ML18136A581
| ML18136A581 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/31/2018 |
| From: | Joseph Sebrosky Beyond-Design-Basis Management Branch |
| To: | Entergy Nuclear Operations |
| Shared Package | |
| ML18136A574 | List: |
| References | |
| CAC MF3313, CAC MF3314 | |
| Download: ML18136A581 (25) | |
Text
Qffl&I ...L Y&E 9Nls¥ &i&WAIW A&lsJt'fli& IHFQAMA'JIQN Glill go t,IQf Alil.lit&li UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 31, 2018 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249
SUBJECT:
NUCLEAR REGULATORY COMMISSION REPORT FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS, INC.'S FLOOD HAZARD REEVALUATION REPORT SUBMITIAl RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (CAC NOS. MF3313 AND MF3314)
Dear Sir or Madam:
By letter dated May 6, 2015 (Agencywide Documents Access and Management System (ADAMS} Accession No. ML15124A340), the U.S. Nuclear Regulatory Commission (NRC}
informed you of the staff's plan to conduct a regulatory audit of Entergy Nuclear Operations, lnc.'s (the licensee) Flood Hazard Reevaluation Report (FHRR} submittal related to the Near-Term Task Force Recommendation 2.1-Flooding for Indian Point Nuclear Generation Unit Nos.
2 and 3. The audit was intended to support the NRC staff review of the licensee's FHRR and the subsequent issuance of a staff assessment.
The NRC conducted audits at AREVA's offices in Washington, D.C. from June 11 to 12, 2015, at NRC Headquarters, in Rockville, MD, from February 2 to 3, 2016, and via webinars June 17, 2015, October 1, 2015, October 22, 2015, December 9, 2015, December 16, 2015, February 11, 2016, and March 24, 2016. The audits were performed consistent with NRC Office of Nuclear Reactor Regulation, Office Instruction LIC-111, "Regulatory Audits," dated December 29, 2008, (ADAMS Accession No. ML082900195). 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.
Enclosure 1 transmitted herewith contains Security-Related Information and Critical Electric Infrastructure Information (CEIi). When separated from Enclosure 1, this document is decontrolled.
0551Cltt 11&E ON1Y SEC!!RITY RE! OIED INFORNOllAN SEIi 89 N8f AELEA&E
Qlilil"l.t.ls ft !iii Q*lls¥ 81i"YAl+Y AlilsAl"lig INFQAMAl"IQN
&Ell B8 H8iif RELEASE If you have any questions, please contact me at (301 ) 415-1132 or by e-mail at Joseph.Sebrosky@nrc.gov.
Docket Nos. 50-247 and 50-286
Enclosures:
- 1. Audit Report (Non-Public)
- 2. Audit Report (Public) cc w/encl: Distribution via Listserv OFF.1C1A! 11&5 ON! Y $EC1!RIIY PF! OXliD 1N!iORH tl!ON CE11 PA MAI es, 54$5
QlalalQIOla ffili Olll.¥ iliQPIAl'fY Alila,l'lil.' laJlaQAH.iA,l'IOlJ Qliill 99 tJQT Aliilr.l!A&&i NUCLEAR REGULATORY COMMISSION AUDIT REPORT FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS, INC'S.
FLOOD HAZARD REEVALUATION REPORT SUBMITTALS RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 BACKGROUND AND AUDIT BASIS By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS} Accession No. ML12053A340}, 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 1O of the Code of Federal Regulations (1 O 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 hazards for their sites against current NRC requirements and guidance.
Subsequent staff requirements memoranda associated with 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 December 23, 2013 ( ADAMS Accession No. ML13364A005), Entergy Nuclear Operations, Inc. (Entergy, the licensee) submitted its Flood Hazard Reevaluation Report (FHRR) for Indian Point Nuclear Generating Unit Nos. 2 and 3 (Indian Point) and revised its FHRR on December 9, 2014 (ADAMS Accession No. ML14357A052). The NRC 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 the licensees' FHRR. This audit summary is being completed in accordance with the guidance set forth in NRC Office of Nuclear Reactor Regulation, Office Instruction UC-111, "Regulatory Audits," dated December 29, 2008 (ADAMS Accession No. ML082900195).
AUDIT LOCATION AND DATES The NRC conducted audits at AREVA's offices in Washington, D. C. from June 11 to 12, 2015, at NRC Headquarters, in Rockville, MD, from February 2 to 3, 2016, and via webinars June 17, 2015, October 1, 2015, October 22, 2015, December 9, 2015, December 16, 2015, February 11, 2016, and March 24, 2016. The audit was completed by document review with the use of the licensee's established electronic reading room {ERR}.
Enclosure 2 Ol'l'ICIAL tJS! 014L I 81!11 88 tJQT Al!l:lsA&I!
8FFl81AL ~8E 8HLV 8E8~Rl'fY RELA'fl!B IHF8RMAfl8N
"&II go No:T AliL.li OIi&
AUDIT TEAM The NRC au d",t team, an d au d"1t oart,oants were as f o IIows:
Title Team Member Oraanization Team Leader, NRR/JLD Victor Hall NRR Team Leader NRR/JLD Tekia Govan NRR Technical Deputy Division Director Andy Camobell NRO Scott Flanders NRO Branch Chief, NRR/JLD Mohamed Shams NRR Technical Branch Chief Christooher Cook NRO Aida Rivera- NRO Technical Branch Chief, NRO/DSEA Varona Technical Suooort Mike Lee NRO Technical Support Michelle Bensi NRO Technical Branch Chief, NRO/DSEA Ken Erwin NRO Technical Lea Brad Harvey NRO Technical Sucoort Barbara Haves NRO Technical Suooort Henry Jones NRO Technical Support Kevin Quinlan NRO Richard Rivera- NRO Technical Suooort Luao Laura Quinn- NRO Technical Monitor Willinaham Oak Ridge National Laboratory NRC Contractor Scott DeNeale {ORNU NRC Contractor David Watson ORNL NRC Contractor Shih-Chieh Kao ORNL NRC Contractor Chris Bender Tavlor Enaineerina (TE}
NRC Contractor Pat Fitzoatrick TE NRC Contractor Jim Marino TE Pacific Northwest National Technical Suooort Raiiv Prasad Laboratory lPNNU Technical Support Nancv Kohn PNNL Technical Suooort Adam Maxwell PNNL AUDIT PARTICIPANTS Don Bentlev Enterav Mike Krupa Enterav Bryan Ford Enterav Viroinia Conrad Enterov Richard Drake Enterov Mirzai Mahvash Enterov Barbara Owens Enterov Steve Prussman Enterav Steve Saunders Enterav John Skonieczny Enterav o,&iQl.\la l.f&&i o*H,¥ &&i"11AIT¥ Alila o;,g IN,OAM:l.'JIQN Cfill PO N01 AliiL.&iOli&i
9FFl&1Als W&li 9Nk¥ &&&WAIO: AlilaMli8 INF9AMMIQN Gill 99 tJQT Aiilsliit.&lii Title Team Member Organization Cindy Fasano Areva Alan Thomas Areva Chad Cox GZA GeoEnvironmenta, Inc.
