ML16112A172
| ML16112A172 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/25/2016 |
| From: | Victor Hall Containment and Balance of Plant Branch |
| To: | Coyle L Entergy Nuclear Operations, Indian Point |
| Hall, V. E., NRC/NRR/JLD, 301-415-2915 | |
| Shared Package | |
| ML16112A152 | List: |
| References | |
| CAC MF3313, CAC MF3314 | |
| Download: ML16112A172 (10) | |
Text
OFFICIAL USE ONLY SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 April 25, 2016
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 - INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO 10 CFR 50.54(f) INFORMATION REQUEST-FLOOD-CAUSING MECHANISM REEVALUATION (CAC NOS. MF3313 AND MF3314)
Dear Mr. Coyle:
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, 2013, (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13079A061 ), flood hazard reevaluation report (FHRR) submitted by Entergy Nuclear Operations, Inc. (Entergy, the licensee) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (Indian Point), 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.
Enclosure two transmitted herewith contains Security-Related Information. When separated from the Enclosure, this document is decontrolled.
OFFICIAL USE ONLY SECURITY RELATED INFORMATION
OFFICIAL USE ONLY SECURITY RELATED INFORMATION The NRC staff has reviewed the information submitted by the licensee and has summarized the results of the review in the tables provided as Enclosure 1 to this letter. Table 1 provides the current design-basis flood hazard mechanisms. Table 2 provides reevaluated flood hazard mechanisms; however, reevaluated hazard mechanisms bounded by the current design-basis (Table 1) are not included. Because Table 2 includes security-related information, Enclosure 1 contains the redacted version of Table 2. Enclosure 2 is withheld from public disclosure and restores the security-related information to Table 2.
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 Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide") for Indian Point. 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.
Revision 2 of NEI 12-06 includes a methodology to perform a Mitigating Strategies Assessment (MSA) with respect to the reevaluated flood hazards. On February 29, 2016, the NRC staff published Japan Lessons-Learned Division (JLD) Interim Staff Guidance (ISG) JLD-ISG-2012-01, Revision 1, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (ADAMS Accession No. ML15357A142) in the Federal Register (81 FR 10283). This ISG endorses Revision 2 of NEI 12-06 (ADAMS Accession No. ML16005A625), dated December 2015.
Based on the guidance provided in Revision 2 of the NEI 12-06 guidance document, flood event duration parameters and applicable flood associated effects should be considered as part of the Indian Point 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 the NRC letter, "Coordination of Request for Information Regarding Flooding Hazard Reevaluation and Mitigating Strategies for Beyond-Design-Basis 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).
OFFICIAL USE ONLY SECURITY RELATED INFORMATION
OFFICIAL USE ONLY SECURITY RELATED INFORMATION If you have any questions, please contact me at (301) 415-2915 or e-mail at Victor.Hall@nrc.gov.
Docket Nos. 50-24 7 and 50-286
Enclosures:
- 1. Summary of Results of Flooding Victor Hall, Senior Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Hazard Re-Evaluation Report (Redacted Version)
- 2. Summary of Results of Flooding Hazard Re-Evaluation Report (Non-Public Version) cc w/encl: Distribution via Listserv OFFICIAL USE ONLY SECURITY RELATED INFORMATION
OFFICIAL USE ONLY SECURITY RELATED INFORMATION ENCLOSURE 1:
SUMMARY
TABLES OF REEVALUATED FLOOD HAZARD LEVELS OFFICIAL USE ONLY SECURITY RELATED INFORMATION
Indian Point Nuclear Generating Units 2 & 3 Table 1. Current Design Basis Flood Hazards for Use in the MSA I
Mechanism Stillwater Waves/
Design Basis Reference Elevation Run up Hazard I
Elevation Local Intense Precipitation Not included Not included Not included Flood Hazard Reevaulation Report in DB in DB in DB (FHRR) Revision 2, Section 4.1.1 Streams and Rivers i Probable Maximum Flood (PMF) 12.7 ft 1.0 ft 13.?ft FHRR Revision 2, Section 2.3.1 and on the Hudson River NGVD29 NGVD29 Table 4.1-1 PMF with Low Tide on the 13.0 ft 1.0 ft 14.0 ft FHRR Revision 2, Section 2.3.1 and Hudson River NGVD29 NGVD29 Table 4.1-1 PMF with High Tide on the 12.4ft 1.0 ft 13.4 ft FHRR Revision 2, Section 2.3.1 and I Hudson River NGVD29 NGVD29 Table4.1-1 Failure of Dams and Onsite Water Control/Storage Structures REDACTED REDACTED REDACTED REDACTED REDACTED I
I Storm Surge Probable Maximum Hurricane 13.5ft 1.0 ft 14.5 ft FHRR Revision 2, Section 2.3.1 and (PMH) with Spring High Tide on NGVD29 NGVD29 Table 4.1-1 the Hudson River Standard Project Hurricane and 13.0 ft 1.0 ft 14.0 ft FHRR Revision 2, Section 2.3.1 and Standard Project Flood on the NGVD29 NGVD29 Table 4.1-1 I
Hudson River I
I REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED REDACTED I
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Indian Point Nuclear Generating Units 2 & 3 Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/
Design Basis Reference Elevation Run up Hazard Elevation Seiche Not included Not included Not included FHRR Revision 2, Section 4.1.5 in DB in DB in DB Tsunami Not included Not included Not included FHRR Revision 2, Section 4.1.6 in DB in DB in DB Ice-Induced Flooding Not included Not included Not included FHRR Revision 2, Section 4.1.7 in DB in DB in DB Channel Migrations/Diversions Not included Not included Not included FH RR Revision 2, Section 4.1.8 in DB in DB in DB Note 1: Reported values are rounded to the nearest one-tenth of a foot.
