Text

Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin Assessments
	ML14038A122
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna
Issue date:	01/31/2014
From:	Korsnick M; Constellation Energy Nuclear Group, EDF Group
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML14038A122 (12)
	v • d • e

Mary G. Korsnick Acting Chief Executive Officer Chief Nuclear Officer CENG.

a joint venture of o

nry ai o,eD Office 40-0470-5133 Fax 443-213-6739 E-mail: Maria.Korsnick@cengllc.com January 31, 20.14 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 ATTENTION:

SUBJECT:

REFERENCES:

Document Control Desk Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-4 10 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244 Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments (a) 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 (ML12073A348)

(b) NRC Letter to Nuclear Energy Institute, Endorsement of Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012 (ML12144A142)

(c)

Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Response to 10 CFR 50.54(f) Request for Information, Recommendation 2.3, Flooding, dated November 27, 2012 (ML12335A029)

(d)

Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC),

Response to 10 CFR 50.54(f) Request for Information: Near-Term Task Force Recommendation 2.3,

Flooding, dated May 29, 2013 (ML13154A374)

(e)

Letter from R. J. Pascarelli (NRC) to List of Addressees, Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns, dated December 23, 2013 (ML13325A891)

Constellation Energy Nuclear Group, LLC 100 Constellation Way, Suite 200C, Baltimore, MD 21202

Document Control Desk January 31, 2014 Page 2 On March 12, 2012, the NRC staff issued Reference (a) requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(f). Enclosure 4 of that letter contains specific Requested Information associated with Near-Term Task Force (NTTF) Recommendation 2.3 for Flooding. By Reference (b), the NRC endorsed Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012. By Reference (c), Constellation Energy Nuclear Group, LLC (CENG) submitted the Calvert Cliffs Nuclear Power Plant, LLC (CCNPP),

R. E. Ginna Nuclear Plant, LLC (Ginna), and Nine Mile Point Nuclear Station, LLC (NMPNS) responses to the request for information contained in NTTF Recommendation 2.3, Flooding. By Reference (d),

CENG submitted a supplemental response to the request for information contained in Recommendation 2.3, Flooding, for CCNPP Unit 2.

One of the requirements of NEI 12-07 is to identify the available physical margin (APM) associated with each applicable flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.

Following the NRC staff's initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow them to complete its assessments. Accordingly, by Reference (e) the NRC staff has issued a request for addition information (RAI). Attachments 1 through 3 provide the CENG response to the NRC's request for additional information for CCNPP, Ginna, and NMPNS, respectively.

There are no new regulatory commitments included within this correspondence.

If there are any questions regarding this submittal, please contact Bruce Montgomery, Manager-Nuclear Safety and Security, at 443-532-6533.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 31, 2014.

SQcerely, I

Mary G. Korsnick MGK/STD/EMT/bjd Attachments:

(1)

Calvert Cliffs Nuclear Power Plant Response to Request for Additional Information (2)

R. E. Ginna Nuclear Plant Response to Request for Additional Information (3)

Nine Mile Point Nuclear Station Response to Request for Additional Information cc:

NRC Project Manager, Calvert Cliffs Resident Inspector, Calvert Cliffs NRC Project Manager, Ginna Resident Inspector, Ginna NRC Project Manager, Nine Mile Point Resident Inspector, Nine Mile Point Regional Administrator, NRC Region I S. Gray, DNR

Document Control Desk January 31, 2014 Page 3 bcc:

M. G. Korsnick J. A. Spina G. Sen B. S. Montgomery G. H. Gellrich M. D. Flaherty D. E. Lauver A. L. Simpson B. J. Dough C. R. Costanzo J. J. Stanley E. P. Perkins T. H. Darling J. E. Pacher M. A. Philippon T. L. Harding J. A. Jackson S. L. Miller C. R. Dedrickson P. M. Amway M. E. Jacobs C. R. Merritt K. A. Picciott G. J. Wrobel E. M. Tyler CCNPP File 36.11 CCNPP Electronic Docket File NMP 1 L2894 Fleet Licensing Letter 14-002 REGULATORY COMMITMENTS IDENTIFIED IN THIS CORRESPONDENCE:

None

ATTACHMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC January 31, 2014

ATTACHMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Request for Additional Information Please provide the following:

1. Confirmation that the process for evaluating APM was reviewed;

2.

Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI;

3. If changes are necessary, a general description of any process changes to establish this consistency;

4.

As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees. Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals:

a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented. No further action was performed if the APM value was greater than the pre--established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.

b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation. In this case, the APM for the seal could have been documented as "not small".

