NLS2013082, Letter Requesting Information from the United States Army Corps of Engineers to Provide Response to March 12, 2012 Letter Regarding Enclosure 2, Recommendation 2.1, Flooding

Letter Requesting Information from the United States Army Corps of Engineers to Provide Response to March 12, 2012 Letter Regarding Enclosure 2, Recommendation 2.1, Flooding

ML13246A075
Person / Time
Site:	Cooper
Issue date:	08/22/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2013082
Download: ML13246A075 (27)

Text

N Nebraska Public Power District Always there when you need us NLS2013082 August 22, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Request to Obtain United States Army Corps of Engineers InfOrmation Required to Provide Response to March 12, 2012, Request for Information, Enclosure 2, Recommendation 2.1, Flooding Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

See Attachment I

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference I to request information associated with Near-Term Task Force Recommendation 2.1: Flooding. Requested Information, Item 1, requires a Flood Hazard Reevaluation (FHR) for plant sites in accordance with the schedule established in Reference 2.

The development of the FHRs for Nebraska Public Power District's (NPPD) Cooper Nuclear Station (CNS) and Omaha Public Power District's (OPPD) Ft. Calhoun Station (FCS) will require an analysis of the six United States Army Corps of Engineers (USACE) Missouri River main stem dams (i.e., USACE Mainstem System). Because of this common flood hazard, NPPD and OPPD (hereinafter referred to as the licensees) are jointly performing the FHR for CNS and FCS. In an attempt to maintain consistency with the USACE flooding analysis of the Missouri River, the licensees have made multiple requests for information to the USACE. In References 3 and 4 (Attachments 2 and 3), the licensees initially requested the USACE provide any available analyses, studies, models, and design data in its records relevant to flooding at CNS and FCS.

In response, the USACE provided HEC-HMS hydrologic models downstream of Gavins Point Dam, 2011 high-water data, and the 1975, 1978, and 1997 flooding reports. After discussions with the USACE, the licensees provided information in Reference 5 (Attachment 4) showing how each item of requested information will be used in the FHR analyses. The licensees have not received an official response from the USACE for the remaining items discussed in References 3 and 4.

During a meeting with the USACE in January 2013, the licensees were told that the USACE would provide selected information from analyses conducted by them, but that they would not release information requested in References 3, 4 and 5. In Reference 6 (Attachment 5), the licensees requested this select information including Spillway Design Hydrographs for all six USACE Mainstem System Dams and data from the USACE's 2009-2010 Mainstem System Dam COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2013082 Page 2 of 4 Failure Consequences Analysis to include flood inundation maps and associated river flows and flood water surface elevations for the Normal High Pool and Maximum High Pool scenarios. In Reference 7 (Attachment 6), the USACE responded in writing to this request stating:

"The USACE security policy limits the release of this data and therefore we cannot release the information. The data has been furnished to the U.S. Nuclear Regulatory Commission with the provision that they are For Official Use Only."

The lack of access to existing USACE data has caused the licensees to increase the original FHR study scope for CNS and FCS. The increased study scope includes the development of an HEC-RAS Unsteady Flow Model from Gavins Point Dam to Rulo, Nebraska in lieu of the use of an existing USACE model, and a hydrologic adequacy analysis for the USACE Mainstem System in lieu of the use of hydrologic adequacy data from the USACE. The original FHR study scope assumed the use of the data from the USACE Dam Failure Consequences Reports for the six Mainstem System Dams (Attachment 7 - Item 8) to provide information related to the hypothetical sunny day and seismic dam failure scenarios for the USACE Mainstem System.

Given the recently published NRC Interim Staff Guidance on dam failure analyses (Reference 8),

and the lack of access to the existing USACE dam failure data, the FHR study scope will need to include detailed dam failure analyses for the USACE Mainstem System dams. This will include the development of a HEC-RAS Unsteady Flow Model covering the USACE Mainstem System reach and the investigation of numerous alternative dam failure parameter assumptions and associated flood routings. The USACE has indicated that they are currently developing an HEC-RAS Unsteady Flow Model covering the USACE Mainstem System. 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. These scope increases have impacted the schedule for the FHRs.

The licensees have been told by the USACE that all requests for information from the USACE should be made through the NRC. Therefore, the licensees request that the NRC obtain the items in Attachment 7 from the USACE and make them available to the licensees. We request expedited release of Items 1 and 2 by September 15, 2013, and release of Items 3 through 5 by October 15, 2013. Delays in receiving this data will force us to rely on less recent publicly available data to develop the HEC-RAS model and dam failure analyses. The USACE had previously indicated that the information in Item 6 would be available to the licensees. Although the need for this data is decreased due to the decision to increase the scope of the FHR, this information is requested to better understand information previously provided to us by USACE.

We understand that the USACE HEC-RAS Unsteady Flow Model covering the USACE Mainstem System (Item 7) will not be available until after December 31, 2013, and request that it be made available to the licensees upon its completion to further verify the results of the HEC-RAS Unsteady Flow Models being developed for the FHRs. Although we have received verbal information from the USACE that Item 8 cannot be released, we request this information since these are the most recent dam failure studies to be completed on the Mainstem System.

