ML16152A116

NRC Report for the Audit of R.E. Ginna Nuclear Power Plant, Llc'S Flood Hazard Reevaluation Report Submittals Relating to the Near-Term Task Force Recommendation 2.1-Flooding for R.E. Ginna Nuclear Power Plant (CAC No. MF6098)

ML16152A116
Person / Time
Site:	Ginna
Issue date:	06/09/2016
From:	Tekia Govan Japan Lessons-Learned Division
To:	Bryan Hanson Exelon Generation Co
Govan T, NRR/JLD, 415-6197
References
CAC MF6098
Download: ML16152A116 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 June 9, 2016 SUBJECT: NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF R.E. GINNA NUCLEAR POWER PLANT, LLC'S FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR R.E. GINNA NUCLEAR POWER PLANT (CAC NO. MF6098) Dear Mr. Hanson: By letter dated June 10, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15148A163), the U.S. Nuclear Regulatory Commission (NRC) informed you of the staff's plan to conduct a regulatory audit of R. E. Ginna Nuclear Power Plant, LLC's (the licensee) Flood Hazard Reevaluation Report (FHRR) submittal related to the Near-Term Task Force Recommendation 2.1-Flooding for R. E. Ginna Nuclear Power Plant. The audit was intended to support the NRC staff review of the licensee's FHRR and the subsequent issuance of a staff assessment. The audit was conducted on August 27, 2015, and was performed consistent with NRC Office of Nuclear Reactor Regulation, Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008, (ADAMS Accession No. ML082900195). Therefore, the purpose of this letter is to provide you with the final audit report which summarizes and documents the NRC's regulatory audit of the licensee's FHRR submittal.

B. Hanson -2-If you have any questions, please contact me at (301) 415-6197 or by e-mail at Tekia.Govan@nrc.gov. Docket No. 50-244 Enclosure: Audit Report cc w/encl: Distribution via Listserv Sincerely, Tekia V. Govan, Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF RE. GINNA NUCLEAR POWER PLANT, LLC'S FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR RE. GINNA NUCLEAR POWER 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 licenses" (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 Force 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 Commission Papers 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 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15072A008), R E. Ginna Nuclear Power Plant, LLC (the licensee) submitted its Flood Hazard Reevaluation Reports (FHRRs) for RE. Ginna Nuclear Power Plant (Ginna). 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 licensee's 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 DA TES The audit was completed by document review via a webinar session in conjunction with the use of the licensee's established electronic reading room (ERR) and teleconference on August 27, 2015, from 1 :00 pm to 4:00 pm. Enclosure

-2 -AUDIT TEAM Title Team Member Organization Team Leader, NRR/JLD Tekia Govan NRC Technical Branch Chief Aida Rivera-Varona NRC Technical Manager Laura Quinn-Willingham NRC Technical Staff Lyle Hibler NRC Technical Deputy Division Director Andy Campbell NRC Technical Contractor Eugene Yan Argonne National Laboratory (ANL) Technical Contractor Vinod Mahat ANL Technical Contractor John Quinn ANL A list of the Licensee's participants can be found in Attachment 2. DOCUMENTS AUDITED Attachment 1 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 the licensee's ERR during the NRC staff's review. The documents, or portions thereof, that were used by the staff as part of the technical analysis and/or will be used as reference in the completion of the staff assessment, were submitted by the licensee and docketed, as necessary, to complete the development of 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 FL0-2D 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.

-3 -Table 1: Technical Topics of Discussion Info Need Information Need Description Post-Audit Status No. 1 All Flood-Causing Mechanisms -In response to this information need the Comparison of Reevaluated Flood licensee referenced the FHRR, the Flood Hazard with Current Design-Basis Walk down Report, and Updated Final Recommendation 2.1 of the 50.54(f) letter Safety Analysis Report (UFSAR) provides instructions for developing the Revision 23. The licensee described that Flood Hazard Reevaluation Report (FHRR). for the purposes of the FHRR, the Under Section 1, Hazard Reevaluation "current licensing basis" and "current Report, Items c and d, licensees are design-basis" were considered requested to perform: interchangeable. c. Comparison of current and The NRC staff concluded that the reevaluated flood-causing information provided by the licensee was mechanisms at the site. Provide an sufficient to address the information need assessment of the current design-request. basis flood elevation to the reevaluated flood elevation for each The NRC staff requested this response flood-causing mechanism. Include be placed on the docket to support the how the findings from Enclosure 4 of development of the Ginna staff the 50.54(f) letter (i.e., assessment. Recommendation 2.3 flooding walk downs) support this determination. If the current design-basis flood bounds the reevaluated hazard for all flood-causing mechanisms, include how this finding was determined. d. Interim evaluation and actions taken or planned to address any higher flooding hazards relative to the design-basis, prior to completion of the integrated assessment described below, if necessary. The Ginna FHRR provides a comparison of the reevaluated flood hazards with the current licensing basis (CLB) instead of the current design-basis (COB). Section 3.0 of the report summarizes of this comparison.

