ML16174A248

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Nuclear Regulatory Commission Report for the Audit of Entergy Nuclear Operations, Inc. Flood Hazard Reevaluation Report Submittal Relating to the Near-Term Task Force Recommendation 2.1-Flooding for Palisades Nuclear Plant
ML16174A248
Person / Time
Site: Palisades Entergy icon.png
Issue date: 08/03/2016
From: Robert Bernardo
Japan Lessons-Learned Division
To:
Entergy Nuclear Operations
Govan T, NRR/JLD, 415-6197
References
CAC MF6128
Download: ML16174A248 (17)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 3, 2016 Vice President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS, INCS. FLOOD HAZARD REEVALUATION REPORT SUBMITTAL RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR PALISADES NUCLEAR PLANT (CAC NO. MF6128)

Dear Sir or Madam:

By letter dated June 1, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15146A293), the U.S. Nuclear Regulatory Commission (NRC) informed you of the staffs plan to conduct a regulatory audit of Entergy Nuclear Operations, Inc.s (the licensees) Flood Hazard Reevaluation Report (FHRR) submittal related to the Near-Term Task Force Recommendation 2.1-Flooding for Palisades Nuclear Plant. The audit was intended to support the NRC staff review of the licensees FHRR and the subsequent issuance of a staff assessment.

The audit, conducted on November 9, 2015, was performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits, dated December 29, 2008 (ADAMS Accession No. ML082900195). The purpose of this letter is to provide you with the final audit report which summarizes and documents the NRCs regulatory audit of the licensees FHRR submittal.

If you have any questions, please contact me at (301) 415-2621 or by e-mail at Robert.Bernardo@nrc.gov.

Sincerely,

~e~ Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch Docket No. 50-255

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS, INCS. FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR PALISADES NUCLEAR PLANT BACKGROUND AND AUDIT BASIS By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a request for information to all power reactor licensees and holders of construction permits in active or deferred status, pursuant to Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.54(f), Conditions of license (hereafter referred to as the 50.54(f) letter). The request was issued in connection with implementing lessons-learned from the 2011 accident at the Fukushima Dai-ichi nuclear power plant, as documented in the Near-Term Task Forces review of insights from the Fukushima Dai-ichi accident. Recommendation 2.1 in that document recommended that the NRC staff issue orders to all licensees to reevaluate seismic and flooding for their sites against current NRC requirements and guidance. Subsequent staff requirements memoranda associated with SECY-11-0124 and SECY-11-0137, instructed the NRC staff to issue requests for information to licensees pursuant to 10 CFR 50.54(f).

By letter dated March 11, 2015, Entergy Nuclear Operations, Inc. (Entergy, the licensee) submitted its Flood Hazard Reevaluation Report (FHRR) for Palisades Nuclear Plant (Palisades) (Agencywide Documents Access and Management System Accession No. ML15106A681). The NRC is reviewing the aforementioned submittal and has completed a regulatory audit of the licensee to better understand the development of the submittal, identify any similarities/differences with past work completed, and ultimately aid in its review of the licensees FHRR. This audit summary was completed in accordance with the guidance set forth in NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits, dated December 29, 2008 (ADAMS Accession No. ML082900195).

AUDIT LOCATION AND DATES The audit was completed by document review via a webinar session in conjunction with the use of the licensees established electronic reading room (ERR) and teleconference on November 9, 2015.

Enclosure

AUDIT TEAM Title Team Member Organization Team Leader, NRR/JLD Vic Hall NRC Technical Monitor Laura Quinn- NRC Willingham Technical Staff Lyle Hibler NRC Technical Deputy Division Andy Campbell NRC Director Technical Branch Chief Aida Rivera-Varona NRC NRC Contractor Eugene Yan Argonne National Laboratory (ANL)

NRC Contractor Vinod Maht ANL NRC Contractor John Quinn ANL A list of the licensees participants can be found in Attachment 2.

DOCUMENTS AUDITED of this report contains a list which details the documents that were reviewed by the NRC staff, in part or in whole, as part of this audit. The documents were located in an ERR during the NRC staffs review. The documents, or portions thereof, that were used by the NRC staff as part of the technical analysis and/or as reference in the completion of the staff assessment, were submitted by the licensee and docketed, as necessary, to complete the staff assessment. These documents are identified in Table 1.

