ML13066A770

Email from Jonathan Bartley, to Leonard Wert, Cc: Victor Mccree, William Jones, Rick Croteau, Subject: Options for Revising Oconee Flood CAL Due Dates, Attachments: Options for Revising Oconee Flood CAL Due Dates

ML13066A770
Person / Time
Site:	Oconee
Issue date:	08/21/2012
From:	Bartley J NRC/RGN-II
To:	Croteau R, William Jones, Mccree V NRC/RGN-II
References
FOIA/PA-2012-0325
Download: ML13066A770 (5)

Text

Bartley, Jonathan From: Bartley, Jonathan Sent: Tuesday, August 21, 2012 8:42 AM To: Wert, Leonard Cc: McCree, Victor; Jones, William; Croteau, Rick

Subject:

Options for Revising Oconee Flood CAL Due Dates.docx fefficiil u.c0

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Attachments: Options for Revising Oconee Flood CAL Due Dates.docx

Len, Attached are the options and timelines for the resolution of the flood issue related to Fukushima. One change from what was provided earlier is the date to start the timeline on Option 1 (follow current CAL timeline) was revised to 9/14/2012 (originally 8/31) to coincide with NRRs plan to issue their response letter to Oconee (answering the 2 questions posed by the licensee in the last RAI response).

Jonathan I

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.............. j Options for Revising Oconee Flood CAL Due Dates Discussion:

The flood CAL was issued on June 22, 2010. The CAL initially directed the licensee to submit a list of all modifications necessary to mitigate the Jocassee failure by November 30, 2010. This was modified and the licensee submitted the list on April 30, 2011. The CAL also directed the licensee to complete the modifications by November 30, 2011. This was modified to 30 months plus the regulatory review period once the RAIs were resolved. The modifications would be complete by February 28, 2016, assuming the RAIs are resolved on 8/30/2012, a 12 month regulatory review period (RRP), and 30 months to complete the modifications. The original CAL items and current due dates are listed in Table 1.

The licensee proposes to make the resolution of the CAL items parallel the resolution of Fukishima initiatives. The staff agrees to this in general. The licensee's proposed modifications are listed in Table 2. The licensee proposes to complete the updated flooding hazard re-evaluation report by March 12, 2013 (per Category 1 timeline) which is reasonable. However, they also propose completing the integrated assessment report by March 2015 and submitting a list of proposed modifications and an implementation schedule by August 2015. Initial staff response is that these are not reasonable for resolution of the flooding due to failure of the Jocassee Dam. For dam failure these are essentially complete and may just need adjustment if the flood level changes due to the flooding hazard re-evaluation. These timelines would be reasonable for newly identified issues such as PMP flooding on-site. The modifications to mitigate flooding from a Jocassee Dam failure would not be complete until February 2019 assuming August 2015 as the start date for a 12 month RRP and 30 months construction schedule.

It would be reasonable to modify the due date for completion of the modifications to relate it to completion of the flood hazard re-evaluation and maybe add a couple of months to allow revising proposed modifications if onsite flood levels change. The CAL currently says 30 months + regulatory review period (RRP) after resolution of all RAI's for CAL 2-10-003. Maybe revise to allow 3 months after completion of the hazard evaluation (due June 12, 2013) and then 30 months + RRP starting June 12, 2013. The modifications to mitigate flooding from a Jocassee Dam failure would be complete around December 2016. The NRC proposed CAL modifications are listed in Table 3.

Figure 1 provides a graphical comparison of the current CAL, the licensee's proposed dates, and the staff's proposed dates.

We will need to discuss with OCO prior to modifying the CAL (either them or us).

Summary:

Current CAL timeline would result in Jocassee flood modifications being complete around February 2016.

Oconee proposed changes would result in Jocassee flood modifications being complete around February 2019.

NRC proposed changes would result in Jocassee flood modifications being complete around December 2016.

