ML13056A120

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Email from M. Franovich, NRR to L. Olshan, NRR Et Al Response: Please Review 50.54(f) Letter on Floods R2
ML13056A120
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 06/24/2008
From: Mike Franovich
Office of Nuclear Reactor Regulation
To: Olshan L, Melanie Wong
Office of Nuclear Reactor Regulation, License Renewal Projects Branch 2
References
FOIA/PA-2012-0325
Download: ML13056A120 (2)


Text

Circle, Jeff From:

Mike Franovich Sent:

Tuesday, June 24, 2008 4:03 PM To:

Leonard Olshan; Melanie Wong Cc:

Kamal Manoly; Raman Pichumani; Jeff Circle; John Stang

Subject:

RE: Response: Please review '50 54(f) letter on floods R2' For sake of time, let's move forward with the letter without DE input. There is no doubt the letter will look like a fishing expedition but so be it. By the time the letter goes through concurrence, it probably won't resemble what was originally written.

From: Leonard Olshan I

C--_-___._

Sent: Tuesday, June 24, 2008 3:24 PM To: Mike Franovich; Melanie Wong Cc: Kamal Manoly; Raman Pichumani; Jeff Circle; John Stang

Subject:

RE: Response: Please review '50 54(f) letter on floods R2'

Mike, Upon further reflection, I'm wondering if asking for the DE information means that we are anticipating an analytical argument from the licensee, rather than a commitment to raise the wall.

I expect that in the 30-day response we would probably get an approach (either analytical or hardware mods) with a schedule; I would be surprised if we actually got some type of analytical justification for the flood height, dam failures, etc. Therefore, we could ask those types of questions after we receive the 30-day response.

Let me know if you still would like to ask for the DE-needed information.

Thanks.

From: Mike Franovich Sent: Tuesday, June 24, 2008 1:04 PM To: Melanie Wong; Leonard Oishan Cc: Kamal Manoly; Raman Pichumani; Jeff Circle; John Stang

Subject:

RE: Response: Please review '50 54(f) letter on floods R2' Melanie W. & John, I've reviewed the new paragraph in the letter. You had the best of intentions but I find that there are some concerns we should address. First, although the paragraph is factual, it is inflammatory since it opens up a sore episode between the licensee and NRC regarding the licensee's bogus estimate of the likelihood of Jocassee Dam failure. We need not mention this fact as it will be a distractor and because the staff has a reasonable estimate of the J-Dam failure firequency. We should simply say in the background section:

Upon further review after the resolution qfthe inspection finding on the breached SSF lood barrier, the stq/f reviewed the facts and circumstances regarding overall adequacy qf the flood protection of the Oconee Nuclear Station given the flood inundation study. Specificallv, given a Jocassee Dam failure, it appears that unfavorable physical characteristics o/

the site exist and that Oconee Nuclear Station lacks appropriate and adequate compensating engineering safe guardds.

This proposed language is similar to IOCFRPart1OO regarding reactor siting criteria which includes hydrological hazards.

In addition, I still think we need to specify the information that DE needs from the licensee such as the inundation study details, the pedigree of the code used, key assumptions, and degree of conservatism in their estimate if any. The specifics of what DE needs from Duke was an action item firom the 05/30/08 meeting since DE proposed the 50.54(f) letter approach.

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Mike From: Melanie Wong Sent: Friday, June 20, 2008 10:18 PM To: Mike Franovich; Leonard Olshan Cc: Kamal Manoly; Raman Pichumani; Jeff Circle; John Stang

Subject:

Response: Please review '50 54(f) letter on floods R2' Gentlemen-See revised attachment with my revisions/comments. Please feel free to change as I'm still new to NRR.

I added in the second para to clarify how the issue arose, reviewed ADM 200 on NRR signatory authority and changed the signature block to Giitter (I could be wrong), and changed the concurrence blocks (e.g., included RFI).

I will be gone until July 1 st and John Stang can concur for me.

Take care, Melanie From: Mike Franovich Sent: Thursday, June 19, 2008 3:18 PM To: Leonard Olshan; Raman Pichumani; Jeff Circle Cc: Kamal Manoly; Melanie Wong

Subject:

Please review '50 54(f) letter on floods R2' Thank you for promptly following up on this action item from our working group meeting of 6/17/08. I believe we are getting closer to sending this letter through the concurrence chain. Attached are my additional comments on the letter and the new enclosure.

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