-4 -Info Need Information Need Description Post-Audit Status No. The licensee is requested to clarify, and where necessary correct, the comparison of the reevaluated flood hazard to the current design bases. 2 All Flood-Causing Mechanisms -In response to this information need the Location of Site Features licensee provided, in the ERR, a revised The FHRR for the Ginna site includes figure with the requested locations several figures that show some of the site added. locations that are mentioned, but lacks annotations or figures that show all of the The NRC staff concluded that the site locations that are referred to in the information provided by the licensee was FHRR clearly. In FHRR Figures 2.1-2, 2.1-sufficient to address the information need 3, 2.2-11, 2.2-12, 2.2-13, for example, the request. cell identification number are not sufficiently clear to reference the location of these site The NRC staff requested this response locations for the purpose consistent with this be placed on the docket to support the information need. development of the Ginna staff assessment. Figure 1.2-1 could be modified or the licensee could provide additional similar figures to illustrate the location of the structures listed in Table 1 to Table 4 of Enclosure 1 "Flood Hazard Reevaluation Tables for Flood-Causing Mechanism and Combined-Effects Floods Not Bound by the Reevaluated Hazard", reactor containment, turbine building, control building, screen house, and diesel generator buildings, auxiliary building, All-volatile, standby auxiliary feedwater building, standby auxiliary feedwater building annex, canister preparation building, contaminated storage building, and the ("shoreline" or "stone" revetment), Ginna Access Road (and culverts) and Driveway Bridge. The licensee is requested to describe the buildings and site feature locations discussed in the FHRR.

-5 -Info Need Information Need Description Post-Audit Status No. 3 Local Intense In response to this information need, the In the FHRR, the Local Intense Precipitation licensee re-ran the model with the correct (LIP) analysis was reported to use a 6-hour 6-hour PMP and found only a small probable maximum precipitation (PMP) in increase in flows from the model run the FL0-20 model. The licensee indicated based on an incorrect 6-hour PMP. The that the 6-hour PMP was derived from the licensee reported that LIP peak Hydrometeorological Report (HMR) 51 PMP elevations, maximum flow depth, and for 10 square miles and a 6-hour duration maximum flow velocity were unchanged (HMR 51 Figure 18). Based on HMR 51 from the reporting level of accuracy (0.1 Figure 18, referenced by the licensee, as feet (ft) and 0.1 feet/second (ft/s) for shown on page A-3 of calculation package these parameters for the structure 32-9190272-000, the HMR 51 value is 23.5 locations reported in FHRR Table 3-1. inches. However, the PMP input in the Therefore, even though the incorrect FL0-20 is 22.4 inches and the FHRR also PMP values were inadvertently used in indicates that 22.4 inches was used for PMP FL0-20, the difference was insignificant. in LIP analysis. Clarify the difference between 6-hour PMP The NRC staff concluded that the information provided by the licensee was values of 22.4 inches used in the FL0-20 model and 23.5 inches from HMR 51. sufficient to address the information need request. The NRC staff requested this response be placed on the docket to support the development of the Ginna staff assessment.

