ML14147A379

Indian Point Units 1, 2, and 3 - Response to Request for Information Regarding Planned Audit for Near Term Task Force Recommendation 2.1: Flooding Hazard Reevaluation Report

ML14147A379
Person / Time
Site:	Indian Point
Issue date:	05/19/2014
From:	Ventosa J A Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-072
Download: ML14147A379 (10)

Text

S' EntergyEnteragy Nuclear NortheastIndian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 10511-0249Tel 914 254 6700John A VentosaSite Vice PresidentNL-14-072May 19, 2014U.S. Nuclear Regulatory CommissionATTN: Document Control Desk11545 Rockville Pike, TWFN-2F1Rockville, MD 20852-2738

REFERENCE:

Response to Request for Information Regarding Planned Audit for Near TermTask Force Recommendation 2.1: Flooding Hazard Reevaluation Report (TACNos. MF3313 and 3314)Indian Point Unit Numbers 1, 2, and 3Docket Nos. 50-247 and 50-286License Nos. DPR-26 and DPR-641. Entergy Letter (NL-1 3-156), Entergy's Required Response for NTTFRecommendation 2.1: Flooding -Hazard Reevaluation Report,Dated December 23, 20132. NRC letter, Request for Additional Information Regarding PlannedAudit for Near Term Task Force Recommendation 2.1: FloodingHazard Reevaluation Report (TAC Nos. MF3313 and 3314), datedMay 5, 2014

Dear Sir or Madam:

In Reference (1), Entergy Nuclear Operations, Inc. (Entergy) submitted a response to the Near TermTask Force Recommendation 2.1: Flooding Hazard Reevaluation Report in response to the NuclearRegulatory Commissions (NRC's) request for information pursuant to Title 10 of the Code of FederalRegulations 50.54(f). In reviewing the Flooding Hazard Reevaluation Report (FHRR), the NRCdetermined that additional information was required to complete the review and support a planned audit(Reference 2). The attachment to this letter provides a response to this request.

NL-14-072Docket Nos. 50-247 and 50-286Page 2 of 2There are no new commitments contained in this submittal. If you have any questions regarding thisconfirmation of receipt, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914)254-6710.I declare under penalty of perjury that the foregoing is true and correct. Executed on May .._, 2014.Respectfully,

Enclosure:

Response to NRC Request for Additional Information Regarding FHRRHard drive with electronic informationcc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORLMr. William M. Dean, Regional Administrator, NRC Region 1 w/o enclosureNRC Resident Inspectors Office w/o enclosureMr. John B. Rhodes, President and CEO, NYSERDA w/o enclosureMs. Bridget Frymire, New York State Dept. of Public Service w/o enclosure ATTACHMENT TO NL-14-072RESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING FHRRENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2, AND 3DOCKET NOS. 50-247, AND 50-286 NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 1 of 6NRC Request For Additional Information Regarding FHRRThe Nuclear Regulatory Commission (NRC) staff requests that the licensee provide the followingfigures and files used in the development of the Flooding Hazard Reevaluation Report (FHRR). Inputand output files are requested in their native file format (*.xlsx, *.out, etc.). Adobe Acrobat PortableDocument Files (PDFs) are not requested to be submitted unless specifically requested in that format.The staff also requests that the licensee provide clarification regarding the scope of, and inputparameters for, the integrated assessment.Local Intense Precipitation, Riverine Flooding, and Dam FailureNRC staff requests that the licensee provide the following figures and files used in the development ofthe FHRR Sections 3.1, 3.2, and 3.3.1. General* High-resolution figures from FHRR: 2.1-2, 2.1-3, 3.1-1, 3.4-52 (combined effect event)* Figures 3.2-1 & 3.3-1 with the Hudson River shown prominentlyResponse: The requested documents are in the "General Figures" folder of the enclosed electronicfiles. Note that Figure 3.1-1 is a FLO-2D output file and cannot be improved.2. Local Intense Precipitation Flood* Input files for FLO-2D modeling (in native FLO-2D format)* Minimum output: Summary.out file from FLO-2D modeling (in native FLO-2D format)* Sufficient output from FLO-2D modeling to review licensee's results independent of the FHRRand electronic reading room modeling (in native FLO-2D format):o MAXWSELEV.outo DEPTH.outo CHVOLUME.outo CHANMAX.outo CROSSMAX.outo HYCROSS.outo CROSSQ.outo HYCHAN.outo HYDROSTRUCT.outo VELTIMEC.outo VELTIMEFP.outo TIMDEP.outResponse: The requested documents are in the "RAI LIP" folder of the enclosed electronic files. Thebullet item 1, above, is the subdirectory "Cl Inputs for FLO 2D.zip", and bullet items 2 and 3 are insubdirectory "C2 Outputs for FLO 2D.zip."3. Riverine Probable Maximum Flood (PMF)* HEC-HMS input files (in native format)* HEC-RAS input file (in native format)* Calibration sets for HEC-HMS and HEC-RAS (in native format)

NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 2 of 6Sufficient output to review licensee's results independent of FHRR and electronic reading room(ERR) (in native format)o HEC-HMS *.DSSo HEC-HMS *.OUTo HEC-RAS *.O## -output fileso HEC-RAS *.R## -restart files (depending on how the initial conditions are specified)o HEC-RAS *.DSSResponse: The requested documents are in the "RAI PMF Hydrology" and "RAI PMF Hydraulics"folders of the enclosed electronic files. The bullet items 1 and sub-bullets 1 and 2 of item 4, are in the"RAI PMF Hydrology\PMF" directory. The bullet item 2 and sub-bullets 3, 4, and 5, are in "RAI PMFHydraulics" directory. Note that no restart files were used. Bullet item 3 is in the "RAI PMFHydrology\Calibration" and "RAI PMF Hydraulics" directories.4. Dam Breach Flood* HEC-HMS input files (in native format)" HEC-RAS input files (in native format)" Sufficient output to review licensee's results independent of FHRR and ERR (in native format)o HEC-HMS *.DSSo HEC-HMS *.OUTo HEC-RAS *.## -output fileso HEC-RAS *.R## -restart files (depending on how the initial conditions are specified)o HEC-RAS *.DSSResponse: The requested documents are in the" RAI Dam Failure" folder of the enclosed electronicfiles. The bullet 1 items are in the "RAI Dam Failure\HMS\IPECCascadeBreach = small dams nearIPEC" and the "RAI Dam Failure\HMS\IPECDamBreach = small dams near IPEC" subfolders. Thebullet 2 items are in the "RAI Dam Failure\HEC RAS" subfolder. Bullet 3, sub-bullets 1 and 2 are in the"RAI Dam Failure\HMS\IPECCascadeBreach = small dams near IPEC" subfolder. Bullet 3, sub-bullets 3, 4, and 5 are in the "RAI Dam Failure\HEC RAS" subfolder (no restart files were used).5. High resolution graphics from select files in the ERR:a. 38-9196956 (IPEC Probable Maximum Flood on Hudson River -Hydrology Calculation:topography file INDIANPOINTTOPO_PLAN.pdf as a large printed map or other largeformat.b. 32-9196321 (Flood Haz Re-eval-Local Intense Precipitation -Generated Flood Flow andElevations at IPEC; several problematic figures from Appendices A and B. In AppendixA, there are four figures: A-1 for maximum water surface elevations, A-2 for maximumdepth, A-3 for maximum velocity, and A-4 grid cell number. In Appendix B, there is onlyone figure, B-1 for the topographic survey.Response: The requested documents are in the "General Figures" and "LIP Figures" folders of theenclosed electronic files for items a. and b., respectively.Storm SurgeNRC staff requests that the licensee provide the following additional information related to theevaluation of storm surge:

NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 3 of 61. NRC staff requests that the licensee provide the ADCIRC models files -as listed below -thatwere applied in the development of probable maximum storm surge as stated in FHRR Section3.4.2.4. Input and output files are requested in their native file format (*.xlsx, *.out, etc.). PDFsof files are requested to not be submitted unless specifically requested in that format.# Files Description1 Fort. 13 ADCIRC Nodal Attribute File2 Fort.14 ADCIRC Grid and Boundary Information File3 Fort.15 ADCIRC Model Parameter and Periodic Boundary Condition File4 Fort.22 Wind input files developed for storms simulated in ADCIRC (discussed on4 __Fort.22 _page 3-35 of FHRR Report)5 Land class data Defines land use in mesh region6 Documentation Reports developed the document mesh development (changes from FEMAcoastal study mesh) and model validation and execution7 Storm Validation data Storm validation forcing files (wind/pressure, fort.22) and measurements for7_StormValidation dtcomparisonResponse: The requested documents are in the "ADCIRC Files" folder in the attached electronicstorage. There are separate subfolders for deterministic, probabilistic, and combined eventcalculations' input and output files. Model file directories each include a readme file with moreinformation on how to navigate the input/output files* Land class data is not a direct input to ADCIRC. Water friction against ocean bottom, surfacecanopy coefficient and surface directional effective roughness (which are parameters specifiedin the nodal attributes file (Fort. 13)) were derived from land cover data. The source of the landcover data used is discussed in the FEMA Land Cover Data Report (see "ADCIRC Files" andsubfolder "Documentation").* Changes from the FEMA coastal study mesh are described in the Probabilistic Storm SurgeCalculation (32-9213352-000), Section 2.4 under the heading "ADCIRC Grid Development andNodal Attribute Assignments"* For Documentation of FEMA coastal study, see "ADCIRC Files" and subfolder "Documentation".* For Storm Validation data, see "ADCIRC Files" and subfolder "Storm Validation" as per notesbelow.* ADCIRC Files\Storm Validation\Measurements = Text files from NOAA tide gages for Sandyand Irene NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 4 of 62. Provide input files (in native format) necessary to recreate two of the SLOSH and ADCIRCmodel results in Tables 3.4-10 and 3.4-12.Response: The requested documents are in the "SLOSH Files" and "ADCIRC Files" folders in theattached electronic storage. The input files to recreate the results in Tables 3.4-10 and 3.4-12 are inthe "SLOSH Files\ProbabilisticJPM" and "ADCIRC Files\Probabilistic Storm Surge Analysis"subdirectories, respectfully.3. NRC staff requests the licensee provide the information listed below related to the probabilisticevaluation of storm surge. In conjunction with the items below, staff requests that the licenseeinclude supporting information to assist the staff in identifying relevant information provided aspart of the RAI response such as provision of (1) indices describing the content of variousinput/output files and (2) field titles (e.g., column headers and row identifiers) for datasets andtables of information. Input and output files, as well as any supporting information, arerequested in their native file format (e.g., *.xlsx, *.txt, etc.). Tables of information are requestedto be provided in a format suitable for import into mathematical software packages (e.g.,delimited text files or spreadsheets). PDFs of files are not requested to be submitted unlessspecifically requested in that format.* Input data (e.g., HURDAT database) used to support development of probabilitydistributions for storm parameters and examination of parameter correlations." Computer codes and input/output files (e.g., files referenced in Section 6.6.2 and AppendixE of AREVA Document No. 32-9207390-000) used to process storm data, computeprobability distributions for storm parameters, and examine parameter correlations.* Tabulation of the events (including event dates) used to compute the omni-directional stormrate (as referenced in Section 6.2 of AREVA Document No. 32-9213352-000).* Tabulation of all storm parameter combinations and resulting surge elevations evaluatedusing SLOSH and (as applicable) ADCIRC (as referenced in Section 2.2 of AREVADocument No. 32-9213352-000).* Spreadsheet used for JPM calculations (as referenced in Appendix H of AREVA DocumentNo. 32-9213352-000).Response:The requested documents are in the "Probabilistic Storm Surge Documentation" and"Stage_Frequency_CurveCalculation" folders in the attached electronic storage. Item 1 is in the"Probabilistic Storm Surge Documentation" subfolder "HURDAT2" file "hurdat2-atlantic-1 851-2012.txt."Item 2 is in the "Probabilistic Storm Surge Documentation" subfolder "APP-E_32-9207390-000." Item 3is in the "Probabilistic Storm Surge Documentation" subfolder and the GIS file used to query theHURDAT storm tracks shapefile is in the "OmnidirectionalRate" subfolder. Item 4 is in the"StageFrequency_CurveCalculation" folder, Tab "JointProbabilities." Item 5 is in the"StageFrequency_CurveCalculation" folder tabs "SLOSH-Surge-Frequency" and "ADCIRC-Surge-Frequency."

NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 5 of 6Integrated AssessmentNRC staff requests that the licensee provide the following additional information related to the scope ofand input parameters for the integrated assessment:1. The NRC staff noted that the cover letter of the FHRR states the following: "Entergy will, inaccordance with Reference 1, Recommendation 2.1, Item 2, perform an integrated assessmentand submit to NRC an Integrated Assessment Report within two years." The licensee isrequested to clarify which flood hazard mechanisms will be included in the IntegratedAssessment.ResponseIndian Point Nuclear Generating Unit 2 & Unit 3 Integrated Assessment will include the following floodhazard mechanisms:" Local Intense Precipitation (LIP)* Flooding on Rivers and Streams* Dam Failure" Storm Surge* Combined Effects2.

