ML16215A086
| ML16215A086 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/04/2016 |
| From: | Robert Bernardo Japan Lessons-Learned Division |
| To: | Dent J Entergy Nuclear Operations |
| Bernardo, Robert, NRR/JLD 301-415-2621 | |
| Shared Package | |
| ML16215A076 | List: |
| References | |
| CAC MF6112 | |
| Download: ML16215A086 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. John Dent, Jr.
Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 August 4, 2016
SUBJECT:
PILGRIM NUCLEAR POWER STATION-INTERIM STAFF RESPONSE TO REEVALUATED FLOOD HAZARDS SUBMITTED IN RESPONSE TO
Dear Mr. Dent:
10 CFR 50.54(f) INFORMATION REQUEST - FLOOD-CAUSING MECHANISM REEVALUATION (CAC NO. MF6112)
The purpose of this letter is to provide a summary of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the reevaluated flood-causing mechanisms described in the March 12, 2015 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML15075A082), flood hazard reevaluation report (FHRR) submitted by Entergy Nuclear Operations, Inc. (Entergy, the licensee) for Pilgrim Nuclear Power Station (Pilgrim), as well as supplemental information resulting from audits.
By letter dated March 12, 2012, 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)
(ADAMS Accession No. ML12053A340). 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 reevaluate 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 COMSECY-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.
The NRC staff has reviewed the information submitted by the licensee and has summarized the results of the review in the tables provided as an enclosure to this letter. Table 1 provides the current design-basis flood hazard mechanisms. Table 2 provides the reevaluated flood hazard mechanisms; however, the reevaluated flood hazard mechanisms bounded by the current design-basis (Table 1) are not included.
The NRC staff has concluded that the licensee's reevaluated flood hazards information, as summarized in the enclosure, 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 Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide") for Pilgrim. 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.
Revision 2 of NEI 12-06 includes a methodology to perform a mitigating strategies assessment (MSA) with respect to the reevaluated flood hazards. On February 29, 2016, the NRC staff published Japan Lessons-Learned Division (JLD) Interim Staff Guidance (ISG)
JLD-ISG-2012-01, Revision 1, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML15357A142) in the Federal Register (81 FR 10283). This ISG endorses Revision 2 of NEI 12-06 (ADAMS Accession No. ML16005A625), dated December 2015. Based on the guidance provided in Revision 2 of NEI 12-06, flood event duration parameters and applicable flood associated effects should be considered as part of the Pilgrim 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 the 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).
If you have any questions, please contact me at (301) 415-22621 or e-mail at Robert. Bernardo@nrc.gov.
Docket No. 50-293
Enclosure:
Summary of Results of Flooding Hazard Re-Evaluation Report cc w/encl: Distribution via Listserv Sincerely,
/W~
Robert Bernardo Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation
Pilgrim Nuclear Power Station Table 1. Current Design Basis Flood Hazards for Use in the MSA Mechanism Stillwater Waves/
Design Basis Reference I
Elevation Run up Hazard I
Elevation Local Intense Precipitation South Side of the Plant Buildings Not included Not included Not included FHRR Section 2.2 & Table 4-1 in DB in DB in DB i
North Side of the Plant Buildings Not included Not included Not included FHRR Sections 2.2; 2.3.1.2; & Table in DB in DB in DB 4-1 I
I Streams and Rivers I
Not included Not included Not included FHRR Section 2.5.1 & Table 4-1 in DB in DB in DB Failure of Dams and Onsite Water Control/Storage Structures Not included Not included Not included FHRR Section 2.5.1 & Table 4-1 in DB in DB in DB I
Storm Surge Storm Surge With High Tide 13.5 ft MSL Not 13.5 ft MSL FHRR Section 2.3.1.1 & Table 4-1 I
applicable Seiche i
' Not included Not included Not included FHRR Table 4-1 in DB in DB in DB I
Tsunami I
Not included Not included Not included FHRR Table 4-1 in DB in DB in DB I I I
Ice-Induced Flooding Not included Not included Not included FHRR Table 4-1
l
Pilgrim Nuclear Power Station 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 Not included Not included Not included FHRR Table 4-1 in DB in DB in DB Note 1: Reported values are rounded to the nearest one-tenth of a foot.