AUDIT ACTIVITIES In general, the audit activities consisted mainly of the following actions:

Review background information on site topography and geographical characteristics of the watershed.

Review site physical features and plant layout.

Understand the selection of important assumptions and parameters that would be the basis for evaluating the individual flood causing mechanisms described in the 50.54(f) letter.

Review model input/output files to computer analyses such as HEC-HMS and FLO-2D to have an understanding of how modeling assumptions were programmed and executed.

Table 1 summarizes specific technical topics (and resolution) of important items that were discussed and clarified during the audit. The items discussed in Table 1 may be referenced/mentioned in the staff assessment in more detail.

EXIT MEETING/BRIEFING On December 23, 2015, the NRC staff closed out the discussion of the technical topics described above.

Table 1: Palisades Information Needs - Audit/Post-Audit Summary INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED 1 All Flood-Causing Mechanisms - Comparison of The licensee stated that the CLB is defined in 10 CFR 54.3(a) as Reevaluated Flood Hazard with Current Design Basis applicable NRC requirements, licensee commitments, and plant specific design-basis information documented in the most recent

Background:

Recommendation 2.1 of the 50.54(f) letter provides final safety analysis report, for the purposes of the Palisades instructions for the Flood Hazard Reevaluation Report (FHRR). FHRR, current design basis (CDB) and current licensing basis Under Section 1, Hazard Reevaluation Report, Items c and d, (CLB) have the same meaning. The NRC staff will treat licensees are requested to perform: references to the the CLB as equivalent to the CDB in its review of

c. Comparison of current and reevaluated flood-causing the FHRR. As part of the licensees response, the licensee mechanisms at the site. Provide an assessment of the showed a modification of FHRR Table 4-1 where:

current design-basis flood elevation to the reevaluated flood elevation for each flood-causing mechanism. a) CLB was replaced with CDB in the table heading, Include how the findings from Enclosure 4 of this letter (i.e., Recommendation 2.3 flooding walkdowns) support b) storm surge CDB was clarified as 594.1 feet [mean sea level]

this determination. If the current design-basis flood MSL [Design basis flood level],

bounds the reevaluated hazard for all flood causing mechanisms, include how this finding was determined.

c) the difference in the Combined Effect Re-evaluated Flood

d. Interim evaluation and actions taken or planned to Height was modified to read flood levelare above the CDB address any higher flooding hazards relative to the flood protected elevation, and design basis, prior to completion of the integrated assessment described below, if necessary. d) the table note was modified: Note: Not evaluated indicates the this flood mechanism was not defined of addressed in current The Palisades FHRR provides a comparison of the reevaluated design-basis documents. As a result, no comparison can be flood hazards with the CLB instead of the current design-basis. made to reevaluated results.

Section 4.0 of the report summarizes this comparison.

The NRC staff concluded that the information provided by the Request: Clarify and where necessary correct the comparison of licensee in response to this information need request was the reevaluated flood hazard to the current design bases. sufficient.

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED 2 Local Intense Precipitation - Site Structures and Critical In response to this information need request, the licensee modified Locations figures provided that shows all the structures listed in Table 3-1 with their names, and representative grid elements for critical

Background:

In FHRR Figure 3-1 and Figures 5, 13, and 14 in locations and their identification numbers. The NRC staff Calculation No. 32-9226944-002 Palisades Nuclear Plant requested that these figures be submitted on the docket.

Flooding Hazard Re-evaluation - Local Intense Precipitation, the identification number for grid elements at locations identified The NRC staff concluded that the information provided by the as critical locations of the plant and the important site structures licensee in response to this information need request was are either illegible or not labeled to reference the locations for sufficient.

the purpose of identifying flooding water depths and elevation based on the reevaluation.

Request: FHRR Figure 3-1 (or selected figure from the LIP calculation package) should be modified or an additional similar figure should be provided that shows all the structures listed in Table 3-1 with their names, and representative grid elements for critical locations and their identification numbers.

