ML14080A139

Columbia, Extension Request Regarding the Flooding Hazard Reevaluation Report Required by NRC Request for Information Pursuant to 10 CFR 50.54(F) Regarding Recommendation 2.1, Flooding, of the Near-Term Task Force Review of Insights.

ML14080A139
Person / Time
Site:	Columbia
Issue date:	03/10/2014
From:	Swank D A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G02-14-036
Download: ML14080A139 (9)

Text

ENERGY NORTHWEST David A. Swank Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509-377-2309 1 F. 509-377-2354 daswank @ energy-northwest.com March 10, 2014 G02-14-036 10 CFR 50.54(f)U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKISHIMA DAI-ACHI ACCIDENT

References:

1) Letter dated March 12, 2012, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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" (ML12053A340)

2) Letter dated May 11, 2012, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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" (ML12097A509)

3) Letter dated March 1, 2013, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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" (ML13044A561)

A OO0 EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Page 2 of 3

Dear Sir or Madam:

This letter transmits a request for extension of the current March 12, 2014, due date for submittal of the Columbia Generating Station (Columbia)

Flood Hazard Reevaluation Report (HRR).On March 12, 2012, the NRC issued Reference 1 requesting information to support the evaluation of the NRC staff recommendations for the Near-Term Task Force review of the accident at the Fukushima Dai-ichi nuclear facility.

Recommendation 2.1 of the referenced letter requested a reevaluation of all appropriate external flooding sources and the submittal of a Flood HRR. In Reference 2, Columbia was identified as a Category 2 site with a submittal date of March 12, 2014.In Reference 3, the NRC provided supplemental information stating incomplete Flood HRRs that only contain an analysis of some flooding hazard mechanisms would not be of substantive benefit for staff review and would not be acceptable.

Therefore, licensees should not submit partial reports, but rather submit an extension request on or before the submittal due date. Reference 3 also provided guidance in requesting extensions of the reporting requirement, in that the following information should be included:

1) the reason for the delay; 2) a proposed schedule for the submittal of a complete Flood HRR; and 3)the basis for the acceptability of the revised schedule.Attachment 1 to this letter contains the reasons for the delay, the proposed schedule, and the basis for the acceptability of the revised schedule.

Attachment 2 contains a list of the revised commitments.

If you have any questions or require additional information, please contact Ms. L. L. Williams at (509) 377-8148.I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.Respectfully, D. A. Swank Assistant Vice President, Engineering Attachments:

1. Reason for the Delay and Basis for the Acceptability of the Revised Flood HRR Schedule 2. List of Revised Commitments EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Page 3 of 3 cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C MA Jones -BPA/1 399 EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT ATTACHMENT 1 Reason for the Delay and Basis for the Acceptability of the Revised Flood Reevaluation Report Schedule EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Attachment 1 Page 1 of 3

Introduction:

On March 12, 2012, the NRC issued Reference 1 requesting information to support the evaluation of the NRC staff recommendations for the Near-Term Task Force review of the accident at the Fukushima Dai-ichi nuclear facility.

Recommendation 2.1 of the referenced letter requested a reevaluation of all appropriate external flooding sources and the submittal of a Flood Hazard Reevaluation Report (HRR). In Reference 2, Columbia Generating Station (Columba) was identified as a Category 2 site with a submittal date of March 12, 2014.On March 1, 2013, the NRC issued Reference 3 to provide supplemental information that stated that incomplete Flood HRRs containing an analysis of only some flooding hazard mechanisms would not be of substantive benefit for staff review and would not be acceptable.

Therefore, licensees were advised not to submit partial reports, but rather submit an extension request on or before the submittal due date.The purpose of this letter is to request an extension to the March 12, 2014, due date for the Columbia Flood HRR.Reason for the Delay: The overarching reason for the additional time is based on the significant number of dams upstream and downstream of Columbia that must be evaluated in order to fully assess the flood hazard. Specifically, based on the location of Columbia, Energy Northwest must evaluate the impact of failure of several potentially critical upstream and downstream dams to accurately assess flood levels at the Columbia site. In addition, there are a large number of dams in the Snake River and Yakima River basins which also must be evaluated because of potential backwater effects caused by their failure.On October 4, 2013, Energy Northwest submitted Reference 4 to request NRC engage the U.S. Army Corps of Engineers (USACE) to provide these analyses.

