ML14120A441
| ML14120A441 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/25/2014 |
| From: | Mozafari B Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Blake Purnell, NRR/DORL 415-1380 | |
| References | |
| TAC MF1108, TAC MF1109 | |
| Download: ML14120A441 (13) | |
Text
Mr. Michael J. Pacilio Senior Vice President UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 25, 2014 Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2-REQUEST FOR ADDITIONAL INFORMATION REGARDING FUKUSHIMA LESSONS LEARNED FLOOD HAZARD REEVALUATION REPORT (TAC NOS. MF1108 AND MF1109)
Dear Mr. Pacilio:
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 letter requesting information pursuant to Title 10 of the Code of Federal Regulations, Paragraph 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued as a part of implementing lessons-learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 2, "Recommendation 2.1: Flooding," of the 50.54(f) letter requested, in part, licensees to perform a flood hazard reevaluation using present-day methodologies and guidance.
By letter dated March 12, 2013 (ADAMS Accession No. ML130810038), Exelon Generation Company, LLC submitted a flood hazard reevaluation report for Quad Cities Nuclear Power Station, Units 1 and 2, in response to the request in Enclosure 2 of the 50.54(f) letter. The NRC staff is ;*eviewing the submittal and has determined that additional information is needed to complete its review.
A response to the enclosed request for additional information is requested by July 3, 2014. This request was discussed with Mr. David Distel of your staff on May 14, 2014.
Should you have any questions, please contact me at 301-415-2020.
Docket Nos. 50-254 and 50-265
Enclosure:
Request for Additional Information cc w/encl: Listserv Sincerely, Brenda Mozafari, Senior Project Manager Plant Licensing 111-2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
REQUEST FOR ADDITIONAL INFORMATION FUKUSHIMA LESSONS-LEARNED FLOOD HAZARD REEVALUATION REPORT QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 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 letter requesting information pursuant to Title 10 of the Code of Federal Regulations, Paragraph 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued as a part of implementing lessons-learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 2, "Recommendation 2.1: Flooding," of the 50.54(f) letter requested, in part, licensees to perform a flood hazard reevaluation using present-day methodologies and guidance.
By letter dated March 12, 2013 (ADAMS Accession No. ML130810038), Exelon Generation Company, LLC (the licensee) submitted a flood hazard reevaluation report (FHRR) and a local intense precipitation (LIP) evaluation report for Quad Cities Nuclear Power Station (QCNPS),
Units 1 and 2, in response to the request in Enclosure 2 of the 50.54(f) letter. The NRC staff is reviewing the submittal and has determined that additional information is needed to complete its review.
The NRC staff has used information provided in the licensee's online reference portal (ADAMS Accession No. ML13206A427) to help develop this request for additional information (RAI).
Where the staff has identified information in a reference portal document, which will address at least part of the specific information needed, the document is cited in the RAI.
RAI 1: Hazard Input for the Integrated Assessment-Flood Event Duration Parameters
Background:
Enclosure 2 of the 50.54(f) letter requests the licensee to perform an integrated assessment of the plant's response to the reevaluated hazard if the flood hazard is not bounded by the current design basis. Flood scenario parameters from the flood hazard reevaluation serve as the input to the integrated assessment. To support efficient and effective evaluations under the integrated assessment, NRC staff will review flood scenario parameters as part of the flood hazard reevaluation and document results of the review as part of the NRC staff assessment of the flood hazard reevaluation.
Request: Provide the applicable flood event duration parameters (see definition and Figure 6 of the NRC interim staff guidance document JLD-ISG-2012-05, "Guidance for Performing an Integrated Assessment," November 2012 (ADAMS Accession No. ML12311A214)), associated with mechanisms that trigger an integrated assessment using the results of the flood hazard reevaluation. This includes (as applicable) the warning time the site will have to prepare for the Enclosure event (e.g., the time between notification of an impending flood event and arrival of floodwaters on site) and the period of time the site is inundated for the mechanisms that are not bounded by the current design basis. The licensee is also requested to provide the basis or source of information for the flood event duration, which may include a description of relevant forecasting methods (e.g., products from local, regional, or national weather forecasting centers) and/or timing information derived from the hazard analysis.
