ML14171A088
| ML14171A088 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/17/2014 |
| From: | Dan Dorman Office of Nuclear Reactor Regulation |
| To: | Limpias O Nebraska Public Power District (NPPD) |
| Sebrosky J, NRR/JLD, 415-1132 | |
| References | |
| TAC MF3632 | |
| Download: ML14171A088 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 17, 2014 Mr. Oscar A. Limpias Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - RELAXATION OF RESPONSE DUE DATE REGARDING FLOODING HAZARD REEVALUATIONS FOR RECOMMENDATION 2.1 OF THE NEAR-TERM TASK FORCE REVIEW OF THE INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT (TAC NO. MF3632)
Dear Mr. Limpias:
By letter dated March 12, 2012, 1 the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations, Section 50. 54(f)
(henceforth referred to as the 50.54(f) letter). The NRC issued the request as a 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 perform a reevaluation of all external flooding hazards using present-day guidance and methodologies.
By letter dated May 11, 2012, 2 the NRC issued a prioritization of due dates for responses from all s1tes. The flooding hazard reevaluation report (FHR.R) was due on March 12. 2014, for Cooper Nuclear Station (CNS).
By letter dated August 22, 2013, 3 Nebraska Public Power District (NPPD, the licensee) requested NRC assistance in obtaining the U.S. Army Corps of Engineers (USACE) analysis of dams that could impact the flood levels at the CNS site. By letter dated February 26, 2014, 4 NPPD requested a delay in submittal of the FHRR for CNS to 10 months after receiving the USACE final analysis. The reason for this request is that the results of the USACE analysis are necessary to complete the flooding hazara reevaluation (FHR) and that it would take about 10 months to incorporate the results and finalize the FHRR.
1 The 50.54(f) letter is available in the Ag.:mcywide Documents flcce::;s and Management System (ADA.MS) under Accession No. ML12053A340.
2 Tile prioritization lettr is available in ADAMS under Access1on No ML 12097A5C9.
3 The request for assistance in obtaining USAGE analysis is availi1ble ii1 ADAMS under Accession No. ML13246A075.
4 The exter.sicn request from Nebraska Public Power District is a\iallaole in ADAMS under Accession No. ML14064A264.
- 0. Limpias The NRC reviewed the justification provided by the licensee and considered the following factors when reviewing the new schedule:
- By letter dated April4, 2014, 5 the NRC staff provided NPPD the USACE portion of the CNS FHR. The USACE portion of the CNS FHR resulted in a higher flood 6
hazard relative to the CNS design basis. In a June 4, 2014, letter, NPPD provided interim actions it is taking or plans to take to address the higher flood hazard. The NRC staff is currently reviewing these interim actions and notes that NPPD is currently addressing the higher hazard due to the USACE FHR and is not waiting until the February 4, 2015, estimated time to complete the CNS FHRR to develop these interim actions.
- As stated in the NRC's interim staff guidance (ISG) JLD-ISG-2013-01, "Guidance for Assessment of Flooding Hazards Due to Dam Failure," dated July 29, 2013, 7 evaluating flooding hazards for nuclear power plants needs to include consideration of floods resulting from dam failures. The FHR for CNS needs to consider the six Missouri River main stem dams that are operated by USACE.
The NRC entered into an interagency agreement with the USACE to evaluate the Missouri River main stem dams and their potential hydrographs at CNS. The NRC also agreed to provide the necessary information for NPPD to complete its FHR. By letter dated April4, 2014, 8 the NRC transmitted the requested information to NPPD.
- As stated in the NRC's letter dated March 1, 2013, 9 "incomplete hazard reports that only contain an analysis of some flooding hazard mechanisms would not be of substantive benefit for staff and would not be acceptable." Therefore, the licensee must incorporate the information that was requested from the USACE provided in the Apri14, 2014, letter before a FHRR can be acceptable for submittal to the NRC in compliance with the request in the 50.54(f) letter.