Terie Dube GZA David Leone GZA Mike Mobile GZA Jeremv Picard GZA Dan Stapleton GZA Christine Stonier GZA Bill Kappel AWA 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 input/output files to computer analyses such as Hydrologic Engineering Center - Hydrologic Modeling System (HEC-HMS) 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.
EXIT MEETING/BRIEFING By letter dated April 25, 2016 (ADAMS Accession No. ML16112A172), the NRC staff issued a summary of the reevaluated flood-causing mechanisms. That letter concluded that the licensee's reevaluated flooding hazard information is a suitable input for assessments associated with Near-Term Task Force Recommendation 2.1 "Flooding," thus closing out the discussion of the technical topics described above.
9FFIGIAls W&i 9Nls¥ &i&WAIT¥ AilsA::a:&& INF9AMATl9H
&liill gg NQi AilaliiA&E
AFF1C1A! !ISF ON! Y m SFC11B1IY RE! AIFD INFORMAIION
£ill go IIQT AliiL,liiO&li Table 1: Indian Point Information Needs - Audit/Post-Audit Summary INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 1 All Flood Causing Mechanisms: Comparison of Reevaluated Flood In responding to this request, during the June Hazard with Current Design Basis (CDB) 4, 2015, audit meeting, the licensee noted The Flood Hazard Reevaluation Report (FHRR) for the Indian Point Energy that it had used the terms "CLB" and the Center (IPEC) site provides comparisons of the reevaluated flood hazards "COB" interchangeably in the revised 2014 with the current licensing basis (CLB) for all flood-causing mechanisms for version of the FHRR (Entergy, 2014) as they which a CLB had been established. Table 4.1.1 of the FHRR has a tabulated were viewed to be synonymous. In response, summary of this comparison. the staff noted that both the terms have distinct regulatory meanings.
The request made of the licensee was to reconcile the CDB/CLB The staff concluded that the information inconsistencies identified in the first version of the FHRR (Entergy, 2013a) provided by the licensee was sufficient to and submit a revised hazard comparison consistent with the instructions address this information need request.
provided in the 50.54(f) letter.
2A Local Intense Precipitation (LIP): Detailed Modeling of the Yard The licensee placed a document in the ERR Common to the IPEC Unit 2 Reactor and Turbine Buildings in December 2015 in response to this Evaluation of the effects of flooding due to LIP on safety-related facilities at information need request. The licensee the IPEC site is requested in the 50.54(f) letter. In its FHRR. the licensee reported that there was no French drain described its LIP analysis in Section 2.2.1. That analysis was based on a system associated with the Unit 2 Turbine site-specific probable maximum precipitation (PMP) estimate rather than the Building. The licensee did note, however, staff-recommended approach to use an appropriate precipitation value that there was a series of gravel-filled cisterns obtained from the National Weather Service's Hydrometeorofogicaf Reports immediately behind the building that (or HMRs). Using the licensee's FL0-2D model for the IPEC site, the staff passively collect rainwater. Following a conducted an alternative LIP simulation using the HMR precipitation value precipitation event, these cisterns are that produced a probable maximum flood (PMF) elevation notably greater mechanically drained by reactor personnel than the elevation obtained by the licensee using a site-specific PMP using portable pumps (see Information Need (ssPMP). This higher flood elevations would occur in the open yard between 5).
the Turbine Building and Reactor Building for Unit 2 where the maximum flood level is expected, as well as other powerblock area areas. During the audit, In order to determine the appropriateness of the licensee noted that this yard location is underlain by a French drain the ssPMP values used by the licensee and the resulting estimated water surface 1 Some information need requests were points of clarification concerning information described in the FHRR or one of its references. Details concerning the results from that type of inquiry are captured in the staffs assessment of the licensee's 50.54(f) FHRR rather than in this table. Questions concerning such clarifications correspond to the numbered information needs are not included in this table and thus explains why the numbering system may have omissions.
OFFIQl.t.la. W81ii QN!sY 81iii&WAl'f¥ Aliiila.Mliii& IN~QAMMIQN
£ill go IIQT AiL,iO&i
Qf.F1;1 eIs Wlili Q*lt.¥ liliCYAIT¥ Alils.t.llig mFQAMMIQtl Clill DO NO:r Ail.Ii OIii INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED 1 system that passively directs flood water away from this location in recognition elevations (WSEs) at the common yard that this area has a propensity to collect rain water, albeit temporarily. location, the staff independently evaluated the sensitivity of the licensee's FL0-2D LIP It is requested that the licensee provide information concerning how the model. The staff compared WSEs from the French drain system will drain the water accumulated in the open yard ssPMP with the WSEs modeled at the between the Turbine Building and Reactor Building for Unit 2. The licensee location in question using precipitation values was asked to describe the sensitivity of the estimated LIP elevations to the obtained from HMR-52 (NOAA, 1982). The efficiency of the drainage system at this particular location. It was asked that 1-h, 1-mi2 PMP value at the Point Beach (NY) this information be based on a sensitivity analysis of the model to alternative site estimated using the HMR-52 method was conditions (system states) for this particular feature (at this location). For 17.3 inch (in.), compared to the 9.4 in.
example, was the French drain at the location in question assumed to be fully estimated using the ssPMP; this resulted in a functional and operating at 100 percent efficiency during the LIP event or, 46% difference in the total estimated rainfall alternatively, was the drain assumed to be partially obstructed and not fully depth. The sensitivity analysis resulted in a functioning? The licensee was also asked to describe any Technical WSE difference of about 1.27 feet (ft.) (71 %)
Specifications, administrative controls or procedures for maintaining the in the open yard between the Turbine efficiency of the drainage system. Building and Reactor Building for Unit 2. The results of the staffs sensitivity analysis indicated that the WSEs estimated using the HMR-derived value were significantly higher than the WSEs estimated using the licensee's ssPMP-based value.
As a consequence, the NRC staff determined that it should review how the licensee generically derived the ssPMP for sites. This generic review action was undertaken as an activity applicable to all of the FHRR submittals relying on a ssPMP-derived estimate. No further action is necessary for this information need request.
