ML14121A431
| ML14121A431 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/05/2014 |
| From: | Pickett D Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Pickett D, NRR/DORL/LPLI-1 | |
| References | |
| TAC MF3313, TAC MF3314 | |
| Download: ML14121A431 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 5, 2014 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3-REGULATORY AUDIT PLAN FOR MAY 27-30, 2014, AUDIT AT THE INDIAN POINT FACILITY TO SUPPORT REVIEW OF NEAR TERM TASK FORCE RECOMMENDATION 2.1: FLOODING HAZARD REEVALAUTION REPORT (TAC NOS. MF3313 AND MF3314)
Dear Sir or Madam:
By letter dated December 23, 2013, Entergy Nuclear Operations, Inc., the licensee, submitted its required response to Near Term Task Force Recommendation 2.1: Flooding Hazard Reevaluation Report, in response to the Nuclear Regulatory Commission's (NRC's) 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-lchi Accident, dated March 12, 2012.
In their response, the licensee used several new, complicated methodologies to calculate certain site hazards in their flooding hazard reevaluation report. In some cases the proposed methodologies are unique and a first of a kind approach. Based on this; the reviews can be complicated and changes in certain parameters can be extremely important and can have large impacts on the final calculated water height at the site. Some details of how the licensee applied these methodologies, which are necessary for the NRC staff to complete its review, are not present in the licensee's flood hazard reevaluation and are critical for the staff to understand. As a result, the staff will conduct an audit at the Indian Point facility during the week of May 27-30, 2014. The purpose of the audit is for the staff to develop a better understanding of how the licensee conducted its analysis and how the licensee's analysis compares to the standard methodology. Enclosed is the plan to support this audit.
If you have any questions, please contact me at 301-415-1364 or via email at Douglas. Pickett@nrc.gov.
Docket Nos. 50-247 and 50-286
Enclosure:
As stated cc w/encl: Distribution via Listserv Sincerely, Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
A.
Background
INDIAN POINT FLOOD HAZARD REEVALUATION REPORT HYDROLOGY AUDIT PLAN By letter dated December 23, 2013, Entergy Nuclear Operations, Inc., the licensee, submitted their required response for the Fukushima Near Term Task Force (NTTF)
Recommendation 2.1: Flooding Hazard Revaluation Report (FHRR). The licensee's submittal included several methodologies for which staff guidance was not used or that go beyond existing guidance. In using these methodologies, the data, models, and methods can be extremely important and can have large effects on the final calculated flooding heights at the site.
Some details of how the licensee applied these methodologies, which Nuclear Regulatory Commission (NRC) staff must understand to complete its review, are not present in the licensee's FHRR.
The NRC staff has questions in four areas regarding the information submitted by the licensee: storm surge analysis, local intense precipitation (LIP), riverine flooding (including dam failures) and documentation contained in calculation packages and references in the electronic reading room (ERR).
With respect to evaluation of probable maximum precipitation (PMP), which serves as input to local intense precipitation and riverine flooding evaluations, the licensee performed a "site-specific" evaluation rather than using previously accepted methodologies and guidance contained in the Standard Review Plan (SRP). This resulted in substantially lower precipitation values. The NRC staff needs to develop a better understanding of how the licensee calculated and applied the PMP and how the licensee's analysis compares to the standard methodology.
In the area of storm surge analysis, the licensee performed a probabilistic storm surge analysis (PSSA), which is a different method than those previously accepted by the staff.
The NRC staff needs more information about the methodology used to implement the PSSA; the licensee's use and interpretation of available data, models, and methods (including use of engineering judgment); computer codes; the identification, treatment, and propagation of uncertainties; and the basis for certain relevant modeling decisions.
The purpose of the audit is for the NRC staff to review the data, models, and methods applied in the licensee's flood hazard reevaluation, supporting documentation, and calculation packages; and discuss these issues with the applicant's subject matter experts, staff, and contractors.
