ML15281A004

2015/10/01 NRR E-mail Capture - Callaway Plant - Technical Review Checklist Related to Interim ESEP Supporting Implementation of NTTF R2.1, Seismic (TAC No. MF5230)

ML15281A004
Person / Time
Site:	Callaway
Issue date:	10/01/2015
From:	Jackson D T Office of New Reactors
To:	Shams M K Japan Lessons-Learned Division
References
TAC MF5230
Download: ML15281A004 (12)

Text

1NRR-PMDAPEm Resource From:Jackson, Diane Sent:Thursday, October 01, 2015 2:53 PM To:Shams, Mohamed Cc:DiFrancesco, Nicholas; Spence, Jane; Devlin

-Gill, Stephanie; Roche, Kevin; Yee, On; Stirewalt, Gerry; Lyons, Sara; Basavaraju, C hakrapani; Graizer, Vladimir; Wyman, Stephen; 50.54f_Seismic Resource; RidsNroDsea Resource

Subject:

CALLAWAY PLANT - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM ESEP SUPPORTING IMPLEMENTATION OF N TTF R2.1, SEISMIC (TAC NO. MF5230)

Attachments:

Callaway R2.1 Seismic ESEP NRC review.docx October 1, 2015 MEMORANDUM TO: Mohamed K. Shams, Chief Hazards Management Branch (JHMB)

Japan Lessons-Learned Division Office of Nuclear Reactor Regulation FROM: Diane T. Jackson, Chief Geosciences and Geotechnical Engineering Branch 2 (RGS2)

Division of Site Safety and Environmental Analysis Office of New Reactors

SUBJECT:

CALLAWAY NUCLEAR STATION - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM EXPEDITED SEISMIC EVALUATION PROCESS SUPPORTING IMPLEMENTATION OF NTTF RE COMMENDATION 2.1, SEISMIC, RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. MF5230)

The NRC technical staff working through the Geosciences and Geotechnical Engineering Branches 1 and 2 (RGS1 and RGS2) completed the Technical Review Checklist of the CALLAWAY PLANT response to Enclosure 1, Item (6) of the March 12, 2012, request for information letter issued per Title 10 of the Code of Federal Regula tions, Subpart 50.54(f), to power reactor licensees and holders of construction permits requesting addressees to provi de further information to support the NRC staff's evaluation of regulatory actions to be taken in response to Fukushima Near-Term Task Force (NTTF)

Recommendation 2.1: Seismic which implements lessons learned from Japan's March 11, 2011, Great Thoku Earthquake and subsequent tsunami. The addre sses the staff review of the interim Expedited Seismic Evaluation Process (ESEP) report in response to Requested Item (6) of Enclosure 1, "Recommendation 2.1: Seismic," of the 50.54(f) letter. Attached is a file containing the technical review checklist to prepare a response letter to the licensee.

The NRC staff reviewed the information provided and, as documented in the enclosed staff checklist, determined that sufficient information was provided to be responsive to this portion of the Enclosure 1 of the 50.54(f) letter. The application of this staff review is limited to the interim ESEP as part of NTTF R2.1: Seismic activities.

This electronic memo constitutes the DSEA concu rrence provided that only editorial changes are made to the staff assessment that would not affect the technical conclusions or technical context of the assessment.

This concludes the NRC's efforts associated with TAC NO. MF5230 for the review of the interim ESEP report for t he CALLAWAY PLANT.

Docket No: 50-483 CONTACT: Stephanie Devlin-Gill Office of New Reactors 301-415-5301

2Copy: Nicholas DiFrancesco, Steve Wyman, Jane Spence, Stephanie Devlin-Gill, Kevin Roche, On Yee, Gerry Stirewalt, Sara Lyons, BP Jain, Basavaraju Chakrapani, Vl adimir Graizer, 50.54f Seismic Resource, RidsNroDsea Resource

Hearing Identifier: NRR_PMDA Email Number: 2438 Mail Envelope Properties (1dfe7f1851924ac18c5de196a745c81b)

Subject:

CALLAWAY PLANT - TECHNICAL REVIEW CHECKLIST RELATED TO INTERIM ESEP SUPPORTING IMPLEMENTATION OF NTTF R2.1, SEISMIC (TAC NO. MF5230) Sent Date: 10/1/2015 2:52:49 PM Received Date: 10/1/2015 2:52:51 PM From: Jackson, Diane Created By: Diane.Jackson@nrc.gov Recipients: "DiFrancesco, Nicholas" <Nicholas.DiFrancesco@nrc.gov> Tracking Status: None "Spence, Jane" <Jane.Spence@nrc.gov> Tracking Status: None "Devlin-Gill, Stephanie" <Stephanie.Devlin-Gill@nrc.gov> Tracking Status: None "Roche, Kevin" <Kevin.Roche@nrc.gov> Tracking Status: None "Yee, On" <On.Yee@nrc.gov> Tracking Status: None "Stirewalt, Gerry" <Gerry.Stirewalt@nrc.gov>

Tracking Status: None "Lyons, Sara" <Sara.Lyons@nrc.gov> Tracking Status: None "Basavaraju, Chakrapani" <Chakrapani.Basavaraju@nrc.gov> Tracking Status: None "Graizer, Vladimir" <Vladimir.Graizer@nrc.gov> Tracking Status: None "Wyman, Stephen" <Stephen.Wyman@nrc.gov>

Tracking Status: None "50.54f_Seismic Resource" <50.54f_Seismic.Resource@nrc.gov> Tracking Status: None "RidsNroDsea Resource" <RidsNroDsea.Resource@nrc.gov> Tracking Status: None "Shams, Mohamed" <Mohamed.Shams@nrc.gov>

Tracking Status: None Post Office: HQPWMSMRS07.nrc.gov

Files Size Date & Time MESSAGE 3014 10/1/2015 2:52:51 PM Callaway R2.1 Seismic ESEP NRC review.docx 53504 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

TECHNICAL REVIEW CHECKLIST BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EXPEDITED SEISMIC EVALUATION PROCESS INTERIM EVALUATION IMPLEMENTING NTTF RECOMMENDATION 2.1 SEISMIC CALLAWAY PLANT UNIT 1 DOCKET NO. 50-483 By letter dated March 12, 2012 (USNRC, 2012a), 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 (10 CFR), Section 50.54(f) "Conditions of License" (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 with the reevaluated seismic hazards. Requested Information Item (6) in Enclosure 1 to the 50.54(f) letter requests addressees to provide an interim evaluation and actions taken or planned to address a higher seismic hazard relative to the design basis, as appropriate, prior to completion and submission of the seismic risk evaluation. Additionally, by letter dated April 12, 2013 1, the Electric Power Research Institute (EPRI) staff submitted EPRI TR 3002000704 "Seismic Evaluat ion Guidance: Augmented Approach for the Resolution of Fukushima Near-Term Task Force (NTTF) Recommendation 2.1: Seismic" (hereafter referred to as the guidance). The Augmented Approach proposed that licensees would use an Expedited Seismic Evaluation Process (ESEP) to address the interim actions as requested by Information Item (6) in the 50.54(f) letter. The ESEP is a simplified seismic capacity evaluation with a focused scope of certain key installed Mitigating Strategies equipment that is used for core cooling and containment functions to cope with scenarios that involve a loss of all AC power and loss of access to the ultimate heat sink to withstand the Review Level Ground Motion, which is up to two times the safe shutdown earthquake (SSE).

Due to the expedited and interim nature of t he ESEP, the assessment does not include many considerations that are part of a normal risk evaluation. These deferred items, include but are not limited to, structures, piping, non-seismic failures, and operator actions, as well scenarios such as addressing loss of coolant accidents. By letter dated May 7, 2013 2, the NRC staff endorsed the guidance. Central and eastern United States licensees with a reevaluated seismic hazard exceeding the SSE submitted an ESEP interim evaluation in December 2014.

Consistent with the interim nature of this activity, the staff performed the review of the licensee's submittal to assess whether the intent of the guidance was implemented. A multi-disciplined team checked whether the identified methods were consistent with the guidance. A senior expert panel reviewed the team's questions, if any, and checklist for consistency and scope.

New or updated parameters (e.g., In-Structure Response Spectra, High Confidence of Low Probability of Failure calculations) presented by the licensees were assessed only based on licensee statements for acceptability for the Item (6) response. The application of this staff review is limited to the ESEP interim evaluati on as part of NTTF R2.1: Seismic activities.

1 ADAMS Accession No. ML13102A142 2 ADAMS Accession No. ML13106A331 NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 2 By letter dated December 22, 2014, 3 Ameren Missouri (the licensee) provided an Expedited Seismic Evaluation Process (ESEP) report in a response to Enclosure 1, Requested Information Item (6) of the 50.54(f) letter, for Union Electric Company Callaway Plant, Unit 1 (Callaway).