-6 -4 Stream and River Flooding In response to this information need, the FL0-20 simulated water depth due to licensee provided an initial response stream flooding. The staff evaluated which described the use of the 2006 Manning's n values assigned in the FL0-20 National Land Cover Data, the FL0-20 model and noticed that several cells' n reference manual, and their engineering values for shrubs or grass are considered judgement to assign roughness very low, i.e., 0.08. These areas (see coefficient across the site. The licensee figure) are along the pathway that slowdown stated that the values were the stream overflow from southwest to conservatively selected. The NRC staff northeast based on the velocity vector plot. requested a more detailed discussion and the licensee subsequently provided a Describe the justification of n values supplemental response via letter dated assigned for vegetation areas surrounding September 30, 2015, "Response to NRC the plant, especially areas near the plant Audit Review Request for Additional and structures. Information Regarding the Fukushima Lessons Learned -Flood Hazard Reevaluation Report" (ADAMS Accession No. ML 15273A 138). The licensee's supplemental response, stated that "the Manning's n-values assigned in the FL0-20 model are judged to be appropriate for the existing land cover and modeled probable maximum flood (PMF) flow depths with a reasonable degree of conservatism." The NRC staff noted that the roughness parameters selected by the licensee were not the minimum values, but rather were best-estimated based on the ground cover of the area modeled. The licensee described their rationale for selecting the roughness values during the audit held on August 27, 2015. Therefore, the staff independently evaluated the roughness using independently-estimated best-estimate values as part of a sensitivity test. The staff's results produced values that were higher than the licensee's results. However, the staff's sensitivity results indicated that the water-level elevations at all buildings locations that were determined as bounded by the COB in the licensee's analysis remained below the CBD except for one building (the

-7 -Standby Auxiliary Feedwater Pump Building). At this one building (the Standby Auxiliary Feedwater Pump Building), the staff's results were approximately 3-inches higher than the COB, which is within the model error and within the range of accuracy of the LIP analysis. Therefore, NRC staff concluded that the information provided by the licensee was sufficient to address the information need request.

-8 -Info Need Information Need Description Post-Audit Status No. 5 Stream and River Flooding In response to this information need, the NUREG/CR-7046 Section 5.4 "Accounting licensee explained that the reevaluated for Uncertainty in Input and Model hazard was based on a "mid-loaded" Parameters for Estimation of Design-Basis PMP event and tested the sensitivity of Flood Hazards", page 5-6 states: the resultant flood flows using an "end "Design-basis flood analysis should loaded" PMP event. The licensee stated that NOAA guidance (HMR-52) does not carefully describe and quantify the recommend a "front loaded" 72-hour sources of uncertainty by PMP distribution. The licensee appropriately selected sensitivity compared the results for both the mid-analyses. The design-basis flood loaded and end-loaded PMP distributions hazards should then be selected and showed that the HEC-HMS modeled carefully from the predicted range of peak PMF flow difference was values of these hazard metrics (e.g., insignificant. depth of flow, density of flow, velocity of flow, and duration of The NRC staff concluded that the inundation) to ensure that the most information provided by the licensee was adverse conditions are accounted sufficient to address the information need for." request. The FHRR presents stream PMF for a 72-hour PMP with center temporal distribution. Other temporal distributions of PMP event (e.g. front or end temporal could result in different peak flows, which might not be bounded by the licensee's PMF value. Provide justification that the PMF analysis presented in the FHRR is bounding_ in terms of peak flow. This justification can include sensitivity analysis of various PMP temporal distributions (e.g., other temporal distributions in addition to a center temporal distribution). The evaluations could identify potentially bounding scenarios with respect to peak flow.

-9 -Info Need Information Need Description Post-Audit Status No. In response to this information need, 6 Storm Surge Datum Conversions the licensee stated that FHRR Table 1.1-FHRR Table 1.1-1 states that 0. 7 ft should 1 contained typographical errors and that be added to elevations given with respect to the correct datum conversion from International Great Lakes Datum of 1985 IGLD85 to NGVD29 is 0.62 ft. The (IGLD85) to get elevations with respect to licensee provided an update to FHRR National Geodetic Vertical Datum of 1929 Table 1.1-1 as Table 6-1 in the response (NGDV29). The FHRR states the . . located in the licensee's ERR. antecedent water level in Lake Ontario 1s 247.3 ft IGLD85 (Section 2.4.2.3) and then The licensee's response referenced the states the PMSS height is 3.2 ft (Section FHRR and AREVA Document No. 32-2.4.3) and the predicted Probable Maximum 9190277-000. Surge (PMS) elevation is 251.1 ft NGVD29 and 250.5 ft IGLD85; a 0.6 ft difference The NRC staff concluded that the which is inconsistent with FHRR Table 1.1-information provided by the licensee was 1. sufficient to address the information need Explain the discrepancy introdu.ced when request. converting between datums which may be The NRC staff requested this response attributed to rounding, and if necessary, be placed on the docket to support the provide the correct value. development of the Ginna staff assessment.

