~QC'9-S ER GAS >HO: CTRlt TORPOR>'lOR ', - '; gv-g'r

January 28, 1981

Director of Nuclear Reactor RegulationAttention: Mr. Dennis M. Crutchfield, Chief

Operating Reactors Branch N5U.S. Nuclear Regulatory CommissionWashington, D.C. 20555

Subject: SEP Topics 'II-3.A, II-3.B, II-3.C, "Hydrology Review"R. E. Ginna Nuclear Power PlantDocket No. 50-244

Dear Mr. Crutchfield:Enclosed are the Rochester Gas and Electric comments regarding

the NRC assessment of SEP Topics II-3.A, II-3.B, and II-3.C,"Hydrology Review" which was transmitted to us by letter dated *

December'2, 1980. Note that an RG&E inspection of the revetmentdisclosed no degradation, although a more detailed inspectionwill be performed when weather and conditions permit.

Very truly yours,

J.'. Maier

JEM:ngAttachments

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Enclosure: RG&E responses to NRC Evaluation of SEP TopicsII-3.A, II-3.B, II-3.C, "Hydrology, Flooding, and UltimateHeat Sink"

g))nb'.

In Section 3.1 of the assessment, it is noted that thesignificance of the local flood level (254.5 ft.) will bereviewed under the DBE's or one of the topics discussed inSection 1.0. However, since it is stated (correctly), inSection 2.0 that the safety related equipment at 253.5 feetmsl (Service Water Pumps, buses 17 and 18, and the dieselgenerators) are protected by elevations of at least 16inches, there should be no need for further review. Protectionfor-this local flood level is provided.In Section 3.1, it would be useful to reference the basisfor assuming a 13e9 acre drainage area.

In Section 3.2, the PMF flow of 37,500 cfs obtained for DeerCreek is simply staggering. This flow, for a creek with adrainage area of 13.3 square miles, is 70% of the maximumestimated ~ow for the Genesee River, which has a drainagearea of over 2,600 square miles.

4 ~

5.

The information provided in the evaluation noted that a100-year flood at Deer Creek would produce a peak dischargeof about 3000 cfs, and that a flow in Deer Creek of 14,000cfs would not result in the overflooding of any safetyrelated equipment. The margin shown in these values isconsidered sufficient to demonstrate that 'no danger from thePMF exists, and that this topic can be considered completed(with no required modifications).In Section 3.2 additional references are required to determinethe basis for a) the NRC analysis verifying that 14,000 cfsis an acceptable Deer Creek flow, and b) the 100-year floodestimate by the U.S.G.S.

In Section 3.3.0, it is stated by the NRC that visualobservations during the SEP site visit indicated that therevetment fronting the plant on the west side of the dischargecanal is significantly degraded. During recent tel'ephoneconversations between RG&E and the NRC staff (Ted .Johnson,Gary Staley, and Drew Persinko), RG&E explained that noobservable degradation of the revetment is apparent. Iceand snow make it impossible to perform a detailed study.However, as soon as weather and conditions permit, RG&E willmake an inspection of the breakwall (accompanied by the NRC,if so desired). RG&E will make any modifications necessaryto bring the breakwall to the original design conditions.

The design basis groundwater level was supplied by telephoneto the NRC in November, 1978. To document this information,attached is an RGaE interoffice memo regarding this subject.As suggested in the topic assessment, the design basisgroundwater level is at grade (253.5 ft.).A summary and conclusions section should be added to theassessment, noting that the Ginna design meets the guidancepresented in Standard Review Plan Sections 2.4.1, e'tc. andRegulatory Guides 1.XX, with certain exceptions. Based onthe responses provided in this letter, the acceptability ofthese deviations should also be stated.It is not clear what the intent of Section 2.0 of SEP TopicAssessment II-3.C is. No references, design criteria, oracceptance criteria are provided. No reference to thenewly-constructed essential service water discharge (intoDeer Creek) is made. Additional NRC input is needed forRG&E to provide comments on the assessment.

Rochester Gas and Electric CorporationInter-OfFice Correspondence

November 21, 1978

SUBJECT: Review of SEP Report Produced By The NRC

TO: R.C. Mecredy

Outlined below is a list of items that should be revised oramended in the notes produced by the NRC in relation to hydrologicalengineering.

A. Page 2, item 3, second sentence to be revised as follows--The6'X8'ntake is used for tempering ice effects in the screenhouse.

Additional information to be provided to the NRC is noted below:

1. topographic maps of the plant area - supplied to G. Wrobelon September 14, 1978.

