ML110750478

E-mail Summary of Clarification Phone Call Regarding the Beaver Valley 2 Spent Fuel Pool Rerack Amendment (ME1079)

ML110750478
Person / Time
Site:	Beaver Valley
Issue date:	03/10/2011
From:	Nadiyah Morgan Plant Licensing Branch 1
To:	Firestone J, Lashley P FirstEnergy Nuclear Operating Co
Morgan Nadiyah, NRR/Dorl, 415-1016
References
TAC ME1079
Download: ML110750478 (2)

Text

From: Morgan, Nadiyah Sent: Thursday, March 10, 2011 6:15 PM To: 'phlashley@firstenergycorp.com'; 'jfirestone@firstenergycorp.com'; 'talentz@firstenergycorp.com' Cc: Guzman, Richard; Salgado, Nancy

Subject:

Summary of Clarification Call Re: Beaver Valley 2 Spent Fuel Pool Rerack AMD (ME1079)

All, The purpose of this e-mail is to provide a summary of the NRC staff's understanding of the issues discussed during the March 9, 2011 clarification conference call with FENOC (the licensee) to ensure that there is alignment regarding the information that is needed from the licensee in order for the Mechanical and Civil Engineering Branch (EMCB) staff to complete its review. The EMCB staff conveyed its expectations during the call regarding the clarification information that the licensee should include in a docketed submittal. This information will be used by the EMCB staff in finalizing the safety evaluation report (SER) input for the BVPS-2 spent fuel pool (SFP) re-rack license amendment request (LAR).

1. Spent Fuel Pool Liner Plate Code of Record

• The licensee indicated during the March 9, 2011 conference call that the 1998 Edition of the ASME B&PV Code,Section III, Subsection NF, would become the new design code of record for the SFP liner following the issuance of this license amendment. The licensee should (1) provide justification that the provisions of Subsection NF is applicable to the SFP liner design; (2) provide a summary of results (e.g., interaction ratios for the limiting liner components such that a quantitative demonstration of compliance with the new code of record is apparent) demonstrating that all aspect of the structural design of the SFP liner system (e.g., welds and anchor adequacy) are in compliance with the provisions of new design code of record; and (3) discuss the applicable design loading conditions, in accordance with the BVPS-2 design basis requirements, have been considered and appropriate service level stress allowable limits have been satisfied. In addition, the licensee has previously indicated that the liner plate satisfies the criteria of Standard Review Plan (SRP) Section 9.1.2, "New and Spent Fuel Storage." The justification regarding the use of the new design code of record should also focus on demonstrating that the use of the new code of record continues to satisfy the criteria of SRP Section 9.1.2, which, among other criteria, stipulates that the SFP liner plate should be designed to withstand a safe shutdown earthquake (SSE).

• The supplemental response provided on January 5, 2011 (ADAMS Accession No. ML110110217) indicated that the design basis calculation for loading conditions including a maximum temperature differential bounded the conditions expected due to the proposed re-rack. Given that the licensee is proposing to update the design code of record for the SFP liner as part of this license amendment, the licensee should also confirm that the analysis remains bounding based on the provisions of the new code of record in conjunction with the discussion establishing the bases for using the new code of record.

• The licensee stated that a fatigue assessment of the liner is performed following the methodology of ASME Code Section III, Subsection NB, 1998 edition. The licensee should provide additional information describing the fatigue assessment of the SFP liner, including acceptance criteria.

• The licensee should explicitly state that the information regarding the use of a new design code of record was not provided in any previous correspondence and, as such, constitutes new information with respect to the ongoing NRC staff review of this LAR.

2. Post-Earthquake Inspection/Rack Fatigue Analysis The licensee should clearly state which components will be exempt from post-earthquake inspection (i.e., pedestal/baseplate welded region below baseplate). As discussed during the March 9, 2011, conference call, these components would only be those components for which post-earthquake event inspection has been determined infeasible. The licensee should provide explicit details regarding the rationale for determining why inspection of the highest stressed regions of the rack is not feasible. The licensee should also be explicit regarding its intentions to inspect the accessible regions of the rack for structural damage following a seismic event, in accordance with the industry standards cited in previous correspondence (i.e., Regulatory Guide 1.167 and EPRI NP-6695). The licensee should also provide additional clarification on the fatigue analyses performed for the high stressed components.

3. Cask Pit Rack Drop Accident In preparing for the proposed re-racking of the BVPS-2 SFP, the licensee stated during the March 9, 2011, conference call that all work performed in the BVPS-2 cask pit has already been completed. The licensee confirmed during this conference call that this work was completed in accordance with 10 CFR 50.59 and, as such, any postulated accidents within the cask pit are not relevant to the BVPS-2 SFP re-rack LAR currently under review by the NRC staff. Therefore, this work does not need NRC approval prior to being performed. The licensee should confirm the irrelevance of the cask pit drop accidents, as they relate to the current re-rack LAR, and note that the description of postulated accidents within the cask pit were provided for information only in the updated licensing report which was docketed on February 18, 2011.

Please contact me if you have any questions or concerns.

Thanks, Dee Nadiyah S. Morgan Beaver Valley Project Manager US Nuclear Regulatory Commission Office phone: 301-415-1016