3 Local Intense Precipitation - Boundary Condition of the The NRC staff reviewed the licensees updated input/output files FLO-2D Model along Lake Michigan for its revised model. The model was revised mainly to include a lake boundary along the western boundary of the FLO-2D model in

Background:

Section 2.2.2 of the FHRR reports the highest response. The main conclusion in licensees response is that recorded monthly mean elevation of Lake Michigan as 583.2 adding a lake boundary in FLO-2D model has a minimal effect on feet National Geodetic Vertical Datum of 1929 (NGVD29). This the water surface elevation (WSE) at critical locations. After the value was used as a fixed stage (water surface elevation) along NRC staff reviewed the input and output files and one independent the model extent of Lake Michigan as a boundary condition in run, and reached the same conclusion although the reservoir the FLO-2D model as a conservative approach. Section 2.2.2 in function used for lake boundary in FLO-2D may not be a correct Calculation No. 32-9226944-002, Palisades Nuclear Plant method. The main observations and NRC staffs results are as Flooding Hazard Re-evaluation - Local Intense Precipitation, follows:

indicates that the constant stage was assigned to the boundary grid elements using the reservoir water elevation feature in the

1) A reservoir function was used in the licensees FLO-2D model to FLO-2D model. The staff examined the grid elements at the create a reservoir with a specified lake level over a surface boundary of the model along the lake (the west edge of the depression zone along the western boundary of the model. The model) as well as the model input files, and didnt find that the reservoir was filled up to the specific lake level within the first time mean lake water elevation (583.2 feet NGVD29) is specified as step (0.1 hr) but was not maintained at the specified lake level for

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED a fixed reservoir water elevation in the model. The staff also the rest of simulation period (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). It dropped by about 2 ft reviewed the model results and found that the maximum water via the simulation period. Apparently, using the reservoir method surface elevation at the model boundary along the lake is less to define lake boundary in FLO-2D does not correctly reflect an than 581 feet NGVD29 suggesting that no constant lake level of actual lake boundary.

583.2 feet NGVD29 is maintained along the lake (the west boundary of the FLO-2D model) as the licensee described in the 2) To confirm the licensees conclusion, the NRC staff made an FHRR. independent run by assigning a constant lake stage along the western boundary of the model. Results from this model run also Request: Examine and verify that the model boundary along indicate that the WSE at the critical location has a minimal Lake Michigan in the FLO-2D model is assigned correctly using increase, which means that the WSE at the critical locations is the highest mean monthly lake elevation (583.2 feet NGVD29) insensitive to the model boundary of the Palisades FLO-2D model.

and provide either justification or correct FLO-2D input files if necessary. Based on this result, the NRC staff finds that the licensee does not need to update its model with a correct boundary setting method.

The NRC staff concluded that the information provided by the licensee in response to this information need request was sufficient.

4 Local Intense Precipitation - Vertical Datum Conversion The licensee stated that an elevation of 1.0 ft NAVD88 was used

Background:

The elevations in the FLO-2D model are used in to establish the datum conversion from NAVD88 to IGLD85 for the NGVD29 datum. The ground surface topography that was Lake Michigan elevations. The arbitrary elevation of 1.0 ft was developed from an aerial survey conducted in 2014 using Light used to simplify the establishment of the conversion factor. The Detection and Ranging (LiDAR) technology which uses licensee noted that a NOAA web-based program was used and NAVD88 datum, and the Lake Michigan level that was taken references to Appendix A in Calculation No. 32-9226944-002 from the National Oceanic and Atmospheric Administration Palisades Nuclear Plant Flooding Hazard Re-evaluation - Local (NOAA) Holland tide station uses IGLD85 datum. Section 1.1 Intenser Precipitation, to document that use. The licensee then and Appendix A in Calculation No. 32-9226944-002, Palisades stated that The resultant datum shift from NAVD88 to IGLD85 was Nuclear Plant Flooding Hazard Re-evaluation - Local Intense -0.09 or -0.30 ft based on an input elevation of 1.0 ft NAVD88.

Precipitation, notes that the web-based program, VERTCON (NGS, 2014a, and 2014b), results in the following relationship to The NRC staff concluded that the information provided by the convert NAVD88 and IGLD85 datums into NGVD29: licensee in response to this information need request was sufficient.

NGVD29 = NAVD88 + 0.48 ft & NAVD88 = IGLD85 + 0.30 ft

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED The staff performed the datum conversion independently using the same web-based program and tool to verify whether the conversion is correct. The staff verified that the ground surface topography elevation conversion from NAVD88 to NGVD29 is correct. For conversion of Michigan Lake level from IGLD85 to NAVD88, however, the staff found a different relationship for the Palisades site: NAVD88 = IGLD85 + 0.48.