2. design basis groundwater level (DBGWL) for all plant structures-C. Mambretti has obtained this information from Gilbertsfor all plant structures they originally designed. Thescreenhouse/ESW structure was designed for a D.B.G.W.L. atfinished grade (ELEV. 253.5').

Gary Goetz

GG:npxc: J. Covey

G. Wrobel '+,C. Mambret"i

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UNITED STATESNUCLEAR REGULATORY COMMISSION

WASHINGTON, D. C. 20555

MAR 3 )8gt

MEMORANDUM FOR: William Russell, ChiefSystematic Evaluation Program BranchDivision of Licensing

THRV: i ~ ames P. Knight, Assistant Directorfor Components and Structures Engineering

Division of EngineeringI

FROM: George Lear, ChiefHydrologic and'eotechnical Engineering BranchDivision of Engineering

SUBJECT: i RESPONSE TO ROCHESTER GAS AND ELECTRIC COMMENTS ON

SEP TOPICS II-3.A, II-3.B AND II-3.C

Attached are the suggested Hydrologic Engineering Section responses to commentsby Rochester Gas and Electric Company on the hydrologic review for TopicsII-3.A, B and C.

Based on the information contained in the I'.censees'omments it appears thathe may not have a firm understanding of how SEP is supposed to work, especiallywith regard to the integrated assessment. His comments indicate the desire toshow acceptability of many items that require further coordination andassessment of safety significance. It also appears that the licensee may nothave a good understanding of hydrologic phenomena as evidenced by hiscomparison of a Probable Maximum Flood to a flood that has a recurrenceinterval of about 100 years. Should this be the case, the licensee may bewell advised to retain a competent Hydrologic Engineering Consultant to assistin this area of the SEP review.

, With respect to comment 7, we agree that a sumary and conclusion sectionshould be added but it would be preferable to resolve the Deer Creek floodlevel first and then include input from structural and system reviewers. Due

to the unavailability of quality data the staff's Deer Creek flood analysis was

very conservative. We had anticipated that the licensee may choose to obtainthe data necessary to do a more accurate analysis for Deer Creek. In lieu of a

refined analysis by the licensee we will use the conservative results of ouranalysis. Your system and structural reviewers should be instructed to basetheir reviews on the current report and furnish input to the HydrologicEngineering Section for inclusion in a Summary and Conclusions Section.

'I

Wi 1 1 i am RussellMAR 3 1981

The Hydrologic Engineering Section contact for these toPics is Gary B.Staley at 492-8141.

Original signed bY Geo gd'or arear

Enclosure:As stated

George Lear, ChiefHydrologic and Geotechnical

Engineering BranchDivision of Engineering

cc: M. Fliegel'. StaleyD. PersinkoH. LevinSEP Section LeadersL. Heller

orrlCr)UR!VAMlg

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Hydrologic Engineering Sect>onResponses to Rochester Gas and Electric Comments on

SEP Topics II-3.A, II-3.B, and II-3.C

1. This res onsponse should come from a system reviewer. If the flood does not

affect the lantp or plant systems then a statement to that effect will be ~

added to the Safety Evaluation.

"RE GI2. Drawing titled, RE GINNA Plot Plan," Redrawn 3/3/79, Dwng Ho. 33013-352,

was used to measure the drainage area.

3. Ho bases have bee n provided for the licensees'tatements. Using the

Generalized PMF curvesurves in Regulatory Guide 1.59, we estimated the PMF

to be 500 000 ccfs for the 2600 S.M. Genesee River Basin. The 37,500 cfs

estimate for the Deer Creek PMF is 7.4X of th 500 00e , 0 cfs value, not 705.

The Deer Creek PMF is about 69K of the estimated maximum historical flow

: of the Genesee River (54,000 cfs on March 18, 1965). This flow can be

considered to be a very rough estimate of the 100 year flood on the Genesee

River and as such should be compared to our estimated 100 year flood for

Deer Creek. The Deer Creek 100 year flood is about 5.6X of this maximum

historical flood in the Genesee Riv Th 1'ver.e icensee has provided no

documentation or bases to shoow that the Deer Creek PMF is less than 37,500

cfs or that only 1100 cfs or less will flow across plant grade during a PMF

on Deer Creek., Therefore o ur position remains that under current criteria

-2-

the plant would have to be protected against an 8.0 foot depth of water

resulting from the PMF on Deer Creek. If the licensee has an analysis

that shows a Deer Creek PMF considerably less than 37,500 cfs, it should

be submitted to NRC for review and approval. Our evaluation could then

be revised accordingly.