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6/22/2010 4/30/2011 9/14/2012" Start 30 3/14/2016 CAL issued Submit Mods

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Complete Mods Current CAL 3/12/2013 3/12/2015 2/12/2019 Complete Complete 8/12/2015 6/22/2010 Complete Submit

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CAL issued mods evaluation report/

Licensee Proposed Timeline 6/12/2013 Complete 3/12/2015 integrated 8/12/2015 Complete report and Submit 3/12/2013 integrated submit mods for 12/12/2016 Complete report for mods for Complete

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other Jocassee Mods CAL issued Jocassee hazards evalu tio hazards NRC Proposed Timeline

• Assume RAI letter issued 9/14/2012

• • Assume RRP to be 12 months

• • • Assumes 42 months (30 + RRP)

Figure 1: Timelines 2

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Table 1: Current CAL Commitments No. External Flooding Commitments Due Date Complete (YIN) 1F Compensatory measures implemented at the Oconee June 3, 2010 Y Site and Jocassee Dam to mitigate potential external flooding hazards resulting from a potential failure of Jocassee dam.

2F Submit all documentation necessary to demonstrate to August 2, Y the NRC that the inundation of the Oconee site resulting 2010 from the failure of the Jocassee Dam has been bounded.

3F Submit a list of all modifications necessary to adequately Nevembe: Y mitigate the inundation of the Oconee site to a potential 30,-2010 failure of Jocassee dam. April 30, 2011 4F Complete all modifications necessary to adequately Nevembei N mitigate the inundation of the Oconee site to a potential 30.,2*1, failure of Jocassee dam. 30 Months +

RRP after resolution of all RAI's for CAL 2 003 Table 2: Oconee Proposed External Fukushima Response Flooding Commitments No. External Flooding Commitments Due Date Complete (Y/N) 1FR Compensatory measures implemented and maintained at June 3, 2010 Y the Oconee Site and Jocassee Dam to mitigate potential external flooding hazards resulting from a potential failure of Jocassee dam until modifications are completed.

2FR Complete updated flooding Hazard Reevaluation Report March 12, N as required by March 12, 2012 10CRF 50.54(f) 2013 Recommendation 2.1 Flooding including a postulated failure of Jocassee dam.

3FR Complete Integrated Assessment Report as required by March 12, N March 12, 2012 10CRF 50.54(f) Recommendation 2.1 2015 Flooding for the bounding flooding hazard.

4FR Submit a list of all modifications and an implementation August 12 N schedule to adequately mitigate the external flooding of 2015 the Oconee site for the bounding flooding hazard.

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=1 Table 3: NRC Staff Proposed External Fukushima Response Flooding Commitments No. . External Flooding Commitments Due Date Complete (YIN) 1F Compensatory measures implemented at the Oconee June 3, 2010 Y Site and Jocassee Dam to mitigate potential external flooding hazards resulting from a potential failure of Jocassee dam.

2F Submit all documentation necessary to demonstrate to August 2, Y the NRC that the inundation of the Oconee site resulting 2010 from the failure of the Jocassee Dam has been bounded.

3FR Complete updated flooding Hazard Reevaluation Report March 12, N as required by March 12, 2012 10CRF 50.54(f) 2013 Recommendation 2.1 Flooding including a postulated failure of Jocassee dam.

4FR Complete portions of Integrated Assessment Report June 12, N required by March 12, 2012 10CRF 50.54(f) 2013 Recommendation 2.1 Flooding for the failure of Jocassee Dam.

Note: Integrated Assessment Report for flooding hazards identified other than the failure of Jocassee dam will be completed by March 12, 2015.

5FR Re-evaluate previously submitted list of modifications June 12, N based on flooding Hazard Reevaluation Report. Provide 2013 revised list of modifications necessary to adequately mitigate the inundation of the Oconee site to a potential failure of Jocassee dam.

6FR Complete all modifications necessary to adequately 30 Months + N mitigate the inundation of the Oconee site to a potential RRP after failure of Jocassee dam. Junre 12, Note: A list of modifications and implementation 2013 schedule to mitigate flooding hazards other than the failure of Jocassee dam will be submitted by August 12, 2015.

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