ML14058A225
| ML14058A225 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/26/2014 |
| From: | Cortopassi L Omaha Public Power District |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LlC-14-0010 | |
| Download: ML14058A225 (9) | |
Text
-~.:..
jjjjjjjj Omaha Public Power District 444 South 1(jh Street Mall Omaha, NE 68102-2247 LlC-14-0010 February 26, 2014 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 10 CFR 50.54(f)
Subject:
Extension Request - Response to March 12, 2012, Request for Information Enclosure 2,
Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report
References:
See Page 5 On March 12, 2012, the NRC staff issued Reference 1 requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(f). of that letter contains specific Requested Information associated with Near-Term Task Force Recommendation 2.1 for Flooding.
On May 11, 2012, the NRC issued Reference 2, which contained the NRC's prioritization plan and due dates for the submittal of Flooding Hazard Reevaluation (FHR) Reports for all sites. Fort Calhoun Station (FCS), Unit 1, was identified as a Category 2 Site requiring the submittal of a FHR Report by March 12, 2014.
In August 2013 (Reference 3), the Omaha Public Power District (OPPD) and the Nebraska Public Power District (NPPD) (hereinafter referred to as the licensees) stated they were jointly developing the FHRs for FCS and Cooper Nuclear Station (CNS), respectively.
This collaboration began in 2012 as discussed in Enclosure 2 and was advantageous to the licensees due to the proximity of the sites and the need to analyze a significant common flooding source, i.e., the Missouri River. The FCS and CNS FHRs will assess flood hazards due to flooding in streams and rivers, including potential site flooding due to failures of the U. S. Army Corps of Engineers (USACE) Missouri River Mainstem Reservoir System dams (USACE System). The licensees requested NRC assistance in obtaining USACE information for this effort so that they were not forced to rely on older publically available data to develop the HEC-RAS model and dam failure analyses. The licensees noted that the inability to acquire the information from the USACE was impacting the schedule to complete the FHA.
In September 2013 (Reference 4), OPPD was informed that the USACE would perform the portion of the FCS FHR associated with the evaluation of potential site flooding due to USACE System dam failures and that the NRC would provide results of the USACE portion of the FHR to OPPD.
Employment with Equal Opportunity
U. S. Nuclear Regulatory Commission LlC-14-0010 Page 2 Pursuant to the guidance provided in Reference 5, the purpose of this letter is to request an extension for the submittal of the FCS FHR Report to ten (10) months after data from the USACE System Dam Failure Analysis is received.
For extension requests, Reference 5 states the following information should be included: 1) the reason for the delay; 2) a proposed schedule for the submittal of a complete Hazard Reevaluation Report; and 3) the basis for the acceptability of the revised schedule.
Reason for the Delay The reasons for the delay are as follows:
In a December 2013 meeting (Reference 6) the licensees were advised that they would receive the USACE analysis results for flooding in streams and rivers from potential USACE System dam failures by April 2014. As discussed in Reference 6, the licensees provided their request for analysis results in the form of flow versus time hydrographs, flow distribution, and water surface elevation versus time hydrographs at locations on the Missouri River for scenarios identified in the Dam Failure ISG (Reference 7).
Due to the large number of dams in the watersheds downstream of the USACE System, the licensees are using the guidance presented in the Dam Failure ISG for analysis of the watersheds contributing to the Missouri River downstream of the USACE System Reservoirs. This analysis cannot be completed until the data from the USACE System Dam Failure Analysis is received.
Reference 1 states the licensee shall provide results of the plant evaluations describing the controlling flood mechanisms and its effects. This includes flood elevations and other effects considered in the flood protection for all flood-causing mechanisms where other effects include dynamic wave effects, scouring, and debris transportation. Flood duration and the condition of the ultimate heat sink upon receding of the floodwaters must also be calculated. The USACE results from the HEC-RAS model are required to calculate this requested information.
Proposed Schedule for the Submittal of a Complete Flooding Hazard Reevaluation Report In support of this extension request, Enclosure 2 provides the project schedule, which incorporates the USACE performance of the dam failure analysis and assumes the receipt of data from the USACE System Dam Failure Analysis on May 1, 2014. The schedule in Enclosure 2 outlines the activities required to comprete the FHR and supports the need to delay submittal of the FCS FHR Report to ten (10) months after data from the USACE System Dam Failure Analysis is received.
The table in Enclosure 2 provides a summary of the changes in the approach, scope, and schedule that have occurred because of the licensees' inability to obtain USACE data and models for the Missouri River. The original approach to developing the FHR was to use the USACE System models. However, significant changes from the original approach occurred in the July 2013 and December 2013 time frames that impacted the schedule to complete the FHA.
U. S. Nuclear Regulatory Commission LlC-14-0010 Page 3 Basis for the Acceptability of the Revised Schedule This extension request is justified on the following basis:
As recognized in the NRC's March 2012 50.54(f) letter, the current regulatory approach and the resultant plant capabilities provide confidence that an accident with consequences similar to the Fukushima accident is unlikely to occur in the United States, and that continued plant operation does not pose an imminent risk to public health and safety.