5 LIP: Supercritical Flow During the June 17, 2015, audit meeting the Evaluation of the effects of flooding of LIP on WSEs at the IPEC site is licensee noted that the FL0-2D computer requested in the 50.54(f) letter. Using the revised FL0-2D simulation, the code did not have the capability to explicitly licensee determined that supercritical flow would occur along the steeply- model hydraulic jumps. As a consequence, QFFICl.t.ls Wlili QNI.¥ &&;WAIT¥ Aliil.!3~1i& ltlli'QAM.t..lQN Clill gg tJQT Aiil.liAlii
8FF181AL tt9E er4tlf 9E8ttRl"PI' RELA,e8 H4,eRMA"er*
&&ill 89 N9T A&k&i/1&&
INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 sloped access road on the northeast side of the Unit 2 Turbine Building the licensee presented an alternative (referred to locally as 'heart attack hill"), and along the sloped access road on calculation to support its view that a hydraulic the southwest side of the power block. The licensee described that the jump would not form downstream along the steeply-sloped access roads transition to less steeply-sloped areas. The base of the steeply-sloped north access road.
licensee did not analyze if a transition from supercritical flow back to In that supplemental analysis, the licensee subcritical flow could occur at or near the transition areas and also did not estimated that the Froude number for the consider how flood WSEs could change both upstream and downstream of upstream cross-section at the downslope end the transition points or potential impacts on flood elevations at structures, of the north access road was approximately systems, and components (SSCs). 2.9, suggesting supercritical flow conditions generally exist in this area. Using the It was requested that the licensee provide an analysis of the supercritical- to conjugate depth equation, the licensee the subcritical-flow transition, and what the related effects of any potential estimated that the flow depth following a transition may be on flood-related WSEs and associated effects such as hydraulic jump in a uniform-width cross-hydrodynamic loading including debris in Unit 2 transformer yard and adjacent section would be about 1.6 ft. Because the to points of access and egress at safety-related SSCs. FL0-2D computer code predicted a maximum flow depth of 1.2 ft. in the area immediately west of the north access road, the licensee expressed the view that a hydraulic jump would not form, that surface flow in this area would remain supercritical, and that there would be no increase in the estimated WSE generally in this area. The licensee further stated that even if a flow transition (from supercritical to subcritical flow) were to occur, the area west of the turbine building is essentially unconfined where surface flows would be expected to dissipate. Aerial photographs of the site indicate that the area in question around Unit 2, west of the Unit 2 Turbine Building is broad and is sufficiently wide to allow the surface flow to spread laterally, flow energy to dissipate, and flow depths to remain relatively small even if a hydraulic jump were to form.
Q&&ICI Al I 1$5 QNI Y $EC! !RIIY PEI 4I5D INFORY 4IION Ql!II 99 NQ'f Alilal!l.&i
9FFIGIAI!: W&li 9NI!:¥ &liQWAIW Alil!:.\'fli8 IHF8RMM19H
,;&11 gg NOl Ail.Ii O&Ii INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED 1 During the discussions related to this particular information need, the licensee was also asked to explain why certain grid cells behind IPEC Unit 2 showed estimated flood elevations of up to 10 ft. based on FL0-2D computer modeling. In response, the licensee noted that the grid cells in question corresponded to topographic depressions that had been filled with permeable material that allowed for the collection of meteoric rainwater; they were not French Drains as previously suspected by the staff. (Also see information need request 2A.) Because these features would act as "sinks" of mass flow in the computer simulations, the WSEs reported by the licensee reflect how much water those depression features collected rather than representing how much rain water might actually accumulate above the nominal powerblock grade in the area behind Unit 2.
The staff concluded that the information provided by the licensee was sufficient to address this information need request.
7 Streams and Rivers: Wind Waves During the June 4, 2015, audit meeting, the Evaluation of the effects of flooding of streams and rivers on WSEs at the licensee noted that this information need IPEC site is requested in the 50.54(f) letter. In connection with that request would be addressed in connection evaluation, American National Standards Institute/American Nuclear Society with its response to Information Need 21, (ANSI/ANS)-2.8-1992 recommends consideration of wind waves induced by below. To address both information need 2-year wind speed applied along the critical direction for floods caused by requests, the licensee made available precipitation events. Wind waves could increase the depth of flooding of the Calculation Package No. 32-9196323-000, reevaluated flood. Section 2.3.1 of the FHRR notes that wind-wave effects (entitled "Combined Events Flood Analysis -
were considered in connection with the PMF. However, it is not clear whether Riverine Calculation") for review in the ERR.
those effects were evaluated consistent the ANSI/ANS recommendations. In its review of that calculation package, the staff subseQuentlv determined that the QFFIQlil.ls W&li QrJI!:¥ &liiQUAIW Aliils.lt'Jlii& INFQAM.t~IQN Qliill gg tJQT AlilsliiA&lii
QFFIQl:l.la W&i QNla¥ &liQWAliY' AlilaMlig ltlFQAM:l3FIQtJ eeu 88 P48T RfLE,tc9f INFO RESPONSE
SUMMARY
INFORMATION NEED DESCRIPTION NEED1 The staff requested that the licensee provide details concerning how the licensee estimated 2-year wind speed using effects of wind-wave activity were considered in connection with the PMF. measured wind data from a National Climatic Data Center (NCDC) station. The licensee then relied a Gumbel type distribution to statistically represent the distribution of the fastest 2-minute wind speeds. The Gumbel distribution is commonly used to model the statistical properties of extreme events. The licensee estimated fetch line lengths on the Hudson River as the longest wetted top width perpendicular to the IPEC shoreline. Lastly, the licensee estimated the wind wave height, period, and wave runup using the U.S. Army Corps of Engineer's (USACE's} CEDAS-ACES v.4.03 software. The CEDAS-ACES software (VTE, 2017) is commonly used as the tool for performing wind wave calculations. Consequently, the staff determined that the licensee's wind-wave estimation methodology was consistent with standard engineering practice.
The staff concluded that the information provided by the licensee was sufficient to address this information need reQuest.
