ML15300A236

Nuclear Regulatory Commission Report for the Audit of Indiana Michigan Power Company'S Flood Hazard Reevaluation Report Submittals Relating to the Near-Term Task Force Recommendation 2.1-Flooding for Donald C. Cook Nuclear Plants Units 1 an

ML15300A236
Person / Time
Site:	Cook
Issue date:	11/03/2015
From:	Govan T V Japan Lessons-Learned Division
To:	Weber L J Indiana Michigan Power Co
Govan, Tekia, NRR/JLD 415-6197
References
TAC MF6096, TAC MF6097
Download: ML15300A236 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106 November 3, 2015

SUBJECT:

NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF INDIANA MICHIGAN POWER COMPANY'S FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MF6096 AND MF6097)

Dear Mr. Weber:

By letter dated June 4, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15152A083),

the U.S. Nuclear Regulatory Commission (NRC) informed you of the staff's plan to conduct a regulatory audit of Indiana Michigan Power Company's (the licensee)

Flood Hazard Reevaluation Report (FHRR) submittal related to the Near-Term Task Force Recommendation 2.1-Flooding for Donald C. Cook Nuclear Plant, Units 1 and 2. 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 October 14, 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.

L. Weber If you have any questions, please contact me at (301) 415-6197 or by e-mail at Tekia.Govan@nrc.gov.

Docket Nos. 50-315 and 50-316

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely, Jb°'( J1C--Tekia V. Govan, Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch NUCLEAR REGULATORY COMMISSION AUDIT REPORT FOR THE AUDIT OF INDIANA MICHIGAN POWER COMPANY'S FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR DONALD C. COOK NUCLEAR PLANT. UNITS 1 AND 2 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 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 6, 2015, Indiana Michigan Power Company (the licensee) submitted its Flood Hazard Reevaluation Reports (FHRRs) for Donald C. Cook Nuclear Plants, Units 1 and 2 (D.C. Cook) ((Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15069A334).

The NRC is in the process of 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 licensees' FHRR. This audit summary is being 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 licensee's established electronic reading room (ERR) and teleconference on October 14, 2015, from 1 :OOpm to 2:00pm. Enclosure AUDIT TEAM Title Team Member Organization Team Leader, NRR/JLD Tekia Govan NRC Technical Monitor Richard Rivera-Lugo NRC Technical Staff Peter Chaput NRC Technical Staff Kevin Quinlan NRC Technical Staff Lvle Hibler NRC 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 an electronic reading room 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 as reference in the completion of the staff assessment, were submitted by the licensee and docketed for completeness of information, as necessary.

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 inpuUoutput files to computer analyses such as Delft-3D and FL0-20 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. Table 1: Technical Topics of Discussion Info Need Information Need Description Post-Audit Status No. 1 The licensee is requested to clarify, and Response in the electronic reading room where necessary

correct, the comparison of (ERR) is sufficient.

The NRC staff would the reevaluated flood hazard to the current like this response from the ERR to be design bases. placed on the docket to support the interim hazard letter. 2 Provide the justification for using the Response in ERR is sufficient.

The NRC Holland, Ml wave information as staff would like this response from the representative of the site wave ERR to be placed on the docket to characterization.

Reference as necessary support the interim hazard letter. appropriate ERR document(s) and figures and other information to support this assumption.

3 Provide a discussion of the uncertainty Response in ERR is sufficient.

The NRC associated with the extrapolated wave staff would like this response from the runup estimation method and provide a ERR to be placed on the docket to justification for not using a more rigorous support the staff assessment.

method to develop the wave runup estimate.

4 Provide a discussion of the Case 3 Response in ERR is sufficient.

Technical conditions analyzed with the SSPMP rainfall staff would like the response placed on hydrograph (e.g. rooftop drains plugged, the docket to support the staff protected storm drainage system),

and the assessment.

The NRC staff reviewed the Case 2 conditions analyzed using the HMR June 16, 2015, docketed submittal and rainfall hydrograph.

confirmed that the LIP input and output files were docketed.

Therefore the licensee does not need to docket the files as requested during the audit. 5 Provide a discussion of the plugged roof Response in ERR is sufficient.

The NRC drainage analyzed with additional runoff to staff would like this response from the adjacent cells in the Case 3 analysis.

