE with a PGA of 0.16g (SHSR Section 3.1 and Updated Final Safety Analysis Report (UFSAR , Section 3.2.1 and 3.8) Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

• The structure housing the SFP was designed using an SSE w i th a Yes PGA of at least 0.1 g. Ill. Structural Load Path to the SFP The licensee:

• Provided a description of the structural load path from the Y e s foundation to the SFP.

• Performed screening based on EPRI NP-6041 Table 2-3 screening Yes criteria. Notes from the reviewer:

1. The staff verified the structural load path to the SFP. The staff confirmed that the structural load path from the reactor building foundation to the SFP consists of a combination of reinforced concrete shear wall elements , reinforced concrete frame elements , post-tensioned concrete elements , and/or structural steel frame elements (UFSAR Section 3.8.4). Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes that:

• Licen see a ppropriately de sc ribed the stru c tur a l l o a d p a th to th e SFP.

• Structures were appropriately screened based on the screen i ng criteria in EPRI NP-6041. Y es Yes IV. 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 (1 O CFR 50.65). Notes from the reviewer:

None 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 Yes performed in accordance with Maintenance Rule (1 O CFR 50.65). Non-Structural Parameters:

V. Applicability of Piping Evaluation The licensee:

• Stated that piping attached to the SFP is evaluated to the SSE . Yes Notes from the reviewer:

1. T h e licen s ee stated th a t piping a tt a ched to th e S F P is Cl a s s 1 p i ping ev a lu a t e d to th e SSE (UFSAR Section 3.2.1.6). Deviation(s) or Deficiency(ies), and Resolution:

No devi a tions or deficienci es w e re i dentified.

The NRC staff concludes that:

• The piping attached to the SFP is evaluated to the SSE . Yes

• Applicability cr i teria specified in Table 3-4 of SFP evaluation Yes guid a nce h a v e been m e t.

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 fo rapid No drain down due to siphoning.

• Stated that no anti-siphoning devices are attached to 2" or smaller piping with extremely large extended operators. Yes

• Provided a seismic adequacy evaluation, in accordance with NP-6041, for cases where active siphoning devices are attached to 2" or N/A smaller piping with extremely large extended operators.

Notes from the reviewer:

1. The licensee stated that anti-siphoning devices are installed on all SFP piping that could lead to siphoning (UFSAR Section 9.1.3.2).

2. Piping of the SFP cooling system is not likely to lead to rapid draindown due to siphoning.

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

No deviations or deficiencies were identified. The NRC staff concludes:

• 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.

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

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.).

• Stated that the peak Sa in the frequency range less than 0.3 Hz is Yes less than 0.1 g. Notes from the reviewer:

1. Unit 1 -SFP dimensions (UFSAR Section 9.1.2.2.1)

-SFP Length -46 ft. -SFP Width -28 ft. -SFP Depth -38. 75 ft. 2. The staff confirmed in the SHSR that the peak Sa in the frequency range less than 0.3 Hz is less than 0.1 g (SHSR). Deviation(s) or Deficiency(ies), and Resolution:

No deviations or deficiencies were identified.

The NRC staff concludes:

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

• The peak Sa in the frequency range less than 0.3 Hz is less than 0.1g.

• Applicability criteria specified in Table 3-4 of SFP evaluation guidance have been met. VIII. Evaporation Evaluation The licensee:

• Provided the surface area of the plant's SFP .

• Stated that the surface area of the plant's SFP is greater than 500 ft 2.

• Provided the licensed reactor core thermal power .

• Stated that the reactor core thermal power is less than 4,000 megawatt thermal (MW1) per unit. Yes Yes Yes Yes Yes Yes Yes Notes from the reviewer:

1. Surface area of pool = 1 , 288 ft 2 2. Reactor thermal power= 2 , 923 MW 1 (UFSAR 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 ft 2. Yes

• The reactor core thermal power is less than 4 , 000 MW 1 per unit. Yes

• Applicability criteria specified in Table 3-4 of SFP evaluation Yes guidance have been met.

Conclusions:

The NRC staff reviewed the licensee's SFP evaluation report. Based on its r eview , the NRC staff concludes that the licensee's implementation of the SFP integrity evaluation met the criteri a of the SFP Evaluation Guidance Report for Brunswick and therefore the licensee responded appropriately to Item 9 in Enclosure 1 of the 50.54(f) letter.

W. Gideon BRUNSWICK STEAM ELECTRIC PLANT , UNITS 1 AND 2 -STAFF REVIEW OF SPENT FUEL POOL EVALUATION ASSOCIATED WITH REEVALUATED SEISMIC HAZARD IMPLEMENTING NEAR-TERM TASK FORCE RECOMMENDATION

2.1 DATED

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