NLS2013082 Page 3 of 4 Please note that the data provided in response to this request for information is necessary to complete the FHRs for both CNS and FCS. As stated in Reference 8, "Ifa Federallyowned dam is identified as criticalto the flooding reanalysis,the licensee should contact the NRC promptly.

The NRC will act as the interface between these agencies and licensees. " Reference 8 also states that "To the extent that these analyses are applicable,they should be used in the Recommendation 2. 1 flooding reanalysis."

This letter contains no new commitments to the NRC. If you should you have questions, please contact David Van Der Kamp, CNS Licensing Manager, at (402) 825-2904.

Sinctr, A. impr tias Vice President - Nuclear and Chief Nuclear Officer

/bk Attachments: 1. Reference List

2. Letter from OPPD (John B. Herman) to USACE (Colonel Robert J. Ruch),

"Request for Information - Missouri River Flood Studies and Main Stem Dams," dated June 20, 2012 (NED-12-0071 ADM)

3. Letter from NPPD (Roman Estrada) to USACE (Colonel Robert J. Ruch),

"Request for Information - Missouri River Flood Studies and Main Stem Dams," dated June 18, 2012

4. Letter from OPPD (Stephen R. Miller) to USACE (Colonel Joel R. Cross),

"Additional Information to Support the Request for Information - Missouri River Flood Studies and Mainstem System Dams for Fort Calhoun Station and Cooper Nuclear Station," dated September 17, 2012 (NED- 12-0118 ADM)

5. Memorandum from OPPD (Stephen R. Miller) to USACE (Colonel Joel R.

Cross), "Request for Information - Missouri River Flood Re-evaluation Studies for Fort Calhoun Station and Cooper Nuclear Station," dated March 20, 2013 (NED-13-074 DEN)

6. Letter from USACE (Joel R. Cross) to OPPD (Stephen R. Miller), dated May 17, 2013

7. Requested Information from United States Army Corps of Engineers for Nebraska Public Power District and Omaha Public Power District

NLS2013082 Page 4 of 4 cc: Regional Administrator, w/attachments USNRC - Region IV Director, w/attachments USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector, w/attachments USNRC - CNS Joe Gasper, w/attachments Omaha Public Power District jkgasper@oppd.com CNS Records, w/attachments NPG Distribution, w/o attachments

NLS2013082 Page 1 of I ATTACHMENT 1 Reference List

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, (Accession No. ML12073A348)

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 Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated May 11, 2012 (Accession No. ML12097A509)

3. Letter from OPPD (John B. Herman) to USACE (Colonel Robert J. Ruch), "Request for Information - Missouri River Flood Studies and Main Stem Dams," dated June 20, 2012 (NED-12-0071 ADM)

4. Letter from NPPD (Roman Estrada) to USACE (Colonel Robert J. Ruch), "Request for Information - Missouri River Flood Studies and Main Stem Dams," dated June 18, 2012

5. Letter from OPPD (Stephen R. Miller) to USACE (Colonel Joel R. Cross), "Additional Information to Support the Request for Information - Missouri River Flood Studies and Mainstem System Dams for Fort Calhoun Station and Cooper Nuclear Station," dated September 17, 2012 (NED-12-0118 ADM)

6. Memorandum from OPPD (Stephen R. Miller) to USACE (Colonel Joel R. Cross), "Request for Information - Missouri River Flood Re-evaluation Studies for Fort Calhoun Station and Cooper Nuclear Station," dated March 20, 2013 (NED- 13-074 DEN)

7. Letter from USACE (Joel R. Cross) to OPPD (Stephen R. Miller), dated May 17, 2013

8. Interim Staff Guidance JLD-ISG-2013-01, "Guidance for Assessment of Flooding Hazards Due to Dam Failure," Revision 0, July 29, 2013 (Accession No. ML13151A153)

NLS2013082 Page 1 of 3 ATTACHMENT 2 MPM 444 WS le .Ser Malt Omaha, NE 6102-2247 June 20, 2012 NED-12-0071 ADM Colonel Robert 1. Ruch District Engineer U.S. Army Corps of Engineers, Omaha District 1616 Capitol Avenue, Suite 9000 Omaha, NE 68102

SUBJECT:

Request for Information - Missouri River Flood Studies and Main Stem Dams In response to the events at the Fukushima Daiichi Nuclear Power Plant following Japan's March 1I.

2011, Great Tohoku Earthquake and subsequent Tsunami, the United States Nuclear Regulatory Commission (NRC) is requesting information from all License holders of Commercial Nuclear Power Reactors pursuant to Title 10 of the Code of Federal Regulations, Section 50.54 (f). The information requested includes a requirement that all licensees report the results of new comprehensive Flooding Hazard Reevaluation for each reactor site in accordance with NRC's current guidelines and criteria. The NRC has posted the 50.54f letter detailing this request on its website in the Public Document Area, hn:/lforms.nrc.gov/readinp-rm/adams~htL ADAMS Accession No.: ML12056A046.