Therefore, the duration of this extension request has no impact on safe plant operation.
OPPD completed walkdowns at FCS (Reference 8), which verified the current licensing basis for flooding and ensured that the current licensing basis was met. In accordance with the design and licensing basis, FCS is protected from design basis floods up 1,014 feet mean sea level.
The events being analyzed in the FCS FHR are beyond the plant's design and licensing basis. Therefore, the FHR results, which are based on beyond design basis events do not constitute a current operability concern. This is consistent with the NRC's supplemental information letter dated March 1, 2013 (Reference 5).
The events being analyzed in the FCS FHR are very low probability events, and the time frame represented by the extension request would result in an insignificant contribution to the overall risk.Section VII of Reference 9 discusses how water level is controlled in the USACE Missouri River Reservoir System. Reference 10 discusses the current status of the reservoirs stating that "the Missouri River System reservoir levels remain below normal due to the lingering effects of the 2012 drought" and that "the upper three reservoirs, Fort Peck in eastern Montana, Garrison in North Dakota, and Oahe in South Dakota, remain 5 to 11 feet below the desired operating levels." Reference 10 further reports:
In addition to the normal flood control capacity of 16.3 MAF [million acre-feet], the latest reservoir forecast indicates that an additional 6 MAF of storage capacity will be available in the carryover multiple-use zone on March 1, near the start of the runoff season.
That effectively increases the total flood control capacity available by more than 35 percent.
This lower water level decreases the probability that large releases would be required during the period for which the extension is requested. Further, the hydraulic pressure on the dams is less than would be present if they were at their normal water levels.
- Reference 11 discusses mitigation measures OPPD has established to address higher flooding hazards relative to the FCS design basis.
Based on the above determinations, OPPD has concluded that the requested extension to the scheduled submittal date for the FCS Flooding Hazard Reevaluation Report does not impact safe plant operation or represent an undue risk to public health and safety.
Accordingly, OPPD requests NRC approval to extend the scheduled submittal date for the FCS Flooding Hazard Reevaluation Report to ten (10) months after data from the USACE System Dam Failure Analysis is received.
A list of regulatory commitments contained in this letter is provided in Enclosure 1.
If you should you have questions, please contact Mr. Bill Hansher at (402) 533-6894.
U. S. Nuclear Regulatory Commission LlC-14-0010 Page 4 I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 26, 2014.
uis P. Cortopassi Site Vice President and CNO LPC/JKG/mle
Enclosures:
- 1. Summary of Regulatory Commitments
E. J. Leeds, Director of Office of Nuclear Reactor Regulation M. L. Dapas, NRC Regional Administrator, Region IV J. W. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector
U. S. Nuclear Regulatory Commission LlC-14-0010 Page 5 References
- 1.
NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2. 1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident; dated March 12, 2012, (ML12073A348) (N RC-12-0021 )
- 2.
NRC Letter, Prioritization of Response Due Dates for Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Flooding Hazard Reevaluations for Recommendations 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-ichi Accident, dated May 11, 2012, (ML12097A509) (NRC 0048).
- 3.
Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Request to Obtain U. S. Army Corps of Engineers (USACE) Information Required to Provide Response to March 12, 2012, Request for Information, Enclosure 2, Recommendation 2.1, Flooding, dated August 26, 2013, (ML13240A128) (LlC-13-01 03)
- 4.
NRC Letter, Request to Obtain U. S. Army Corps of Engineers Information to Support Development of Flood Hazard Reevaluation Response, dated September 17, 2013, (ML13241A216) (NRC-13-0122)
- 5.
NRC Letter, Supplemental Information Related to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Flooding Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 1, 2013, (ML13044A561) (NRC 0023)
- 6.
NRC Letter, Summary of December 17, 2013, Meeting Between Representatives of the Army Gorp of Engineers, Nuclear Regulatory Commission, Omaha Public Power District, and Nebraska Omaha Public Power District to Discuss Flooding Analysis Associated with Fort Calhoun Station, Unit 1 and Cooper Nuclear Station (TAG Nos. MF3035 and MF3036), dated February 10, 2014, (ML14031A162)
- 7.
JLD-ISG-2013-01, Guidance for Assessment of Flooding Hazards Due to Dam Failure, Interim Staff Guidance, Revision 0, July 29,2013, (ML13151A153)
- 8.
Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), OPPD Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)
Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated August 15, 2013, (ML13228A098) (LlC-13-0102)
- 9.
Missouri River Mainstem Reservoir System Master Water Control Manual, Reservoir Control Center U. S. Army Corps of Engineers, Northwest Division - Missouri River Basin, Omaha, Nebraska, Revision March 2006
- 10.