QFFIQI OIs: Uili QN&.¥ iliQMAIT¥ Alila,t;i;:liD 1*1rOAH OIIO*I Qlill gg tlOi Alilali.t.ili
Qlilil"'° Is U&li ,n11.v &liQUAl+Y AlilsMlig ltJliQAMMIQtl Qlill gg tJQT Alilsli.t.&ii INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED 1 8 Streams and Rivers: Snowmelt and Rainfall Timing During the June 17, 2015, audit meeting, the Evaluation of the effects of flooding of streams and rivers on WSEs at the licensee noted that it relied on both the IPEC site is requested in the 50.54(f) letter. In connection with that Federal Energy Regulatory Commission's evaluation, the licensee stated that hourly snowmelt rates were calculated for (FERC's) "Engineering Guidelines for the each subwatershed (e.g., subbasin}, and an" ... additional 4.6 inches (in.} of Evaluation of Hydropower Projects" and snow-water equivalent (varies by subbasin location) was added to the 72-hour ANSI/ANS-2.8-1992 to estimate the temporal (hr} Cool Season [probable maximum precipitation] PMP .... " Timing issues distribution of snowmelt during a cool-season of the snowmelt and rainfall-runoff processes would have an impact on the PMP event. The licensee estimated the 100-characteristics of the flooding characteristics near the IPEC site. It is year snowmelt rates for each 1,000-ft.
requested that the licensee provide information describing the time- increment in topographic elevation at hourly distribution of the snowmelt hydrograph and how it was added to the site- time steps. Meteorological time series data specific, cool-season PMP time distribution. (precipitation, temperature, dew point, and wind speed} were then obtained from that storm among eight storms used in the estimation of the site-specific cool-season PMP, which had the overall greatest observed average temperature, dew point, and wind speed. The hourly time series were created for a 120-hr period including the 72-hr PMP period. The data were temporally arranged in the same order as that of the PMP data set. The energy budget method described by the USACE (USACE EM1110-2-1406) was then used to estimate hourly snowmelt rates. Finally, the estimated temporally-varying snowmelt depths were added to the cool-season site-specific PMP depths (according to Calculation Package No.
32-9196314-000, "IPEC Probable Maximum Precipitation Calculation"} to obtain the cool-season hyetograph.
The staff concluded that the information provided by the licensee was sufficient to address this information need reauest.
OEEICf A! I !SE ONI.¥ SliCI 1PII¥ PEI OtliD INEOPYOtlAN Qlill gg *1g:r Alilsli0Sli
QlrlrlQl.\ls l.l&li Qtills¥ &liQUAlrt Alilsl.lli9 IJilFQAMMIQJil Clill go NOT Alil..li O&Ii INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 10 Streams and Rivers: Infiltration Losses and Computation of PMF The licensee provided a draft response in the Discharges ERR in advance of the June 17, 2015, audit Evaluation of the effects of flooding of streams and rivers on WSEs at the meeting (file name "Indian Point Info Needs IPEC site is requested in the 50.54(f) letter. In connection with that Draft Responses Part 2 without 2, 3, 27. 28, evaluation, the licensee stated that initial and constant loss rates for the HEC- 29," dated June 15, 2015). The licensee HMS model were calibrated. FHRR Table 3.2-1 shows that the verified initial noted that the Manning's infiltration rate loss rates for all subbasins were set to zero. Table 3.2-1 of the FHRR also values selected for the HEC-HMS computer shows that the verified constant loss rates for the subbasins ranged from 0.03 simulations were taken from Maidment's to 0.17 in./hr. The cumulative precipitation losses over the 72-hr duration of 1993 Handbook of Hydrology. Consistent the PMP storm, therefore, ranged from 2.16 to 12.24 in, which is a significant with the staff's request, the licensee prepared fraction (16 to 92%) of the combined water equivalent, 13.3 in., of the basin- tables containing the requested information specific, basin-average cool-season PMP and snowmelt. When discussing and described how they applied that infiltration rates during the May 27-30, 2014, audit meeting (NRC, 2014), the information to the computer simulations that licensee's subject matter expert explained that constant loss rates were formed the basis for the FHRR. The licensee initially based on minimum published infiltration rates for each hydrologic soil specified the initially-estimated infiltration rate group which were changed during calibration. High infiltration rates can have ( constant or continuing loss rate) for each a significant impact on flood characteristics. subbasin by calculating the area-weighted average of the minimum infiltration rates for It is requested that the licensee provide a table describing the cumulative 72- the hydrologic soil types in each subbasin.
hr average combined water equivalent of a cool-season PMP that takes into The licensee reported that the IPEC area-account snowmelt as well as infiltration losses for each subbasin area. It is average initial constant loss rate was 0.081 also requested that the precipitation loss fraction during the PMP event be in./h. During validation of the model using compared to other available PMF applications carried-out by other authorities floods events from October 1995, June 2006, in the Hudson River watershed. The licensee should also provide the and November 2006, the licensee estimated constant loss rates used before calibration based on hydrologic soil groups for the constant loss rate to be 0.073 in./h.
each subbasin referenced in the May 2014 audit meeting.
The staff concluded that the information In reference to the precipitation loss rates listed in Table 3.2-1, which were provided by the licensee was sufficient to calibrated and validated to flood events much smaller than the PMF event, the address this information need request.
FHRR text does not include a narrative describing the basis for their selection; However, the staff used the information in the it is requested that the justification for their selection be provided. Lastly, it is tables provided in the licensee's response to requested that the licensee provide any other information available that could develop follow-on Information Need 10A.
support such high infiltration rates.
O&&ICI Al I P&li 0111.X
~
QlrlrlQl:t.ls U&li ,n11.¥ lliQ\ilAIW Alil..t.;lig IHFQAMMIQJtJ Qlill gg JtlQT Ali .. li.t.lili INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 This information need request is also related to Information Needs 19, 20, and 26.
10A Streams and Rivers: Infiltration Losses and Computation of PMF The licensee's response to this information Discharges need request was placed in the ERR and is Evaluation of the effects of flooding of streams and rivers on WSEs at the dated December 21, 2015; in that response, IPEC site is requested in the 50.54(f) letter. Table 4.1-1 of the FHRR the staff-recommended sensitivity analysis (Revision 2) and updates to this table included in the licensee's response to was not included. In reviewing that response, Information Need 1 show that the current design basis for a PMF in the the staff noted the following regarding the Hudson River at the reactor site is 12.7 ft. National Geodetic Vertical Datum of licensee's modeling views concerning loss 1929 (NGVD29). This table also lists the current design basis for combined rates and potentially frozen soils:
effects flooding to be 15.0 ft. NGVD29. The plant site grade is also 15.0 ft NGVD29. The reevaluated PMF stillwater elevation (without wind-wave
- Frozen soils: The licensee stated that effects) is reported as 14.6 ft. NGVD29, giving an available margin of 0.4 ft. because 58% of the Hudson River watershed surface area has a minimum of The licensee provided infiltration losses for subbasins of the greater Hudson 66% forest cover; these areas are likely to River watershed in Table 10.2 of its June 15, 2015, responses to information remain unfrozen during winter months needs. Using the data in this table, the NRC staff independently estimated (i.e., during a cool season PMP that the 72-hr losses range from 15.7 to 64.7% of 72-hr PMP plus coincident event). The licensee further stated that snowmelt. The staff also estimated that the watershed-average loss is 36.7%. the assumptions used for the cool-season The magnitude of the loss is a significantly high fraction of the precipitation PMF calculations are not compatible with plus coincident snowmelt, especially for an extreme event like the PMP and frozen soils (ripe snowpack indicating pre-the fact that during winter, at least part of the watershed is likely to have warming and insulating properties of a frozen soils. snowpack).