RAJ 2: Hazard Input for the Integrated Assessment-Flood Height and Associated Effects
Background:
Enclosure 2 of the 50.54(f) letter requests the licensee to perform an integrated assessment of the plant's response to the reevaluated hazard if the flood hazard is not bounded by the current design basis. Flood scenario parameters from the flood hazard reevaluation serve as the input to the integrated assessment. To support efficient and effective evaluations under the integrated assessment, NRC staff will review flood scenario parameters as part of the flood hazard reevaluation and document results of the review as part of the staff assessment of the flood hazard reevaluation.
Request: Provide the flood height and associated effects (as defined in Section 9 of JLD-ISG-2012-05) that are not described in the flood hazard reevaluation report for mechanisms that trigger an integrated assessment. This includes the following quantified information for each mechanism (as applicable):
Hydrodynamic loading, including debris; Effects caused by sediment deposition and erosion (e.g., flow velocities, scour);
Concurrent site conditions, including adverse weather; and Groundwater ingress.
RAJ 3: Site Information
Background:
The March 12, 2013, letter (Section c), and FHRR Sections 2.a and 4 state that the current design-basis flood elevation is 603 feet (ft) mean sea level (MSL, 1912 datum) and that this corresponds to the probable maximum flood (PMF) elevation (FHRR Section 4, Table 1 ). However, Section 4.a of the flooding walkdown report for QCNPS (ADAMS Accession No. ML12332A307), states that the original design-basis flood elevation is 589 ft MSL, which was based on the 200-year flood that was considered to be the PMF at the time of the plant design. The flooding walkdown report further states that floods in excess of the 200-year event are plausible and notes that the Updated Final Safety Analysis Report provides a stage discharge curve indicating that PMF is estimated to reach an elevation of 601 ft MSL. The walkdown report (Section 4.a) discusses the 603ft MSL elevation in the context of an elevation to which the plant can mitigate flood effects, but does not identify 603ft MSL as the design-basis flood elevation. The comparison between the design basis and the reevaluated hazard is key for determining which hazards, if any, should be evaluated in the integrated assessment report.
Request: Provide clarification regarding the apparent discrepancy between the FHRR and the flooding walkdown report with respect to the design-basis PMF elevation.
RAI 4: Local Intense Precipitation (LIP)- Supporting Analysis and Electronic Files
Background:
The information provided in the LIP evaluation report does not adequately describe modeling assumptions and key features of the modeling implementation such as the representation of topography and land cover, model input parameters, and model output accuracy. The NRC staff review of information in the licensee's online reference portal found that some of this information is described in Calculation Package LIP-QDC-001, Revision 3, "Quad Cities Local Intense Precipitation Evaluation."
Request: Provide the following information:
- 1) The body of the supporting analysis (LIP-QDC-001, Revision 3, pages 1-19).
- 2) Appendix A (Figures) of the supporting analysis (LIP-QDC-001, Revision 3, pages 20-65).
- 3) Electronic versions of input and output files for the LIP analysis, including:
- a. Digital Elevation Model or other x-y-z data files used to produce the ground surface elevation map (Figure A-01 in Calculation Package LIP-QDC-001, Revision 3)
- b. An electronic version of the ground surface elevation map (Figure A-01 in Calculation Package LIP-QDC-001, Revision 3)
- c. An electronic version of the map showing land cover and Manning's n roughness coefficients (Figure A-02 in LIP-QDC-001, Revision 3)
- d. Electronic versions of all FL0-20 flood routing model input files (including model execution and numerical solution control files) used for surface flow modeling of the LIP PMP event described in LIP-QDC-001, Revision 3, and all FL0-20 output files listed in Appendix D of Calculation Package LIP-QDC-001, Revision 3 RAI 5: LIP-Storm Analysis Basis for Design Storm
Background:
The LIP analysis relied on the storm analyses performed by National Weather Service in developing hydrometeorology reports (HMRs) 51 and 52. However, the licensee conducted a site-specific PMP study to support the PMF analysis in the FHRR. The site-specific PMP study included storms not considered in HMRs 51 and 52.
