ML14076A023

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Response to NRC RAI Regarding the Fermi 2 Flood Hazard Reevaluation Report
ML14076A023
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 03/13/2014
From: Conner J
DTE Energy Services
To:
Document Control Desk
References
NRC-14-0016, TAC MF1101
Download: ML14076A023 (8)


Text

J. Todd Conner Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: connerj@dteenergy.com DTE Energy-10 CFR 50.54(f)

March 13, 2014 NRC-14-0016 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
2) NRC Letter, "Request For Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012
3) DTE Electric Company Letter to NRC, "DTE Electric Submittal of Flooding Hazard Reevaluation Report in Response to March 12, 2012 Information Request Regarding Flood Protection Evaluations,"

NRC-13-0013, dated March 8, 2013

Subject:

Response to NRC Request for Additional Information Regarding the Fermi 2 Flood Hazard Reevaluation Report (TAC No. MF1101)

On March 12, 2012, the NRC issued Reference 2 to all power reactor licensees and holders of construction permits in active or deferred status. Reference 2 requested specific Actions, Information and Responses associated with Recommendation 2.1 regarding flooding evaluations.

In Reference 3, DTE Electric Company (DTE) submitted the Fermi 2 Flood Hazard Reevaluation Report as requested in Reference 2.

In an email dated February 28, 2014 from Mr. Thomas Wengert of the NRC to Mr.

Alan Hassoun of DTE (ADAMS Accession No. ML14063A000), the NRC provided a Request for Additional Information (RAI) regarding the Fermi 2 Flood Hazard Reevaluation Report.

USNRC NRC-14-0016 Page 2 The Enclosure to this letter provides DTE's response to the Request for Additional Information. Also enclosed is a compact disc containing the files requested by RAI-1.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Mr.

Kirk R. Snyder, Manager, Industry Interface at (734) 586-5020.

Sincerely, Enclosures cc: NRC Project Manager (w/ cd)

NRC Resident Office (w/o cd)

Reactor Projects Chief, Branch 5, Region III (w/o cd)

Regional Administrator, Region III (w/o cd)

Michigan Public Service Commission, Regulated Energy Division (kindschlmichigan. ov) (w/o cd)

USNRC NRC-14-0016 Page 3 I, J. Todd Conner, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

On this 13th day of March, 2014 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. MARSHALL NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun 14, 2019 ACTING IN COUNTY OF 4

Enclosure to NRC-14-0016 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Response to NRC Request for Additional Information Regarding the Fermi 2 Flood Hazard Reevaluation Report

Enclosure to NRC-14-0016 Page 1 NRC Request for Additional Information Regarding the Fermi 2 Flood Hazard Reevaluation Report RAI No. 1 (Local Intense Precipitation)

Please provide electronic versions of input files used for the HEC-RAS analysis in the flood hazard reevaluation report (FHRR).

Response to RAI No. 1:

The input files used for the HEC-RAS analysis described in the Fermi 2 FHRR are provided on the enclosed compact disc.

Enclosure to NRC-14-0016 Page 2 RAI No. 2 (Local Intense Precipitation)

The Nuclear Regulatory Commission staff has observed use of various datums in the FHRR; these include New York Mean Tide 1935, IGLD85, NAVD88, and NGVD1929. In order to compare elevations and flood levels, and to assess the associated errors of conversion, the staff requests the following:

a) Descriptions of the source of the surface elevations including vertical resolution, methods to incorporate elevation measurements (if any), and the level of the uncertainty of the various elevations in the onsite area in order to determine uncertainties associated with the onsite LIP flood level.

b) Consistent description and conversion between the datums used in the FHRR for elevations and water levels (including both LIP and other sections of the FHRR).

Response to RAI No. 2:

a) Surface elevations used in the on-site local intense precipitation (LIP) analysis were taken from elevations shown on a plant plot plan. The elevations on the plot plan are in plant datum (New York Mean Tide 1935). The contours used in the analysis, shown in Figures 4 and 5 of the FHRR, were developed by interpolation between the surface elevations on the plant plot plan. The relative accuracy of the elevations on the plant plot plan used in the analysis is +/- 0.1 ft.

b) The elevations and water levels described in the FHRR are all in New York Mean Tide 1935.