4. (a) Our conservative analysis was accomplished by developing rating curves

for (1) the area south of the plant where the flow leaves Deer Creek

to flow across the plant yard and (2) for the main Deer Creek channel..

The discharge of 1100 cfs was established'y~ising the discharge channel

wall as a weir and backing flow across the plant yard until the

limiting elevation of 254.25 was attained (1100 cfs). Using the ratingl i

curve from item (1) and the 1100 cfs, a water elevation'was obtained;

this elevation was then applied to the Deer Creek rating curve to obtain

the corresponding discharge of 14,000 cfs.

(b) The Albany, NY office of the USGS was contacted on January 16, 1979.

The office furnished draft formulae for computing the 2, 25, 50 and

100 year discharges for Western New York. They stressed that they were

in draft form and not approved. As pointed out in our report the

frequency data was for information purposes only and primarily for

NRC management as a decision making'ool.

5. No response required.

-3-

6. The report will be corrected to include the groundwater information.

7. This cannot be done until system and structural reviewers have assessed

the effects of flood levels and the revetment is repaired.

"8. There is no special criteria for the Systematic Evaluation Program and

the current criteria is defined on page ll. The report states (implies)

that the water supply is acceptable with respect to availability but that

flooding must be resolved. Input from the interface topf'cs can not be

included until the topic reviews are completed. The report will be modified

to show that the water supply and temperature are adequate to meet the

requirements of Regulatory Guide 1.27 and therefore acceptable.

gal% RECy+~4 ~o

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Docket No. 50-244LS05-81 - 04-01 3

P

UNiTED STATESNUCLEAR REGULATORY COMMlSSlON

WASHINGTON, D. C. 20555

April 10, 1981

Mr. John E. MaierYice PresidentElectric and Steam ProductionRochester Gas and Electric CorporationRochester, New York 14649

Dear Mr. Maier:

SUBJECT: SEP TOPICS II-3A "Hydrologic Description"II-3B "Flooding Potential and Protection

Requirements"II-3.81 "Capability of OperatiTig Plants to

Cope With Design Basis FloodingConditions"

II-3C "Safety-Related Mater Supply (Ultimate HeatSink (UHS)) I)

Il

Enclosure 1 is a copy of our evaluation of Systematic Evaluation ProgramTopics II-3A, B, C. This assessment compares your facility, as describedin Docket No. 50-244 and associated submittals, with criteria currentlyused by the regulatory staff for licensing new facilities. Please informus if your as-built facility differs from the licensing basis assumed inour assessment.

Enclosure 2 contains our responses to the additional information you haveprovided to us. Following exchanges between the NRC staff and your staff,we have revised the evaluation to reflect this additional information. Insome cases you have not provided a technical basis for us to alter our con-clusions. Therefore, our review of these topics is complete and thisevaluation will be a basic input to the integrated safety assessment foryour facility unless you identify changes needed to reflect the .as-builtconditions. This topic assessment may be revised in the future if yourfacility design is changed, if NRC criteria relating to these topics aremodified before the integrated assessment is completed or if additionalinformation is provided to the staff.

Enclosure 3 is a draft evaluation of Topic II-3.Bl. You are requested to

reexamine

the facts upon which the staff has based its evaluation and respondeither by confirming that the facts are correct, or by identifying errors and

\

John E. Haier

supplying the corrected information. We encourage you to supply any othermaterial that might affect the staff's evaluation of this topic or be signifi-cant in the integrated assessment of your facility. Your response is requestedwithin 30 days of receipt of this letter. If no response is received- within.that time, we will assume that you have no comments or corrections.

Sincerely,

Enclosure:As stated

nnss H. Crutchfsel , iefOperating Reactors BranDivision of Licensing

CC:See next page

e

fh g

Nr. 8ohn E. Naier

CC

Harry H. Voigt, EsquireLeBoeuf, Lamb, Leiby and NacRae1333 New Hampshire Avenue, N. W.

