W3F1-2015-0020, Extension Request - Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flood Hazard Reevaluation Report
| ML15064A014 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/05/2015 |
| From: | Chisum M Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| W3F1-2015-0020 | |
| Download: ML15064A014 (6) | |
Text
Michael R. Chisum Site Vice President Waterford 3 W3F1-2015-0020 March 5, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
Subject:
Extension Request - Response to March 12, 2012, Request for Information, Recommendation 2.1, Flooding, Required Response 2, Flood Hazard Reevaluation Report Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38
References:
- 1.
NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012
- 2.
NRC Letter, Prioritization of Response Due Dates for Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Flooding Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident, dated May 11, 2012
- 3.
Entergys Response to the NRC Request for Information (RFI)
Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. W3F1-2012-0045 dated June 7, 2012
- 4.
NRC Letter, Supplemental Information Related to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)
Regarding Flooding Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 1, 2013
- 5.
Flooding Walkdown Report - Entergys Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, W3F1-2012-0101 dated November 27, 2012.
Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 mchisum@entergy.com
W3F1-2015-0020 Page 2 of 4
- 6.
NRC, Interim Staff Guidance, Guidance for Performing the Integrated Assessment for External Flooding, JLD-ISG-2012-05, Revision 0, November 30, 2012.
- 7.
U.S. Nuclear Regulatory Commission, NUREG/CR-7046, "Design-Basis Flood Estimation for Site Characterization at Nuclear Power Plants in the United States of America", dated November 2011.
Dear Sir or Madam:
On March 12, 2012, the NRC issued Reference 1 to request information associated with NearTerm Task Force (NTTF) Recommendation 2.1 for Flooding. One of the required responses in this letter directed licensees to submit a Hazard Reevaluation Report, including the interim action plan requested in Item 1.d of Reference 1, Enclosure 2, if appropriate. On May 11, 2012, the NRC issued the prioritization plan developed by the NRC and resultant Flooding Hazard Reevaluation due dates for all sites. Reference 2, Enclosure 1 identified the Waterford 3 site as a Category 3 Site requiring a Flooding Hazard Reevaluation Report submittal due date of March 12, 2015. In Reference 3, Waterford 3 indicated that it planned to comply with the requested response dates.
The purpose of this letter is to request an extension to the scheduled submittal date for the Waterford 3 Flooding Hazard Reevaluation Report. In Reference 4, the NRC states "an extension request should include: 1) the reason for the delay; 2) a proposed schedule for the submittal of a complete Hazard Reevaluation Report; and 3) the basis for the acceptability of the revised schedule." These items are addressed below.
- 1. Reason for the Delay - Refinement of Probable Maximum Hurricane (PMH), Probable Maximum Storm Surge (PMSS) and the combined effects flooding hazard scenarios require additional coupled model simulations. The analysis of storm surge in the Gulf of Mexico coupled with modeling of Mississippi River flooding in the vicinity of Waterford 3 is complex and requires significant computation time per storm surge simulation. Also, the Nuclear Plant Island Structure (NPIS) Local Intense Precipitation (LIP) calculation is being updated to reflect realistic credit for passive drain systems. Based on the substantial effort required to model the flood and complete the reevaluation report, Waterford 3 is requesting an extension to the response date from March 12, 2015 to July 24, 2015.
- 2. Proposed schedule for the submittal of a complete Flood Hazard Reevaluation Report - Waterford 3 is planning to complete and submit the Flood Hazard Reevaluation Report on July 24, 2015, with interim milestones as shown.
Milestone Date Activity May 14, 2015 Complete Refinement of calculations May 28, 2015 Complete 3rd party review of calculations June 19, 2015 Develop appropriate interim and long term action plan July 9, 2015 Site reviews and 50.9 Certification July 24, 2015 Management reviews and submittal
W3F1-2015-0020 Page 3 of 4
- 3. Basis for the acceptability of the revised schedule As recognized in the NRC's March 12, 2012 50.54(f) letter, the current regulatory approach and resultant plant capabilities provide confidence that an accident with consequences similar to the Fukushima accident is unlikely to occur in the United States, and that continued plant operation does not pose an imminent risk to public health and safety. Therefore, the duration of this extension request has no impact on safe plant operation.
Waterford 3 performed walkdowns that verified its current flooding licensing basis (Reference 5). During the walkdowns, all features were determined to be acceptable or deficiencies were entered into the corrective action program and determined to be operable. Therefore, Waterford 3 is protected from current design basis flood events.
The events being analyzed in the Waterford 3 Flooding Hazard Reevaluation are beyond the plant's design and licensing basis. Therefore, the reevaluation results based on beyond design basis events do not constitute an operability concern. This is consistent with the NRC supplemental information letter dated March 1, 2013 (Reference 4).
Refinements in progress have confirmed the site is currently protected from combined effect scenario hurricanes of significant intensity. An extreme scenario where PMSS with wind driven waves in conjunction with a 25 year river flood and levee failure is currently undergoing refinement. The postulated scenario would require a high Mississippi river level in conjunction with a major hurricane. Historically, Mississippi river levels are typically low in the August and September time frames when the most intense storms occur in the Atlantic and Gulf of Mexico basins. This is a very low probability event and the time frame represented by the extension request would result in an insignificant contribution to the overall risk.
High Mississippi River level predictions/monitoring and approaching storm/hurricane intensities forecast allow Waterford 3 to take pre-emptive measures to minimize storm impacts. Procedural guidance is in place to complete plant shutdown two hours prior to expected hurricane force winds on site.
These actions provide a sufficient level of flood hazard protection for the period of the extension request. No additional flood hazard mitigation or protection actions beyond those identified above are warranted for the period of the extension request.
Based on the above determinations, Entergy has concluded that the requested extension to the scheduled submittal date for the Waterford 3 Flooding Hazard Reevaluation Report does not impact safe plant operation or represent an undue risk to public health and safety. Accordingly, Entergy requests NRC approval to extend the scheduled submittal date for the Waterford 3 Flooding Hazard Reevaluation Report to July 24, 2015.
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SummaryofRevisedRegulatoryCommitment
(1page) to W3F1-2015-0020 Page 1 of 1 Summary of Revised Regulatory Commitment The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
COMMITMENT TYPE (Check One)
SCHEDULED COMPLETION DATE (If Required)
ONE-TIME ACTION CONTINUING COMPLIANCE Submit flood hazard re-evaluation to the NRC.
X July 24, 2015