ML15238B537

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

ML15238B537
Person / Time
Site:	FitzPatrick
Issue date:	09/04/2015
From:	Victor Hall Japan Lessons-Learned Division
To:	Entergy Nuclear Operations
Minarik A, NRR/JLD, 415-6185
References
TAC MF6106
Download: ML15238B537 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 4, 2015 Vice President, Operations Entergy Nuclear Operations, Inc.

P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO 10 CFR 50.54(f) INFORMATION REQUEST- FLOOD-CAUSING MECHANISM REEVALUATION (TAC NO. MF6106)

Dear Sir or Madam:

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, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15082A250), flood hazard reevaluation report (FHRR) submitted by Entergy Nuclear Operations, Inc. (Entergy, the licensee) for James A. FitzPatrick Nuclear Power Plant (FitzPatrick), 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 COM-SECY-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 1.icensee and has summarized the results of the review in the tables provided as an Enclosure to this letter.

Table 1 provides the current design-basis flood hazard mechanisms. Table 2 provides the reevaluated flood hazard mechanisms; however, the reevaluated hazard mechanisms bounded by the current design-basis (Table 1) are not included.

The staff has concluded that the licensee's reevaluated flood hazards information, as summarized 1n Enclosure 1, 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 FitzPatrick. 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 FitzPatrick 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.

As stated above, Table 2 of the enclosure to this letter describes the reevaluated flood hazards that exceed the current design-basis. In order to complete its response to the information requested by Enclosure 2 to the 50.54(f) letter, the licensee is expected to submit an integrated assessment or a focused evaluation, as appropriate, to address these reevaluated flood hazards, 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).

If you have any questions, please contact me at (301) 415-2915 or e-mail at Victor.Hall@nrc.gov.

Sincerely, Victor E. Hall, Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

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

ENCLOSURE:

SUMMARY

TABLES OF REEVALUATED FLOOD HAZARD LEVELS

FitzPatrick 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 Not included Not included Not included FHHR Table 4-1 in DB in DB in DB I i i I

I Streams and Rivers I Not included Not included Not included  ! FHRR Table 4-1 in DB in DB in DB I I

i Failure of Dams and Onsite Water Control/Storage Structures Not included Not included Not included FHRR Table 4-1 in DB in DB in DB Storm Surge I i

I

' Storm Surge 254.1 ft 7.9 ft 262 ft FHRR Table 4-1 I

USLS35 USLS35 Storm Surge at Screenwell 254.0 ft 1.0 ft 255 ft FHRR Table 4-1 USLS35 I USLS35 Seiche 1

Not included Not included Not included FHRR Table 4-1 in DB in DB in DB Tsunami Not included Not included I Not included I FHRR Table 4-1 in DB in DB in DB Ice-Induced Flooding Not included Not included Not included FHRR Table 4-1 in DB in DB in DB

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FitzPatrick Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard Elevation Channel Migrations/Diversions Not included Not included Not included FHRR Table 4-1 in DB in DB in DB Note: Reported values are rounded to the nearest one-tenth of a foot.

FitzPatrick

,- Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA Mechanism Stillwater Elevation I

Waves/

Run up Reevaluated Hazard Elevation Reference --

Local Intense Precipitation 272.8 ft Minimal 272.8 ft FHRR Table 4-1 and FHRR USLS35 USLS35 Appendix A Streams and Rivers Unnamed Stream 272.8 ft Not 272.8 ft FHRR Table 4-4 USLS35 applicable USLS35 Storm Surge PMSS + PMP +Waves 252.8 ft 15.2 ft 268.0 ft FHRR Sect 3.4.3 & Table 4-1 USLS35 USLS35 FHRR Table 4-1 Note 1: The licensee is expected to develop flood event duration parameters and applicable flood associated effects to conduct the MSA. The staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood associated effects during its review of the MSA.

Note 2: Reevaluated hazard mechanisms bounded by the current design basis (see Table 1) are not included in this table.

Note 3: Reported values are rounded to the nearest one-tenth of a foot.

PKG ML152388540; LTR: ML152388537; ENCL: ML15229A023 *via email OFFICE NRR/JLD/JHMB/PM* NRR/JLD/LA* NRO/DSEA/RHM2/TR* NRO/DSEA/RHM2/BC*

NAME AMinarik Slent LHibler ARivera-Varona DATE 08/28/15 08/27/15 08/17/15 08/17/15 OFFICE NRR/JLD/JHMB/BC OGC* NRR/JLD/JHMB/PM NAME MShams SClark VHall DATE 08/28/15 08/14/15 09/04/15