ML15321A156

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Interim Staff Response to Reevaluated Flood Hazards Submitted in Response to 10 CFR 50.54(f) Information Request- Flood-Causing Mechanism Reevaluation
ML15321A156
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 12/04/2015
From: Minarik A
Japan Lessons-Learned Division
To: Pierce C
Southern Nuclear Operating Co
Minarik, Anthony, NRR/JLD 415-6185
References
Download: ML15321A156 (5)


Text

OFFICIAL USE ONLY SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 4, 2015 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

P.O. Box 1295 /BIN 8038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 - INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO 10 CFR 50.54(f) INFORMATION REQUEST- FLOOD-CAUSING MECHANISM REEVALUATION (TAC NOS. MF3868 AND MF3869)

Dear Mr. Pierce:

The purpose of this letter is to provide a summary of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the re-evaluated flood-causing mechanisms described in the March 6, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14069A054), flood hazard reevaluation report (FHRR) submitted by Southern Nuclear Operating Company, Inc. (the licensee) for Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch),

as well as supplemental information resulting from requests for additional information and audits.

By letter dated March 12, 2012 (ADAMS Accession No. ML12053A340), the NRC issued a request for information pursuant to Title 10 of the Code of Federal Regulations, Section 50.54(f)

(hereafter referred to as the 50.54(f) letter). The request was issued as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 2 to the 50.54(f) letter requested licensees to re-evaluate flood-causing mechanisms using present-day methodologies and guidance. Concurrently, with the reevaluation of flooding hazards, licensees were required to develop and implement mitigating strategies in accordance with NRC Order EA-12-049, "Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12054A735). On March 30, 2015, the Commission provided Staff Requirements Memoranda (SRM) (ADAMS Accession No. ML15089A236) to COM-SECY-14-0037, "Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards," dated November 21, 2014 (ADAMS Accession No. ML14309A256), affirming that licensees need to address the reevaluated flooding hazards within their mitigating strategies for beyond-design-basis external events.

Enclosure two transmitted herewith contains Security-Related Information. When separated from the Enclosure, this document is decontrolled.

OFFICIAL USE ONLY SECURITY RELATED INFORMATION

OFFICIAL USE ONLY SECURITY RELATED INFORMATION C. Pierce The NRC staff has reviewed the information submitted by the licensee and has summarized the results of the review in the tables provided as Enclosure 1 to this letter. Table 1 provides the current design-basis flood hazard mechanisms. Table 2 provides reevaluated flood hazard mechanisms; however, reevaluated hazard mechanisms bounded by the current design-basis (Table 1) are not included. Because Table 2 includes security-related information, Enclosure 1 contains the redacted version of Table 2. Enclosure 2 is withheld from public disclosure and restores the security-related information to Table 2.

The NRC staff has concluded that the licensee's reevaluated flood hazards information, as summarized in Enclosure 1, is suitable for the assessment of mitigating strategies, developed in response to Order EA-12-049 (i.e. defines the mitigating strategies flood hazard information described in guidance documents currently being finalized by the industry and NRC staff) for Hatch. Further, the NRC staff has concluded that the licensee's reevaluated flood hazard information is a suitable input for other assessments associated with Near-Term Task Force Recommendation 2.1 "Flooding." The NRC staff plans to issue a staff assessment documenting the basis for these conclusions at a later time.

In addition, the Nuclear Energy Institute (NEI) guidance document NEI 12-06 "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" is currently being revised. This revision will include a methodology to perform a Mitigating Strategies Assessment (MSA) with respect to the reevaluated flood hazards. Once this methodology is endorsed by the NRC, flood event duration parameters and applicable flood associated effects should be considered as part of the Hatch MSA. The NRC staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood- related associated effects developed by the licensee during the NRC staff's review of the MSA.

As stated above, Table 2 of the enclosure to this letter describes the reevaluated flood hazards that exceed the current design-basis. In order to complete its response to the information requested by Enclosure 2 to the 50.54(f) letter, the licensee is expected to submit an integrated assessment or a focused evaluation, as appropriate, to address these reevaluated flood hazards, as described in NRC letter, "Coordination of Request for Information Regarding Flooding Hazard Reevaluation and Mitigating Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML15174A257). This letter describes the changes in the NRC's approach to the flood hazard reevaluations that were approved by the Commission in its SRM to COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants" (ADAMS Accession No. ML15209A682).