Q&&l~IO L. llllii O*IL.¥
.&M
OlililCIOL. Pili OIIL.¥ eett INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 Given the limited available margin (0.4 ft.) between the licensee's reevaluated
- Loss rates: The licensee stated that PMF stillwater elevation and the current design basis, the staff recommended about 83% of the Hudson River that the licensee perform a sensitivity analysis to evaluate the likely variation watershed surface area has soils of PMF stillwater elevation at the IPEC site with lower loss rates that account belonging to Hydro/ogic Soil Group (HSG) for extreme precipitation events and potentially frozen soils. A, B, or C. According to Calculation Package 32-9196315-000, out of 19 subbasins of the JPEG watershed, 6 subbasins have constant loss rates of 0.05 in/hr or less (effectively group HSG D). Soils classified as group HSG D constitute about 42.4% of the JPEG watershed surface area. Thus, there appeared to be a discrepancy in the area percentages reported in the information need response (83%, above) and that obtained from Calculation Package 32-9196315-000 (i.e., 100%- 42.4% =
57.6%).
During the February 11, 2016, audit meeting, the staff requested clarification concerning the highlighted discrepancy. The licensee uploaded a revised response to the ERR on February 24, 2016. In its amended response, the licensee clarified that it used NRCS soil classification data to obtain the area of each subbasin for each soil class, then summed the subbasin data to obtain a total of 1.3 million acres classified as group HSG D, or less than 17% of the 8-million-acre total Hudson River watershed surface area and hence the remaining 83% of the watershed having been classified as having either HSA A, B, or C soil Qrouos. The response also OFFICIAi PSF ONI X SECPPIIY PEI OIFD INFOPMOIION Qliill go ti OT AFl.lii Oiii
8FFl91Ak W&E 8PfkY &li&WAI.V AiikME& INF8AM.t.'f18N
&ill gg *IQT Ail.ii 1.:&ii INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 clarified that subbasin loss rates were assigned after the HEC-HMS model calibration and verification process was completed, thus loss rates should not be used to determine the specific NRCS soil classification( s ).
The staff concluded that the information provided by the licensee was sufficient to address this information need request.
11 Streams and Rivers: HEC-RAS Setup and Calibration The licensee provided a draft response to this Evaluation of the effects of flooding of streams and rivers on WSEs at the information need request in the ERR in IPEC site is requested in the 50.54(f) letter. In connection with that advance of the June 17, 2015, audit meeting evaluation, the licensee stated that the HEC-RAS model was calibrated by (file name "Indian Point Info Needs Draft uniformly adjusting Manning's n values of the main channel until peak WSEs Responses Part 2 without 2, 3, 27, 28, 29,"
at US Geological Survey (USGS) Gage Station 01376304 were " ... generally dated June 15, 2015). In its response, the within one foot of the peak observed historical data .... " Calibration of licensee noted that during the calibration of hydraulic parameters can impact flood characteristics near the IPEC site. the HEC-RAS model, they observed a model behavior that was hydraulically counter-It is also requested that the licensee provide justification that a uniform intuitive - i.e., the WSEs predicted by the Manning's roughness coefficient value applied over the entire model reach is computer simulation increased with a reasonable assumption. In this regard, it is requested that the licensee decreasing valves of the Manning's explain whether this one-foot difference is conservative (i.e., above or below roughness coefficient. The licensee the historical value), and whether any filtering (e.g., moving average or box expressed the opinion that this modeling smoothing) was performed. For example, were the trends compared with the behavior was caused by the tidal influence in higher harmonics removed? The licensee should provide time-series the model reach (specifically a terminal comparison plots, if available, and some quantification of error associated with boundary condition at the Manhattan Battery the analysis. location). Thus, when lower values of the Manning's roughness coefficient are applied to their model, tidal flow influences occurring at the Manhattan Battery location would extend upstream, effectively creating a backwater effect, and in doing so lead to an increase in flow depth near the IPEC site.
Although this type of behavior might be true Olzlal£10 la I Iii 0*11.Y ii£! IAITY Ail OiiC> INlaOAtf OIION
&Ell 88 Pf 9'f AEkliA&I!
QfliltlaAl. 1l&li Qtll.¥ &li~IJAl'lY Alil..OJlig ltlfQAIUJIQN Gill PO llQJ" Aliil.i OSli INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 for nominal flow conditions within the HEC-RAS computer model, the staff observed that the same model behavior, of varying Manning's roughness coefficient values during calibration runs, would also be valid during PMF discharges, which are several times larger than the discharges used during model calibration. (The staff noted that the literature tends to support the licensee's interpretation of the modeling results relative to tidal influences.)
In response to the second part of this information need request, the licensee prepared a table containing the observed WSEs for two calibration events and modeled peak WSEs corresponding to three different Manning's n values. The licensee described how they applied that information to the computer simulations that formed the basis for the FHRR. The staff concluded that the information provided by the licensee in the ERR was sufficient to address the information need request. However, the staff used the information in the table in the licensee's response to develop follow-on Information Need 11A.