-10 -Info Need Information Need Description Post-Audit Status No. 7 Stream and River Flooding In response to this information need, the The FHRR presents that the peak flow from licensee placed two documents in its flood re-evaluation for PMF is 28,460 ERR (NUS, 1981; NRC, 1982) and the (rounded to 28,500) cubic feet per second staff has reviewed these documents for (cfs), which is about three-fourths of the the purposes of understanding the peak flow (38,700 cfs) estimated in the methods and model parameters used to previous study in 1982. In the FHRR, develop past PMF flood hazards. Section 2.2.3 explains that the discrepancy is mainly caused by dividing the watershed The NRC staff determined that the into two contributory watersheds (Deer previous PMF peak flow value was not Creek and Mill Creek) in the re-evaluation flow model, which results in a decreased used as the COB flow and therefore, composite peak flow due to the difference in comparison to the previous PMF peak flow is not needed for the FHRR review. peak time between two peak flows. The The model parameter values that were staff found that the peak flow for re-used to determine the reevaluated PMF evaluation PMF is 20,530 cfs for Mill Creek peak flow and associated flood hazards and 8, 140 cfs for Deer Creek. The sum of were discussed in the licensee's two peak flows without considering response and the NRC staff concluded difference in peak timing is 28,670 cfs, that the information provided by the which is much less than the previous flow licensee was sufficient to address the study. information need request. Justify why the reevaluated PMF is The NRC staff requested this response conservative and bounding in terms of peak be placed on the docket to support the flow. If necessary, provide a comparison development of the Ginna staff between the reevaluation PMF model and the previous PMF model. assessment. 8 Combined Effects In response to this information need, the Wind wave effects are reported in the FHRR licensee referenced the FHRR, AREVA for Deer Creek under the PMF condition Document No. 32-9190280-000 and based on the use of CEDAS-ACES v4.03 McMahan (2012) (topographic software as documented in Appendix I of information drawing). The response Document 32-9190280-000. The described the estimation of the topographical parameters used to estimate parameters necessary for a conservative the wind wave effects are not completely evaluation of the maximum wave effects described in the FHRR or other docketed resulting from the combined event material. For example, the COT AN of the including Deer Creek PMF and wind-nearshore slope is set to 40 without wave effects. reference to site information. This is information is needed for staff's review and The NRC staff concluded that the documentation within the staff assessment. information provided by the licensee was The combined effect named H.4.1 scenario

-11 -Info Need Information Need Description Post-Audit Status No. considers the Deer Creek PMF plus wave sufficient to address the information need action due to a 2-year return period request. winds. Document No. 312-9190280 (Enclosure 3 of the FHRR submittal) provides CEDAS-ACES output for one location in Appendix I. Provide the basis for the determination that the maximum runup is represented in Appendix I. Identify other locations that were examined or how this particular set of CEDAS-ACES input values were determined to define the maximum. For each location examined, include a descriptive site feature (e.g., Turbine Building, Auxiliary Building), FL0-2D cell identification number, associated grid cell elevation, maximum water surface elevation, maximum flow depths, and ground slope used as CEDAS-ACES input and the maximum elevation including wave runup. The FHRR states that at the southern edge of the powerblock the maximum runup is 0.9 ft; this appears to be associated with FL0-2D cell 7885, which has a PMF max elevation of 275.0 ft MSL (or NGVD29). Explain where the combined event maximum water surface elevation, presumably 275.9 ft NGVD29, is included as the maximum combined effect wave runup elevation and incorporated into the FHRR conclusions. 9 Flood Event Duration Parameters In response to this information need The March 12, 2012, 50.54(f) letter, request, the licensee indicated that for Enclosure 2, requests the licensee to parameters for which no numerical perform an Integrated Assessment of the values were provided in the FHRR or plant's response to the reevaluated hazard if supplemental letters, the licensee will the reevaluated flood hazard is not bounded develop flood event duration parameters by the current design-basis. Flood scenario and applicable flood associated effects parameters from the flood hazard as part of the MSA as discussed in the reevaluation serve as the input to the latest revision to NEl-12-06, Appendix G Integrated Assessment. To support efficient (see COMSECY-15-0019). The staff will and effective evaluations under the evaluate the flood event duration

-12 -Info Need Information Need Description Post-Audit Status No. Integrated Assessment, staff will review parameters (including warning time and flood scenario parameters as part of the period of inundation) during its review of flood hazard reevaluation and document the MSA. The staff will include the results of the review as part of the staff parameters that are provided and assessment of the flood hazard appropriately note ones that were not reevaluation. The information is also provided in the staff assessment. necessary for conducting the MSA in accordance with NEI 12-06 App G. The licensee provided a docketed response (ADAMS Accession No. Provide the applicable flood event duration ML 15273A 138) including flood water parameters (see definition and Figure 6 of surface elevation at key locations over the Guidance for Performing an Integrated time (LIP: Figures 9-1 to 9-9; Combined Assessment, Japan Lessons-Learned Effect Flood: Figures 9-10 to 9-19). The Division (JLD) Interim Staff Guigance (ISG) NRC staff examinations of these figures JLD-ISG-2012-05) associated with would allow for its review of some flood mechanisms that trigger an Integrated event duration parameters (duration of Assessment using the results of the flood inundation and recession times). hazard reevaluation. This includes (as applicable) the warning time the site will The licensee stated in the letter response have to prepare for the event (e.g., the time (and refers to the FHRR) that the river between notification of an impending flood flood protection measures are triggered event and arrival of floodwaters on site) and based on the flood levels at the Driveway the period of time the site is inundated for Bridge. The licensee stated that there is a the mechanisms that are not bounded by greater than 35-hour delay for the the current design basis. Provide the basis combined effect flood at the Driveway or source of information for the flood event Bridge and flooding near plant structures. duration, which may include a description of relevant forecasting methods (e.g., products The also licensee stated in the letter from local, regional, or national weather response that "detailed evaluation of forecasting centers) and/or timing timing required for potential flood information derived from the hazard mitigation strategies will be addressed as analysis. The FHRR does state a PMF part of the Integrated Assessment phase flood duration (6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) but other of work." parameters are lacking. The NRC staff concluded that the In Section 3.3 of the FHRR, LIP, flooding on information provided by the licensee was rivers and streams, and two combined-sufficient to address the information need effects flood scenarios were stated to request. exceed the CLB. 10 Flood Height and Associated Effects -In response to this information need, the Flood scenario parameters from the flood hazard reevaluation serve as the input to licensee indicated that for parameters for the Integrated Assessment. To support which no numerical value is provided in the FHRR, the licensee will develop flood

-13 -Info Need Information Need Description Post-Audit Status No. efficient and effective evaluations under the event duration parameters and applicable Integrated Assessment, the staff will review flood associated effects as part of the flood scenario parameters as part of the MSA, as discussed in the latest revision 50.54(f) letter, FHHR and document results to NEl-12-06, Appendix G (see of the review as part of the staff's COMSECY-15-0019). The NRC staff will assessment. The March 12, 2012, 50.54(f) evaluate the flood-related associated letter, Enclosure 2, requests that the effects during its review of the MSA. The licensee perform an Integrated Assessment staff will include the parameters that are of the plant's response to the reevaluated provided and appropriately note ones that hazard if the reevaluated flood hazard is not were not provided in the staff bounded by the current design basis. This assessment. information is also necessary for conducting the MSA in accordance with NEI 12-06 App The response references the FHRR, G. UFSAR Revision 23, FL0-20 2012 documentation, AREVA Document No. Provide the flood height and associated 32-91902080-000, and USACE 1984 effects (as defined in Section 9 of JLD-ISG-erosion control guidance. 2012-05) that are not described in the FHRR for mechanisms that trigger an The NRC staff concluded that the Integrated Assessment. This includes the information provided by the licensee was following quantified information for each sufficient to address the information need mechanism (as applicable): request.

• Wind waves and run up, The NRC staff requested this response

• Hydrodynamic loading, including debris, from the ERR to be placed on the docket

• Effects caused by sediment deposition to support the development of the Ginna and erosion (e.g., flow velocities, scour), staff assessment.