Omaha Public Power District (OPPD) owns and operates Fort Calhoun Station (FCS). FCS is a Single Unit 500 MWe Pressurized Water Nuclear Reactor located on the west banks of the Missouri River south of Blair, NE. The NRC has directed OPPD to complete and submit its Flooding Hazard Analysis for FCS by March 12,2014.

In particular, the flood hazard analysis consists of developing the flood levels at FCS due to Probable Maximum Flooding (PMF) in the Missouri River and due to upstream dam failures. The drainage above FCS contains approximately 320,000 square miles of the Missouri River watershed, and a number of United States Army Corp of Engineers (USACE) designed and operated facilities including the Missouri River Main Stem Dam System. Therefore, we are requesting the USACE provide OPPD any available analyses, studies, models, and design data in its records relevant to flooding at FCS. We will utilize this information in the Flooding Hazards Reevaluation responding to the NRC's request for information discussed above. We have identified a need for the following specific items:

I. Original design memorandums for each of the main stem dams.

2. As-built plans and O&M manuals for each main stem dam.

3. Operating rules of gates and releases for each main stem dam.

4. Emergency operation procedures for the main stem dams.

5. Spillway design hydrographs for each main stem dam.

6. Spillway and gate rating curves for each main stem dam.

Eiapkbyne with Eq at Opponi-try

NLS2013082 Page 2 of 3 Colonel Robert J. Ruch NED-12-0071 ADM Page 2

7. Most recent reservoir elevation-capacity data for each main stem reservoir.

8. Original HEC-2 models for reaches from Fort Peck Dam to Gavins Point Dam, and HEC-RAS model from Gavins Point to Mississippi River used in developing HEC-RAS unsteady model used in USAR study.

9. HEC-RAS unsteady model for USAR study -Fort Peck Dam to Mississippi River.

10- Any recent extreme Precipitation Meteorological StudiC3 perorrmcd by or for the USACE within the Missouri River Basin.

I1. All available documentation and electronic models developed for the 2004 Upper Mississippi River System Flow Frequency Study.

12. All available documentation and electronic Models for the following Dam Break Studies:

a. Gavins Point Darn, Missouri River, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated October 2009, prepared by the Omaha District, Corps of Engineers.

b. "Fort Randall Dam, Missouri River, Pickstown, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

c. "Big Bend Dam, Missouri Riven; Fort Thompson, South Dakota, Critical Infrastructure Protection and Resilience Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated October 20 10, prepared by the Omaha District, Corps of Engineers

d. "Oahe Dam, Missouri River; Pierre, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

e. "Garrison Dam, Missouri River, North Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

f. "Fort Peck Dam, Missouri River; Montana, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary,"

dated February 2010, prepared by the Omaha District, Corps of Engineers.

13. HEC-RAS "Fioodway Model" from Gavins Point to Mississippi, preferably reflecting the additional calibration efforts undertaken during the 2011 flood event.

14. HEC-HMS models for basins below Gavins Point

15. Draft HEC-HMS models for basins above Gavins Point still under development

16. Post 2011 flooding LiDAR data

17. 2011 Flooding high-water data

NLS2013082 Page 3 of 3 Colonel Robert 1. Ruch NED-12-0071 ADM Page 3 IS. Historic hydrology information or flooding reports for Missouri River floods/high nmoff years (1952, 1993, 1997, 2011, etc.)

19. 5-year annual inspection reports for the main stem dams

20. Historic aerialltopography/navigation mapping of the Missouri River from Gavins Point Dam to Ruio, Nebraska.

We also request that USACE advise us of any additional information it is aware of (e.g., in-process, planned, proposed) that may be relevant to our hazard reevaluation efforts. Our preference is that you provide as much of this information as possible in an electronic format.

OPPD has retained the services of a Sargent Lundy, Inc. of Chicago IL, and HDR Inc. of Omaha NE to perform the engineering and analysis work associated with this evaluation. It will be necessary to share any information USACE provides us with these consultants.

Please also note that the OPPD is working closely with the Nebraska Public Power District in its Flooding Hazards Reevaluation of Cooper Nuclear Station. We have both selected the Sargent Luadyl-iDR team as consultants for this work. NPPD is making a similar request for infornation in a separate letter.

Thank you again for your assistance. Please contact Joe Gasper at 402-533-7233, ikzserflaonn,.cQm to make deliveryipick up arrangements or to discuss our request further.

Sincerely, John. em Division Manager%Nuclear Engineering Fort Calhoun Station JBHIJKG:keb c: 1. K. Gasper

NLS2013082 Page 1 of 3 ATTACHMENT 3 Nebraska Public Power District "Always Lheewhen yosuneed us" June18", 2012 Colonel Robert J. Ruch, District Engineer U.S. Army Corps of Engineers, Omaha District 1616 Capitol Avenue, Suite 9000 Omaha, NE 68102 RE: Request for Information - Missouri River Flood Studies and Main Stem Dams.