The following shows the conversion on the NOAA website:

The difference between the two datums for the Lake Michigan at Palisades site is (177.6965 - 77.5518)

  • 3.28 = 0.47 feet (not 0.30 feet). The 177.55 meters (582.37 feet IGLD85) is the highest recorded monthly mean elevation of Lake Michigan, which is used in the FLO-2D model. The resulting vertical datum converted from 582.37 ft IGLD85 is 582.85 ft NAVD88 and 583.33 ft NGVD29.

Request: Examine and verify that the conversion between the vertical datums was done correctly and correct where needed in any references used for this conversion.

5 Local Intense Precipitation - Supercritical Flow The licensee stated that the duration in which the flow velocity exceeds the permissible velocity of rough asphalt of 12 feet per

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED

Background:

FLO-2D PRO model limits supercritical flow by second at cross section No. 2 was estimated to be 54 minutes.

reducing the velocity. Thus, the actual velocity at the place The licensee concluded that because the peak velocity exceeds where supercritical flow occurs would be higher than the velocity the suggested permissible velocity by only 30 percent and only for determined by the FLO-2D PRO model. The FHRR identifies a less than an hour, it is likely that if any erosion of asphalt occurred, roadway near the cooling tank that has supercritical flow (Figure it would be limited. The licensee described the location where, if 3-7) and shows a manually calculated flow velocity based on the erosion were to occur, it would happen at cross section 2 located maximum flow at that place. The calculated flow velocity at this near the toe of the cooling tower road that leads to the Cooling location is 15.6 feet per second, which is higher than Towers. The licensee stated that erosion at this locations would permissible velocity (i.e., 12 feet per second for rough asphalt not affect critical structures related to safety. The licensee (USACE, 1984)). Section 6.4 in Calculation No. 32-9226944- references Calculation No. 32-9226944-002, Palisades Nuclear 002, Palisades Nuclear Plant Flooding Hazard Re-evaluation - Plant Flooding Hazard Re-evaluation - Local Intense Local Intense Precipitation, assumes that this would not cause Precipitation, in their response.

the significant erosion due to the short duration of high flow rates. The NRC staff concluded that the information provided by the licensee in response to this information need request was Request: Provide the duration that speeds in excess of the sufficient.

permissible velocity last and a reference to support the conclusion that significant erosion would not be anticipated for that duration.

6 Local Intense Precipitation - CDB, CLB, and Safety-Related a) In response to this information need, the licensee stated Elevations that the CDB and CLB have the same definition and should be read as CDB where CLB is listed. However, through

Background:

The FHRR uses current design-basis (CDB: e.g., further discussion, the licensee agreed that the pump 594.1 ft NGVD29 and 594.4 ft NGVD29 in Section 2.2), current elevations and the CDB are not interchangeable, and are licensee basis (CLB: e.g., flood depth of 5 ft on the east side of written to mean list two different elevations. The response Service Building and 0.5 ft for the rest of powerblock area in to Information Need 1 for CDB and CLB resolves this info Sections 2.3.1.1 and 4.1.1 as well as Table 4-1), and safety- need.

related elevations (e.g., 594.4 ft NGVD29 in Section 5, Tables b) The licensee is going to defer providing additional 5.1 and 5.3).

information on associated effects to the MSA.

Request: c) This information need is resolved per Information Need 1 a) Clarify if CDB, CLB and safety-related elevations are and 6a and the NRC staff now has the CDB number to defined or used differently. complete the comparision with the reevaluated hazard.

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED b) Provide an explanation (in Table footnotes) or d) After discussions on Information Needs 1, 6a-c, the NRC justification for why the associated effect is bounded by staff determined that this information need was no longer CLB in Table 4-2, if the given effect has not been needed.

reevaluated (e.g., wind wave and runups).

c) Specify that each critical location is bounded or not bounded by a selected criterion, such as CDB, CLB, or safety-related elevation, in Table 4-3, which provides the maximum flood elevations and depths based on the FLO-2D results for all the critical locations identified by the licensee.

d) Provide either references or safety-related elevations (as indicated in Table 5-1) to support the evaluation and action for the last three critical locations in Table 5-2.

