ML16019A061

Additional NRC Staff Comments on MSA Template and Example -Transmittal Email 2016-01-15

ML16019A061
Person / Time
Issue date:	01/15/2016
From:	Marshall M Japan Lessons-Learned Division
To:	Jeffrey Riley Nuclear Energy Institute
Marshall, Michael NRR/JLD 415-2871
References
Download: ML16019A061 (7)

Text

From:

Marshall, Michael To:

"RILEY, Jim" Cc:

Shams, Mohamed

Subject:

RE: Additional NRC Staff Comments on MSA Template and Example Date:

Friday, January 15, 2016 9:34:00 AM Hello Jim,

Below are 6 comments that I neglected to include in the list of comments that I sent you on December 22, 2015. To minimize confusion with the list of comments that was sent on December 22, 2015, I started the numbering of this list of additional comments at 31. In addition to the comments added below, please, delete comment 4 from the list of comments sent to you on December 22, 2015.

Additional Comments or Questions on Content of Template

31. Page 1, Section 1.1 and Table 1: Section 1.1 indicates that MSFHI can be characterized by summary or reference to FHRR submittal. In Table 1, will the values for flood scenario parameters be explicitly listed or provided by reference?

32. Page 1, Column 2: FLEX design basis is clearly defined in section G.3. In some cases the FLEX design basis may differ from the [site] current design basis. Consider adding guidance to the template to explicitly state whether the FLEX design basis differs from or is the same as the [site] current design basis.

33. Page 1, Table 1: The table indicates for max Stillwater elevation and max wave run-up elevation that the height should be listed in feet mean sea level (MSL). Not all licensees used MSL as the datum for their site. Consider expanding the units to include the other datum used such as NAVD88.

34. Page 1, Table 1, Note 4: The items listed for discussion in note 4 appear to be only for the effects of erosion. Because note 4 is intended to address both deposition and erosion, consider listing effects for deposition such as sediment deposition.

35. Page 3, Section 1.3.1.3 and Section 1.3.1.4: Consider adding an additional bullet similar to the second bullet in Section 1.3.1.3 for flood protection features. If flood protection features are changed, a description and justification of the change should be provided.

36. Page 3, Section 1.3.1.3, Second Bullet and Section 1.3.1.4, First Bullet: After the Description consider adding and justification. A summary justification should be included with any changes to the sequence of events for the flood hazard.

Best Regards, Michael L. Marshall, Jr.

Senior Project Manager

Hazard Reevaluation Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation

301-415-2871

From: Marshall, Michael Sent: Tuesday, December 22, 2015 3:49 PM To: 'RILEY, Jim' <jhr@nei.org>

Cc: Shams, Mohamed <Mohamed.Shams@nrc.gov>

Subject:

RE: MSA Example

Hello Jim,

Here are our comments on the MSA template and example that you shared via email on December 9, 2015:

Comments on Content of Template

1. General Comment: Consider adding a short section prior to section 1.1 that provides an summary overview of the mitigating strategies assessment results, identify changes, if any, in mitigation strategies (e.g., modified FLEX, AMS, THMS), and key changes/modifications to equipment, connections, or deployment.

2. General Comment: To minimize misunderstanding it would be best if the terminology used is consistent across the final integrated plan; flood hazard reevaluation report; NEI 12-06, Appendix G; and mitigating strategies assessment template. For example:

a. Page 1, Section 1.2, First Sentence: The sentence refers to nature of any element. It is clear from the sentence context that nature of any element is being used interchangeable with flood parameters or flood event duration parameters. But it may be better to use the terminology that is most aligned with flood hazard reevaluation report and MSFHI letter.

b. Page 2, Section 1.3.1.2, Second Bullet: The last part of the sentence that includes FLEX, AMS, or THMS. It appears form the context of the sentence that FLEX should be modified FLEX, modifying FLEX, or modifications to FLEX.

c. Page 3, Second Paragraph, Third Bullet: The sentence includes reference to a revised FLEX. It is clear from the sentence context that revised FLEX is being used interchangeable with modified FLEX, modifying FLEX, or modifications to FLEX. But it may be better to use the terminology that is most aligned with Appendix G.