Dear Colonel Ruch,

In Response to the events at the Fukushima Daiichi Nuclear Power Plant following Japan's March 11, 2011, Great Tohoku Earthquake and subsequent Tsunami, the United States Nuclear Regulatory Commission (NRC) is requesting information from all License holders of Commercial Nuclear Power Reactors pursuant to Title 10 of the Code of Federal Regulations, Section 50.54(f). The information requested includes a requirement that all licensees report the results of a new comprehensive Flooding Hazard Reevaluation for each reactor site in accordance with NRC's current guidelines and criteria. The NRC has posted the 50.54f Letter detailing this request on its website in the Public Document Area, https:g/forms.nrc.eov/reading-rm/adams.html, ADAMS Accession No.: ML12056A046.

The Nebraska Public Power District (NPPD) owns and operates Cooper Nuclear Station (CNS). CNS is a Single Unit 800 MWe Boiling Water Nuclear Reactor located on the west banks of the Missouri River south of Brownville, NE. The NRC has directed NPPD to complete and submit its Flooding Hazard Analysis for CNS by March 12, 2014.

In particular the flood hazard analysis consists of developing the flood levels at CNS due to Probable Maximum Flooding (PMF) in the Missouri River and due to upstream dam failures. The drainage above CNS contains approximately 420,000 square miles of the Missouri River watershed, and a number of USACE designed and operated facilities including the Missouri River Main Stem Dam System. Therefore, we are requesting the USACE provide NPPD any available analyses, studies, models, and design data in its records relevant to flooding at CNS. We will utilize this information in the Flooding Hazards Reevaluation in responding to the NRC's Request for Information discussed above. We have identified a need for the following specific items:

1. Original design memorandums for each of the main stem dams.

2. As-built plans and O&M manuals for each main stem dam.

3. Operating rules of gates and releases for each main stem dam.

4. Emergency operation procedures for the main stem dams.

5. Spillway design hydrographs for each main stem dam.

Cooper Nuclear Station - Nebraska Public Power District 72676 - 648A Avenue / P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5099 http://www.nppd.com

NLS2013082 Page 2 of 3 Page Z of 3 June 1 8 th' 2012 NPPD Request for Information - Missouri River Flood Studies and Main Stem Dams

6. Spillway and gate rating curves for each main stem dam.

7. Most recent reservoir elevation-capacity data for each main stem reservoir.

8. Any recent extreme Precipitation Meteorological Studies performed by or for the USACE within the Missouri River Basin.

9. All available documentation and electronic models developed for the 2004 Upper Mississippi River System Flow Frequency Study.

10. All available documentation and electronic Models for. the following Dam Break Studies including the steady/unsteady flow HEC-RAS models from Fort peck Dam to the mouth of the Missouri River:

a. "Gavins Point Dam, Missouri River; Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated October2009, prepared by the Omaha District, Corps of Engineers.

b. "Fort Randall Dam, Missouri River; Pickstown, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

c. "Big Bend Dam, Missouri River; Fort Thompson, South Dakota, Critical infrastructure Protection and Resilience Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated October 2010, prepared by the Omaha District, Corps of Engineers

d. "Oahe Dam, Missouri River; Pierre, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

e. "Garrison Dam, Missouri River, North Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

f. "Fort Peck Dam, Missouri River; Montana, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers.

11. HEC-RAS "Floodway Model" from Gavins Point to Mississippi, preferably reflecting the additional calibration efforts undertaken during the 2011 flood event.

12. HEC-HMS models for basins below Gavins Point

13. Draft HEC-HMS models for basins above Gavins Point still under development

14. Post 2011 flooding LiDAR data

15. 2011 flooding high-water data Cooper Nuclear Station - Nebraska Public Power District 72676 - 648A Avenue / P.O. Box 98 / Brownvifle, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5099 http://www.nppd.com

NLS2013082 Page 3 of 3 Page 3 of 3 June 18", 2012 NPPD Request for Information - Missouri River Flood Studies and Main Stem Dams

16. Historic hydrology information or flooding reports for Missouri River floods/high runoff years(1952, 1993, 1997, 2011, etc.)

17. 5-year annual inspection reports for the main stem dams

18. Historic aerial/topography/navigation mapping of the Missouri River from Gavins Point Dam to Rulo, Nebraska, We also request that USACE advise us of any additional information it is aware of (eg, in-process, planned, proposed) that may be relevant to our hazard reevaluation efforts. Our preference is that you provide as much of this information as possible in an electronic format.

NPPD has retained the services of a Sargent Lundy, Inc. of Chicago, IL and HDR Inc. of Omaha, NE to perform the engineering and analysis work associated with this evaluation. It will be necessary to share any information USACE provides us with these consultants.

Please also note that the NPPD is working closely with the Omaha Public Power District in its Flooding Hazards Evaluation of Ft. Calhoun Nuclear Station. We have both selected the Sargent Lundy/HDR team as consultants for this work. OPPD is making a similar request for information in a separate letter.

Thank you again for your assistance. Please contact Bob Taylor with our Civil Engineering Group at 402-825-2933, rmntavlo@nppd.com to make delivery/pick up arrangements or to discuss our request further.