Suite 1100Washington, D. C. 20036

Nr. Michael Slade12 Trailwood CircleRochester, New, York 14618

Ezra BialikAssistant Attorney GeneralEnvironmental Protection BureauNew York State Department of Law2 World Trade CenterNew York, New York 10047

Jef frey CohenNew York State Energy Offi ceSwan Street BuildingCore 1, Second FloorEmpire State PlazaAlbany, New York 12223

Director, Technical DevelopmentPrograms

State of New York Energy OfficeAgency Building 2Empire State PlazaAlbany, New York 12223

Rochester Public Library115 South AvenueRochester, New York 14604

Supervisor of the Townof Ontari o

107 Ridge Road WestOntario, New York 14519

Resident InspectorR. E. Ginna Plantc/o U. S. NRC

1503 Lake RoadOntario, New York 14519

Director, Criteria and StandardsDivision

Office of Radiation Programs(ANR-460)

-U. S. Environmental ProtectionAgency

Washington, D. C. 20460

U. S. En vi ronmenta 1 P rotect i onAgency

'egionII OfficeATTN: EIS COORDINATOR26 Federal PlazaNew York, New York 10007

Herbert Grossman, 'Esq-, Chairman'tomicSafety and Licensing Board

U. S. Nuclear Regulatory CommissionWashington, D. C. 20555

I

Dr. Richard F. Cole "

Atomic Safety and Licensing BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Dr. Emmeth A. LuebkeAtomic Safety and Licensing BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Nr. Thomas B. CochranNatural Resources Defense Council, Inc.1725 I Street, N. W.

. Suite 600

. Washington, D. C. 20006

Ezra I. BialikAssistant Attorney GeneralEnvironmental Protection BureauNew York State Department of Lair2 World Trade CenterNew York, New York 10047

~~

TOPIC II-3.A AND B HYDROLOGIC DESCRIPTION AND FLOODING POTENTIAL ANDPROTECT ION REQUIREMENTS

1. 0 INTRODUCTION

This topic encompasses both surface and groundwater and their interface

with plant safety-related buildings and systems. It provides a brief

description of the hydrologic features of the site ard surrounding area.

A Design Basis Flood for the plant is developed, using current criteria, and

compared to the design basis event that was used for construction, if any.

Deviations and their safety significance are discussed. In addition to an

external Design Basi: Flood (off site source), a local Probable Maximum Flood

resulting from Probable Maximum Prei.'ipitation on the plant area is also

developed to determine flood potential from the local runoff.

>Jhere physical protection is used to prevent plant flooding, its design

and design bases are reviewed and compared to current criteria. The variations,

if any, and safety significance of the variations are discussed.

The. Design Basis Groundwater Level is determined in accordance with current

criteria. Permanent Dewatering Systems (underdrains) are identified. The

eva1uation oi. underdrains is described in Topic III-3.B.

The information used to perform the reviews was gathered from the licensee'ss

files, NRC files, and the site visit. In some cases, detailed information was

not available. In such cases, the staff conservatively estimated any

parameters required for analysis.

The current criteria applicable to this topic are: (1) Standard Review

Plans 2.4.1, 2.4.2, 2.4.3, 2.4.5, 2.4.7, 2.4.8, 2.4.10, 2.4.11, 2.4.13,

2.4.14, 3.4.1 and 9.2.5; (2) Regulatory Guides 1.102, 1.127, 1.27,

1.59, and 1.70; and . (3) American National Standard Institute Standard

N170-1976.

-2-

Regulatory Guides 1.59 and 1.102 have been specifically identified by the

NRC's Regulatory Requirements Review Committee as needing consideration for back-

fit on operating reactors. These guides are utilized in determining whether

the facility design ccmplies with current criteria or has some equivalent

alternatives acceptable to the staff. The acceptability or'onacceptability of

any deviations identified in this evaluation .and the need for further action willbe judged during the integrated assessment for this facility.

This output from these analyses include groundwater and surface water levels

and associated loadings for safety related buildings agd equipment. These values

are furnished to structural and system reviewers for assessment of effects.

Interface topics are: (1) II-4E Dam Integrity; (2) III-3.A Effects of High

~Water Level on Structures; (3) III-3.B Structural and Other Consequences (

(e.g., Flooding of Safety-Related Equipment in Basements) of Failure of Underdrain-

Systems; (4) III-6 Seismic Design Considerations; (5) YII-3 Systems Required

for Safe Shutdown; (6) VIII-2 Onsite Emergency Power Systems - Diesel Generator;

(7) IX-3 Station Service and Cooling Water Systems; and (8) XYI Technical

Specifications.

The category of "In Service Inspection'of Water Control Structures"

requires hydrologic review and input; however, the hydro'logic aspects are

addressed in Topic III-3.C.

2. 0 HYDROLOGIC. DESCRIPTION

Lake Ontario, on which the site is located, is about 190 miles long, 50 miles .

wide, a maximum of 780 feet deep and covers an area of about 7500 square miles.

The:.verage lake level, based on over a hundred years of record, is 246 feet msl.

