ML101730329

Confirmatory Action Letter (CAL 2-10-003), Commitments to Address External Flooding Concerns

ML101730329
Person / Time
Site:	Oconee
Issue date:	06/22/2010
From:	Reyes L Region 2 Administrator
To:	Baxter D Duke Energy Carolinas
References
Download: ML101730329 (7)

Text

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 22, 2010 CAL 2-10-003 Mr. David A. Baxter Site Vice President Duke Energy Carolinas, LLC Oconee Nuclear Station 7800 Rochester Highway Seneca, SC 29672

SUBJECT:

CONFIRMATORY ACTION LETTER - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 COMMITMENTS TO ADDRESS EXTERNAL FLOODING CONCERNS (TAC NOS. ME3065, ME3066, AND ME3067)

Dear Mr. Baxter:

This letter confirms commitments made by Duke Energy Carolinas, LLC (the licensee) in your June 3, 2010, letter. Specifically, the June 3, 2010, letter listed compensatory measures the licensee will implement at the Oconee Site and Jocassee Dam to mitigate potential external flooding hazards resulting from a potential failure of the Jocassee Dam. The compensatory measures listed in the enclosure shall remain in place until final resolution of the inundation of the Oconee site from the failure of the Jocassee Dam has been determined by the licensee and agreed upon by the U.S. Nuclear Regulatory Commission (NRC), and all modifications are made to mitigate the inundation. The compensatory measures and implementation dates are set forth in the enclosure to this letter.

In addition to implementing the compensatory measures, pursuant to my telephone conversation with Mr. Bill Pitesa of your company on June 22, 2010, you shall submit to the NRC by August 2, 2010, all documentation necessary to demonstrate to the NRC that the inundation of the Oconee site resulting from the failure of the Jocassee Dam has been bounded. Also, you shall submit by November 30, 2010, a list of all modifications necessary to adequately mitigate the inundation, and shall make all necessary modifications by November 30, 2011.

Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:

1) Notify me immediately if your understanding differs from that set forth above;

2) Notify me if for any reason you cannot complete the actions within the specified schedule and advise me in writing of your modified schedule in advance of the change; and

3) Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION DEC 2 Issuance of this Confirmatory Action Letter does not preclude issuance of an Order formalizing the above commitments or requiring other actions on the part of the licensee; nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.

This Confirmatory Action Letter will remain in effect until the NRC has concluded that all modifications necessary to adequately mitigate the inundation of the Oconee site from the failure of the Jocassee Dam has been completed.

Sincerely,

/RA/

Luis A. Reyes Regional Administrator Docket Nos. 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55

Enclosure:

Compensatory Measures cc w/encl: (See next page)

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

_________________________ G SUNSI REVIEW COMPLETE OFFICE NRR RII:EICS RII:DRP RII:ORA RII:DRP SIGNATURE Via email CFE /RA/ JTM /RA/ VMM /RA/ JHB /RA/

NAME *ELeeds *CEvans *JMunday VMcCree *JBartley DATE 6/21/2010 6/21/2010 6/21/2010 06/22/2010 06/21/2010 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL USE ONLY - SECURITY RELATED INFORMATION DEC 3 cc w/encl: Kent Alter David A. Baxter Regulatory Compliance Manager Vice President Oconee Nuclear Station Oconee Nuclear Station Duke Energy Carolinas, LLC Duke Energy Carolinas, LLC ON03RC 7800 Rochester Highway 7800 Rochester Highway Seneca, SC 29672 Seneca, SC 29672 Richard J. Freudenberger Safety Assurance Manager Duke Energy Carolinas, LLC Oconee Nuclear Station 7800 Rochester Highway Seneca, SC 29672 Terry W. King Site Security Manager Duke Energy Carolinas, LLC Oconee Nuclear Station 7800 Rochester Highway Seneca, SC 29672 Daniel C. Durham Security Support Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672 Timothy J. Wadsworth Security Specialist Duke Energy Carolinas, LLC P. O. Box 1006 526 S. Church St., EC05P Charlotte, NC 28201-1006 David A. Cummings Assistant General Counsel Duke Energy Corporation P.O. Box 1006 526 S. Church St., EC07H Charlotte, NC 28201-1006 OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Letter to David A. Baxter from Luis A. Reyes dated June 22, 2010