Request: Justify using one set of storms as a basis for the LIP estimates and a different set of storms as the basis for the PMF analysis.
RAI 6: LIP - Design Storm Duration and Temporal Distribution
Background:
Although the basic approach for developing the design storm is outlined in HMR 52, several key details are left to the discretion of the analyst. Among these are the duration of the design storm (e.g., in relation to watershed characteristics, such as, the time of concentration) and the temporal distribution of the rainfall within the selected duration.
Request: Describe the rational, including any sensitivity analysis, that indicates whether the 1-hour PMP scenario used in the LIP analyses (Figure 3-2) bounds the effects of LIP in comparison with alternative duration PMP scenarios (e.g., 6, 12, 48, or 72-hour PMP scenarios).
The licensee is requested to evaluate the bounding LIP scenarios in terms of the severity of flood level as well as inundation duration. The licensee is also requested to describe the rationale for evaluating LIP using a temporal rainfall distribution in which the peak rainfall intensity occurs at the beginning of the PMP event and declines thereafter (e.g., in comparison with another temporal distribution, such as a centered distribution).
RAI 7: LIP-Precipitation onto Buildings
Background:
The LIP evaluation report does not describe how precipitation onto building roofs was modeled. The NRC staff review of information in the licensee's online reference portal found that some of this information is described in LIP-QDC-001, Revision 3.
Request: Provide a detailed description of how rainfall onto buildings is modeled in the LIP analysis, including a description of how water draining from roofs is routed and how this is implemented in the FL0-20 model. Provide justification for any assumptions regarding water storage by buildings.
RAI 8: LIP-Modeling Approach for Spray Canal
Background:
The LIP evaluation report indicates that the spray canal is included within the FL0-20 modeling domain. However, no discussion of the modeling approach used for the spray canal is provided. A Manning's n roughness coefficient for the canal water surface is provided instead of a Manning's n roughness coefficient based on the canal sides and bottom, which implies that the canal is not treated a flow element.
Request: Provide clarification regarding the modeling approach used for the spray canal.
RAI 9: LIP-Modeling of Concrete Security Barriers
Background:
The LIP evaluation report does not describe how flow over (or around) concrete security barriers is modeled. The NRC staff review of information in the licensee's online reference portal found that some of this information is described in LIP-QDC-001, Revision 3.
The staff is aware that FL0-20 treats flow over structures, such as levees, as flow over a broad-crested weir with a fixed weir coefficient of 2.85. A weir coefficient of 2.85 is within the range found in several hydrology text books. However, weir coefficients provided in standard hydrology and hydraulics texts are for flow measurement weirs. The concrete security barriers are not flow measurement devices. In addition, the weir coefficient is a function of the breadth and the head upstream of the weir.
Request: Provide justification for modeling the flow over concrete security barriers using the FL0-20 levee function (i.e., as flow over a broad-crested weir with a fixed weir coefficient of 2.85), including a discussion of any physical characteristics which prompt such a selection and any sensitivity analysis that was performed.
RAI10: Consistent Vertical Datums
Background:
The submittals do not use a consistent vertical datum. The LIP evaluation report provides elevations with respect to the North American Vertical Datum of 1988 (NAVD88).
Analyses for other flooding phenomena in the FHRR report elevations with respect to the legacy General Adjustment of 1912 (MSL 1912) datum. Furthermore, the submittals do not provide a conversion between the two datums. The NRC staff review of information in the licensee's online reference portal found that datum conversions are provided in Calculation Package QDC-0085-S-1991, "Calculation of Probable Maximum Flood (PMF) Water Surface Elevation:
Evaluation of Riverine Hydraulics for the Upper Mississippi River at QCNGS [Quad Cities Nuclear Generating Station]."