During a teleconference on January 22, 2014, between Energy Northwest and members of the NRC staff, it was stated that Energy Northwest would require an extension of the submittal date if USACE input was necessary for completing the Columbia Flood HRR.Proposed Submittal Schedule At this time, the estimated date for receipt of the USACE final analysis is not known.Energy Northwest will submit the required Columbia Flood HRR within 60 days of receiving the USACE's final analysis.

If additional time is required, Energy Northwest will coordinate a revised submittal schedule with the NRC Project Manager.

EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Attachment 1 Page 2 of 3 Basis for the Acceptability of the Delay The Energy Northwest proposed schedule extension is acceptable based on the following discussion.

The cover letter of the NRC's March 12, 2012, Request for Information states that 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. The NRC letter concluded that continued plant operation and the continuation of licensing activities do not pose an imminent risk to public health and safety.Columbia is currently categorized as a "dry site" in accordance with NRC Regulatory Guide 1.102, "Flood Protection for Nuclear Power Plants." As described in the Columbia Final Safety Analysis Report, the recorded history of the Columbia Basin indicates that no historical floods have exceeded plant grade. The current license basis evaluations of upstream dam failures also show that flood waters to not reach plant grade. The limiting flooding event is currently the Probable Maximum Precipitation event. The water from this event also does not reach the plant grade. The Flooding Walkdown Report (Reference

5) submitted on November 12, 2012, found that the plant was in compliance with the current license basis for flooding.The Flood HRR project includes analyses that contain beyond-design-basis scenarios.

In accordance with Item 1 .d of Enclosure 2 of the March 12, 2012, Request for Information, interim evaluations and actions will be taken or planned to address any reevaluated higher flooding hazards relative to the design basis. These interim evaluations and actions, if any, will be included in the Columbia Flood HRR. Energy Northwest's position is that, assessed qualitatively, the reevaluated flooding hazard is a very low probability event and the probability of such events occurring within the extension request timeframe is very low.References

1) Letter dated March 12, 2012, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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" (ML12053A340)

2) Letter dated May 11, 2012, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "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 EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Attachment 1 Page 3 of 3 Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" (ML12097A509)

3) Letter dated March 1, 2013, from E. J. Leeds (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Supplemental Information Related to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.43(f) Regarding Flooding Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" (ML13044A561)

4) Letter GO2-13-141, dated October 4, 2013, from D. A. Swank (Energy Northwest) to NRC, "Energy Northwest's Request for NRC Assistance to Obtain Information from the US Army Corps of Engineers (USACE) related to Dam Failure Analysis" 5) Letter G02-12-164, dated November 12, 2012, from D. A. Swank (Energy Northwest) to NRC, "Flooding Walkdown Report" (ML12319A476)

EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT ATTACHEMENT 2 List of Revised Commitments EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO 10 CFR 50.54(f) REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF GNSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT Attachment 2 Page 1 of 1 The following table identifies the changes to the scheduled completion dates of previous regulatory commitments to support the extension request date in Attachment

1. These commitments were originally made in letter G02-13-012 dated January 22, 2013, from D. A. Swank (Energy Northwest) to NRC, "Energy Northwest's Response to the March 12, 2012 Information Request- Flooding Integrated Assessment Approach." Any other statements in this submittal, including intended or planned actions, are provided for information purposes and are not considered to be regulatory commitments.

Commitment Scheduled Completion Date Following completion of the Flooding Hazard Reevaluation Report, Energy Northwest will utilize the guidance in the NRC letter dated December 3, 2012, from DL Skeen (NRC) to JE Pollock (NEI),"Trigger Conditions for Performing an Integrated Assessment and Due Date for Response," to determine if an Integrated Assessment or limited evaluation is required.If a limited evaluation is performed, the results will be submitted along with the Flooding Hazard Reevaluation Report.Ma-rch 12, 2014 Energy Northwest will submit the required Flood Hazard Reevaluation Report within 60 days of receiving the U.S. Army Corps of Engineering's (USACE's) final analysis.If an Integrated Assessment is required, March 12, 2016 Energy Northwest will perform the assessment utilizing the guidance in JLD- Energy Northwest will complete the ISG-12-05, "Guidance for Performing the Integrated Assessment (if required) within Integrated Assessment for External two years of the Flood Hazard Flooding." Reevaluation Report date.