The audit will allow the staff to better understand the modeling results, in order to make conclusions that: (1) the licensee responded appropriately to the 50.54(f) letter, (2) the responses are sufficient to determine whether or not the reevaluated flood causing mechanisms are, or are not, bounded by the current design basis flood hazard, and (3) whether the staff needs additional information from the licensee. The audit will also assist the staff in identifying any additional information that the staff will need during its review of the licensee's FHRR.
Enclosure B.
Regulatory Audit Bases This regulatory audit was based on the following:
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-lchi Accident, dated March 12, 2012 (Agencywide Documents Access and Management System Accession No. ML12053A340).
C.
Regulatory Audit Scope or Methodology The area of focus for the audit will be the Indian Point Recommendation 2.1 Flood Hazard Reevaluation Report and supporting documentation.
D.
Information and Other Material Necessary for the Regulatory Audit Indian Point FHRR (ML13364A005)
Information needs (the NRC staff requests the information listed in the attachment to this Enclosure)
Computer codes (including subroutines) used in performing the FHRR analyses, relevant input/output files, and electronic versions of any supporting analyses or spreadsheets Computers on which to view electronic files and access the ERR One hard copy of calculation packages used to perform or validate the PSSA and associated calculations, including the following:
o AREVA Document No. 32-9196319-000, "IPEC [Indian Point Energy Center]
Deterministic Probable Maximum Storm Surge Calculation" o
AREVA Document No. 32-9207390-000, "Probable Maximum Hurricane for Indian Point Energy Center", 2013.
o AREVA Document No. 38-9216321-000, "Acquisition of Coastal Flood Analysis Data from Federal Emergency Management Agency Region II Indian Point Energy Center Flooding Hazard Re-evaluation", August, 2013.
o AREVA Document No. 32-9196317-000, "Indian Point Energy Center Flood Hazard Re-evaluation - Probable Maximum Seiche" o
AREVA Document No. 32-9193356-000, "Flood Hazard Re-evaluation-Combined Effect Floods - Coastal Processes for Indian Point Energy Center",
o AREVA Document No. 32-9196319-000, "IPEC Deterministic Probable Maximum Storm Surge Calculation" o
AREVA Document No. 32-9213352-000, "Flood Hazard Re-evaluation-Probabilistic Storm Surge for Indian Point Energy Center
Subject Matter Experts who are knowledgeable about the PSSA methodology, LIP, riverine and dam failure flood causing mechanisms, files, and calculations used in the FHRR Two separate enclosed rooms The ability to print documents from the ERR or receive hard copies of documents from the licensee Hard copies of key references from the ERR for LIP, riverine and dam failure:
o AREVA Document No 32-9196314 (PMP report) o AREVA Document No 32-9196321 (Flood Haz Re-evai-Locallntense Precipitation-Generated Flood Flow and Elevations at IPEC) o AREVA Document No 32-9196315 (IPEC Probable Maximum Flood on Hudson River-Hydrology Calculation) o AREVA Document No 32-9196316-000 EC 46705 (IPEC Probable Maximum Flood on Hudson River - Hydraulics Calculation) o AREVA Document No 32-9196320-000 EC 46705 (IPEC Dam Failures Calculation. pdf}
High resolution graphics from select files in the ERR for LIP, riverine and dam failure:
o AREVA Document No 38-9196956 (Indian Point Energy Center (IPEC)
Topographic Survey INDIAN_POINT _ TOPO_PLAN.pdf as a large printed map or other large format.)
o AREVA Document No 32-9196321 (Flood Haz Re-evai-Locallntense Precipitation-Generated Flood Flow and Elevations at IPEC; several figures from Appendices A and B that are needed. In Appendix A, there are four figures: A-1 for maximum water surface elevations, A-2 for maximum depth, A-3 for maximum velocity, and A-4 grid cell number. In Appendix B, there is only one figure, B-1 for the topographic survey.)
E.