Request: Provide a consistent set of vertical datum for the submittals or provide a conversion between the various datums used. In particular, describe what relationships were used to convert between modern datums such as NAVD88 and legacy datums such as MSL 1912.
RAI 11: Probable Maximum Precipitation Analysis
Background:
The discussion of the PMP analysis in FHRR Section 3.1 does not adequately describe the overall logic, key assumptions, methods, inputs, and results. The NRC staff review
- of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-1989, "Probable Maximum Precipitation (PMP) for the Upper Mississippi River Watershed Contributory to QCNGS."
Request: Provide the following portions of QDC-0085-S-1989:
Main text (pages 1-36)
- , Figures
- , Seetion 10 (Storm Dimensions)
- , Section 13 (Recommendations for Applications)
- , Appendix E (Storm Precipitation Analysis System System Description)
Also provide electronic editable files for the following portions of QDC-0085-S-1989:
Depth-Area Duration Tables (Attachment 7)
Percentage of 6-hour PMP Increment Tables (Attachment 8)
Average 6-hour Incremental PMP Spreadsheets (Attachment 9)
All Season and Cool Season Hyetographs (Attachment 1 0) 1 00-year Snowpack Calculation Spreadsheet (Attachment 11)
Meteorological Time Series Data for Snowmelt (Attachment 13)
Snowmelt Spreadsheet (Attachment 14)
RAI 12: Site-Specific PMP Estimates
Background:
FHRR Section 3.1 states that a site-specific PMP analysis was performed to calculate PMP values specific to the 88,000 square-mile (mi 2
) contributory watershed of the Mississippi River upstream of the QCNPS site because HMR 51 does not provide PMP estimates for areas in excess of 20,000 mr The FHRR further states that the site-specific PMP analysis used techniques and databases that differ from those used in HMR 51. However, the FHRR does not provide adequate detail to evaluate the differences in techniques and data used. The NRC staff review of information in the licensee's online reference portal found that some of this information is documented in QDC-0085-S-1989.
Request: Provide the following information:
A detailed description of the techniques and databases used, including storm selection.
Describe any difference between techniques and databases used in the current analysis and those used in HMR 51.
A detailed comparison between PMP results in HMR 51 and the FHRR analysis for those areas and duration common to both analyses. Include an explanation for differences that may exist.
A detailed description of the alternate dewpoint climatology used, including data sources, methods, and resulting maps or databases. An existing report that includes this information would suffice.
Electronic versions of the storm analysis spreadsheets developed for the site-specific PMP study (QDC-0085-S-1989, Attachment 2, Appendix F).
Electronic versions of the spreadsheets used to perform the depth-area and depth-duration envelopments.
Electronic versions of the final all-season and cool-season PMP maps (QDC-0085-S-1989,. Attachment 2, Appendices A and B).
RAI No. 13: Probable Maximum Flood Analysis
Background:
The discussion of the PMF analysis in FHRR Section 3.1 does not adequately describe the overall logic, key assumptions, methods, inputs, and results. The NRC staff review of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-1990, "Probable Maximum Flood (PMF) for the Upper Mississippi River Watershed Contributory to QCNGS."
Request: Provide the following portions of QDC-0085-S-1990:
Main text (Pages 1-73)
- , Figures
- , Nonlinearity Adjustment
- , Muskingum-K Estimates Also provide electronic editable files for the following:
Natural Resources Conservation Service Soil Data (QDC-0085-S-1990, )
U.S. Geological Survey Monthly Flow Data (QDC-0085-S-1990, Attachment 5)
Input and Output files for the HEC-HMS hydrologic model calibration and verification runs Input and Output files for the HEC-HMS hydrologic all-season PMF and cool-season PMF simulations RAI14: Flooding on Streams and Rivers-Cool-Season Baseflow
Background:
FHRR Section 3.1 states that streamflow data for March was used to estimate the cool-season mean monthly baseflow. Stream data for April was not used. The stated rational for omitting the April data was to avoid double-accounting for April snow melt.