Background:

The March 12, 2012, 50.54(f) letter, Enclosure 2, requests the licensee to performan integrated assessment of the plant's response to the reevaluated hazard if the reevaluatedflood hazard is not bounded by the current design basis. Flood scenario parameters from theflood hazard reevaluation serve as the input to the integrated assessment. To support efficientand effective evaluations under the integrated assessment, NRC staff will review flood scenarioparameters as part of the flood hazard reevaluation and document results of the review as partof the staff assessment of the flood hazard reevaluation.Request: The licensee is requested to provide the flood height and associated effects (asdefined in Section 9 of JLD-ISG-2012-05) that are not described in the flood hazard reevaluationreport for mechanisms that trigger an Integrated Assessment. This includes the followingquantified information for each mechanism (as applicable):* Flood height,* Wind waves and runup,* Hydrodynamic loading, including debris,* Effects caused by sediment deposition and erosion (e.g., flow velocities, scour),* Concurrent site conditions, including adverse weather,* Groundwater ingress, and* Other pertinent factorsResponseFlooding on Rivers and Streams flood height of 14.6 ft exceeds the CLB flood height of 12.7 ft howeverremains below site grade of 15.0 ft. (FHRR 3.2.3). Dam Failures flood height of 14.9 ft exceeds theCLB of 7.2 ft however does not does not exceed site grade of 15.0 ft. (FHRR4.1.3.2). Local IntensePrecipitation maximum flood heights are 19.0 ft in the Unit 2 transformer area and 19.2 ft in the Unit 3transformer area. Flood height in other areas vary as discussed in the FHRR section 3.1.2.1.3. Water NL-14-072Docket Nos. 50-247 and 50-286AttachmentPage 6 of 6depth and flow velocities do not result in debris or hydrodynamic loading. Storm Surge and combinedeffects flood height are 15.8 ft Stillwater, 16.3 ft wave crest and 17.7 ft runup. Refer to FHRR table 3.4-12 for the 2x1 06 annual exceedance probability flood heights. Hydrostatic loads, hydrodynamic loads,debris impact loads, wave loads are evaluated and included in the FHRR section 3.4.2.6.2 subsequentto table 3.4-2.3.

Background:

The March 12, 2012, 50.54(f) letter, Enclosure 2, requests the licensee to performan integrated assessment of the plant's response to the reevaluated hazard if the reevaluatedflood hazard is not bounded by the current design basis. Flood scenario parameters from theflood hazard reevaluation serve as the input to the integrated assessment. To support efficientand effective evaluations under the integrated assessment, the NRC staff will review floodscenario parameters as part of the flood hazard reevaluation and document results of the reviewas part of the staff assessment of the flood hazard reevaluation.Request: The licensee is requested to provide the applicable flood event duration parameters(see definition and Figure 6 of the Guidance for Performing an Integrated Assessment, JLD-ISG-2012-05) associated with mechanisms that trigger an integrated assessment using theresults of the flood hazard reevaluation. This includes, as applicable, the warning time the sitewill have to prepare for the event (e.g., the time between notification of an impending floodevent and arrival of floodwaters on site) and the period of time the site is inundated for themechanisms that are not bounded by the current design basis. The licensee is also requestedto provide the basis or source of information for the flood event duration, which may include adescription of relevant forecasting methods (e.g., products from local, regional, or nationalweather forecasting centers) and/or timing information derived from the hazard analysis.ResponseFor Local Intense Precipitation, the warning time is discussed under section 5.1.6 of the FHRR withtriggering from National Weather Service quantitative precipitation forecast (QPF). QPF providescontinental US rainfall as isohyets in varying increments. When QPF forecast for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rainfallexceed 5" (less than the LIP event), plant procedures trigger installation of pre-staged sandbags ineach transformer yard. From the notification until the sandbags in the transformer yard are in place isexpected to be no more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Duration of the site above the protected elevation is depicted inthe FHRR figures 3.1.2 and 3.1.3. From beginning of the LIP event until water is below the normal levelwhere sandbag protection is no longer needed is 6 hrs and inundation ends.Flood event duration parameters are for the combined event of Storm Surge, 25-year storm-relatedriver flood, antecedent 10% exceedance tide, and coincident wind-generated wave activity. Thehurricane will be forcast to reach the area of the site more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in advance. About 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />sprior to hurricane impact, preparation begins which is estimated to be completed in no more than 24hours. Flooding duration is less than 4 hrs. After that time, flood waters recede below site grate. Referto the FHRR section 5.0.

ENCLOSURE TO NL-14-072HARD DRIVE WITH ELECTRONIC INFORMATIONENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2, AND 3DOCKET NOS. 50-247, AND 50-28