- In the February 26, 2014, extension request, NPPD provided a Gantt chart that included a detailed timeline for integrating various aspects of the FHR. This Gantt chart was discussed with NPPD in public meetings on May 9, 10 and May 22, 2014. 11 NPPD provided a more detailed Gantt chart in the May 22, 2014, public meeting. The Gantt chart provides a detailed schedule and milestones to 5
NRC's cover letter transmitting the USAGE CNS FHR is available in ADAMS under Accession No. ML14091A383.
6 NPPD's cover letter transmitting the interim actions it will take or plans to take to address the USAGE analysis which resulted in a higher flood hazard relative to the CNS design basis is in available in ADAMS under Accession No. ML14167A340.
7 JLD-ISG-2013-01 is available in ADAMS under Accession No. ML13151A153.
8 NRC's April4, 2014, cover letter transmitting USAGE FHR is available in ADAMS under Accession No. ML14091A383.
9 NRC's March 1, 2013, letter is available in ADAMS under Accession No. ML13044A561.
10 The May 9, 2014, meeting summary is available in ADAMS under Accession No. ML14139A358.
11 The May 22, 2014, meeting summary is available in ADAMS under Accession No. ML14156A283.
- 0. Limpias be completed in order for NPPD to provide a FHRR 10 months after receiving the USACE results.
- As discussed in the May 9 and May 22, 2014, public meetings, NPPD is sharing resources with Omaha Public Power District, which is developing a FHR for the Fort Calhoun Station, Unit 1 (FCS) site. Because of the limited number of technical experts who are available to perform this work, some of the FHR work for CNS and FCS cannot be done in parallel and must be done in series.
- The Missouri River watershed is a large and complex watershed, and integrating the USACE results with the site-specific FHR to be developed by NPPD takes time.
Given these considerations, the NRC considers the revised schedule proposed by NPPD to be acceptable. Accordingly, and based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the revised required response date for submitting the FHRR for CNS is February 4, 2015 (1 0 months after NPPD received the USACE final analysis).
If you have any questions regarding this matter, or if it is necessary to revise the submittal schedule, please contact your NRC project manager, Ms. Andrea George, at (301) 415-1081 or via e-mail at andrea.george@nrc.gov.
Sincerely, Daniel H. Dorman, Acting Director Office of Nuclear Reactor Regulation Docket No. 50-298 cc: Listserv
- 0. Limpias be completed in order for NPPD to provide a FHRR 10 months after receiving the USACE results.
- As discussed in the May 9 and May 22, 2014, public meetings, NPPD is sharing resources with Omaha Public Power District, which is developing a FHR for the Fort Calhoun Station, Unit 1 (FCS) site. Because of the limited number of technical experts who are available to perform this work, some of the FHR work for CNS and FCS cannot be done in parallel and must be done in series.
- The Missouri River watershed is a large and complex watershed, and integrating the USACE results with the site-specific FHR to be developed by NPPD takes time.
Given these considerations, the NRC considers the revised schedule proposed by NPPD to be acceptable. Accordingly, and based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the revised required response date for submitting the FHRR for CNS is February 4, 2015 (1 0 months after NPPD received the USACE final analysis).
If you have any questions regarding this matter, or if it is necessary to revise the submittal schedule, please contact your NRC project manager, Ms. Andrea George, at (301) 415-1081 or via e-mail at andrea.george@nrc.gov.
Sincerely, IRA!
Daniel H. Dorman, Acting Director Office of Nuclear Reactor Regulation Docket No. 50-298 cc: Listserv DISTRIBUTION:
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DATE 07/17/14 06/20/14 07/09/14 07/02/14 06/30/14 OFFICE DSENRHM2/BC* OGC NLO** NRRIJLD/D NRRID NAME RKaras BHarris DSkeen DOorman DATE 06/27/14 06/27/14 07/03/14 07/17/14 OFFICIAL RECORD COPY