11A Streams and Rivers: HEC-RAS Setup and Calibration The licensee submitted a response to this Evaluation of the effects of flooding of streams and rivers on WSEs at the information need request to the ERR on IPEC site is requested in the 50.54(f) letter. Table 4.1-1 of the FHRR December 21, 2015; however, the response (Revision 2) and updates to this table included in the licensee's response to did not include the staff-recommended Information Need 1 show that the current design basis for a PMF in the sensitivity analysis. Alternatively, the Hudson River at the reactor site is 12.7 ft. NGVD29. This table also lists the licensee cited a few references from the current design basis for combined effects flooding to be 15.0 ft. NGVD29. literature to support an argument that the The plant site grade is also 15.0 ft. NGVD29. The reevaluated PMF stillwater lower Manning's n values obtained during OFFICl41 IISF ON! Y SFCIIPIIY PEI AlED INFAPMAllON
~ill gg tlQ1 Aliil.i O&Ii
8FFl81~L tl8E 8 ..e!L"111 8 EBYRl'f¥ RELIW ee HeT PH!.LP!.;;:" IHP'811tMIWION INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 elevation (without wind-wave effects) is reported as 14.6 ft. NGVD29, giving model calibration were appropriate. The an available margin of 0.4 ft. licensee stated that the Manning's n value of 0.022 obtained during model calibration In its June 15, 2015, responses to information needs, the licensee stated that provided a better match with observed flood its HEC-RAS calibration process was counter-intuitive because lower values discharges. The licensee also noted that the of Manning's roughness coefficient resulted in higher model-predicted PMF discharge is largely contained by fjord-stillwater elevations at the IPEC site. The staff performed a sensitivity test to like geometry (i.e., high valley walls) of the determine if the counter-intuitive behavior of the water-surface elevation to Hudson River.
Manning's roughness coefficient values holds for cool-season PMF discharges. The staff's results, using the licensee's HEC-RAS model and In connection with its independent evaluation only altering the Manning's roughness coefficient value, suggest that the of the FHRR results, the staff performed a predicted stillwater elevation at the IPEC site is highly sensitive to changes in sensitivity analysis using the licensee's HEC-Manning's roughness coefficient values. Additionally, the PNL staff found that RAS computer model. That sensitivity for the cool-season PMF discharge, the HEC-RAS predictions show the analysis indicated that at PMF discharge expected behavior with Manning's roughness coefficient (higher values of levels, the WSE increased as the magnitude Manning's roughness coefficient lead to higher predicted stillwater elevations). of the Manning's n value increased; these The staff also observed that a small change in Manning's roughness results were contrary to those reported by the coefficient resulted in the model-predicted stillwater elevation to exceed the licensee during its calibration runs.
current design basis for combined effects flooding, 15.0 ft. NGVD29.
During a February 11, 2016, audit telephone Given the small available margin (0.4 ft) between the licensee's reevaluated call, the licensee agreed to perform the PMF stillwater elevation and the current design basis, the staff requested that requested sensitivity analysis. Following the a sensitivity analysis be carried out to evaluate the likely variation of PMF completion of those sensitivity runs, the stillwater elevation at the IPEC site for the range of literature-recommended licensee provided an updated response to Manning's roughness coefficient values for natural streams. In particular, it Information Need 11 A to the ERR dated was requested that the licensee explain why varying the values of Manning's February 24, 2016. In that response, the roughness coefficient during calibration runs would be valid during PMF licensee described additional HEC-RAS discharges, which are several times larger than the discharges used during computer simulations that it had performed calibration. The staff also requested that the licensee provide a parametric based on a Manning's n value that had been sensitivity to support its reasoning. increased over a range of 10 to 20%. The licensee reported that the corresponding WSEs now being estimated given a larger Manning's value were 14 to 23% higher than that originally reported in the FHRR. The WSE behavior observed by the licensee QF~ICiilAI. W&li Qtlls¥ &liCiiWAIW AlilsJ.ilig ltlFQAMl~IQH CE!I PO NOI BE! EASE
e,1'1e1A
. t t,SI!!! er*t'.
1 - Sl!!!et, 81iiilll"'P'f PU!LA 99 tl9'f AliiiLEA::fJ INl'OPt'MJCTION INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 qualitatively agreed with the staff's sensitivity analysis. Using a Manning's n value of 0.022 that was obtained from earlier HEC-RAS computer simulations, the licensee's calibrated HEC-RAS computer model predicted a stillwater elevation of 14.6 ft.
NGVD29 at the reactor site. When taking into account the tidal influence at the downstream Manhattan Battery location, the computer simulations are likely to show lower Manning's n values and higher stillwater elevations near the IPEC site (i.e., the lower value of Manning's n would favor tidal waters to move farther upstream in the Hudson River thereby resulting in higher stillwater elevations upstream). Based on this reasoning, the staff concluded that the licensee's use of a Manning's n value of 0.022 in the tidally-influenced alternative PMF sc_enarios (ANSI/ANS-2.8-1992 Section 9.2.2.2 Alternatives II and Ill) was reasonable. 2 The staff noted that this determination is based in large measure on the fact that the licensee-estimated storm surge-influenced flooding scenario currently bounds the PMF resulting from a precipitation and/or snowmelt event combination occurring within the Hudson River drainage area.
2 A copy of the licensee's preferred Alternative II HEC-RAS computer model was not made available to the staff. Alternatively, a sensitivity analysis was performed by the staff using the PMF HEC-RAS computer model with the downstream boundary condition changed to reflect NRC's estimate of the antecedent tidal level at the Manhattan Battery location.
9FF181...L Y&E 8HLY 8E8YRlff RELM'E9 INF8RMM'l8H
~lill gg *tQT Alilsli.f1&i
Olililtltl., !Iii o*n.¥ iiCIIAIP( Ail.at;r;g 1*1FQAMATION Gill &Q *JQ'f Alilelii\&&
INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 The staff concluded that the information provided by the licensee was sufficient to address this information need reQuest.
15 Streams and Rivers: Downstream Boundary Condition for the HEC-RAS The licensee's response to this information Model need request was in the file entitled "Indian Evaluation of the effects of flooding of streams and rivers on WSEs at the Point Info Needs Draft Responses Part 2 IPEC site is requested in the 50.54(f) letter. In connection with that without 2,3,27,28,29", and dated June 15, evaluation, the FHRR does not describe the downstream boundary condition 2015. During the June 17, 2015, audit used for the HEC-RAS model to evaluate this hazard. The formulation of the meeting, the licensee noted that it had relied downstream boundary condition (at the Manhattan Battery) could impact flood on tidal records taken in the vicinity of the characteristics at the IPEC site. For tidally-influenced downstream boundary Manhattan Battery to estimate the conditions, the HEC-RAS manual recommends using a temporal weighting downstream boundary condition for the factor (theta) as close to 0.6 as possible. It was requested that the licensee Hudson River HEC-RAS computer model.
describe how the downstream boundary condition for the stream/river flood The upstream and downstream model limits, analysis was formulated using HEC-RAS, and how it reflects the 10-percent and the respective boundary conditions exceedance high tide as recommended in NUREG/CR-7046, Appendix H. selected for the FHRR analysis, were initially For the PMF calculation, for example, it was requested that the licensee described in the Sections 2.1. 1 and 6.1. 1 of explain whether a historical time series or predicted time series of tidal Calculation Package No. 32-9196316-000, elevations was used at the downstream boundary of HEC-RAS. The licensee entitled "IPEC Probable Maximum Flood on was asked to describe the time period considered and how did peak tide Hudson River - Hydraulics Calculation." The correlate with travel time to the IPEC site of the inflow hydrograph. The staff reviewed that calculation package. The licensee was also asked to explain how tidal asymmetry was handled by the licensee also noted that it had selected a 10-HEC-RAS model and whether there were any stability problems. The percent exceedance high tide for the licensee was asked to describe the value of theta used and whether other downstream boundary condition at the adjustments were made to avoid reductions in the accuracy associated any Manhattan Battery location based on the theta values greater than 0.6. Lastly, the staff requested that the licensee recommendations of Appendix H to provide a description of any error or warning messages obtained from the NUREG/CR-7046. The licensee also stated HEC-RAS model when it was executed. that the 10-perecent exceedance high tide downstream boundary condition was specified as a constant WSE value, and was not treated as a varying tide level.