Note 2: For the Local Intense Precipitation flooding mechanism, the licensee reports still water elevations obtained during the IPEEE studies, as this mechanism is not part of the plant's Current Licensing Basis.
Pilgrim Nuclear Power Station Table 2. Reevaluated Flood Hazards for Flood-Causing Mechanisms for Use in the MSA Mechanism Stillwater Waves/
1 Reevaluated Reference Elevation Run up Hazard I
Elevation I
I Local Intense Precipitation I
South Side of the Plant I
I 25.2 ft MSL Minimal 25.2 ft MSL FHRR Sections 3.1.2; 3.1.3 & Tables I
3-1; 4-1 ; 4-2 & 4-3 i
North Side of the Plant I 23.5 ft MSL Minimal 23.5 ft MSL FHRR Tables 3-1 ; 4-1 & 4-3 I
i West Side of the Plant 23.3 ft MSL Minimal 23.3 ft MSL FHRR Tables 3-1 ; 4-1 & 4-3 Storm Surge Probable Maximum Hurricane i 15.8 ft MSL 4.0 ft 19.8 ft MSL FHRR Sections 3.4.2.2.3 & Tables 3-Plus Wind Wave Effects at I
8; 3-16 & 4-1 Upstream Face of Intake I
Structure FHRR Section 3.9.2.1.8; 3.9.3 &
Tables 4-1 & 4-4 Probable Maximum Hurricane 15.8 ft MSL 6.3 ft 22.1 ft MSL FHRR Section 3.4.3 & Tables 3-8 &
Plus Wind Wave Effects Near 4-1 Reactor Building FHRR Section 3.9.2.1.6; 3.9.2.1.7 &
I Tables 4-1 & 4-4 Probable Maximum Wind Storm 15.3 ft MSL 7.1 ft 22.4 ft MSL FHRR Section 3.9.2.1.4 Plus Wind Wave Effects Near i
the Reactor Building Memo on Probable Maximum Wind I
Storm for Pilgrim Nuclear Power Station (ADAMS Accession No. ML16210A013)
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.
If you have any questions, please contact me at (301) 415-22621 or e-mail at Robert. Bernardo@nrc.gov.
Docket No. 50-293
Enclosure:
Sincerely, IRA/
Robert Bernardo, Project Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Summary of Results of Flooding Hazard Re-Evaluation Report cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RBernardo, NRR RidsNrrOorllpl1 -1 Resource RidsRgn1 MailCenter Resource RidsOpaMail Resource ARivera-Varona, NRO MWillingham, NRO MShams, NRR JLD R/F LQuinn-Willingham, NRO RidsNrrDorl Resource RidsNrrLASLent RidsAcrsAcnw_MailCtr Resource KErwin, NRO LHibler, NRO RRivera-Lugo, NRO RidsNRRJLD Resource RidsNroOsea Resource RidsNrrPMPilgrim Resource RidsOgcMailCenter Resource CCook, NRO ACampbell, NRO BHarvey, NRO GBowman, NR ADAMS Accession Nos.: PKG ML16215A076 LTR: ML16215A086 ENCL: ML16211A447 *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRO/DSEA/RHM1/TR*
NAME RBernardo Slent SBreithaupt*
DATE 08/1/2016 08/2/2016 07/29/2016 OFFICE NRO/DSEA/RHM1/BC*
NRR/JLD/JHMB/BC NRR/JLD/JHMB/PM NAME CCook GBowman RBernardo DATE 07/29/2016 08/3/2016 08/4/2016 OFFICIAL AGENCY RECORD