Sincerely, Roman Estrada Design Engineering Manager Cooper Nuclear Station Cooper Nuclear Station - Nebraska Public Power District 72676 - 648A Avenue / P.O. Box 98 / Brownville. NE 68321-0098 Telephone: (402) 825-3811 1 Fax: (402) 825-5099 http:/Iwww.nppd.com

NLS2013082 Page 1 of 12 ATTACHMENT 4 MPH 444 SOtAh 16e S&M Hoaf Omaha, NE 68102-2247 September 17, 2012 NED-12-0118 ADM Colonel Joel R. Cross District Engineer U.S. Army Corps of Engineers, Omaha District 1616 Capitol Avenue, Suite 9000 Omaha, NE 68102

Dear Colonel Cross:

Subject- Additional Information to Support the Request for Information - Missouri River Flood Studies and Mainstem System Dams for Fort Calhoun Station and Cooper Nuclear Station

Reference:

1. Letter from OPPD (John B. Herman) to USACE Omaha District (Colonel Robert J.

Ruch), -Request for Information - Missouri River Flood Studies and Main Stem Dams" dated June 20,2012 (NED'-12-0071)

2. Letter from NPPD (Roman Estrada) to USACE Omaha District (Colonel Robert J.

Ruch), "Request for Information - Missouri River Flood Studies and Main Stem Dams" dated June 18, 2012 Thank you for your delivery of the HEC- HMS models, the 2011 high-water data and the 1975, 1978 and 1997 flooding reports in response to our request for USACE analyses, studies, models and design data pertaining to the Missouri River Mainstern System dams (References I and 2). In those letters we listed 18 items of information which are needed to perform the analyses to prepare the Flood Hazard Reevaluation report which must be submitted to the NRC by March 12. 2014 for both stations. We are in urgent need of the remaining information so that we can expeditiously proceed with the required analysis.

To clarify the reason we requested this information we have prepared the attached table showing how each item of requested information will be used in the Flooding Hazard Reevaluation analyses.

The table also includes:

" a description of the level of impact on the project (schedule) if the information cannot be provided,

" notes from our July 5, 2012 meeting concerning the USACE's ability to provide the information,

" an estimated amount of time required to deliver the information (as discussed in our July 5, 2012 meeting) and

" the impact on the project if this information cannot be delivered.

EfwIoy-eW3dtu~h FiJvaJ powrtunihp

NLS2013082 Page 2 of 12 Colonel Cross NED-12-01 18 ADM Page 2 We understand you have received verbal feedback from the NRC staff that this information may not be necessary for completion of the Flood Hazard Reevaluations mandated by (he NRC. We were told by a member of your staff that this is hindering USACE approval to provide us with the NRC staff indicated to us that they believe that this information is necessary for completion of the Flood Hazard Reevaluations at the Fort Calhoun and Cooper Nuclear Stations. We would be happy to coordinate a meeting or conference call between appropriate members of your staffand the NRC staff to discuss this if necessary. Please let us know if you wish to pursue either or both actions.

If you do not wish to pursue further discussions with NRC staff please provide us a written response outlining which items will be provided, and if the item cannot be provided in the time frame identified during our July 5, 2012 meeting, the date when you will provide the information. Your response is necessary so that we can proceed with the contingency actions identified in the attached table and inform the NRC of the potential impact on our submittal schedule.

Thank you again for your assistance. Please contact Joe Gasper, Project Manager -Fukushima Response, at 402-533-7233, jkgasper@oppd.com to discuss our request further.

Sincere' I S enR Mil er Manager, Design ineering Nuclear Fort Calhoun Station SRMJJKG.keb c: J.K. Gasper Pqie 2 of 14

NLS2013082 Page 3 of 12 Table: USACE - Request For Information - Clarification Summary Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery I Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5/2012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule) if information is not provided*

I. Original Design a PMF Calculation - High Will need Headquarters USACE Likely will take 3 to 4 months

• Separate HMS model or Memorandums Spillway Design (HQ) approval, (see ,5below) minimum equivalent hydrologic Hydrograph (SDH) analysis will have to be at GAPT to be used developed to estimate in conjunction with rainfall/runoff relationship PMF below GAPT for the upper basin above

" PMF Calculation - GAPT (-280,000 mi2)

Evaluate assumption resulting in a 3 month delay of SDH at Gavins in the project.

Point vs. PMF from stochastic methods of basin above GAPT

" Dam Breach Calculation - SDH for main stem dams; characterization of upper basin response for developing runoff from PMP events

" Verification of HEC-RAS Dam Breach model inputs Page 3 of 12

NLS2013082 Page 4 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 715/2012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule) if information is not provided*

2. As-built plans and 9 Assess dam design High Will need HQ approval Likely will take 3 to 4 months 9 Site visit will be required to O&M Manuals for evaluation of minimum approximate dam Sunny Day Breach dimensions for breach Requirement parameters resulting in a I a Dam characteristics month delay in the project and dimensions

• Conservative assumptions needed to evaluate will be made and discussed breach failure modes with USACE at later date and parameters resulting in a I month delay

• Verification of in the project.