Audit Team The following are the audit team members:
Support:
Kenneth Erwin, NRC Audit Team Lead Douglas Pickett, NRC Project Manager Wayne Schmidt, Senior Reactor Analyst, Region I Storm Surge Methodology:
Henry Jones, NRC Audit Team Member, Storm Surge Lead Michelle Bensi, NRC Audit Team Member Chris Bender, Taylor Engineering, Inc., NRC Audit Team Member Don Resio, Taylor Engineering, Inc., NRC Audit Team Member Local Intense Precipitation I Riverine Flooding I Dam Failure Methodology:
Barbara Hayes, NRC Audit Team Member, PMP Lead Kevin Quinlan, NRC Audit Team Member Rajiv Prasad, PNNL, NRC Audit Team Member Steve Breithaupt, PNNL, NRC Audit Team Member F.
Logistics Tuesday (05/27/14)- 1:30 p.m.-5:30p.m.
Audit opens-meeting at IP offices NRC group one staff (Erwin, Pickett, Schmidt, Jones, Bensi, Bender, Hayes, Quinlan) enter site IP staff present FHRR report and methodology overview for storm surge analysis Wednesday (05/28/14)- 8:30a.m.- 4:30p.m.
Audit resumes-meeting at IP offices NRC group two staff (Resio, Prasad, Breithaupt) enter site IP staff present FHRR report and methodology overview for PMP, LIP, riverine and dam failure Breakout sessions-technical NRC and IP staff Daily debrief Thursday (05/29/14)- 8:30a.m.- 4:30p.m.
Audit resumes-meting at IP offices Breakout sessions-technical NRC and IP staff Daily debrief Friday (05/30/14)- 8:30a.m.- 12:00 p.m.
Audit resumes-Meeting at IP offices Audit concludes (11 :30 a.m.)
Audit exit (11 :30am-12:00 p.m.)
Location:
Indian Point Energy Center 450 Broadway Buchanan, NY 10511 G.
Deliverables The NRC will issue its audit report within 90 days from the completion of the audit.
St:lrial No~
1 2
FHRR Section FHRR FHRR INDIAN POINT FLOOD HAZARD REEVALUATION REPORT HYDROLOGY AUDIT PLAN -INFORMATION NEEDS
,', al'lioi'lt1;tion Needs There appear to be instances of incorrect references in the body of the FHRR or missing/incorrect references in the reference list. Have available a copy of the FHRR with any incorrect references clearly identified and corrected.
Have available electronic copies of the calculation packages below; as well as the means to access them (preferably on licensee computers rather than through the use of the electronic reading room (ERR):
AREVA Document No. 32-9207390-000, "Probable Maximum Hurricane for Indian Point Energy Center [IPEC]," 2013.
AREVA Document No. 38-9216321-000, "Acquisition of Coastal Flood Analysis Data from Federal Emergency Management Agency Region II Indian Point Energy Center Flooding Hazard Re-evaluation," August, 2013.
AREVA Document No. 32-9196317-000, "Indian Point Energy Center Flood Hazard Re-evaluation-Probable Maximum Seiche" AREVA Document No. 32-9193356-000, "Flood Hazard Re-evaluation-Combined Effect Floods-Coastal Processes for Indian Point Energy Center" AREVA Document No. 32-9196319-000, "IPEC Deterministic Probable Maximum Storm Surge Calculation" AREVA Document No. 32-9213352-000, "Flood Hazard Re-evaluation-Probabilistic Storm Surge for Indian Point Energy Center" Attachment Serial FHRR
- c.
lnformatioocNeeds No~
Section
. **.C 3
3.1 Local Intense Have available a clear description of the current licensing basis (CLB) related to local intense Precipitation precipitation (LIP). Also, have available a brief and clear description of the individual plant examination of external events (IPEEE) analysis related to the LIP.