7 Local Intense Precipitation - Runoff Loss (Infiltration Loss) The licensee calculated the infiltration rates using a maximum value instead of minimum value (0.44 instead of 0.3) and states

Background:

Section 3.1.2.1.2 of the FHRR and Section 6.2.5 in that they are in the range of the SCS curve (though higher range).

Calculation No. 32-9226944-002, Palisades Nuclear Plant The NRC staff determined that the justification for the use of 0.44 Flooding Hazard Re-evaluation - Local Intense Precipitation, was reasonable, especially given the other conservativisms in the account for the infiltration loss rate in the model based on the model. The HMR-PMP used by the licensee embodies a great SCS curve number method. The estimation of the infiltration deal of conservatism such that compounding that conservatism loss rate has some level of uncertainty, even though the SCS with parameter conservatism is not required or necessary for the curve number method is commonly used. The guidance, R2.1 reviews. In the event that an analysis uses a sub-PMP event, NUREG/CR-7046 (NRC 2011), states that the infiltration loss additional parameter conservatism could be warranted; staff rates should be set to minimum recommended values (FERC, consider the HMR-based PMP to be primary source of 2001) for the drainage basin where estimated loss rates cannot conservatism. Because the LIP analysis for the Palisades site be validated. The estimated infiltration rate at the Palisades site used a HMR-based event and reasonable (but not necessarily the has not been validated. most conservative) parameter values, the NRC staff determined that infiltration rate value used is reasonable. The response Request: Evaluate the infiltration loss using the loss rates included that justification to establish the values reasonableness recommended by NRC (2011) or justify the infiltration loss used. using site specific information. Because the value that the licensee Confirm that loss rate obtained by using the SCS curve number used was in the range of the guidance that the licensee provided method in the model is the same or more conservative than the (at the upper end, however), the NRC staff concluded that loss rate obtained by using this NRC recommended values reasonable value rather than a conservative characterization of this suggested by FERC (2001). parameter was adequate for use in reevaluating the LIP

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED hazard. Considering the other conservatisms in the other LIP analysis, conservatisms do not need to be compounded for the purposes of the R2.1 site-specific justification.

The licensee referenced NRCS guidance (NRCS, 2004) in the determination of soil curve numbers, maximum potential retention, and initial abstraction, net constant losses (infiltration). The licensee referenced Table 8-8.1, Minimum Infiltration Rates for Hydrologic Soil Groups FERC (2001).

The NRC staff concluded that the information provided by the licensee in response to this information need request was sufficient.

8 Failure of Dams and Onsite Water Control/Storage Structures The licensee stated that there are no onsite water control/storage structures (i.e., onsite cooling or auxiliary water reservoirs and onsite

Background:

In the March 12, 2012, 50.54(f) letter, Enclosure 2, levees) located at or above SSCs important to safety. The licensee licensees are requested to perform an evaluation of flood waves referenced PLP FSAR, Figure 1-1, Sht 1 and Figure 1-1, Sht 2).

resulting from the breach of upstream dams, including domino-type or cascading dam failures. Water storage and water The NRC staff concluded that the information provided by the control structures (such as onsite cooling or auxiliary water licensee in response to this information need request was reservoirs and onsite levees) that may be located at or above sufficient.

structures, systems, and components (SSCs) important to safety should also be evaluated. Additional effects for earthen embankments, such as sediment, should also be considered.

Models and methods used to evaluate the dam failure and the resulting effects should be applicable to the type of failure mechanism and should be appropriately justified. Recent analyses completed by State and Federal agencies with appropriate jurisdiction for dams within the watershed may be used.

The staff did not find an evaluation in the FHRR, of onsite water storage and water control structures, nor a statement that none exist at the site. The staff also reviewed PLP-RPT-15-00009

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED Palisades Nuclear Plant Flooding Hazard Re-Evaluation -

Screening for Dam Failures as posted in the Palisades Electronic Reading Room and found no statement regarding onsite water control/storage structures within it.

Request: Provide a flood hazard evaluation of onsite water control/storage structures if any exist, or provide a statement that no such structures exist at the site.