Request: Provide justification for the inclusion of baseflow values for March instead of April, with consideration of the likelihood that streamflows for both months result from a combination of snowmelt and rainfall.
RAI 15: Probable Maximum Flood Water Surface Calculations
Background:
The discussion of the PMF water surface calculation in FHRR Section 3.1 does not adequately describe the overall logic, key assumptions, methods, inputs, and results. The NRC staff review of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-1991, "Calculation of Probable Maximum Flood (PMF) Water Surface Elevation: Evaluation of Riverine Hydraulics for the Upper Mississippi River at QCNGS."
Request: Provide the following portions of QDC-0085-S-1991:
Main text (Pages 1-32)
- , Figures
- , Data Conversions
- , Bridge Plans Also provide electronic editable files for the following:
Bridge Spreadsheets (QDC-0085-S-1991, Attachment 6)
Stream Flow Data (QDC-0085-S-1991, Attachment 7)
U.S. Army Corps of Engineers (USACE) Observed Historical Profiles (QDC-0085-S-1991, Attachment 8)
HEC-RAS hydraulic model input and output files for the calibration floods (QDC-0085-S-1991, Attachment 9)
HEC-RAS hydraulic model input and output files used for water level simulation resulting from the PMF event reported in FHRR Section 3.1, including those in QDC-0085-S-1991, Attachments 10-14 RAI 16: Flooding on Streams and Rivers-Manning's n Roughness Coefficient
Background:
The description of the PMF analysis in FHRR Section 3.1 states that the Manning's n roughness coefficient was the main parameter adjusted during HEC-RAS hydraulic model calibrations. However, the FHRR does not adequately describe how this adjustment was performed or discuss the adequacy of the final coefficient values.
Request: Provide additional details on the initial and final values of Manning's n roughness coefficient, and describe how those values compare with recommended values in the standard references for site conditions existing in the watershed. For example, provide a table similar to Table 1 in the LIP evaluation report, which includes the type of surface coverage and the extent of coverage.
RAI 17: Dam Failure-Supporting Analysis and Electronic Files
Background:
The discussion of the upstream dam failure flood analysis in FHRR Section 3.2 does not adequately describe the key assumptions, methods, and results. The NRC staff review of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-2032, "Upstream Dam Failure Flood Evaluations at QCNGS."
Request: Provide the following portions of QDC-0085-S-2032:
Main text (Pages 1-49)
- , Figures
- , Dams Information
- , Datum Conversions
- , Reservoir Storage Information
- , Muskingum-Cunge Parameters Also provide electronic editable files for the following:
QDC-0085-S-2032, Attachment 2, Major Dams in Watershed QDC-0085-S-2032, Attachment 1 OA, National Inventory of Dams Subwatershed Dams HEC-RAS hydrologic model and HEC-RAS hydraulic model input and output files used for surface flow modeling of the individual and cascading dam failure events discussed in FHRR Section 3.2 HEC-RAS hydrologic model input and output files used for the screening analysis for failure of all dams in the upstream watershed (i.e., Approach 2) discussed in FHRR Section 3.2 RAI 18: Dam Failure-Large Dam Criteria
Background:
Many dam safety agencies consider dams over 50ft in height as "large dams."
However, the dam failure flood analysis reported in FHRR Section 3.2 limited consideration to dams over 60ft in height (labeled "significant" dams). The limitation to dams over 60ft in height may potentially exclude some dams that could have a significant impact on estimated flood levels due to dam failure.
Request: Provide justification for limiting consideration to dams over 60ft in height in the dam failure flood analysis.