3. Page 1, Acronyms: To better align the template with Appendix G, consider adding FLEX DB to the list of acronyms along with the definition from Appendix G.

4. Page 1, Table 1: Consider including an entry for localized intense precipitation in the table.

5. Page 1, Table 1: Consider including an entry for other effects in the associated effects portion of the table.

6. Page 2, Table 1, Bullet 3: Consider including a description similar to bullet 4 instead of none for bullet 3.

7. Page 2, Table 1, Bullet 10: In addition to discussing period of recession, when flood waters completely recede, and plant is safe and stable state, consider including a discussion on when site access is restored under this bullet.

8. Page 2, Section 1.3.1.2: Consider addressing the possibility that two or more of the alternate strategies may need to be selected to address different parameters that are not bounded by the FLEX design-basis flood.

9. Page 2, Section 1.3.1.2: Consider including a discussion of or list of the portion of FLEX strategy (incl., equipment) that could not be implement for MSFHI.

Comments on Level of Detail of Template

10. Page 1, Table 1: If associated effects were not described in the flood hazard reevaluation report and MSFHI letter, then a description on how the associated effects were determined should be provide consistent with the level of detail in flood hazard reevaluation report.

11. Page 3, Section 1.3.1.3, Third Bullet: Will the description include modification to deployment plans?

12. Page 3, Section 1.3.1.4, Third Bullet: Will the detailed list include both passive and active equipment?

Other Comments on Template

13. Page 2, Table 1, Bullet 10: As written the bullet could be misread to indicate that the plant was note safe at some point. Since the purpose of strategies is to keep the plant safe, consider revising sentence to indicate that plant continued to be safe or plant was safe and stable throughout the event.

14. Page 2, Table 1, Bullet 10: If the goal is to maintain the plant in a safe and stable state indefinitely, then consider adding indefinitely to the end of the sentence.

15. Page 3, First and Fourth Paragraphs: It appears that the paragraph should include a reference to Section 1.3.1 - not Section 2.3.1.

16. Page 3, Last Sentence: Consider providing a fuller title for the Program Document (e.g., FLEX Program Document).

Comments on Content of Example

17. Page 3, Section 1.3.1.1, Storage: It would be helpful if a statement or reference

is provided at beginning of section or elsewhere that clearly indicated whether equipment being discussed (e.g., flood pump) is or is not part of FLEX, modified FLEX, AMS, or THMS. It is unclear whether the flood pump discussed in this section is an existing FLEX pump. If the pump being described is one of the pumps listed in Attachment 1 under a detailed list of equipment necessary for the mitigating strategies then it would be helpful if the description is consistent within the document.

Comments on Level of Detail of Example

18. Page 2, Table 1, Bullets: When completed, will this table include references to FHRR, an attachment to the MSA letter, or other document that contains the discussions listed in the notes? It would be helpful if the notes explicitly cite any reference, if the information will not be included directly in the note (especially for bullets 10 through 12).

19. Page 2, Last Paragraph: It was difficult to determine which flood hazard FLEX DB flood, MSFHI, or both) was being discussed in this paragraph. It would helpful to consistently, explicitly refer to MSFHI and FLEX DB flood. (see Comment 2)

20. Page 3, First Paragraph, Fifth Sub-Bullet: A reference that describe the actions being taken or a descriptions of the action being taken should be provided.

21. Page 6, Table, Row 1: It would be helpful to include the entry criteria or reference to the entry criteria that initiate strategy in the remarks column.

22. Page 8, First Paragraph, Last Sentence: For key assertions, like the one in this sentence, please, include a reference that contains the basis for the statement or provide a summary description of the basis.

23. Page 9, First Paragraph (partial), Second Sentence: Since the table was not complete in the example, it was not clear if the river flood level was bounded by the FLEX DB flood. If it was not bound, a discussion should be included of deployment and access consideration should be provided, even if it is a discussion that states with explanation that deployment and access is not affected by higher flood level.

24. Page 9, Third Paragraph (complete): Since this is a strategy that is different than the one reviewed under Order AE-12-049, additional detail should be provided such as special access provisions for the operators.