OFFICIAL USE ONLY SECURITY RELATED INFORMATION

OFFICIAL USE ONLY SECURITY RELATED INFORMATION C. Pierce If you have any questions, please contact me at (301) 415-6185 or e-mail Anthony.Minarik@nrc.gov.

Sincerely, y Minarik, Project anager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Summary of Results of Flooding Hazard Re-Evaluation Report (Redacted Version)
2. Summary of Results of Flooding Hazard Re-Evaluation Report (Non-Public Version) cc w/encl: Distribution via Listserv OFFICIAL USE ONLY SECURITY RELATED INFORMATION

ENCLOSURE 1:

SUMMARY

TABLES OF REEVALUATED FLOOD HAZARD LEVELS

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard Elevation Local Intense Precipitation Not included Not included Not included FHRR Section 4.b.1 and Table 13 in DB in DB in DB II I

Streams and Rivers Flooding of the Altamaha River 105.0 ft Not 105.0 ft at Plant Hatch NGVD29 applicable NGVD29 FHRR Section 4.b.2 and Table 13 I Failure of Dams and Onsite 1

Water Control/Storage Structures

[Redacted] [Redacted) [Redacted] [Redacted] [Redacted]

[Redacted] [Redacted] [Redacted) [Redacted) [Redacted]

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 1. Current Design Basis Flood Hazards for Use in the MSA

~*--*--*--**--*---- - - - - - - - - - - - - - - - - - - - - - - - - * - . - - - - - - - - - - - * - * - - - - - - - - * - - * - - -----------

Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard Elevation Channel Migrations/Diversions No Impact No Impact No Impact FHRR Section 4.b.8 and Table 13 on the Site on the Site on the Site Identified Identified Identified L-.----~---*-~--***--*--**---.

Note 1: Reported values are rounded to the nearest one-tenth of a foot.

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA I Mechanism Stillwater I Waves/ Reevaluated Reference Elevation Run up Hazard Elevation Local Intense Precipitation Control Building 1-hr 1 sq. mi. 131.2 ft Minimal 131.2 ft i FHRR Table 3 PMP NGVD29 NGVD29 Intake Structure 1-hr 1 sq. mi. 111.2 ft Minimal 111.2 ft FHRR Table 3 PMP NGVD29 NGVD29 Diesel Generator Building 1-hr 1 130.2 ft Minimal 130.2 ft FHRR Table 3 I

sq. mi. PMP NGVD29 NGVD29 Turbine and Reactor Building 130.4 ft Minimal 130.4 ft FHRR Table 3 (Unit 1 and 2) 1-hr 1 sq. mi. PMP NGVD29 I NGVD29 I

I I

Streams and Rivers I Flooding of the Altamaha River 109.6 Not 109.6 FHRR Section 5.b and Table 13 at Plant Hatch NGVD29 applicable NGVD29 Failure of Dams and Onsite Water Control/Storage Structures

[Redacted] [Redacted] [Redacted] 1 [Redacted] [Redacted]

1

[Redacted] [Redacted] [Redacted] [Redacted] (Redacted]

[Redacted] 1

[Redacted] [Redacted] [Redacted] (Redacted]

--- _______________  ! __ ----------- --~--------i----- ------------- --

Note 1: The licensee is expected to develop flood event duration parameters and applicable flood associated effects to conduct the MSA. The staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood associated effects during its review of the MSA.

Note 2: Reevaluated hazard mechanisms bounded by the current design basis (see Table 1) are not included in this table.

Note 3: Reported values are rounded to the nearest one-tenth of a foot.