~~

3

The highest instantaneous still water lake level was 250.2 feet msl. Lake

Ontario seldom freezes over, but ice occurs in the winter usually along the1

southern and northern shores and in the northeastern end of the lake.'*

The surface of the land on the southern shore of Lake Ontario, at the site

and east and west of it, is either flat or gently roll-ing as shov(n on

Figure 2.0.1. It slopes upward to the south from an elevation of about 255 feet

msl near the edge of the lake to 440 feet msl at Ridge'Road (New York State

Highway 104) 3 1/2 miles south of the lake.

There are no perennial streams on the site, but Oeer Creek, an intermittentl<~ F~i

stream with a drainage area of abouts square miles, enters the site from thel

west, passes south of the plant and empties into the lake near the northeastern

corner of the site.

The main plant area and buildings are at grade elevation 270.0 feet msl l

the north side of the turbine building and the river screenhouse are at elevation

253.5 feet msl.

The plant is protected from surges and wind. driven waves by a revetment

with a top elevation of 261.0 feet msl. All facilities necessary to shut

down and to maintain safe shutdown are flood-protected to a maximum stillwater level of 254.25 feet msl. The screenhouse floor is at elevation 253.5

feet.msl and the 0.75 foot curbs provide additional protection from pote'ntial

exterior flooding. Additional flood protection is available. in the

screenhouse for the diesel generator buses, which are set 16 inches

above the floor, and the service water pump motors which are set 24 inches

above the floor. The diesel generators, which are located in the north

side of the turbine building, are flood protected by steel curbs projecting

18 inches above elevation 253.5 feet msl.

3.0 FLOOD POTENTIAL AND PROTECTION RE UIREMENTS

. Independent estimates were made of the flood levels which would

occur at safety related buildings, assuming an occurrence of the local~CM

v'robableMaximum Precipitation (PMP). Rainfall was assumed to occur

in the immediate plant area and the resultino flow (runoff) movedI

overland toward the discharge canal. Rainfall depths were: obtained

from Hydrometeorological Report No. 51, 'for the 13.9 acre drainage(a)

area. The time of concentration and peak discharge of 400 cf were

computed with methods described in Design of Small Dams. The flood(5)

water will pond to an elevation of about 254.5 feet msl at the north

(lower) portion of the site in the vicinity of the screen house.

3.2 Deer Creek PMFr

The water levels produced by a Probable Maximum Flood (PMF) on Deer Creek,

a small stream which, under normal conditions flows north and eastwardI

around the Ginna site, were evaluated. The drainage area of Deer Creek

is 13.3 square miles. The Probable Maximum Precipitation (PMP)

was obtained from reference (4). The runof hydrograph was developed

using procedures from reference (5) and backwater computations were made

using the HEC-2 Backwater Program (6). Cross sections for the backwater

ccmputations were taken from drawing Ho. SK447-93.

The PMF flow of 37,500 cfs would produce a water surface elevation ofl

about 275 ft msl on the south: (higher) side of .the plant. Since plant

grade in this area is elevation 271.0 ft msl, flood water will flow over

the plant yard toward the screenhouse and discharge channel at a rate

of about 13,500 cfs. The discharge canal does not have sufficient

capacity to discharge this flow. Mater will pond to a depth of about

eight feet over plant grade in this area of the plant. Safety related

equipment is protected to a depth of only 0.75 to 2.0 feet.

Further analysis has revealed that elevation 254.25 would not be exceeded

if the flow in Deer Creek did not exceed 14,000 cfs, of which 1100 cfs

flows overland toward the screenhouse and discharge channel.

For informational purposes only, the 100-year flood on Deer Creek would

produce a peak discharge of about 3000 cfs, based on regional estimates

'ecently developed by the U. S. Geological Survey.

V

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3.2.1 Availabilit of Safet S stems

It must be emphasized that there will be little, if any, warning time

before the plant is flooded by a PHF on Deer Creek due to short times of

concentration of flood flows. Therefore, credit should not be given forh

implementation of temporary flood-proofing measures to protect safety

systems. Rather, permanent flood protection appears to be the best

measure for protecting the plant.

3.2.2 Probabilit of Initiatin Events4'" g,~i r

The PNF estimate was calculated using a deterministic method of analysis,

wherein various flood-producing parameters were maximized to produce theC

most, severe lood considered reasonably probable in She region. No

statistical analyses were used by the NRC staff to determine these

parameters. Me therefore believe that no attempt can or should be made

to assign a probability to the PHF for Deer Creek.

3.2.3 Past Plant Ex erience

Plant personnel have stated that no serious floods have occurred on Deer

Creek during the operating life of the plant.