25. Page 10, Section 3.2.1.3.2, Fourth Sentence: For key assertions, like the one in this sentence, please, include a reference that contains the basis for the statement or provide a summary description of the basis. (see Comment 22)

26. Page 10, Section 3.2.1.3.2, Last Sentence: Since the table was not complete in the example, it was not clear if the MSFHI flood parameters were bounded by the FLEX DB flood parameters. If it was not bound, a justification should be included, if any, on dc buses along with ac power, even if it is a discussion that

states with explanation that is not affected by higher flood level. (see Comment 23)

27. Page 11, Section 3.2.2, Ninth Sentence: A discussion on how Phase 3 equipment will be transported from the staging area to the site should be provided.

28. Page 12, Section 6.2.3.1, Last Sentence and Page 13, third Paragraph, Only Sentence: If statement is included that equipment is being moved to higher location or more time, a discussion should be provided whether additional equipment (e.g., additional hose) is needed or will be staged.

29. Page 14, Section 11.5, Last Sentence and Page 15, Section 11.8: Consider being more explicit regarding equipment that may be added to FLEX unavailability program. An explicit statement should be included whether the equipment will have the same unavailability controls as the FLEX equipment.

Other Comments on Example

30. Page 2, Last Paragraph, Fourth Sentence: The sentence refers to the US Weather Bureau. Should this have been a reference to the National Weather Service?

Best Regards, Michael L. Marshall, Jr.

Senior Project Manager

Hazard Reevaluation Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation

301-415-2871

From: RILEY, Jim [1]

Sent: Wednesday, December 09, 2015 3:17 PM To: Marshall, Michael <Michael.Marshall@nrc.gov>; Shams, Mohamed

<Mohamed.Shams@nrc.gov>

Cc: BAUER, Scott <sab@nei.org>; Bill Webster (william.webster@dom.com)

<william.webster@dom.com>; bolognar@firstenergycorp.com; Bunt, Randy

<rcbunt@southernco.com>; Christopher P Burks (Generation - 6)

<christopher.p.burks@dom.com>; Dave Schupp <david.schupp@exeloncorp.com>;

Dean Hubbard (dmhubbard@duke-energy.com) <dmhubbard@duke-energy.com>;

Dean Price (Generation - 6) <dean.price@dom.com>; Don Bentley (DBENTLE@entergy.com) <DBENTLE@entergy.com>; Gambrell, David

<dlgambre@southernco.com>; GASPER, JOSEPH K <jgasper@oppd.com>; Geiger, Charlotte <Charlotte.Geiger@pseg.com>; George Attarian

<george.attarian@outlook.com>; Giddens, John <jmgidden@southernco.com>;

Greg Halnon <ghalnon@firstenergycorp.com>; joe.bellini@aterrasolutions.com; Lingle, Ronnie <Ronnie.Lingle@fpl.com>; Lyter, Jay W:(GenCo-Nuc)

<jay.lyter@exeloncorp.com>; Michael Henig (Generation - 6)

<michael.henig@dom.com>; Miller, Andrew <APMiller@erineng.com>; Nick Pappas (nicholas.pappas@aps.com) <nicholas.pappas@aps.com>; Powell, Michael

<michael.powell@aps.com>; Ray Schneider (schneire@westinghouse.com)

<schneire@westinghouse.com>; RILEY, Jim <jhr@nei.org>; Ruf, Gary (Gary.Ruf@pseg.com) <Gary.Ruf@pseg.com>; Spink, Thomas E <tespink@tva.gov>

(tespink@tva.gov) <tespink@tva.gov>

Subject:

[External_Sender] MSA Example

Mo, Mike;

Attached is an example MSA for a generic G.4.4 plant (THMS). We are continuing to work on examples for G.4.1, G.4.2, and G.4.3 plants and will send you those examples when they are completed.

Please send us your comments on this example and on the MSA template which we sent to you earlier (attached again for convenience).

Thanks,

Jim Riley NEI W: (202) 739-8137 C: (202) 439-2459 jhr@nei.org

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