ML15212A010

Interim Staff Response to Reevaluated Flood Hazards Submitted in Response to 10 CFR 50.54(f) Information Request - Flood-Causing Mechanism Reevaluation

ML15212A010
Person / Time
Site:	Clinton
Issue date:	09/03/2015
From:	Tekia Govan Japan Lessons-Learned Division
To:	Bryan Hanson Exelon Generation Co
Minarik A, NRR/JLD, 415-6185
Shared Package
ML15230A012	List: ML15212A010 ML15219A645
References
TAC MF3654
Download: ML15212A010 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 3, 2015 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO 10 CFR 50.54(f) INFORMATION REQUEST- FLOOD-CAUSING MECHANISM REEVALUATION (TAC NO. MF3654)

Dear Mr. Hanson:

The purpose of this letter is to provide a summary of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the re-evaluated flood-causing mechanisms described in the March 12, 2014 (Agencywide Document Access and Management System (ADAMS) Accession No. ML14079A415), flood hazard reevaluation report (FHRR) submitted by Exelon Generation Company, LLC (Exelon, the licensee) for Clinton Power Station, Unit No. 1 (Clinton), as well as supplemental information resulting from requests for additional information and audits.

By letter dated March 12, 2012, the NRC issued a request for information pursuant to Title 10 of the Code of Federal Regulations, Section 50. 54(f) (hereafter referred to as the 50. 54(f) letter)

(ADAMS Accession No. ML12053A340). The request was issued as part of implementing lessons-learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 2 to the 50.54(f) letter requested licensees to re-evaluate flood-causing mechanisms using present-day methodologies and guidance. Concurrently, with the reevaluation of flooding hazards, licensees were required to develop and implement mitigating strategies in accordance with NRC Order EA-12-049, "Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12054A735). On March 30, 2015, the Commission provided Staff Requirements Memoranda (SRM) (ADAMS Accession No. ML15089A236) to COMSECY-14-0037, "Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards," dated November 21, 2014 (ADAMS Accession No. ML14309A256), affirming that licensees need to address the reevaluated flooding hazards within their mitigating strategies for beyond-design-basis external events.

The NRC staff has reviewed the flood hazard information submitted by the licensee and has summarized the results of the review in the table provided as an Enclosure to this letter.

B. Hanson Table 1 provides the current design-basis flood hazard mechanisms. All the reevaluated flood hazard mechanisms at Clinton are bounded by the current design-basis.

The NRC staff has concluded that the licensee's reevaluated flood hazards information, as summarized in the Enclosure, is suitable for the assessment of mitigating strategies developed in response to Order EA-12-049 (i.e., defines the mitigating strategies flood hazard information described in guidance documents currently being finalized by the industry and NRC staff) for Clinton. Further, the NRC staff has concluded that the licensee's reevaluated flood hazard information is a suitable input for other assessments associated with Near-Term Task Force Recommendation 2.1 "Flooding". The NRC staff plans to issue a staff assessment documenting the basis for these conclusions at a later time.

In addition, NEI 12-06 "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" is currently being revised. This revision will include a methodology to perform a Mitigating Strategies Assessment (MSA) with respect to the reevaluated flood hazards. Once this methodology is endorsed by the NRC, flood event duration parameters and applicable flood associated effects should be considered as part of the Clinton MSA. The NRC staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood-related associated effects developed by the licensee during the NRC staff's review of the MSA.

Because the reevaluated flood hazard mechanisms at Clinton are bounded by the current design-basis, it is unnecessary for the licensee to perform an integrated assessment or focused evaluation, as described in NRC letter, "Coordination of Request for Information Regarding Flooding Hazard Reevaluation and Mitigating Strategies for Beyond Design Bases External Events" (ADAMS Accession No. ML15174A257). This letter describes the changes in the NRC's approach to the flood hazard reevaluations that were approved by the Commission in its SRM to COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants" (ADAMS Accession No. ML15209A682). Therefore, the NRC staff confirms that the licensee responded appropriately to Enclosure 2 of the 50.54(f) letter.

B. Hanson If you have any questions, please contact me at (301) 415-6197 or e-mail at Tekia.Govan@nrc.gov.

Tekia Govan, Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-461

Enclosure:

Summary of Results of Flooding Hazard Re-Evaluation Report cc w/encl: Distribution via Listserv

ENCLOSURE:

SUMMARY

TABLE OF REEVALUATED FLOOD HAZARD LEVELS

Clinton 1 Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard

• ~~~~--+-~~

Elevation

~~~~~-

Local Intense Precipitation Local Intense Precipitation and 736.8 ft MSL Not 736.8 ft MSL FHRR Section 2.2.1 and Table 4.0.2 Associated Drainage applicable Streams and Rivers No impact on No impact on No impact on FHRR Section 2.2.2 the site the site the site identified identified identified 1

Failure of Dams and Onsite Water Control/Storage Structures

. I No impact on No impact on No impact on : FHRR Section 2.2.3 the site the site the site 1 1

identified identified identified I I Storm Surge Probable maximum flooding on No impact on No impact on No impact on 1

FHRR Section 2.2.5 cooling pond the site the site ' the site identified identified i identified I

I Seiche I

No impact on No impact on No impact on FHRR Section 2.2.5 the site the site the site I

identified identified identified I

Tsunami 1

I i

No .impact on IN o .impact on No impact on FHRR Section 2.2.6 the site  ; the site the site identified identified identified Ice-Induced Flooding I

No impact on I No impact on No impact on FHRR Section 2.2.7 the site

• the site the site identified identified identified 1

Channel Migrations/Diversions No impact on No impact on No impact on FHRR Section 2.2.8 the site the site the site identified identified identified Note: Reported values are rounded to the nearest one-tenth of a foot.

PKG ML15230A012; LTR: ML15212A010; ENCL: ML15219A645 *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRO/DSEA/RHM2/TR* NRO/DSEA/RHM2/BC*

NAME AMinarik Slent PChaput ARivera-Varona DATE 8 / 25 /15 07/31/15 08/17/15 08/17/15 OFFICE NRR/JLD/JHMB/BC OGC* NRR/JLD/JHMB/PM NAME MShams SClark TGovan DATE 8 / 28 /15 08/14/15 9 / 3 /15