4 3.1 Local Intense Have available the knowledgeable subject matter experts (SMEs) that performed the site-specific Precipitation probable maximum precipitation (PMP) analysis described in AREVA Document No. 32-9196314-000. Also, have available an example storm analysis (including computation software and and runs/simulations, if necessary) to walk the NRC staff through the analysis. Be prepared to define terms used in the site-specific PMP analysis-e.g., "extreme rainfall event," "transpositionability,"
3.2 Flooding in "maximum average dew point," and others.
Rivers and Streams 5
3.1 Local Intense Have available storm data that was used in the site-specific PMP analysis. Have available a Precipitation knowledgeable SME to explain how the storm data was analyzed, including details of any statistical analyses. Be prepared to explain how the storm data and/or results from storm data analyses were and used in the site-specific PMP estimation and how this varies from the storm data used in HMR51.
3.2 Flooding in Rivers and Streams 6
3.1 Local Intense Have available a list of assumptions that were made in the site-specific PMP analysis. Have Precipitation available a knowledgeable SME to discuss the justifications and/or data supporting these assumptions.
and 3.2 Flooding in Rivers and Streams 7
3.1 Local Intense Have available any references which describe the methodology used in the site-specific PMP Precipitation estimation. Have available a knowledgeable SME to discuss the differences between values resultant from the site-specific PMP estimation used in the FHRR, and values which would have and been derived from the NOAAINWS Hydrometeorological Report (HMR) methodology. Be prepared
~---
Serial FHflR lnfol11latiQn'"eeds' No.
Section
/
to discuss the level of conservativeness associated with these values and how these results could 3.2 Flooding in affect the flood hazard analysis at or near the IPEC site.
Rivers and Streams 8
- 3. 1 Local Intense Have available a knowledgeable SME to discuss how the hierarchical hazard assessment (HHA)
Precipitation approach described in NUREG/CR-7046 was applied to determine the LIP flood at and near the IPEC site.
9 3.1 Local Intense Have available a map of IPEC site and vicinity clearly showing topographic and hydraulic features Precipitation and structures that influence local site drainage.
10 3.1 Local Intense Have available the FL0-20 documentation (input and output files; calculation packages) and a Precipitation knowledgeable SME to discuss:
Precipitation transformation
- Building runoff
- Channel routing Obstructions in the floodplain Hydraulic control structures 11 3.1 Local Intense Have available the FL0-20 documentation (input and output files; calculation packages) and a Precipitation knowledgeable SME to discuss:
Quality control checks
- Sub-grid scale flow balances 12 3.1 Local Intense Have available the FL0-20 documentation (input and output files; calculation packages) and a Precipitation knowledgeable SME to discuss:
- Water surface elevation results
- Velocity results 13 3.2 Flooding in Have available a knowledgeable SME to discuss how the hierarchical hazard assessment (HHA)
Rivers and Streams approach described in NUREG/CR-7046 was applied to determine the probable maximum flood (PMF) at and near the IPEC site.
L_ _ _ - * - - - * - - ---------
Serial FHRR lnformatiorrNeeds
>c'v No.
Section
~,;*c\\c 14 3.2 Flooding in Have available a knowledgeable SME to discuss the selection of the centering and orientation for Rivers and Streams the basin-wide PMP storm for estimation of the PMF. Be prepared to present justifications and/or data support for this selection.
15 3.2 Flooding in Have available a knowledgeable SME to discuss reasonable alternative centering locations and Rivers and Streams orientations for the site-specific PMP storm for estimation of the PMF. Be prepared to discuss how these alternative centering locations could affect the flood hazard at or near the IPEC site and the associated levels of conservatism.
I 16 3.2 Flooding in Have available a map of the domains used for Hydrologic Engineering Center Hydrologic Modeling I
Rivers and Streams System (HEC-HMS) and Hydrologic Engineering Center River Analysis System (HEC-RAS) that I
clearly shows rivers, tributaries, dams and other hydraulic structures, reservoirs, watershed I
boundaries, and the location of gage stations. The map should clearly show the domains used for HEC-HMS and HEC-RAS, as well as the locations of cross sections used for HEC-RAS analyses.