The licensee stated that its use of theta value of 1.0 is appropriate according to the HEC-RAS User's Manual. The licensee also OEFIC!AI ! !SE ON! Y - SEC! 1B!IY BF! AIEP !NFQBMAJION el!II
- a,e N8'f ffELEA8E
0551£IOI. I !Iii QNI Y SEC! IRPIY REI OiliD Ptl&OPIIO'AQN GliH gg a,or Rlit.litlli INFO 1 INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED
-- - --+---
performed a sensitivity analysis by setting the theta value to 0.6 in. the HEC-RAS computer model. The licensee's sensitivity analysis showed minimal change in the maximum estimated WSE at the IPEC site. The licensee also provided a listing of HEC-RAS model waming messages and noted that no error messages were produced by the model during the computer simulation. The staff reviewed these warning messages and determined that they were not germane to the computational stability of the model.
The staff concluded that the information I provided by the licensee was sufficient to I address the information need reQuest.
,__ 16 IDam Failures: Debris Loads . ---------- During the June 4, 2015, audit meeting, the f,Sef,I) Evaluation of the effects of dam failures on WSEs at the IPEC site is licensee noted that the debris load portion of 1
. requested in the 50.54(f) letter. In connection with that evaluation, the 1
the dam failure analysis had been completed 1 licensee stated that debris load was evaluated but was unclear whether this in April 2013 prior to the issuance of NRC was evaluated as debris impact on SSCs at IPEC, or with respect to the dam interim guidance JLD-ISG-2013-01 (in July breach. The staff requested that the licensee provide clarification on this 2013). The licensee also expressed that view point, as NUREG/CR-7046 discusses debris loads relative to SSCs, but japan that its analysis was, nevertheless, consistent lessons-Learned Division (JLD) Interim Staff Guidance (ISG) JLO-ISG-2013- with the staff's interim guidance and within 01 recommends that they also be with respect to effects on dams. It was also the available water level margin at the site requested that the licensee provide a description of how debris flow was (i.e. t h ~ difference between the treated in the dam failure evaluation. C1iii lifcrtt1cal PMF WSE f~SSCs within the powerblock and the (11111* WSE associated with the dam failure scenario).
The licensee also reported that it had conducted a n sis -n involvin a lthe forced failure of the ( ]); that a -sis aroduced an estimated WSE of l_ [ at the IPEC site which is less than the finished grade of the reactor site.
Q~~IQIAls U&li QNls¥ &liQUAITY RlilsAiliQ INFQRMMIGN
- &II gg alQl AlilsliA&i
8P'P1e1J1tt t,91!!! er*tt: 9E8tjftllf¥ Pl!!LJlc'Fl!!!9 H4P8PlMM11814 GEIi 99 PJ&f A:&LEA8E INFO INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
NEED1 Following the audit meeting, the licensee submitted a supplemental response to this information need dated June 8, 2015 (filename "Indian Point Info Needs Responses 6-4-15 Part 1 PMP"). Later, during an October 26, 2015, telephone conference with the licensee there was further discussion of this particular information need request. During that discussion, reference was made to Calculation Package No. 32-9213356-000, "Combined Effect Floods - Coastal Processes for Indian Point Energy Center",
which included the details of a calculation of debris load impacts on SSCs at the site for the controlling flood effects which were higher than the WSEs attributed to dam failure. The licensee's supplemental response included the following points:
- At the maximum WSE resulting from dam failure, waterborne debris would not reach or exceed site grade owing to a low bulkhead that rises slightly above the site grade and therefore would prevent any flood waters from significantly impacting any SSCs.
- Dam failure would not occur because all of the upstream impoundments considered in the dam failure calculations have significant freeboard and would not overtop during a PMF event; the controlling dam failure O&&ICIOI PS1ii o*n Y SliiClllillXV lilliiL:Ol'liiE> **1&01ilMOl'ION
~liill ae N&T Aliik[A&lii
8fflelAL ~9E 8NLY &E&WRIW RELM'EB 1Hf8RMM'l8 ..
£fill gg *10:i Aliiilsliiit&liii r INFO -
NEED 1 INFORMATION NEED DESCRIPTION RESPONSE
SUMMARY
i--- :::..::;::__-+---- ----------------- ------ ----
a
- f j * .,. .... *ed failure of the Ir] within the watershed.
Upon review of this information, the NRC staff noted that current guidance includes consideration of operational failures as well as the potential for flood debris to block spillways or interfere with dam gates or other mechanical equipment. While dams upstream of the IPEC site might not fail because of adequate freeboards during the watershed-scale PMF event, the possibility exists that individual dams could fail during a sub-basin-scale PMF event, possibly in concert with debris loading effects. However.
under this alternative scenario, flood discharge within the Hudson River is be expected to be significantly less than that during a watershed-scale PMF event Moreover, it is also unlikely that there would be multiple (simultaneous) upstream dams failures during PMP/PMF events limited to a select few sub-basins. The staff determined, based on engineering judgment and the consideration of downstream wave attenuation effects, that the licensee's I omission of debris effects causing failures of
- individual upstream dams is not likely to affect the most severe dam breach flooding scenario at the IPEC site.
The staff concluded that the information provided by the licensee was sufficient to address the information need reouest.
OFFICIA1 1155 ONI Y SFCPRIIY RF! AXED 1NFORYAIION
&&II 99 NQT AlilaliiiA&liii
9FFl&IAI: Y&&Z 9JJk¥ &li&WAIW Alil:MliQ nJFQAMaf;R9~J een ee t4e, 1tEtEJ1tee References ANSI/ANS) ANSI/ANS-2.8-1992, "Determining Design Basis Flooding at Power Reactor Sites," American Nuclear Society, LaGrange Park, IL, July 1992.