3.3.0 Lake Ontario Surae Floodin

Visual observations during the SEP site visit- indicate the revetment fronting

.the plant on. the west side of the discharge canal is significantly degraded.

Portions of. the revetment would be incapable of providing adequate protection

from wave attack during a severe storm', up to and including the Probable

Maximum Mater Level (PHWL), resulting from the Probable tlaximum Surge (PV5)

I

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&7

on Lake Ontario which is the design basis flood for the revetment. It is

not possible at this time, due to a lack of information regarding revetment

geometry and stone sizes, to determine the exact water levels and wave

heights for which the existing protection will function. If the revetment

is assumed to be eroded significantly (as it apparently is), and the design-

basis storm occurs, we calculate that about 2.5 feet of water would be

ponded in the vicinity of the screen house and discharge canal, which would

exceed the elevation of the emergency buses and be about the same elevation

as the eight service water pump motors.

I'Q!

We have, however, performed an independent analysis, using procedures

from the Shore Protection Manual, of the stability of the revetment(7)

Iassuming it exists as designed. We find that, under these conditions, the

revetment would be capable of resisting the Lake Ontario PMl<L and a'ssociated

wave action and wou1d, therefore, meet current regulatory criteria.

As a condition of the FTOL, the staff required the placement of additional

shoreline erosion protection. This protection was added to ensure minimum

wave overtopping of the concrete wall fronting the plant and lower water

levels in the vicinity of the screen house. Nevertheless, the revetment,

as it currently exists, would likely fail during an occurance of. the PHWL.

This failure would likely lead to a subsequent fai lur'e of the additional,

protection installed as a requirement of the FTOL.

We, therefore, recommend that damaged or inadequate portions of the revetment

be repaired and returned to design conditions. The repairs should be

performed as soon as the weather permits. In addition, we recommend thata technical specification be developed and implemented to provide formaintenance of the revetment as designed.

1

4.0 Desi n Basis Groundwater Levels

The design basis groundwater elevation for the Screenhouse/ESW

structure was 253.5 feet HSL and the design basis for all other

safety related structures was elevation 250.0 feet HSL (Ref. Letter

RGE to DRC November 14, 1979; Letter RGE to NRC January 28, 1981)./

The design basis under current criteria should be ground elevation

at the structure in question. This will vary from elevation 253.5

feet HSL on the north side of the plant to about elevation 270.0 feet

HSL on the south side. No groundwater contour map's or we'l hydro-

graphs have been submitted to justify using a lower groundwater level.

0

5.0 Conclusions

5.1 ~L1 F1 di

It is concluded that flood water will pond to an elevation of

about 254.5 feet HSL at the north area of the site in the vicinity

of the screenhouse. As a result of RGE's response number one in

the submittal dated 1/28/81, it is concluded that the statements

in the Ginna FSAR 2;6-,10 are still valid and the paragraphs on

pages 3 and 4 of the Topic II-3A, B, C evaluation regarding limit-

ing equipment elevations are correct. Per the Ginna FSAR 2.6-10,

the limiting elevation for'lass I equipment -is elevation 253.5

(screenhouse floor elevation). Adding 0.75 feet for curbs aroundh

the screenhouse floor provides protection to elevation" 254.25. This

is still below the predicted local flood level; however, the licensee

has verified that the limiting elevation of safety-related equipment

is 254.8 feet MSL (screenhouse floor elevation of 253.5 plus 1.3'odiesel generator buses 17, 18). Therefore, safety related equipment

would be unaffected by local floods, and the plant would be able to with-

stand local flooding with no detrimental effects.

5.2 Deer Creek PHF

The PMF will cause a water surface elevation of about 275'eet MSL on

the south side of the plant where grade is approximately 271 feet HSL.

On the north side of the plant where grade is approximately 253.5,. feet

HSL, the PMF will cause water to pond approximately eight feet::above

grade. This would lead to unacceptable consequences to pla'nt systems

in the auxiliary and diesel generator buildings due to in-leakage. The

ability of plant structures to withstand this water level is considered

in Topic III-3A.

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5.3 Lake Ontario Sur e Floodin

The plant is protected by a revetment fronting Lake Ontario. Signifi-

. cant erosion of the revetment was noted during the site visit. Assum-

ing that the revetment is eroded, approximately 2.5 feet of water

will pond in the vicinity of the screenhouse submerging the emergency

buses. If the revetment exists as designed, it would be capable of

resisting surge flooding from Lake Ontario and therefore meet current

regulatory criteria. The licensee has agreed to inspect the revetment

for erosion and return it to its original design condition.