HEC-RAS Dam Breach model inputs

3. Operating Rules

• Dam Breach Medium Will need HQ approval Likely will take 3 to 4 months

• Conservative assumptions of gates and Calculation - minimum will be made and discussed releases Evaluate dam with USACE at later date release I system resulting in a I month delay storage optimization in the project.

for best casetworst case response time for cascading dam failure

• Verification of HEC-RAS Dam Breach model input (see 10)

Page4 of 12

NLS2013082 Page 5 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5,/2012 Meeting Time (from 07105/2012) Data not Received Requests needed (schedule) if information is not provided*

4 Emergency 9 Dam Breach Medium USACE indicated that they have N/A

• N/A Operation Plan Calculation - no written protocol to address Evaluate dam dam failure.

release / system storage optimization for best case/worst case response time for cascading dam failure.

• Verification of HEC-RAS Dam Breach model inputs (see 10)

PageS of 12

NLS2013082 Page 6 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5,2012 Meeting Time (from 07/0512012) Data not Received Requests needed (schedule) if information is not provided' S. Spillway Design e PMF Calculation - High Will need HQ approval. All are Likely will take 3 to 4 months

• Separate HMS model or Hydrograph data Spillway design available electronically with the minimum equivalent hydrologic hydrograph (SDH) exception of Fort Peck. Will analysis will have to be at GAPT to be used check on Fort Peck availability developed to estimate in conjunction with rainfall/runoff relationship PMF below GAPT for the upper basin above

" PMF Calculation - GAPT (-280,000 mi2)

Evaluate assumption resulting in a 3 months in of'SDH at Gavins the project.

Point vs. PMF from stochastic methods of basin above GAPT

" Dam Breach Calculation - SDH for main stem dams; characterization of upper basin response for developing runoff from PMP events

" Verification of HEC-RAS Dam Breach model inputs Page 6 of 12

NLS2013082 Page 7 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5/2012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule ) it information is not provided*

6. Spillway gate

• Dam Breach Medium Curves are represented in existing Can provide electronic

• Develop rating curves rating curves for Calculation - HEC-RAS Dam Breach model - spreadsheets - no HQ resulting in a I month delay each Mainstem Evaluate dam Garrison, Oahe, and Fort Peck approval required. Likely I to in the project.

dam release / system outlet works not included (minor 2 months & Conservative assumptions storage optimization discharges) will be made and discussed for best case/worst with USACE at later date case response time resulting in a I month delay for cascading dam in the project.

failure Verification of rating curves for of HEC-RAS Dam Breach model (see

10) inputs

7. Most recent 9 Dam Breach Medium Available Likely I month

• Develop stage storage reservoir stage- Calculation - relationship resulting in a I capacity data Evaluate dam month delay in the project.

release / system

• Conservative assumptions storage optimization will be made and discussed for best case/worst with USACE at later date case response time resulting in a I month delay for cascading dam in the project.

failure.

• Verification of HEC-RAS Dam Breach model inputs (see 10)

Page 7 of 12

NLS2013082 Page 8 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which T Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/512012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule) if information is not provided.

8. Any recent a Development of Low Joint study with BOR report Likely I to 2 months

• N/A extreme Probable Maximum available, as well as isohyetals precipitation Precipitation data developed for more recent storm studies events (no depth duration yet for those events)_

9. All documentation PMF Calculation - High Will not provide, but can provide Not provided, individual

• Project schedule assumed and models for 2004 IFFS Study specific elements as requested requests estimated (by HDR) receipt of HEC-RAS Dam 2004 FFS study Model, considered and required for verification to take 1-2 months. Breach model (see 10). If as best available (topographic information, source, model cannot be obtained, information, etc.) elements of 2004 FFS model required to route will be used to route dam GAPT SDH and breach below GAPT basin below GAPT resulting in a 2 month delay PMF to FCS and in the project.

CNS 9 Project schedule assumed Dam Breach necessary elements of 2004 Calculation - 2004 FFS HEC-RAS unsteady FFS Study Model model would be available.

required to mute Ifunavailable. HEC-RAS dam breach below Steady model (see I1) will GAPT if HEC-RAS require significant Dam Breach model modification to execute (see 10) cannot be required unsteady obtained simulations. A minimum of 9 Verification of 3 months delay in the HEC-RAS unsteady project is anticipated..

and dam breach model inputs Page 8 of 12

NLS2013082 Page 9 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5/2012 Meeting Time (from 07/0512012) Data not Received Requests needed (schedule) if information is not provided$

10. Documentation

• Dam Breach High Will require HQ approval, results Likely will take 3 to 4 months Project schedule assumed and electronic Calculation - Use in and inundation mapping may not minimum receipt of dam breach model files for dam breach rouing be provided. Model development routing model. If dam HEC-RAS Dam of cascading failure documentation will be provided. breach and 2004 FFS model Breach model associated and studies, o FCS to Cscad fir and CNS No scenario provided. likely will befilesiresults cannot be obtained, anxb band a Verification HEC-significant modification to RAS Dam Breach HEC-RAS floodway model model inputs will be required to execute dam breach routing downstream of GAPT. In addition, construction of unsteady model and dam breach for entire reach above GAPT to Ft Peck, including incorporation of main stem dam reservoirs, gates, etc. A minimum ofa 6 month delay in the project is anticipated.