17 3.2 Flooding in Have available the HEC-HMS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
Precipitation transformation
- Channel routing characteristics Reservoir characteristics 18 3.2 Flooding in Have available the HEC-HMS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
Quality control checks (if applicable)
Model calibration 19 3.2 Flooding in Have available the HEC-HMS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
- Discharge results 20 3.2 Flooding in Have available the HEC-RAS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
- Boundary conditions (upstream and downstream)
Serial FHRR Information Needs No:
Section Tributary and lateral inflows Channel routing characteristics 21 3.2 Flooding in Have available the HEC-RAS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
- Quality control checks
- Model calibration 22 3.2 Flooding in Have available the HEC-RAS documentation (input and output files; calculation packages) and a Rivers and Streams knowledgeable SME to discuss:
- Water surface elevation results 23 3.3 Dam Breaches Have available a knowledgeable SME to discuss how the hierarchical hazard assessment (HHA) and Failures approach described in NUREG/CR-7046 was applied to determine the flooding from dam failure mechanisms at and near the IPEC site.
24 3.3 Dam Breaches Have available a knowledgeable SME to discuss the centering and orientation for the basin-wide I
and Failures PMP storm used for estimation of the maximum flooding from the dam failure flood causing mechanism. Be prepared to present justifications and/or data support for this selection.
25 3.3 Dam Breaches Have available a knowledgeable SME to discuss reasonable alternative centering locations for the and Failures site-specific PMP storm for estimation flooding from dam failures. Be prepared to discuss how these alternative centering locations could affect the flood hazard at or near the IPEC site.
26 3.3 Dam Breaches Have available a map of the domain that clearly shows the locations of dams and reservoirs and Failures considered in dam failure analysis, as well as the rivers and tributaries along which any flood resulting from dam failures would be routed.
27 3.3 Dam Breaches Have available the HEC-HMS and HEC-RAS documentation (input and output files; calculation and Failures packages) and a knowledgeable SME to discuss:
Selection of reservoirs and dams for failure analysis Breach flood routing characteristics I
Serial No.
28 FHRR Section 3.4 Storm Surge Information NeeCis Have available the following documents and appropriate references, as well as a knowledgeable SME to discuss the methodology used for the deterministic characterization of storm surge, including:
The application of the SLOSH model as a screening tool, including the assumptions used to implement model simplifications, grid resolution near the Indian Point facility, and no river inflow at the upstream boundary Comparisons of SLOSH model results with measurements to validate the SLOSH model's ability to simulate storm surge near the Indian Point facility Development and application of probability distributions applied to develop the SLOSH model input parameter combinations. As part of this discussion, provide information on the upper limits applied for the meteorological forcing parameters. If this upper limit involved the estimation of an MPI central pressure, describe how this was done. If this was done via an upper limit derived based on Extreme Value Statistics, describe how this was done. Also, discuss the application of the Extreme Value Statistics (EVS) performed to estimate the probability of strong storms in the study region. Include the probability distributions used for different storm parameters and any references to their previous application to this region. If there are no previous applications of the specific distributions used here, provide a plot of the data and the fit to the data provided by the specific distributions used in this effort Application of the ADCIRC model within the deterministic analysis and any modeling difficulty encountered (such as instability for strong storms)
Comparisons of the SLOSH and ADCIRC results for similar storms and whether the results indicate suitable model results for application of SLOSH as a screening tool Comparisons of the ADCIRC tidal model results to confirm consistency between the simulated and predicted tidal phasing, range, and amplitude Development of the stillwater, wave crest elevation, and limit of run-up for Combined Flood Event Alternatives 1, 2, and 3 Provide evidence that wave setup is not important at the site Details of methods applied to develop the flow velocity and hydrodynamic loads at the site Discuss the source of the bathymetry data and interpolation method applied in the development of the ADCIRC model mesh. Discuss the scope of changes made to the Federal
Serial**
No.
FHRR Section r Information Needs
~ - \\~:;_.:____
- ~~
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Emergency Management Agency (FEMA) Region II mesh to refine the area near the Indian Point facility.
Provide input files necessary to recreate two of the SLOSH and ADCIRC model results in Tables 3.4-10 and 3.4-12.