PKG ML15329A135; Letter ML15321A156; *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRO/DSEA/RHM2/TR*

NAME AMinarik Slent PChaput DATE 12/2/2015 12/2/2015 11/24/2015 OFFICE NRO/DSEA/RHM2/BC* NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME ARivera-Varona MShams AMinarik DATE 11/24/2015 12/4/2015 12/4/2015 OFFICIAL USE ONLY SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 4, 2015 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

P.O. Box 1295 /BIN 8038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 - INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO 10 CFR 50.54(f) INFORMATION REQUEST- FLOOD-CAUSING MECHANISM REEVALUATION (TAC NOS. MF3868 AND MF3869)

Dear Mr. Pierce:

The purpose of this letter is to provide a summary of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the re-evaluated flood-causing mechanisms described in the March 6, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14069A054), flood hazard reevaluation report (FHRR) submitted by Southern Nuclear Operating Company, Inc. (the licensee) for Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch),

as well as supplemental information resulting from requests for additional information and audits.

By letter dated March 12, 2012 (ADAMS Accession No. ML12053A340), the NRC issued a request for information pursuant to Title 10 of the Code of Federal Regulations, Section 50.54(f)

(hereafter referred to as the 50.54(f) letter). The request was issued as part of implementing lessons learned from the accident at the Fukushima Dai-ichi nuclear power plant. Enclosure 2 to the 50.54(f) letter requested licensees to re-evaluate flood-causing mechanisms using present-day methodologies and guidance. Concurrently, with the reevaluation of flooding hazards, licensees were required to develop and implement mitigating strategies in accordance with NRC Order EA-12-049, "Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12054A735). On March 30, 2015, the Commission provided Staff Requirements Memoranda (SRM) (ADAMS Accession No. ML15089A236) to COM-SECY-14-0037, "Integration of Mitigating Strategies for Beyond-Design-Basis External Events and the Reevaluation of Flooding Hazards," dated November 21, 2014 (ADAMS Accession No. ML14309A256), affirming that licensees need to address the reevaluated flooding hazards within their mitigating strategies for beyond-design-basis external events.

Enclosure two transmitted herewith contains Security-Related Information. When separated from the Enclosure, this document is decontrolled.

OFFICIAL USE ONLY SECURITY RELATED INFORMATION

OFFICIAL USE ONLY SECURITY RELATED INFORMATION C. Pierce The NRC staff has reviewed the information submitted by the licensee and has summarized the results of the review in the tables provided as Enclosure 1 to this letter. Table 1 provides the current design-basis flood hazard mechanisms. Table 2 provides reevaluated flood hazard mechanisms; however, reevaluated hazard mechanisms bounded by the current design-basis (Table 1) are not included. Because Table 2 includes security-related information, Enclosure 1 contains the redacted version of Table 2. Enclosure 2 is withheld from public disclosure and restores the security-related information to Table 2.

The NRC staff has concluded that the licensee's reevaluated flood hazards information, as summarized in Enclosure 1, is suitable for the assessment of mitigating strategies, developed in response to Order EA-12-049 (i.e. defines the mitigating strategies flood hazard information described in guidance documents currently being finalized by the industry and NRC staff) for Hatch. Further, the NRC staff has concluded that the licensee's reevaluated flood hazard information is a suitable input for other assessments associated with Near-Term Task Force Recommendation 2.1 "Flooding." The NRC staff plans to issue a staff assessment documenting the basis for these conclusions at a later time.

In addition, the Nuclear Energy Institute (NEI) guidance document NEI 12-06 "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" is currently being revised. This revision will include a methodology to perform a Mitigating Strategies Assessment (MSA) with respect to the reevaluated flood hazards. Once this methodology is endorsed by the NRC, flood event duration parameters and applicable flood associated effects should be considered as part of the Hatch MSA. The NRC staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood- related associated effects developed by the licensee during the NRC staff's review of the MSA.

As stated above, Table 2 of the enclosure to this letter describes the reevaluated flood hazards that exceed the current design-basis. In order to complete its response to the information requested by Enclosure 2 to the 50.54(f) letter, the licensee is expected to submit an integrated assessment or a focused evaluation, as appropriate, to address these reevaluated flood hazards, as described in NRC letter, "Coordination of Request for Information Regarding Flooding Hazard Reevaluation and Mitigating Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML15174A257). This letter describes the changes in the NRC's approach to the flood hazard reevaluations that were approved by the Commission in its SRM to COMSECY-15-0019, "Closure Plan for the Reevaluation of Flooding Hazards for Operating Nuclear Power Plants" (ADAMS Accession No. ML15209A682).