Page 9 of 12

NLS2013082 Page 10 ofl2 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5.t2012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule ) if information is not provided* __,

II. HEC-RAS

• Basis of design Low - if 2004 2007 Floodway model - may Likely I to 2 months

• Project schedule assumed Floodway Model calculation FFS can be have been edited by states, but receipt of 2004 FFS from Gavins to

• PMF Calculation - obtained, they will provide base model. unsteady model. Model will Mississippi with High - if 2004 Some calibration done to 2011 require significant 2011 calibration Model required to FFS and dam events, but they mostly used route GAPT SDH breach model breach model because of quicker modification to execute and basin below cannot be turnaround. 'Calibrated' model to required unsteady GAPT PMF to FCS obtained. 2011 will not be provided, simulations resulting in a 3 and CNS if 2004 month delay in the project.

FFS model cannot . Project schedule assumed be obtained (see 9) receipt of dam breach

• Dam Breach routing model. If dam Calculation - Model breach and 2004 FFS model required to route cannot be obtained, dam breach if dam significant modification to breach studies model HEC-RAS floodway model (see 10) or 2004 FFS will be required to execute model (see 9) cannot dam breach routing be obtained downstream of GAPT. In

& Verification of addition, construction of HEC-RAS steady unsteady model and dam state, unsteady, and breach for entire reach dam breach model above GAPT to Ft Peck, inputs including incorporation of main stem dam reservoirs, gates, etc. A minimum ofa 6 month delay in the project is anticipated.

Page 10 of 12

NLS2013082 Page 11 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated LISACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5/2012 Meeting Time (from 07/05/2012) Data not Received Requests needed (schedule ) if information is not provided*

12. HEC-HMS PMF Calculation - High Will provide latest copies of Model received O3/ 1712012 . N/A models for basins Model to be used for model files below Gavins basin response in support of PMF calculation below GAPT to FCS and FCS toNCS

13. Draft HEC-HMS PMF Calculation - Medium Will not provide N/A

• N/A models for basins Evaluate basin above Gavins response above GAPT compared to assumption of SDH at GAPT

14. Post 2011 PMF and Dam Medium Will be provided. Coverage is Ft. September/Ociober 2012

• N/A Flooding LiDAR Breach Calculation Peck on down. Cross-section data Verification of provided as well steady state, unsteady, and breach routing model inputs

15. 2011 Flooding PMF and Dam Medium GIS shape file is available and Information received

• N/A HIW marks Breach Calculation will be provided 08117/2012 Verification of steady state, unsteady, and breach routing model inputs Page Ii of12

NLS2013082 Page 12 of 12 Table: USACE - Request For Information - Clarification Summary (Continued)

Information Requested Analysis for which Impact on USACE Response Provided Estimated USACE Delivery Impact on Project Schedule if in OPPD and NPPD requested data is Project during 7/5/2012 Meeting Time (from 07105/2012) Data not Received Requests needed (schedule ) if information is not provided*

16. Historic PMF Calculation - Low Several exist: 52, 75, 78, 84, 93, Information received on

• N/A hydrology Evaluate basin 97, 2011 and will be provided 8/ 17/2012 for 1975, 1978, and information or response compared 1997. Awaiting information flooding reports on 1952, 1993, and 2011.

on Missouri. to computed PMF

17. 5-year periodic Assess dam design Medium Will check on what can be 4+ months a Conservative assumptions inspection reports for evaluation and provided. Concern over will be made and discussed defense of Sunny terminology based on previous with USACE at later date Day Breach NRC discussions resulting in a I month delay Requirement / in the project.

Credibility Verification of model input values

18. Historic - Geomorphologic Medium Lots of data available both At July 5, 2012 Meeting,

• Pre-dam information may aerial/topography/ Assessment per electronic and hard copy. Some USACE committed to deliver only exist with USACE.,

navigation NUREG/CR746 of the hard copy files have begun electronic format of requested Project delay of up to I Section conversion and are geo- aerials, with supplemental Pon mapping on Missouri River Section 3.8. referenced. They will deliver hard copies that could be th due to multiple Gavins to Rulo. available electronic files and we requested following review of state/local agency contacts can request hard copies to electronic data. Subsequent (DNR, FSA, USDA, etc.)

supplement if needed. USACE response was that this required to obtain historic mapping is available aerial photographs elsewhere and they will not provide.

Page 12 of 12

NLS2013082 Page 1 of 1 ATTACHMENT 5 Memorandum Date: March 20, 2013 NED-13-074 DEN From: Stephen R. Miller To: Colonel Joel R. Cross Subject. Request for Infonrintion - Missouri River Flood Re-evaluation Studies for Fort Calhoun Station and Cooper Nuclear Station Thank you for your statffs participation in our meeting of January 25, 2013 regarding USACE data related to the Fort Calhoun Station and the Cooper Nuclear Station FloodlHazard Re-evaluation Studies. These studies have been requested by the Ntcler Regulatory Commission (NRC) and must be submitted to the NRC by March 12, 2014 for both stations.