• Concurrent site conditions, including adverse weather,

• Groundwater ingress The FHRR indicated that the Integrated Assessment will include LIP, flooding on rivers and streams, and two combined-effects flood scenarios. For these mechanisms or their combination not all the associated effects listed above were stated in the FHRR. Provide the analysis used to support the conclusions for each associated effect. Provide analysis of the associated effects for these flood-causing mechanisms that will be included in the Integrated

-14 -Info Need Information Need Description Post-Audit Status No. Assessment or a clear justification of why these effects are excluded. During the audit the licensee committed to provide all requested audit responses on the docket. All responses were received by the NRC by letter dated September 30, 2015, "Response to NRC Audit Review Request for Additional Information Regarding the Fukushima Lessons Learned Flood Hazard Reevaluation Report" (ADAMS Accession No. ML 15273A 138). EXIT MEETING/BRIEFING On October 30, 2015, the NRC staff closed out the discussion of the technical topics described above. There are no outstanding information needs remaining as a result of this audit.

ATTACHMENT 1 ERR Reference List 1. AREVA. 2014. Flood Hazard Re-evaluation -Local Intense Precipitation (LIP) -Generated Flow and Elevations at R. E. Ginna Nuclear Power Plant. Document Number 32-9190271-000. 2. AREVA. 2013. Flood Hazard Re-evaluation -Probable Maximum Precipitation (PMP) for Streams near R. E. Ginna Nuclear Power Plant. Document Number 32-9190272-000. 3. AREVA. 2013. Flood Hazard Re-evaluation -Probable Maximum Flood Flow in Streams near R. E. Ginna Nuclear Power Plant. Document Number 32-9190273-000. 4. AREVA. 2013. Flood Hazard Re-evaluation -Probable Maximum Flood Elevations in Streams near R. E. Ginna Nuclear Power Plant. Document Number 32-9190274-000. 5. AREVA. 2013. Flood Hazard Re-evaluation -Wind Generated Waves near R. E. Ginna Nuclear Power Plant. Document Number 32-9190279-000. 6. AREVA. 2013. Flood Hazard Re-evaluation -Combined Events Flood Analysis for R. E. Ginna Nuclear Power Plant. Document Number 32-9190280-000. 7. NUS Corporation. 1981. Ginna Station Design Basis Flooding Study for Rochester Gas and Electric Corporation. August 1981. Rockville Md. (Attachment letter dated August 18, 1981 from J.E. Maier to NRC (attn.: D. M. Crutchfield) Subject: SEP Topics 11-3.A, 11-3.B, 11-3.B.1, 111-3.A R. E. Ginna Nuclear Power Plant Docket No. 50-244. 8. NRC. 1982. Letter dated May 27, 1982 from D. R. Crutchfield (NRC) to D. M. Maier. Subject: Ginna Nuclear Power Plant -Final Evaluation of SPE Topics 11-3.A, 11-3.b, 11-3.C, and 11-4.D. May 27, 1982. 9. Ginna. 2014. RE. Ginna Nuclear Power Plant. Updated Final Safety Analysis Report. Revision 25. November 19, 2014.

ATTACHMENT 2 List of R.E Ginna Nuclear Power Plant, LLC Participants Name Organization 1. Chuck Behrend Exelon 2. Vined Aggarwal Exelon 3. Joseph Bellini Exelon 4. David Distel Exelon 5. George Wrobel Exelon 6. John Traynor Exelon 7. Cynthia Fasano AREVA 8. Dan Brown AREVA 9. David Leone GZA GeoEnvironmental, Inc. (GZA) 10. Ken Hunu GZA B. Hanson -2-If you have any questions, please contact me at (301) 415-6197 or by e-mail at Tekia.Govan@nrc.gov. Docket No. 50-244 Enclosure: Audit Report Sincerely, IRA/ Tekia V. Govan, Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch cc w/encl: Distribution via Listserv DISTRIBUTION: PUBLIC JLD R/F MShams, NRR ARivera, NRO CCook, NRO LHibler, NRO RidsNRRJLD Resource MFranovich, NRR ACampbell, NRO JBowen, NRR RidsNrrPMGinna Resource KErwin, NRO RidsNrrDorl1-1 Resource LQuinn-Willingham, NRO ADAMS Accession No.: ML 16152A116 *via e-mail OFFICE NRR/JLD/JHMB/PM NRR/JLD/JHMB/LA NRO/DSEA/RHMB 1 /TR NRO/DSEA/RHMB1/TM NAME TGovan Slent LHibler* LQuinn-WillinQham* DATE 05/31/2016 05/31/2016 06/09/2016 06/08/2016 OFFICE NRO/DSEA/RHM2/BC NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME ARivera-Varona MShams TGovan DATE 06/07/2016 06/03/2016 06/09/2016 OFFICAL RECORD COPY