I. Review Level Ground Motion The licensee:

• described the determination of the review level ground motion (RLGM) using one of the means acceptable by the guidance

• identified location of the control point and is consistent with March 2014 Seismic Hazard and Screening Report submittal

• compared the site ground motion response spectra used to select the ESEP RLGM to the SSE Yes Yes Yes Callaway used 2 x SSE.

Notes from reviewer:

• The licensee used the maximum ratio of two times the SSE because the GMRS from the March 2014 Seismic Hazard and Screening report (SHSR) 4 was greater than two times the SSE for the site, except for three surface mounted items that used the GMRS. Deviation(s) or Deficiency(ies)s and Resolution:

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

• the licensee's RLGM meets the intent of the guidance

• the RLGM is reasonable for use in the interim evaluation Yes Yes II. Selection of the Success Path The licensee:

• described the success path

• described normal and desired state of the equipment for the success path

• ensured that the success path is consistent with the plant's overall mitigating strategies approach or provided a justification for an alternate path

• stated that the selection process was in accordance with the guidance or meets the intent of the guidance

• used installed FLEX Phase 1 equipment as part of the success path

• included FLEX Phase 2 and/or 3 connections

• considered installed FLEX Phase 2 and/or 3 equipment Yes Yes Yes Yes Yes Yes Yes Notes from reviewer: None Deviation(s) or Deficiency(ies)s and Resolution:

• No deviations or deficiencies were identified 3 ADAMS Accession No. ML14363A311 4 ADAMS Accession No. ML14090A448 NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 3 The NRC staff concludes that:

• the selected success path is reasonable for use in the interim evaluation

• the licensee considered installed Phase 2 and 3 connections or equipment in the interim evaluation Yes Yes III. Selection of the Equipment List The licensee:

• developed and provided the ESEL by applying the ESEP

• identified equipment considering the following functions:

o Core cooling (with focus on Mode 1) function o Available, sustainable water source o Containment function and integrity Yes Yes Yes Yes Notes from reviewer: 1. In the initial submittal, the licensee did not include many of the components that were needed in the ESEL per the ESEP guidance. However, in the RAI response, the components, including atmospheric relief valves, accumulators, accumulation isolation

valves, reactor head vent or pressurizer power operated relief valve, were added to the ESEL per a letter from the licensee dated September 9, 2015 (ML15259A322 and ML15259A323). The staff finds this acceptable for the purpose of this interim evaluation. 2. The licensee committed to installing a new hardened condensate storage tank (HCST), but did not include the HCST in the ESEL. The licensee did not address changes in the flow path resulting from the new HCST. This was a concern to the extent that the new flow path may include components that would fall within the scope of the ESEL. Therefore, the staff requested confirmation whether the HCST and associated SSCs will achieve a HCLPF capacity at the level of the RLGM.

In the response dated June 3, 2015 (ML15155A459), the licensee stated that the HCST will achieve a HCLPF capacity at the level of the RLGM and that the air operated valve in the new flow path will be seismically analyzed to meet ESEP requirements. The staff finds this acceptable for the purpose of this interim evaluation.

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

• No deviations or deficiencies were identified.

PWR Plants ONLY

The licensee included indicators / instrumentation for the following functions:

level, pressure, temperature, that would be indicative of (but not explicitly identified to specific instruments): water level of the steam generator (SG),

pressure of SG, containment, and RCS; and temperature of the RCS.

Yes BWR Plants ONLY

The licensee considered indicators for the following functions: level, pressure, temperature that would be indicative of, but not explicitly identified with, specific instruments: Temperature of suppression pool, RCS, containment; pressure of suppression pool, RCS, and drywell; water level of the suppression pool.

N/A NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 4 Notes from reviewer: 1. In the initial submittal, all necessary instrumentation did not appear to be included in ESEL. The staff asked the licensee to confirm that instrumentation for the following SSCs are included in, or will be added to, the ESEL: (a) SG water level, (b) SG pressure, (c) containment pressure, (d) RCS pressure, (e) RCS temperature. In a letter response dated September 9, 2015 (ML15259A322 and ML15259A323), the licensee added all

necessary instrumentation to the ESEL and in cluded a regulatory commitment to perform associated walkdowns, HCLPF updates, report required modifications, and report this information to the NRC. The staff finds that the responses adequately addressed the question and met the intent of the guidance for this interim evaluation.