We understand that the information and data requested in our letter of September 17, 2011 "Additional Information to Support the Request for Information - Missouri River Flood Studies and Mainstern System Dams for Fort Calhoun Station and Cooper Nuclear Station" currently cannot be released.

We are requesting the following datL to assist us fulfilling the NRC request:

• Spillhway Design Hydrogaphs for all six Missouri River Mainstem System Dams, and

• Flood inundation maps. including associated river floAs and flood water surface elevations, for the Normal High Pool and Maximum High Pool Scenarios.

Thank you again for your assistance, Please contact Joe Gasper, Project Manager - Fukushima Response, at 402-533-7233.Jkgasper(oppd.com if you have any questions related to this request.

Sinecrcy, Stephen R. Miller Manager. Design Engineering Nuclear Fort Calhoun Station OI4 NOMH tVVbf~

NLS2013082 Page 1 of I ATTACHMENT 6 DEPARTMENT OF THE ARMY COWS OF ENGINEERS, OMAIA DISTRICT 1616 CAPITOL AVENUE OMAHA NE 68102-4Wl1 qRlY' TO ITENT**O OF KAY 17 2013 District Commander Mr. Stephen Rk Miller Manager, Design Engineering Nuclear OPPD, Fort Calhoun Station 444 Soulh 16th Street NMa Omaha, Nebraska 68102-2247

Dear Mr. Mfilter,

On March 20, 2011- the U.S. Army Corps of Engincers (USACE4 Omaha District received a request for information for the Missouri River Flood re-evaluation studies for Fort Calhoun Station and Cooper Nuclear to include Spill-way Design Hydrographs for all six Missouri River Mainstern Systcm Dams and flood inundation maps, including associated river flows and flood water surface etevations for the Normal High Pool and Maximum High Pool scenarios.

The I.SACE security poicy limits the release of this data and therefore we cannut release the infurmatiorL The data has been furnished to the U.S. Nuclear Regulatory Commission with the provision that they are For Official Use Only.

If you have questions or need further assistance conceming this information, plea1e contact Mis. Kim Thomas at 4(Y2-995-2448 or email at Kimberltvomashjusacc.arras.mi, Sincerely, t Moroel, Corps ot Engineer!,

f isarrnt Cu ramander Ptrwd T Recycle Fspý

NLS2013082 Page 1 of 2 ATTACHMENT 7 Requested Information from United States Army Corps of Engineers for Nebraska Public Power District and Omaha Public Power District

1. Any available LiDAR or other topographic data along the Missouri River above Gavins Point Dam.

2. Reservoir Bathymetry and Spillway Design Flood Inflow and Outflow Hydrographs for all six Missouri River United States Army Corps of Engineers (USACE) Mainstem System dams.

3. Most current Missouri River Mainstem Reservoir System regulation statistics (including individual data for each reservoir), i.e. - pool elevation, outflows, inflows, power generation, and evaporation, for the period from 1967 to the present.

4. Any available estimates/studies on the expected debris types and loads during floods for the Mainstem System Reservoirs and the Missouri River from Gavins Point Dam to Rulo, Nebraska.

5. Any additional or updated information, including original design memorandums, to the publicly available Missouri River Master Water Control Manual dated March 2006 for the following Mainstem Dams data:

a. Dam geometry (e.g. height, width, slopes, top width)

b. Dam embankment materials

c. Dam foundation and abutment types

d. Outflow rating curves for emergency spillway, outlet works, power plants (pool/tailwater elevation vs. discharge)

e. Reservoir storage capacity (reservoir elevation-capacity data) curves

f. Pool and release probability curves Assuming there are no updates, we will rely on the data from the 2006 Master Manual for the FHR.

6. Data from the 2009-2010 USACE analysis of the Missouri River Mainstem System dam failure consequences to include:

a. Inundation mapping at Fort Calhoun Station (FCS) and Cooper Nuclear Station (CNS) for each dam failure scenario analyzed

NLS2013082 Page 2 of 2

b. Dam failure flood water surface elevations at FCS and CNS for each dam failure scenario analyzed

c. Dam failure hydrographs for each dam failure scenario analyzed

d. Flood lead time information (time from the initiation of the event to peak flooding at FCS and CNS) for each dam failure scenario analyzed

7. Missouri River HEC-RAS Unsteady Flow Model from Ft. Peck to Rulo, NE (currently under development by the USACE).

8. The following reports:

a. "Gavins Point Dam, Missouri River, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary,"

dated October 2009, prepared by the Omaha District, Corps of Engineers

b. "Fort Randall Dam, Missouri River; Pickstown, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers

c. "Big Bend Dam, Missouri River; Fort Thompson, South Dakota, Critical Infrastructure Protection and Resilience Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated October 2010, prepared by the Omaha District, Corps of Engineers

d. "Oahe Dam, Missouri River; Pierre, South Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers

e. "Garrison Dam, Missouri River; North Dakota, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers

f. "Fort Peck Dam, Missouri River; Montana, Critical Infrastructure Security Program, Dam Failure Analyses, H&H Methodology Report and Consequences Summary," dated February 2010, prepared by the Omaha District, Corps of Engineers