OFFICIAL USE ONLY SECURITY RELATED INFORMATION

OFFICIAL USE ONLY SECURITY RELATED INFORMATION C. Pierce If you have any questions, please contact me at (301) 415-6185 or e-mail Anthony.Minarik@nrc.gov.

Sincerely, y Minarik, Project anager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Summary of Results of Flooding Hazard Re-Evaluation Report (Redacted Version)
2. Summary of Results of Flooding Hazard Re-Evaluation Report (Non-Public Version) cc w/encl: Distribution via Listserv OFFICIAL USE ONLY SECURITY RELATED INFORMATION

ENCLOSURE 1:

SUMMARY

TABLES OF REEVALUATED FLOOD HAZARD LEVELS

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard Elevation Local Intense Precipitation Not included Not included Not included FHRR Section 4.b.1 and Table 13 in DB in DB in DB II I

Streams and Rivers Flooding of the Altamaha River 105.0 ft Not 105.0 ft at Plant Hatch NGVD29 applicable NGVD29 FHRR Section 4.b.2 and Table 13 I Failure of Dams and Onsite 1

Water Control/Storage Structures

[Redacted] [Redacted) [Redacted] [Redacted] [Redacted]

[Redacted] [Redacted] [Redacted) [Redacted) [Redacted]

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 1. Current Design Basis Flood Hazards for Use in the MSA

~*--*--*--**--*---- - - - - - - - - - - - - - - - - - - - - - - - - * - . - - - - - - - - - - - * - * - - - - - - - - * - - * - - -----------

Mechanism Stillwater Waves/ Design Basis Reference Elevation Run up Hazard Elevation Channel Migrations/Diversions No Impact No Impact No Impact FHRR Section 4.b.8 and Table 13 on the Site on the Site on the Site Identified Identified Identified L-.----~---*-~--***--*--**---.

Note 1: Reported values are rounded to the nearest one-tenth of a foot.

Edwin I. Hatch Nuclear Power Plant, Units 1 & 2 Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA I Mechanism Stillwater I Waves/ Reevaluated Reference Elevation Run up Hazard Elevation Local Intense Precipitation Control Building 1-hr 1 sq. mi. 131.2 ft Minimal 131.2 ft i FHRR Table 3 PMP NGVD29 NGVD29 Intake Structure 1-hr 1 sq. mi. 111.2 ft Minimal 111.2 ft FHRR Table 3 PMP NGVD29 NGVD29 Diesel Generator Building 1-hr 1 130.2 ft Minimal 130.2 ft FHRR Table 3 I

sq. mi. PMP NGVD29 NGVD29 Turbine and Reactor Building 130.4 ft Minimal 130.4 ft FHRR Table 3 (Unit 1 and 2) 1-hr 1 sq. mi. PMP NGVD29 I NGVD29 I

I I

Streams and Rivers I Flooding of the Altamaha River 109.6 Not 109.6 FHRR Section 5.b and Table 13 at Plant Hatch NGVD29 applicable NGVD29 Failure of Dams and Onsite Water Control/Storage Structures

[Redacted] [Redacted] [Redacted] 1 [Redacted] [Redacted]

1

[Redacted] [Redacted] [Redacted] [Redacted] (Redacted]

[Redacted] 1

[Redacted] [Redacted] [Redacted] (Redacted]

--- _______________  ! __ ----------- --~--------i----- ------------- --

Note 1: The licensee is expected to develop flood event duration parameters and applicable flood associated effects to conduct the MSA. The staff will evaluate the flood event duration parameters (including warning time and period of inundation) and flood associated effects during its review of the MSA.

Note 2: Reevaluated hazard mechanisms bounded by the current design basis (see Table 1) are not included in this table.

Note 3: Reported values are rounded to the nearest one-tenth of a foot.

PKG ML15329A135; Letter ML15321A156; *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRO/DSEA/RHM2/TR*

NAME AMinarik Slent PChaput DATE 12/2/2015 12/2/2015 11/24/2015 OFFICE NRO/DSEA/RHM2/BC* NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME ARivera-Varona MShams AMinarik DATE 11/24/2015 12/4/2015 12/4/2015