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

• No deviations or deficiencies were identified. Through a sampling of the ESEP key components, the NRC staff concludes that:

• the licensee's process to develop the ESEL meets the intent of the guidance for the interim evaluation

• the desired equipment state for the success path were identified

• the licensee considered the support equipment for the ESEL

• both front-line and support systems appeared to be included in the ESEL as evidenced by inclusion of SSCs on the success path and of support systems (e.g., batteries, motor control centers, inverters)

Yes Yes Yes Yes IV. Walkdown Approach The licensee:

• described the walkdown screening approach, including walkbys and walkdowns performed exclusively for the ESEP, in accordance with the guidance

• credited previous walkdown results, including a description of current action(s) to verify the present equipment condition and/or configuration (e.g., walk-bys), in accordance with the guidance

• stated that the walkdown was performed by seismically trained personnel Yes Yes No Notes from reviewer:

1. The licensee did not initially indicate that seismic walkdown personnel were trained in seismic walkdown procedures. The staff requested confirmation that the walkdowns were conducted by personnel who had successfully completed training specific for seismic walkdown procedures. In an email response dated June 3, 2015 (ML15155A459), the licensee confirmed that walkdown personnel were properly trained in seismic walkdown procedures. The staff finds that the response adequately addressed the question and met the intent of the guidance for this interim evaluation.

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

• No deviations or deficiencies were identified.

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 5 The licensee:

• described adverse material condition of the equipment (e.g., material degradation)

• credited previous walkdown results, included a description of current action(s) to verify the present equipment condition (e.g., walk-bys), meeting the intent of the guidance No Yes The licensee:

• described the conditions of structural items considered for the interim evaluation, including:

o spatial interactions (i.e., interaction between block walls and other items/components) o anchorage o piping connected to tanks (i.e., differential movement between pipes and tanks at connections)

Yes Yes Yes Notes from reviewer:

1. The licensee did not describe adverse material condition of any equipment because no adverse material conditions were found during the walkdown, so this item is "no." The staff finds this acceptable for the purpose of this interim evaluation.

Deviation(s) or Deficiency(ies) and Resolution: No deviations or deficiencies were identified The licensee reported no deviations for Callaway

If deviations were identified, there is a discussion of how the deficiencies were or will be addressed in the ESEP submittal report.

N/A The NRC staff concludes that:

• the licensee described the performed walkdown approach, including any credited previous efforts (e.g., Individual Plant Examination of External Events (IPEEE) consistent with the guidance

• the licensee addressed identified deviations consistent with the guidance, if any Yes

Yes V. Capacity Screening Approach and HCLPF Calculation Results The licensee:

• described the capacity screening process for the ESEL items, consistent with the guidance (e.g., use of EPRI NP-6041 screening table).

• presented the results of the screened-out ESEL items in the ESEP report.

• described the development of in-structure response spectra (ISRS) based on scaling

• described the development of ISRS based on new analysis consistent with the guidance

• described the method for estimating HCLPF capacity of screened-in ESEL items, including both structural and functional failure modes consistent with the guidance:

o use of Conservative Deterministic Failure Margin (CDFM) o use of fragility analysis (FA)

Yes Yes Yes N/A Yes Yes (CDFM) N/A NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 6 o use of experience data or generic information

• credited IPEEE spectral shape for HCLPF capacity estimates is similar to or envelopes the RLGM, and anchored at the same control point

• presented the results of HCLPF capacities including associated failure modes for screened-in ESEL items

• reviewed the ESEL items with the lowest HCLPF values to ensure that their capacities are equal or greater than the RLGM N/A N/A Yes Yes Notes from reviewer: None Deviation(s) or Deficiency(ies) and Resolution:

• No deviations or deficiencies were identified The NRC staff concludes that:

• the licensee described the implementation of the capacity screening process consistent with the intent of the guidance

• the licensee presented capacity screening and calculation results, as appropriate, in the ESEP report

• the method used to develop the ISRS is consistent with guidance for use in the ESEP

• for HCLPF calculations, the licensee used HCLPF calculation methods as endorsed in the guidance

• no anomalies were noted in the reported HCLPF Yes Yes Yes Yes Yes VI. Inaccessible Items The licensee:

• provided a list of inaccessible items

• provided a schedule of the planned walkdown and evaluation for all inaccessible items

• provided Regulatory Commitment to complete walkdowns Yes Yes Yes Callaway will complete walkdowns and evaluations and provide results by no later than 60 days following completion of Refueling Outage 21, Spring 2016.

NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 7 Notes from reviewer: 1. In the original ESEP Section 7.1, the lic ensee stated that sufficient access was provided for all ESEL items and no additional walkdowns are planned. By letter dated September 9, 2015 (ML15259A322 and ML15259A323), the licensee provided a list of additional ESEL items, a schedule to walkdown the items and perform HCLPF table updates, report any required modifications with proposed completion dates, and to provide a letter with this supplemental information to the NRC no later than 60 days following completion of Refueling Outage 21, Spring 2016.

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

• No deviations or deficiencies were identified The NRC staff concludes that the licensee:

• listed inaccessible items

• committed to provide the results (e.g., walkdowns, walkbys, etc.) of the remaining inaccessible items consistent with the guidance

• substitutions, if needed, were appropriately justified N/A N/A N/A VII. Modifications to Plant Equipment The licensee:

• identified modifications for ESEL items necessary to achieve HCLPF values that bound the RLGM (excluding mitigative strategies equipment (FLEX)), as specified in the guidance

• provided a schedule to implement such modifications (if any), consistent with the intent of the guidance

• provided Regulatory Commitment to complete modifications

• provided Regulatory Commitment to report completion of modifications Yes Yes Yes Yes Callaway will

• Complete modifications by: December 31, 2016 for modifications not requiring a planned refueling outage, and within two planned refueling outages after December 31, 2016 for modifications requiring a refueling outage.

• Report completion of all ESEP modifications by: Not later than 60 days following completion of any required modifications, and not later than 60 days following completion of Refueling Outage 22, Fall 2017.

Notes from reviewer:

None Deviation(s) or Deficiency(ies) and Resolution:

• No deviations or deficiencies were identified The NRC staff concludes that the licensee:

• identified plant modifications necessary to achieve the target seismic capacity

• provided a schedule to implement the modifications (if any) consistent with the guidance Yes Yes NTTF Recommendation 2.1 Expedited Seismic Evaluation Process Technical Review Checklist for the Callaway Plant, Unit 1 8 VIII. Conclusions

The NRC staff assessed the licensee's implementation of the ESEP guidance. Due to the interim applicability of the ESEP evaluations, use of the information for another application would require a separate NRC review and approval. Based on its review, the NRC staff concludes that the licensee's implementation of the interim evaluation meets the intent of the guidance. The staff concludes that, through the implementation of the ESEP guidance, the licensee identified and evaluated the seismic capacity of certain key installed Mitigating Strategies equipment that is used for core cooling and containment functions to cope with scenarios that involve a loss of all AC power and loss of access to the ultimate heat sink to withstand a seismic event up to the Review Level Ground Motion (RLGM) and thus, provides additional assurance while the plant seismic risk evaluation is being conducted. In the case of Callaway, the RLGM was set at the maximum ratio of two times the SSE in accordance with the guidance because the GMRS is above two times the SSE, except for three surface mounted items that used the GMRS. The application of this staff review is limited to the ESEP interim evaluation as part of NTTF R2.1: Seismic activities. As noted in the review checklist, the staff did not identify deviations or exceptions were taken from the guidance. The licensee will complete currently identified modifications by December 31, 2016, for modifications not requiring a planned refueling outage. The licensee committed to provide a letter with supplemental information regarding the evaluation results of the additional ESEL items to the NRC no later than 60 days following completion of Refueling Outage 21, Spring 2016.

Modifications requiring a refueling outage will be completed within two planned refueling outages after December 31 2016. The licensee committed to report completion of all ESEP modifications not later than 60 days following completion of the modifications, and not later than 60 days following completion of Refueling Outage 22, Fall 2017.

In summary, the licensee, by implementing the ESEP interim evaluation, has demonstrated additional assurance which supports continued plant safety while the longer-term seismic

evaluation is completed to support regulatory decision making. The NRC staff concludes that the licensee responded appropriately to Enclosure 1, Item (6) of the 50.54(f) letter, dated March 12, 2012, for Callaway Plant, Unit 1.

Principal Contributors: Vladimir Graizer, Kevin Roche, Sara Lyons, Jinsuo Nie, B.P. Jain, Basavaraju Chakrapani, Kaihwa Hsu, Gerry Stirewalt, Carl Costantino (NRC Consultant)