ERR to be placed on the docket to support the staff assessment. Info Need Information Need Description Post-Audit Status No. 6 The licensee is requested to provide the Withdrawn

-This information need is applicable flood event duration parameters being withdrawn and will be revisited (see definition and Figure 6 of the Guidance during the review of the mitigation for Performing an Integrated Assessment, strategies assessment.

(Japan Lessons-Learned Directorate)

(JLD) Interim Staff Guidance (ISG) JLD-ISG-2012-

05) associated with mechanisms that trigger an Integrated Assessment using the results of the flood hazard reevaluation.

This includes (as applicable) the warning time the site will have to prepare for the event (e.g., the time between notification of an impending flood event and arrival of floodwaters on site) and the period of time the site is expected to be inundated for the mechanisms that are not bounded by the current design basis. The licensee is also requested to provide the basis or source of information for the flood event duration, which may include a description of relevant forecasting methods (e.g., products from local, regional, or national weather forecasting centers) and/or timing information derived from the hazard analysis. Info Need Information Need Description Post-Audit Status No. 7 The licensee is requested to provide the Withdrawn

-This information need is flood height and associated effects (as being withdrawn and will be revisited defined in Section 9 of JLD-ISG-2012-during the review of the mitigation

05) that are not described for LIP. This strategies assessment.

includes the following quantified information for each mechanism (as applicable):

• Wind waves and run up,

• Hydrodynamic

loading, including debris,

• Effects caused by sediment deposition and erosion (e.g., flow velocities, scour),

• Concurrent site conditions, including adverse weather,

• Groundwater ingress Provide the analysis used to support the conclusions for associated effects.

It is requested that the licensee provide analysis of associated effects for these flood causing mechanisms or a clear statement with justification as to why these effects are excluded.

During the audit the licensee committed to provide all requested audit responses on the docket by November 13, 2015. EXIT MEETING/BRIEFING On October 15, 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. Document No. MD-12-FLOOD-005-N, Rev 0, "Local Intense Precipitation (LIP) Generated Flood Elevations, Cook Nuclear Plant Flood Hazard Re-evaluation"

2. Document No. MD-12-FLOOD-007-N, Rev 0, "Ice Induced Flooding at the D.C. Cook Nuclear Power Plant Units 1 and 2" 3. Document No. MD-12-FLOOD-009-N, Rev 0, "Probable Maximum Flood (PMF), Cook Nuclear Plant Flood Hazard Re-evaluation"

4. Document No. MD-12-FLOOD-012-N, Rev 0, "Site-Specific Probable Maximum Precipitation (PMP) for Cook Nuclear Plant Flood Hazard Re-evaluation"

5. Document No. MD-12-FLOOD-014-N, Rev 1, "Site-Specific Local Intense Precipitation (LIP) Generated Flood Elevations, Cook Nuclear Plant Flood Hazard Re-evaluation" ATTACHMENT 2 List of D. C. Cook Audit Participants Name Title Organization

1) John R. Anderson Fukushima Project Manager Indiana Michigan Power 2) Lee J. Bush Fukushima Portfolio Manager Indiana Michigan Power 3) Brenda G. Kovarik Fukushima Technical Consultant Indiana Michigan Power 4) Michael S. Dschida CNP Flood Protection Program Owner 5) Joseph R. Waters Fukushima Licensing Engineer Indiana Michigan Power 6) Rebecca A. Leneway Fukushima Project Specialist Indiana Michigan Power 7) Mitchell R. Peters Principal Engineer Alden Research Laboratory L. Weber If you have any questions, please contact me at (301) 415-6197 or by e-mail at Tekia.Govan@nrc.gov.

Sincerely, IRA/ Tekia V. Govan, Project Manager Office of Nuclear Reactor Regulation Japan Lessons-Learned Division Hazards Management Branch Docket Nos. 50-315 and 50-316

Enclosure:

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

PUBLIC JLD R/F MShams, NRR ARivera, NRO CCook, NRO PChaput, NRO RidsNRRJLD Resource MFranovich, NRR RRivera-Lugo, NRO JBowen, NRR KErwin, NRO LHibler, NRO ACampbell, NRO RidsNrrDorl3-1 Resource RidsNrrPMDCCook Resource ADAMS Accession No.: ML 15300A236 OFFICE NRR/JLD/JHMB/PM NRR/JLD/JHMB/LA NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME TGovan Slent MShams TGovan (MMarshall) for DATE 10/27/2015 10/30/2015 111/3/2015 11/3/2015 OFFICAL RECORD COPY