U. S. Army Corps of Engineers (USACE), Missouri River Monthly Water Management Report, January 9,2014, Release No. 20140109-001 11.
Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), 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, dated October 26,2013, (ML13310A889) (LlC-13-0140)
LlC-14-0010 Page 1 Summary of Regulatory Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
COMMITMENT COMMITTED DATE COMMITMENT TYPE OR "OUT AGE" One-Time Programmatic Action (Yes/No)
(YeslNo)
OPPD will submit the Flooding Hazard Ten (10) months after Yes No Revaluation Report, including interim receipt of data from action plan, requested in Item 1.d of the USACE System of NRC Letter, Request for Dam Failure Analysis.
Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)
Regarding Recommendations 2. 1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ML12073A348) (NRC-12-0021).
LlC-14-0010 Page 1 OPPD and NPPD Joint Flooding Hazard Reevaluation Project Project Schedule The Fort Calhoun Station (FCS) Flooding Hazard Reevaluation (FHR) Report Project Schedule is provided at the end of this Enclosure. The schedule provides details and dependencies for tasks that require the U. S. Army Corps of Engineers (USACE) hydrographs. The project schedule assumes that the hydrographs from the USACE analyses will be acquired in sufficient time (Le.,
not later than May 1,2014) such that they can be integrated into the vendor's HEC-RAS model as shown in Task 22 of the schedule. Each of the major subsequent tasks (Le., Tasks 25, 28, and
- 33) are dependent on receipt of the USACE analyses. The schedule shows that these activities will require ten (10) months to complete after receiving the USACE System Dam Failure Analysis data.
History The project was initiated in June 2012 with the issuance of contracts to a single vendor by OPPD and NPPD for the development of the FHR Reports for FCS and CNS. The original schedule required to meet the March 12, 2014 submittal date had a completion date of December 2013 to January 2014 and required receipt of the USACE HEC-RAS model by September 2012. The following table summarizes key events that resulted in project approach, scope, and schedule changes.
Date Event Impact on Project Completion Date June 2012 Request to USACE to provide HEC-RAS, HEC-HMS and other data related to the Missouri River Mainstem Reservoir System dams and the Missouri River Basin.
August 2012 HEC-HMS and some data provided by USACE.
September 2012 Second request sent to USACE enumerating reasons models and data requested in June 2012 are needed.
November 2012 Vendor developed compressed schedule showing HEC-RAS model must be obtained from the USACE by end of 2012 to meet 2014 submittal date.
December 2012 Licensees request vendor to develop method Completion date indeterminate and schedule to proceed without USACE HEC-because new input data needed RAS model.
from USACE.
December 2012 Regulatory HEC-RAS files and LiDAR data to develop HEC-RAS model from Gavins Point to Rulo, NE are obtained.
January 2013 Vendor authorized to develop of unsteady state HEC-RAS model from Gavins Point to Rulo, NE.
January 2013 Meeting with USACE requesting data needed to perform PMF including dam breaks using vendor developed unsteady state HEC-RAS model.
March 2013 Formally requested data from USACE to perform Schedule assuming USACE data PMF using vendor developed unsteady state received by July 2013 showed HEC-RAS model.
FCS submittal in May 2014 and CNS in October 2014
LlC-14-00 10 Page 2 Date April 2013 May 2013 May 2013 July 2013 July 2013 August 2013 August 2013 September 2013 September 2013 October 2013 December 2013 Event Impact on Project Completion Date Dam Failure ISG Draft for Public Comment available. Draft ISG stated that the NRC would act as an interface between licensees and federal agencies owning/operating dams. Not all comments and questions related to this interface process were resolved, as the NRC stated that the Memoranda of Agreement between government agencies was still under development.
USACE response to March 2013 request indicating data would not be provided.
Licensees direct vendor to develop scope and schedule for development of FHR Report using publically available data without any USACE data.
Dam Failure ISG published, providing official guidance regarding dam failure analyses.
Licensees and vendor agree to scope to complete FHR using publically available data and to perform dam failure analyses in accordance with the recently published Dam Failure ISG.
Vendor develops schedule for agreed to scope.
FCS and CNS FHR Reports to be completed by February 2015 OPPD sends letter (LlC-13-0103) to NRC stating: "Because of the uncertainty of the schedule for the completion of the USACE model and the uncertainty that the USACE will make this model available to the licensees upon completion, we must proceed with the development of a similar modeL" The letter also noted that the scope increase had impacted the schedule for the FHR.
Contract scope change for development of FHR Report using publically available data.
NRC notifies OPPD & NPPD that USACE will be performing dam failure analysis consistent with Dam Failure ISG.
Contract scope change for FHR Report with Schedule developed for Scope USACE providing results from their dam failure Change considered a March 2014 analyses.
receipt of USACE analysis, and FCS and CNS FHR Reports to be completed by February 2015.
Licensees told that the NRC would provide USACE dam failure analysis data in April 2014.