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~

~~

6.0 REFERENCES

1. Standard Review Plans, NUREG 75/087, U. S. Nuclear RegulatoryComnission, Office of Nuclear Reactor Regulation.

a ~

b.C.d.e.f.9.h.i.

'-

k.l.

2.4.1-2.4.2-2.4.3-2.4.5-2.4.7-2.4.8-2.4.10-2.4.11-2.4.13-2.4.14'-

3.4.1-9.2.5-

Hydrologic DescriptionFloodsProbable Maximum Flood (PMF) on Streams and Rivers.Probable Maximum Surge and Seiche FloodingIce EffectsCooling Water Canals and ReservoirsFl ooding Protection RequirementsLow Mater ConsiderationsGroundwaterTechnical Specifications and Emergency OperationRequirementsFlood ProtectionUltimate Heat Sink

2. Regulatory Guides, U.S. Nuclear Regulatory Comnission, Officeof Standards Development.

a.b.

C.d.e.

1.102 - Flood Protection for Nuclear Power Plants1.127 - Inspection of Water Control Struc .ures Associated

with Nuclear Power Plants l1.27 - Ultimate Heat Sink for Nuclear Power Plants1.59 '

Design Basis Floods for Nuclear Power Plants1.70 - Standard Format and Content of Safety Analysis Reports

for Nuclear Power Plants, NUREG-75/094

3. American National Standard N170-1976, "Standards for DeterminingDesign Basis Flooding at Power Reactor Sites," Published by the AmericanNuclear Society (ANS-2.8)

4. U. S. Department of Conrnerce, Nat'ional Oceanic and AtmosphericAdministrati,on - U.S. Department of the Army Corps of Engineers, Hydro-meteorological Report No, 51, June 1978, "Probable Maximum PrecipitationExtimates: United States East of the 105th Meridian."

5. U.S. Department of Interior, Bureau of Peclamation, 1977,"Designof Small Dams."

6. U.S. Army Corps of Engineers Hydrologic Engineering Center,February 1972, "Water Surface Profiles (HEC-2) Users Manual."

7. U.S. Army Coastal Engineering Research Center, 1977, "ShoreProtection Manual."

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TOPIC II-3.C. SAFETY RELATED MATER SUPP' {UHS)

1. 0 INTRODUCTION

This topic'reviews the acceptability of' particular feature of the

cooling water system, namely, the Ultimate Heat Sink (UHS). The review is

based on. current criteria contained in Regulatory Guide 1.27 {Rev. 2) which

is an interpretation of General Design Criteria 44, "Cooling Mater" and General

Design Criteria 2, "Design Bases for Protection Against Natural Phenomena," of

Appendix A to 10 CFR Part 50. This regulatory guide has been specifically identified

by the NRC's Regulatory Requirements Review Commit ee as needing consideration't

for backfit on operating reactors. This guide is'til'ized i'n determining whether

the facility design complies with current criteria or has some equivalent

alternatives acceptable to the staff; The acceptability or non-acceptability ofk c

any deviations identified in this evaluation and the need for furth'er action will

be judged during the integrated assessment for this facility.

In addition to Regulatory Guide 1.27, guid'ance is also contained in:

Standard Review Plans 2.4.11. and 9.2.5, American National Standards Institute

Standard N170-1976, and Regulatory Guides 1.59 and 1.127.

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The UHS as reviewed under this topic is that complex of water sources,

including necessary retaining structures (e.g., a pond with its dam or a cooling

tower supply basin) and the canals or conduits connecting the source with but not

including, the cooling water system intake structures.

This topic interfaces with Topic numbers II-3.B, III-l, III-3.A, III-3.B, III-3.fIII-6, VI-7.D, VII-3, VII-4, VIII-2, IX-3, XV-24, and XVI, for the review of

structures containing the safety related wa .er supply system, the systems themselves

and emergency electrical power.

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2.0 Ultimate Heat Sink UHS

The ultimate heat sink for the Ginna Plant is Lake Ontario. The inlet crib

for the plant is on the lake floor about 3000 feet offshore. Hater is

conveyed from the crib to the Screenhouse (intake structure) through a buried

conduit. The circulating and service water pumps are located in the screenhouse.

The minimum mean monthly lake level of record for Lake Ontario at the

Rochester, NY gage is elevation 243.0 ft. msl. The lowest entrance level

into the intake crib is elevation-.217.0 ft msl. This 26 foot (243.0-217.0)

depth of water at minimum lake level is more than adequate to accommodate the

maximum setdown (negative surge) for this part of the lake which is less thanI l

5.0 feet. Lake Ontario meets the current regulatory criteria with regard

to low water requirements.

The consideration of design basis temperature for safety-related

equipment is only required where the supply may be limited or where

the temperature of plant intake water from the sink may eventually

become critical (e. g., Ponds, small lakes, cooling towers or other

sinks where recirculation between plant cooling water discharge and

intake can occur). This is not a consideration for the Ginna Plant

and Lake Ontario because the intake water is withdrawn from the

bottom of the lake and the water temperature of this large lake

are relatively stable.

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Based on our analyses, the ultimate heat sink complex would meet current

regulatory criteria with regard to flooding except for an occurrence'f the

probable Maximum Flood on Deer Creek. Flooding at the screen house would

inundate both the service water and circulating water pumps. .The seismic

capability of UHS structures and conveyances is being reviewed in

Topic III-6. Our review of the availability of cooling water from

Lake Ontario indicates that it is an acceptable source for the safety

related water supply and ultimate heat sink.

Enclosure 2

NRC Responses to Rochester Ggs and Electric Commentson SEP Topics II-3.A, II-3.B, and II-3.C (RGE submittal 1/28/81)

1. The evaluation has been revised to reflect the plant's ability to

resist local flooding.

2. Drawing titled, "RE GINNA Plot Plan," Redrawn 3/3/79, Dwng No. 33013-352,

was used to measure the drainage area.

3. No bases have been provided for the licensees'tatements. Using the

Generalized PHF curves in Regulatory Guide 1.59; we estimated the PMF

to be 500,000 cfs for the 2600 S.M. Genesee River Basin. The 37,500 cfs

estimate for the Deer Creek PMF is 7.4Ã of the 500,000 cfs value, not 70K.

The Deer Creek PMF is about 69K of the estimated maximum historical flow

of the Genesee River (54,000 cfs on March 18, 1965). This flow can be

considered to be a very rough estimate of the 100 year flood on the Genesee

River and as such should be compared to our estimated 100 year flood for

Deer Creek. The Deer Creek 100 year flood is about 5.6X of this maximum

historical flood in the Genesee River. The licensee has~provided no

documentation or bases to show that the Deer Creek PHF is less than37,500'fs

or that only 1100 cfs or less will flow across plant grade during a PHF

II

on Deer Creek. Therefore our positon remains that under current criteriathe plant would have to be protected against an 8.0 foot depth of water

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resulting from the PHF on Deer Creek. If the licensee has an analysis

that shows a Deer Creek PHF considerably less than 37,500 cfs. it should

be submitted to NRC for review and approval. Our evaluation could then

be revised accordingly.

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4

6. The report has been corrected to include the groundwater information.

7. Conclusions have been added to the extent possible. Com'piete con-

clusions regarding flooding protection requirements cannot be made

until the effects of flood levels on systems and structures have been

addressed and the revetment is repaired.

8. There is no special criteria for the Systematic Evaluation Program and

the current criteria is defined on page 11. The report states (implies)

that the water supply is acceptable with respect to availability but that

flooding must be resolved. Input from the interface topics can not be

included until the topic rev'iews are completed The 'report has been

modified to show that the water supply and temperature are adequate to

meet the requirements of Regulatory Guide 1.27 and therefore acceptable.I,

Enclosure 3

SEP Safety Topic Evaluation.Ginna Nuclear Power Station.

Topic II-3.B.1 - Capability of Operating Plants to Cope with Design BasisFlooding Conditions

I. INTRODUCTION

One method of protecting a plant against postulated floods is by

implementing appropriate technical specifications and emergency procedures.

This topic reviews existing technical specifications and emergency

procedures to assure that the originally imposed technical specifications

and emergency procedures can still adequately protect Category I structures,

systems and components.

II. CURRENT REVIEW CRITERIA

Current review criteria are identified in Regulatory Guide 1.59, and

Standard Review Plan Section 2.4.10.

III. RELATED SAFETY TOPICS AND INTERFACES

The following topics relate to Topic II-3.B.l:

l. II-3A Hydrologic Description

2. II-3B Flooding Potential and Protection Requirements

3. III-3A Effects of High Water Level on Structures.

V. EVALUA1ION

There are no existing emergency plans or Technical Specifications for

the Ginna Plant that relate to flooding from external sources. The determination

of need to install emergency plans or Technical Specificationsas a result of

revised design bases flood levels will be made during the integrated assessment

of the plant.