SUBJECT:

CONFIRMATORY ACTION LETTER - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 COMMITMENTS TO ADDRESS EXTERNAL FLOODING CONCERNS (TAC NOS. ME3065, ME3066, AND ME3067)

Distribution w/encl:

RidsNrrPMOconee Resource C. Evans, RII L. Slack, RII B. Westreich, NSIR E. McNiel, NSIR OE Mail (email address if applicable)

RIDSNRRDIRS OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION COMPENSATORY MEASURES NUMBER COMPENSATORY MEASURES IMPLEMENTATION STATUS 1 Perform flooding studies using the Hydrologic Engineering Complete Center -- River Complete Analysis System (HEC-RAS) model for comparison with previous DAMBRK models to more accurately represent anticipated flood heights in the west yard following a postulated failure of the Jocassee Dam.

2 Maintain plans, procedures (Jocassee and Oconee) and Implemented guidance documents implemented (Oconee) to address mitigation of postulated flood events which could render the Standby Shutdown Facility inoperable and are consistent with current perspectives gained following the HEC-RAS sensitivity studies and the subsequent 2D inundation studies.

To the extent practical, the mitigation strategy is similar to existing extensive plant damage scenario (B.5.b) equipment, methods and criteria.

3 Duke Energy Hydro Generation will create a guidance Implemented document to consolidate river management and storm management processes. (Includes the Jocassee Development and the Keowee Development.)

4 Maintain a dam safety inspection program that includes: Implemented (1) weekly dam safety inspections of the Jocassee Dam by Duke Energy personnel, (2) dam safety inspections following any 2-inch or greater rainfall or felt seismic event, (3) annual dam safety inspections by Duke Energy, (4) annual dam safety inspections by FERC representatives, (5) five year safety inspections by FERC approved consultants, and (6) five year underwater inspections.

5 Maintain a monitoring program that includes: (1) continuous Implemented remote monitoring from the Hydro Central Operating Center in Charlotte, NC, (2) monthly monitoring of observation wells, (3) weekly monitoring of seepage monitoring points, and (4) annual surveys of displacement monuments.

6 Assign an Oconee engineer as Jocassee Dam contact to Implemented heighten awareness of Jocassee status.

7 Install ammeters and voltmeters on Keowee spillway gates Complete for equipment condition monitoring.

8 Ensure forebay and tailrace level alarms are provided for Complete Jocassee to support timely detection of a developing dam failure.

9 Add a storage building adjacent to the Jocassee spillway to Complete house the backup spillway gate operating equipment (e.g.,

compressor and air wrench).

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 2

NUMBER COMPENSATORY MEASURES IMPLEMENTATION STATUS 10 Obtain and stage a portable generator and electric drive Complete motor near the Jocassee spillway gates to serve as a second set of backup spillway gate operating equipment.

11 Conduct Jocassee Dam failure Table Top Exercise with 06/30/2010 Oconee participation to exercise and improve response procedures.

12 Instrument and alarm selected seepage monitoring locations 08/31/2010 for timely detection of degrading conditions.

13 Provide additional video monitoring of Jocassee Dam (e.g., 08/31/2010 dam toe, abutments, and groin areas) for timely assessment of degrading conditions.

14 Obtain and stage a second set of equipment (including a 11/30/2010 B.5.b-type pump) for implementation of the external flood mitigation guidance.

15 Conduct Jocassee Dam/Oconee Emergency Response 12/31/2010 Organization Drill to exercise and improve response procedures.

NOTES:

1. The word complete is used in the status column if the commitment regards a specific one-time equipment-related or analysis-related action that has been completed.

2. The word implemented is used in the status column if the commitment describes an on-going action that has been implemented.

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION Enclosure