29 I 3.4 Storm Surge 1 Have available appropriate documents and references, as well as an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the following:
Rationale for selecting 2 x 10-6 as the appropriate level to establish the reevaluated storm surge elevation Interpretation of the hazard curve and annual exceedance probability (AEP) of 2 x 10-6 in light of the use of deterministic models and event combinations and any associated potential bias inherent in models employed as well as any uncertainties that were considered or neglected.
30 I 3.4 Storm Surge 1 Have available appropriate documents, codes, and references as well as an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the following:
- 1. Characterization and propagation of relevant sources of aleatory variability (e.g., probability density functions associated with storm parameters and model errors).
- 2. The means by which epistemic uncertainties in related data, models and methods were addressed, including, but not limited to, the following topics:
alternate technical interpretations of relevant data, including considerations of different means of selecting, interpreting, and filtering data from the HURDAT database.
alternate technical interpretations of relevant probability density (mass) functions used to characterize aleatory uncertainty associated with storm parameters (e.g., intensity, storm track, radius to maximum winds, and storm translational speed) alternate technically defensible models and modeling decisions
- 3. The means by which epistemic uncertainties were quantified and propagated (e.g., development of logic trees, if applicable).
Serial FHRR lnformation.. Nieds--,
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31 3.4 Storm Surge Have available an electronic copy of the Excel spreadsheet JPM_SLOSH_ADCIRC_1 03013.xlsx referenced in Appendix H of calculation package 32-9213352-000 as well as personnel knowledgeable in its contents and usage.
32 3.4 Storm Surge Have available relevant documentation and an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss any sensitivity studies performed to support the probabilistic storm surge analysis (PSSA).
33 3.4 Storm Surge Have available appropriate documents, codes, and references as well as an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the following:
Probability distributions associated with storm parameters and error terms (as applicable) in the JPM integral.
- Basis for distribution models and parameters selected, including any analyses performed using expert judgment, based on existing studies, or based on available data (e.g., HURDAT) including selection, interpretation, and filtering of available data.
34 3.4 Storm Surge Have available appropriate documents, codes, and references as well as an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the selected discretization shown in FHRR Tables 3.4-5 through 3.4-9, including (but not limited to) discussion of the basis for the selected discretization and the treatment of the contribution of probability mass associated with parameter values outside the range of parameters shown in Tables 3.4-5 through 3.4-9.
35 3.4 Storm Surge Have available relevant codes, references, and documentation as well as an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the basis for the calculated omni-directional storm rate including (but not limited to) the basis for the selected capture zone and any sensitivity studies that were performed or alternate methods that were considered. NRC also requests that the licensee have available a tabulation of the events (including event dates) that L._
Serial FHRR No.
Section Information Needs
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were used to compute the omni-directional storm rate (as referenced in Section 6.2 of calculation package 32-9213352-000).
36 3.4 Storm Surge Have available relevant documentation and an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the use and interpretation of deterministic load combinations (e.g., a 25-year river flow in conjunction with the storm surge event) in conjunction with the probabilistic characterization of storm surge and the basis for those decisions.
37 3.4 Storm Surge Have available relevant documentation and an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss components of the PSSA that relied on engineering judgment or experience, including (but not limited to) the filtering of data, statistical methods used to develop probability density functions (PDFs), selected PDFs, event combinations considered (e.g.,
treatment of concurrent tides and river flows), model selection, and model parameters.
38 3.4 Storm Surge Have available relevant codes, references, and documentation; and an SME who is knowledgeable about the probabilistic characterization of storm surge to discuss the results of verification and validation exercises, including the means by which the Joint Probability Method (JPM) integration accounted for model errors.
If you have any questions, please contact me at 301-415-1364 or via email at Douglas.Pickett@nrc.gov.
Docket Nos. 50-247 and 50-286
Enclosure:
As stated Sincerely, IRA/
Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/encl: Distribution via Listserv DISTRIBUTION:
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NRO LPL 1-1/BC NAME DPickett KGoldstein KErwin BBeasley DATE 05/02/14 05/02/14 05/05/14 05/05/14 OFFICIAL RECORD COPY