RAI19: Dam Failure-Failure of All Upstream Dams
Background:
FHRR, Section 3.2, describes a screening method that considers all upstream dams by lumping them into several hypothetical dams (referred to as Approach 2). However, the FHRR does not adequately describe the modeling decisions made when lumping upstream dams into hypothetical dams.
Request: Describe how dams were lumped, including justification of any adjustments made to storage volumes during the lumping process.
RAI 20: Ice Jam Flooding-Supporting Information
Background:
The ice jam flooding analysis described in FHRR Section 3.6 does not adequately describe key assumptions, methods, and results. The NRC staff review of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-2033, "Ice-Induced Flooding Evaluation at QCNGS."
Request: Provide the following portions of QDC-0085-S-2033:
Main text (Pages 1-12)
- , Figures
- , Stage Flow Rating Curve, including the source for the curve Also provide electronic editable files for the following:
USAGE Ice Jam Query Results (QDC-0085-S-2033, Attachment 2)
HEC-RAS hydraulic model input and output files for the calculation of water surface elevations for the historic, upstream, and downstream ice jams discussed in FHRR Section 3.6 RAJ 21: Ice Jam Flooding - Ice Jam Locations
Background:
NUREG/CR-7046, "Design-Basis Flood Estimation for Site Characterization at Nuclear Power Plants in the United States of America," November 2011 (ADAMS Accession No. ML11321A195), recommends that the size and location of the jam or dam and its breach parameters should be postulated conservatively to maximize the flood caused by release of impounded water. In part, this should include an examination of locations that may be susceptible to ice jam formation. The most common location for ice jam formation is a reach where the river slope decreases significantly. Other common locations include river bends and areas of obstructions, such as a bridge or dam piers. Confluences of tributary streams with larger rivers or confluences of rivers with lakes or reservoirs are also prone to ice jam formation.
However, FHRR Section 3.6 identifies the first upstream and downstream bridge with no rational given for choosing these locations.
Request: Provide the rational for choosing to locate the ice jams at the first upstream and downstream bridges giving consideration to the common ice jam formation locations discussed above.
RAI 22: Combined Effects -Supporting Information
Background:
The discussion of the combined effect flood analysis in FHRR Section 3.8 does not adequately describe the key assumptions, methods, and results. The NRC staff review of information in the licensee's online reference portal found that this information is documented, in part, in Calculation Package QDC-0085-S-2034, "Combined Events Flood Assessment at QCNGS."
Request: Provide the following portions of QDC-0085-S-2034:
Main text (Pages 1-28)
- , Figures
- , 2-Minute Wind Speed Calculation and Formulas RAI 23: Combined Effects-Waves
Background:
The discussion of the combined effect flood analysis in FHRR Section 3.8 states that the licensee used engineering judgment and information on topography and bathymetry of the Mississippi River bottom to determine that waves will not break at or near the QCNPS site, thus eliminating the need to calculate the wave set up.
Request: Provide the topography and bathymetry of the Mississippi River in the vicinity of QCNPS site associated with this conclusion in FHRR Section 3.8.
RAI 24: Combined Effects -Clarification of Scenarios
Background:
In the combined effects flood analysis (FHRR Section 8), the licensee briefly describes three alternatives with respect to floods caused by precipitation events and two alternatives with respect to floods caused by seismic dam failure and states that the alternatives are "described in detail earlier." However, it is not clear where the alternatives are described in earlier sections of the document. Further, the discussion in this section did not provide a clear rational for why the described alternatives were selected and why others were excluded.
Request: Clarify how the alternatives discussed in this section relate to scenarios, alternatives and approaches described in earlier sections of the document. Provide a clear and detailed description of how the alternatives used in the combined event analysis were selected.
Should you have any questions, please contact me at 301-415-2020.
Sincerely, IRA BPurne/1 for/
Brenda Mozafari, Senior Project Manager Plant Licensing 111-2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Request for Additional Information cc w/encl: Listserv DISTRIBUTION:
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