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Indian Point Nuclear Generating Units 2 & 3 Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA I
I Mechanism Stillwater Waves/
Reevaluated Reference Elevation Run up Hazard Elevation Local Intense Precipitation Unit 2 Transformer Yard Doors 18.8 ft Minimal 18.8 ft Letter dated August 18, 2014, Maximum Water-Surface NGVD29 NGVD29 entitled "Revised FL0-2D Analysis Elevation - Door ID U2-ABFP-2 to Address the Current LIP Regarding the Flooding Aspects of Unit 2 Transformer Yard Doors 18.8 ft Minimal 18.8ft Recommendations 2.1 of the Near-Term Task Force Review of the Maximum Water-Surface NGVD29 NGVD29 Insights from the Fukushima Dai-ichi Elevation - Door ID U2-ABFP-3 Accident Indian Point Units Nos. 2 and 3." ADAMS Accession Unit 2 Transformer Yard Doors 19.1 ft Minimal 19.1 ft No. ML16116A060 Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U2-CB-1 Unit 2 Transformer Yard Doors 19.2 ft Minimal 19.2 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U2-PAB-1 Unit 2 Transformer Yard Doors 19.0 ft Minimal 19.0 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U2-ABFP-1 Unit 3 Transformer Yard Doors 18.3 ft Minimal 18.3 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-ABFP-1 Unit 3 Transformer Yard Doors 18.5 ft Minimal 18.5 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-ABFP-2 Unit 3 Transformer Yard Doors 18.6 ft Minimal 18.6 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-ABFP-3 Unit 3 Transformer Yard Doors 18.8 ft Minimal 18.8 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-PAB-1 Unit 3 Transformer Yard Doors 18.9 ft Minimal
- 18. 9 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-PAB-2 Unit 3 Transformer Yard Doors 19.2 ft Minimal 19.2 ft Maximum Water-Surface NGVD29 NGVD29 Elevation - Door ID U3-CB-1
Indian Point Nuclear Generating Units 2 &.3 Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA Mechanism Streams and Rivers Cool Season on Hudson River PMF with Snow Pack Coincident with 25-year Surge and 10%
Exceedance High Tide Failure of Dams and Onsite Water Control/Storage Structures REDACTED Storm Surge Combined Event with 150,000 cfs Flow in Hudson River Coincident with the Probable Maximum Storm Surge (PMSS), Including Antecedent Water Level (AWL) and Coincident Wind-Generated Waves (CWGW) - Values Reported in Open Water in River Outboard of River Bulkhead and U2 Intake Structure Combined Event with 150,000 cfs Flow in Hudson River Coincident with PMSS, Including AWL and CWGW - Values Reported in Open Areas of Powerblock Yard Between U2 Intake Structure and U2 Turbine Building Combined Event with 150,000 cfs Flow in Hudson River Coincident with PMSS, Including AWL and CWGW - Values Reported at River-facing Sides of Structures Between the River Bulkhead and the Turbine Buildings (Including West Sides of U2 and U3 Intake Structures) and River-facing (West) Side of U2 and U3 Turbine Buildings Stillwater Elevation 16.5 ft NGVD29 REDACTED 18.9 ft NGVD29 18.9 ft NGVD29 18.9 ft NGVD29 Waves/
Run up 2.1 ft REDACTED 2.9 ft 2.1 ft 4.7 ft Reevaluated Hazard Elevation 18.6 ft NGVD29 REDACTED 21.8 ft NGVD29 21.0 ft NGVD29 23.6 ft NGVD29 Reference FHRR Rev. 2 (12/9/2014) Sections 3.4.2.5.1, 3.4.2.5.2, and FHRR (Rev.
12/10/2015) Section 6.2.2 REDACTED Letter dated April 5, 2016, entitled "Entergy Supplement to Basis for Performance of the Mitigating Strategies Assessment with the Flood Hazard Information and Report for Recommendations 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ADAMS Accession No. ML16104A041
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Indian Point Nuclear Generating Units 2 & 3 Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA Mechanism Stillwater Waves/
Reevaluated Reference Elevation Run up Hazard I
Elevation 1-Storm Surge (continued)
I Combined Event with 150,000 cfs 18.9 ft 0.0 ft 18.9 ft Letter dated April 5, 2016, entitled Flow in Hudson River Coincident NGVD29 NGVD29 "Entergy Supplement to Basis for I
with PMSS, Including AWL and Performance of the Mitigating CWGW - Values Reported at Strategies Assessment with the Location East of U2 and U3 Flood Hazard Information and Report Turbine Buildings for Recommendations 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" ADAMS Accession No. ML16104A041 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.
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PKG ML16112A152; LTR: ML16112A172 (PUBLIC); ENCL1: ML16112A368 ENCL2: ML16112A356 (NON-PUBLIC)
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NAME VHall Slent Mlee CCook DATE 04/20/2016 04/21/2016 04/21/2016 04/21/2016 OFFICE NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME MShams VHall DATE 04/25/2016 04/25/2016