9 Combined Effect - Flood Event Duration and Associated The licensees response include statements related to flood Effects duration and associate effects. These statements included:

Background:

FHRR Section 4.1 and Table 4-4 identifies several associated effects and indicated that the effects of sediment Calculations for hydrostatic, hydrodynamic, wave and debris loads deposition/erosion was not evaluated but determined to be are included in Sections 2.4 and 6.4 of the Palisades Combined bounded by the CLB. The FHRR also states that the flood Events Calculation (32-9226981-000 - Palisades Nuclear Plant event duration parameters were not evaluated. The staff Flooding Hazard Re-evaluation - Combined Events).

reviewed Calculation No. EA-EC5490-03, 32-9226981-000 -

Palisades Nuclear Plant Flooding Hazard Re-evaluation - Flood durations above sites grade was calculated at Combined Events and did not find this information. approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. The calculation was based on that eduratino of the surge hydrograph above the PLP site grade Request: Provide quantitative evaluation for the flood height and presented in Section 6.4 of the Palisades Combined Events associated effects (as defined in Section 9 of JLD-ISG-2012- Calculation, 32-9226981-000 - Palisades Nuclear Plant Flooding

05) for the combined event, or describe when the evaluation will Hazard Reevaluation - Combined Events.

be performed. Provide flood event duration parameters associated with the combined event, or describe when the parameters will be provided. The flood event duration Groundwater in the vicinity of the site is generally controlled by the parameters and associated effects with the combined event level of Lake Michigan (PLP, 2014). The surge hydrograph is include all parameters and effects listed in FHRR Table 4-4. above PLP site grade for approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. Permeability data from the FSAR indicates that the sandy lake deposits under the dunes have a slow percolation rate. Because of the relatively short duration of flooding and slow percolation rate for the underlying soil, short-term water level changes (i.e., storm surge) is unlikely to affect groundwater levels in the vicinity of the PLP.

INFO INFORMATION NEED DESCRIPTION ACTION (POST-AUDIT)

NEED Regarding sediment deposition and erosion, The coastline near PLP is not within a high risk erosion area as defined by the Michigan Department of Environmental Quality as shown in Appenix J (MIDEQ, 1996).

The NRC staff concluded that the information provided by the licensee in response to this information need request was sufficient.

ATTACHMENT 1 Palisades Audit Document List

1. FERC (Federal Energy Regulatory Commission). 2001. Engineering Guidelines for the Evaluation of Hydropower Projects, Chapter 8 - Determination of the Probable Maximum Flood. Washington, D. C.
2. AREVA. 2014. Palisades Nuclear Plant Flooding Hazard Re-Evaluation - Local Intense Precipitation. Document No. 32-9226944-002. January 30, 2014.
3. AREVA. 2014. Palisades Nuclear Plant Flooding Hazard Re-Evaluation - Combined Event.

Document No. 32-9226944-002. January 30, 2014.

4. NRCS. 2004. Chapter 9 hydrlogi9c Soil-Cover Complexes, Part 630 hydrology, National Engineering Handbook.

ATTACHMENT 2 List of Entergy Audit Participants Name Organization

1. Don Bentley Entergy
2. Gregory Hubers Entergy
3. Barbara Owens Entergy
4. Cindy Fasano AREVA
5. Stacy Thomson AREVA
6. Chad Cox GZA
7. Bryant Furtado GZA
8. David Leone GZA

If you have any questions, please contact me at (301) 415-2621 or by e-mail at Robert.Bernardo@nrc.gov.

Sincerely,

/RA/

Robert Bernardo, Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch Docket No. 50-255

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC JLD R/F RidsNRRJLD Resource TGovan, NRR LQuinn-Willingham, NRO RidsNroDsea Resource RidsNrrDorlLpl4-2 Resource RidsNrrDorl Resource RidsNrrPMFitzPatrick Resource RidsRgn3MailCenter Resource RidsNrrLASLent RidsOgcMailCenter Resource RidsOpaMail Resource RidsAcrsAcnw_MailCtr Resource CCook, NRO ARivera-Varona, NRO KErwin, NRO ACampbell, NRO RRivera-Lugo, NRO LHibler, NRO BHarvey, NRO MShams, NRR GBowman, NRR ADAMS Accession No.: ML16174A248 *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/JHMB/LA NRO/DSEA/RHM2/TR* NRO/DSEA/RHM2/TM NAME TGovan SLent LHibler RRivera-Lugo DATE 06/24/2016 06/22/2016 07/29/2016 07/29/2016 OFFICE NRO/DSEA/RHM2/BC NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME ARivera-Varona GBowman RBernardo DATE 07/13/2016 06/26/2016 08/03/2016 OFFICAL RECORD COPY