Using a common datum in the FHRR was done for consistency. The FHRR, in itself, does not quote different datums. However, different datums may be used in some of the source documents used for the FHRR, specifically referring to the Fermi 3 FSAR. This is discussed below. The elevation and water level information in the FHRR is taken from the following sources:

Fermi 2 Updated Final Safety Analysis Report (UFSAR) (Reference 2 in the FHRR):

The elevation and water level information in the Fermi 2 UFSAR is provided in New York Mean Tide 1935.

Supporting calculations for the Local Intense Precipitation (LIP - Reference 19 in the FHRR) and Wave Run-Up (Reference 20 in the FHRR): The elevation and water level information in these two supporting calculations are in what is referred to as "Plant Datum," which is a common term for New York Mean Tide 1935 at Fermi 2.

Fermi 3 Final Safety Analysis Report (FSAR) (Reference 3 in the FHRR): Several different datums are provided in the Fermi 3 FSAR, although, as described in Section 2.1 of the Fermi 3 FSAR, NAVD88 is the reference datum for the Fermi 3 site.

Enclosure to NRC-14-0016 Page 3 Other datums in the Fermi 3 FSAR include IGLD85 and NGVD1929. Conversion factors for these datums are shown at the bottom of the first page in Section 2.1 of the Fermi 3 FSAR. IGLD85 and NGVD1929 are not used to support the Fermi 2 FHRR.

The elevation and water level information from the Fermi 3 FSAR was converted to "Plant Datum" using the conversion shown on the bottom of the first page in Section 2.1 of the Fermi 3 FSAR. The conversion is as follows:

NAVD88 + 1.22 ft = Plant Datum The difference of 1.22 ft is rounded to 1.2 ft as all the elevations and water levels are presented to one decimal point. Following are examples of use of this conversion:

Section 3.2 in the FHRR discusses flooding in streams and rivers. The results described in Section 3.2 of the FHRR are taken from the Fermi 3 FSAR, Section 2.4.3.3. Section 3.2 of the FHRR describes three alternative event combinations that are considered as part of the flooding analysis in the Fermi 3 FSAR - Alternatives I, II, and III. The following table compares the results as presented in the FHRR vs. the results from the Fermi 3 FSAR to demonstrate that the difference is the 1.2 ft conversion from NAVD88 to Plant Datum.

FHRR, Section 3.2, Fermi 3 FSAR Difference Alternative Result (ft. Plant Section 2.4.3.3 Result (ft)

Datum)

(ft. NAVD88) 1 580.6 579.4 1.2 II 579.5 578.3 1.2 III 586.6 585.4 1.2 Section 3.4 in the FHRR discusses flooding due to storm surge, including wind-wave activity. The results described in Section 3.4 of the FHRR are taken from the Fermi 3 FSAR, Section 2.4.5.2.2.2. Section 3.4 in the FHRR presents a water level result of 586.6 ft Plant Datum as compared to a result of 585.4 ft NAVD88 in the Fermi 3 FSAR Section 2.4.5.2.2.2, for a difference of 1.2 ft. It is also noted that the Fermi 3 FSAR Section 2.4.5.2.2.2 provides the result of 586.6 ft in Plant Datum.

Therefore, the FHRR is consistent in that all of the elevations and water level information are provided in one datum; i.e., New York Mean Tide 1935 which is also referred to as Plant Datum.

Enclosure to NRC-14-0016 Page 4 RAI No. 3 (Storm Surge)

Provide the reference and/or source of the following equation (see FHRR Section 3.4, page 25 of

44) used to calculate the stability of a submerged breakwater:

(h'c / h) = (2.1 + 0.1 S) exp (-0.14 N*s)

Response to RAI No. 3:

The above equation to calculate the stability of a submerged breakwater is from the U.S. Army Corps of Engineers, "Coastal Engineering Manual," Engineer Manual 1110-2-1100, Table VI 25 (Reference 16 in the FHRR). This reference is available online from the following URL:

http://chl.erdc.usace.army.mil/Media/2/0/7/CEMPart-VI Chap-5-pt 1.pdf.