BOSS International, 1988, "BOSS HMR52 User's Manual, Version 1.10," Boss International, Inc., 1988.
Entergy, 2013a, "Entergy's Required Response for NTTF Recommendation 2.1: Flooding - Hazard Reevaluation Report. Indian Point Unit Numbers 2 and 3. Docket Nos. 50-247 and 50-286. License Nos. DPR-26 and DPR-64," dated December 23, 2013, ADAMS Accession No. ML13364A006. [Original FHRR submittal.]
Entergy (Entergy Nuclear Northeast), 2013b, "Response to Request for Informations Regarding Planned Audit for Near-Term Task Force Recommendation 2.1 :Flooding Hazard Reevaluation Report," ADAMS Accession No. ML14147A379.
Entergy, 2014, "Entergy Fleet Fukushima Program Flood Hazard Reevaluation Report for Indian Point Energy Center (IPEC) Units 2 and 3.
Docket Nos. 50-247 and 50-286," Document No.: 51-9195289-002, dated May 2, 2014, ADAMS Accession Nos. ML14356A634, ML14356A635, and ML14356A636. [Revision to original December 2013 FHRR submittal.]
Entergy, 2014, Letter NL-14-072 from J.A. Ventosa (Entergy Nuclear Northeast) to NRC dated May 19, 2014,
Subject:
Response to Request for Information Regarding Planned Audit for Near Term Task Force Recommendation 2.1: Flooding Hazard Reevaluation Report (TAC Nos. MF3313 and 3314), Indian Point Unit Numbers 1, 2, and 3, ADAMS Accession No. ML14147A379.
Entergy, 2016, "Entergy Basis for Performance of the Mitigating Strategies Assessment with the Flood Hazard Information and Report for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. Indian Point Unit Numbers 2 and 3. Docket Nos. 50-247 and 50-286. License Nos. DPR-26 and 64," March 21, 2016, ADAMS Accession No. ML16088A025.
Federal Energy Regulatory Commission, "Engineering Guidelines for the Evaluation of Hydropower Projects," Office of Hydropower Licensing, FERC 0119-1, 1987-2016.
GZA International, Inc., 2015, "White Paper: Evaluation of River Flood and Strom Surge- Hudson River," September 25, 2015, ADAMS Accession No. ML15351A071.
Maidment, D.R., Handbook of Hydrology, New York, McGraw-Hill, 1993.
NOAA (National Oceanographic and Atmospheric Administration),"Probable Maximum Precipitation Estimates - United States, East of the 105th Meridian," US Department of Commerce, Hydrometeorological Report No. 51, June 1978.
OEEIGIAI I !SE ONI Y - SFCI IBIIY BEi AXED fNEOBNAIION (rill gg HQT Aril.liA&li
8FFl&II.I: W81: 8tJls¥ &liQWAll¥ Alil:Afl:9 nJF8AMA;:IQN
&lill 99 PJQf Alil:liA&li NOAA, "Seasonal Variation of 10-Square-Mile Probable Maximum Precipitation Estimates, United States East of the 105th Meridian," U.S.
Department of Commerce, Hydrometeorological Report No. 53, April 1980.
NOAA, "Application of Probable Maximum Precipitation. Estimates - United States, East of the 105th Meridian," U.S. Department of Commerce, National Oceanic and Atmospheric Administration, NOAA Hydrometeorological Report No. 52, August 1982.
USACE (U.S. Army Corps of Engineers), 1998, "Engineering and Design - Runoff from Snowmelt," Engineer Manual EM 1110-2-1406, March 1998.
USGS (U.S. Geological Survey), 1982, "Guidelines for Determining Flood Flow Frequency. Bulletin #17B of the Hydrology Subcommittee,"
lnteragency Advisory Committee on Water Data, March 1982.
NRC, 2014, Indian Point Nuclear Generating Units 2 and 3 - Regulatory Audit Report for May 27-30, 2014, Audit at the Indian Point Facility to Support Review of Near-Term Task Force Recommendation 2.1: Flooding Hazard Reevaluation Report (TAC Nos. MF3313 and MF3314)," August 29, 2014, ADAMS Accession No. ML14227A672.
Veritech Enterprises, LLC (VTE) 2017. CEDAS (Coastal Engineering Design and Analysis System) ACES (Automated Coastal Engineering System). Available at http://www.veritechinc.com/products/cedas/cedas-details. (U.S. Army Corps of Engineer's (USACE's) CEDAS-ACES v.4.03 software) 8Ffl81AL ~9E 8NLY 9Eetnu,v ftELAfEB IHf8ftMAfl8H
£ill gg *101 Alilsli ft iii
OFFICIO! IISF ONI Y SFCIIRIIY Bil OIED IMSQPIIOJIOM
&&II 88 ~,s, Al!k&A&li
SUBJECT:
NUCLEAR REGULA TORY COMMISSION REPORT FOR THE AUDIT OF ENTERGY NUCLEAR OPERATIONS, INC.'S FLOOD HAZARD REEVALUATION REPORT SUBMITTAL RELATING TO THE NEAR-TERM TASK FORCE RECOMMENDATION 2.1-FLOODING FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DATED May 31, 2018 DISTRIBUTION:
PUBLIC PBMB R/F RidsNrrLASLent Resource JSebrosky, NRR RRiveria, NRO RidsNroDsea Resource RidsNrrDorllpl1 Resource RidsNrrDorl Resource RidsNrrPMlndianPoint Resource RidsRgn1 MailCenter Resource RidsOpaMail Resource Mlee, NRO CCook, NRO SDevlin-Gill, NRO RidsACRS_MailCtr Resource ADAMS Accession Nos.: Pkg ML18136A574; Audit Report ML16181A204 (NON-PUBLIC); Audit Report M L18136A581 (PUBLIC) *via email IIOFFICE NRR/DLP/PBMB/PM NRR/DLP/PBMB/LA NRO/DSEA/RHMfTR* NRO/DSEA/RHM/BC*
IINAME JSebrosky SLent Mlee SDevlin-Gill DATE 5/31/2018 5/16/2018 4/27/2018 4/27/2018 OFFICE NRR/DLP/PBMB/BC NRR/JLD/JHMB/PM NAME MShams JSebrosky DATE 5/17/2018 5/31/2018 OFFICAL RECORD COPY OlililQ,O Is IJ&li 0*11.x iliCIIPIIY RlilsOJliD ***soe1u110M
£ill "'UIOT AilsiO&i