As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.

If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:

a) Enter the condition into the [Corrective Action Program] CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment. If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes. These actions do not need to be complete prior to the RAI response.

b) Report the APM as "undetermined" and provide the CAP reference in the RAI response.

1 of 2

ATTACHMENT (1)

CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CCNPP Response Constellation Energy Nuclear Group, LLC (CENG) has completed a review and revision of the process used for flooding design basis walkdown Available Physical Margin (APM) for Calvert Cliffs Nuclear Power Plant Unit I and 2 (CCNPP). All seals were inspected as part of the original walkdowns for signs of degradation, and corrective actions were taken, if required. In areas where negative APM existed, flood protection devices were evaluated based upon acceptability of walkdown inspection results and engineering judgment of whether the seal type was capable of performing its credited Current License Basis (CLB) flood protection function. However, the process for evaluating APM was not originally consistent with Approaches A or B, as discussed in the RAI, or the guidance contained in NEI 12-07. Changes made to establish this consistency include the following:

Small APM has been defined.

Numerical values for APM have been established or documented as undetermined.

For those instances where numerical values for APM were not determined, or where the licensing basis for the APM, as governed by the plant's design control process since installation, was not documented, the APM is considered "undetermined" and has been entered into the CAP as condition report CR-2014-000300, "External Flooding Hazard Available Physical Margin (APM)

Were Not Determined during Industry Flooding 2.3 Walkdowns." This single CAP entry captures this issue for multiple seals. CR-2014-0003000 disposition for the seals will consider the guidance provided in NEI 12-07, Section 5.8. CAP disposition will confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment.

The APM process is now consistent with the guidance in NEI 12-07 and as discussed in the RAI.

2 of 2

ATTACHMENT (2)

R. E. GINNA NUCLEAR PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC January 31, 2014

ATTACHMENT (2)

R. E. GINNA NUCLEAR POWER PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Request for Additional Information Please provide the following:

1. Confirmation that the process for evaluating APM was reviewed;

2.

Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI;

3.

If changes are necessary, a general description of any process changes to establish this consistency;

4. As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees. Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals:

a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented. No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.

b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation. In this case, the APM for the seal could have been documented as "not small".

As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.

If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:

a) Enter the condition into the [Corrective Action Program] CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height.

Disposition may occur as part of the Integrated Assessment. If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes. These actions do not need to be complete prior to the RAI response.

b) Report the APM as "undetermined" and provide the CAP reference in the RAI response.

1 of 2

ATTACHMENT (2)

R. E. GINNA NUCLEAR POWER PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Ginna Response Constellation Energy Nuclear Group, LLC (CENG) has completed a review and revision of the process used for flooding design basis walkdown Available Physical Margin (APM) for R. E. Ginna Nuclear Power Plant, LLC (Ginna). The original walkdown effort followed the process for evaluating APM as provided in NEI 12-07, including a definition for a small margin. All seals were inspected as part of the original walkdowns for signs of degradation, and corrective actions were taken, if required. Seals were determined to provide protection to a value greater than the pre-established small-margin threshold value if the walkdown inspection results were acceptable and engineering judgment determined that the seal type was capable of performing its credited CLB flood protection function. No instances where small APM with potentially significant consequences were identified.

However, the process for evaluating APM was not originally consistent with Approaches A or B, as discussed in the RAI. Changes made to establish this consistency include the following:

For those instances where numerical values for APM were not determined, or where the licensing basis for the APM, as governed by the plant's design control process since installation, was not documented, the APM is considered "undetermined" and has been entered into the CAP as condition report CR-2014-000064, "Potentially Small Available Physical Margin for Flooding Requires Evaluation". This single CAP entry captures this issue for multiple seals. CR-2014-000064 disposition for the seals will consider the guidance provided in NEI 12-07, Section 5.8.

CAP disposition will confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment. If an Integrated Assessment is not performed, determination will be made as to whether there are significant consequences associated with exceeding the capacity of the seals and interim action(s) will be taken, if necessary, via the CAP processes.

The APM process is now consistent with the guidance in NEI 12-07 and as discussed in the RAI.

2 of 2

ATTACHMENT (3)

NINE MILE POINT NUCLEAR STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Constellation Energy Nuclear Group, LLC January 31, 2014

ATTACHMENT (3)

NINE MILE POINT NUCLEAR STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION NRC Request for Additional Information Please provide the following:

1. Confirmation that the process for evaluating APM was reviewed;

2. Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI;