ML13310A889

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Superseding Omaha Public Power District'S (OPPD) Response to NRC Request for a Timeline to Implement Strategies at Fort Calhoun Station, Unit 1 to Address Higher Flooding Hazards Relative to the Design Basis
ML13310A889
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 10/26/2013
From: Cortopassi L P
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-13-0140
Download: ML13310A889 (6)


Text

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 ATTACHMENT 3 CONTAINS SECURITY-RELATED INFORMATION.

UPON REMOVAL OF ATTACHMENT 3, THIS LETTER IS DECONTROLLED. iJppB ----Omaha Public Power District 444 South 1 fr Street Mall Omaha, NE 68102-2247 October 26,2013 LI C-13-0 140 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

References:

1. Docket No. 50-285 2. Letter from NRC (Joseph M. Sebrosky) to OPPD, "Summary of Closed Meeting Held on April 22, 2013, with Omaha Public Power District to Discuss Means for Protecting Fort Calhoun Station Unit 1 , Against Flooding (T AC No. MF0598)," dated April 25, 2012 (ML13114A881) (NRC-13-0051)
3. Letter from U.S. Army Corps of Engineers (S. C. Kessler) to OPPD (K. Stultz), "Missouri River Flood Discharges for Flood Recurrence Intervals," dated January 14, 1993 4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District (OPPD) Response to NRC Request for a Timeline to Implement Strategies at Fort Calhoun Station Unit 1 to Address Higher Flooding Hazards Relative to the Design Basis," dated September 12, 2013 (LlC-13-0116)

Subject:

Superseding Omaha Public Power District's (OPPD) Response to NRC Request for a Timeline to Implement Strategies at Fort Calhoun Station Unit 1 to Address Higher Flooding Hazards Relative to the Design Basis In order to address additional NRC concerns, OPPD hereby withdraws Reference 4 and supersedes it with this submittal.

In Reference 2, the NRC requested that OPPD provide a timeline to implement strategies at Fort Calhoun Station, Unit 1 to address higher flooding hazards relative to the design basis. Attachment 1 provides a list of the actions taken or planned to be taken along with additional supporting details and the dates by which they have or will be implemented.

OPPD will not modify any of these interim actions or completion dates without notifying the NRC Project Manager in advance. OPPD has verified that the elevation of the alternate emergency operations facility is sufficient to ensure that this facility will be available in the event of a beyond design basis flood. Per Emergency Plan Implementing Procedure (EPIP)-TSC-2, Catastrophic Flooding Preparations, "An alternate location for the EOF [Emergency Operations Facility]

would be within Energy Plaza [OPPD's corporate office building]

or other OPPD facility with similar communication and technology capabilities

." Energy Plaza, located at 444 South 16 th Street , Omaha , Nebraska is at elevation 1,070' mean sea level (MSL) and is 12 blocks west and 4 blocks south of the 1-480 WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 ATTACHMENT 3 CONTAINS SECURITY-RELATED INFORMATION. UPON REMOVAL OF ATTACHMENT 3 , THIS L ETTER IS DECONTROLLED. Employment with Equal Opportunity WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 ATTACHMENT 3 CONTAINS SECURITY-RELATED INFORMATION.

UPON REMOVAL OF ATTACHMENT 3, THIS LETTER IS DECONTROLLED.

U. S. Nuclear Regulatory Commission L1C-13-0140 Page 2 Bridge over the Missouri River. Therefore, the alternate EOF location at Energy Plaza will be available.

Attachment 2 is a topography map showing the location of Energy Plaza. Attachment 3 describes OPPD's ability to protect the plant from a Beyond Design Basis flood. The information in Attachment 3 is security-related and must be withheld from public disclosure in accordance with 10 CFR 2.390. Upon removal of Attachment 3, this letter is decontrolled. As stated in Reference 2, OPPD also agreed to provide feedback to the Regional Staff on whether or not non-safety related switchgear cooling is needed for conditions less than the design basis flood. The response to that issue is not contained in this submittal.

However, OPPD is tracking the issue under Performance Improvement Integrated Matrix (PIIM) No. 2013-0085 and Asset Suite Action Request (AR) 59063-02.

The attachment to this letter contains new regulatory commitments.

Actions that remain are denoted by an AR tracking number in bold font. If you should you have questions, please contact Mr. Bill Hansher at (402) 533-6894.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 26, 2013. Sincerely, Louis P. Cortopassi Site Vice President and CNO LPC/JKG/mle Attachments:

1. Interim Action Commitments to Address Higher Flooding Hazards Relative to the Design Basis 2. Elevation of the Alternate Emergency Operations Facility 3. Strategy to Protect Fort Calhoun Station From Beyond Design Basis Flood c: M. l. Dapas, NRC Regional Administrator, Region IV J. M. Sebrosky, NRC Senior Project Manager l. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector WITHHOLD FRO M PUBLIC DISCLOSURE UNDER 10 CFR 2.390 ATTACH M ENT 3 CONTAINS SECURITY-RELATED INFORMATION.

UPON REMOVAL OF ATTACHMENT 3, THIS LETTER IS DECONTROLLED.

LlC-13-0140 Attachment 1 Page 1 Item Number 1 2 3 4 5 Fort Calhoun Station Interim Action Commitments to Address Higher Flooding Hazards Relative to the Design Basis Actions Taken or Planned to Take as Additional Actions Discussed in Reference 2 Analysis of steam flow requirements, None adequacy of natural circulation, maintenance of RCS inventory, boration strategy, hydraulic requirements for SG and RCS makeup, diesel sizing and fuel consumption, and Auxiliary Building roof loading to implement the strategy to mitigate a Beyond Design Basis (BDB) flood. Design equipment to implement the None strategy to mitigate a Beyond Design Basis (BDB) flood. Procure equipment to implement the None strategy to mitigate a Beyond Design Basis (BDB) flood. Functional testing of equipment to None implement the strategy to mitigate a Beyond Design Basis (BDB) flood. Deploy equipment to implement the None strategy to mitigate a Beyond Design Basis (BDB) flood. Implementation Date Action is complete Action is complete Action is complete Action is complete Action is complete L1C-13-0140 Attachment 1 Page 2 Item Number 6 Fort Calhoun Station Interim Action Commitments to Address Higher Flooding Hazards Relative to the Design Basis Actions Taken or Planned to Take as Discussed in Reference 2 Revise procedures, V&V procedures and I None train personnel on procedures Actions completed:

Plant walk downs and tabletop reviews were conducted to ensure that the tasks of the strategy could be completed in the allotted time. This included stepping through the procedures to verify that connection pOints and labeling were accurate, measuring distances between emergency portable equipment (EPE) and plant connection pOints to confirm hose and cable lengths, measuring openings and pathways to confirm packages could be transported to their deployment location, and verifying connection sizes. The tabletop review included reviewing procedure steps to determine conservative timing for the deployment of the EPE components and an approximation of manpower required.

Operators received overview training on the equipment, draft procedures, and deployment strategy.

Additional Actions Implementation Date Action is complete LlC-13-0140 Attachment 1 Page 3 Item Number 7 8 9 Fort Calhoun Station Interim Action Commitments to Address Higher Flooding Hazards Relative to the Design Basis Actions Taken or Planned to Take as Additional Actions Discussed in Reference 2 Verify that the flood mitigation strategy can Verify that the flood mitigation be properly implemented within the strategy can be properly implemented required timeframes.

Timing evaluations within the required timeframes using have been completed.

reasonable simulation as defined in NEI 12-07. (AR 60073-03)

Preventative Maintenance Issue preventative maintenance procedures and initiate preventative maintenance. (AR 60073-04)

Flooding actions for Modes 4 and 5 when 1. Develop strategy. (AR 60073-05)

RCS is not intact 2. Revise procedures and complete training. (AR 60073-06)

3. Verify that the flood mitigation strategy can be properly implemented within the required timeframes. (AR 60073-07)

_._-Implementation Date March 31,2014 December 31, 2013 I 1. June 30,2014 2. September 30, 2014 3. Prior to start of 2015 refueling outage (Le., spring 2015)

LlC-13-0140 Attachment 2 Page 1 u; £ ,... ... rn Elevation of the Alternate Emergency Operations Facility o 1 2.525 50 Scale Howard St