ML14058A074

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Slides on Oconee Ssf Flood Barrier Breach SDP - Lessons Learned
ML14058A074
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 02/04/2014
From: Jeff Circle
NRC/NRR/DRA/APOB
To:
Shared Package
ML14055A421 List: ... further results
References
FOIA/PA-2012-0325
Download: ML14058A074 (18)
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Oconee SSF Flood Barrier Breach SDP - Lessons Learned Jeff Circle NRR/DRAIAPOB 1 [2U.US.NRC UrE DSTATESNUR COMMON nUIATRY Enviromment Proteetin People and Mea

Purpose s To brief the RMT of the lessons learned from the disposition of the Oconee Standby Shutdown Facility (SSF) wall SDP finding, s To discuss potential regulatory actions considered to ensure safety.

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Discussion Topics

@Background of finding.

@Technical lessons learned.

s Process lessons learned.

s Actions taken to date.

s Considered draft action plan.

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Importance of the SSF at Oconee

  1. The SSF contains the only means to shut all three units down following a station blackout induced by catastrophic flood, fire, or other external events.

s The Oconee site does not have emergency diesel generators.

- On-site emergency ac power isprovided by two hydro-electric generators at the Keowee dam,

@Catastrophic flooding to the site can render all the switchyards and Keowee dam unavailable thus blacking out all three units.

Under these conditions, the additional failure of the SSF function results incore damage.

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Aerial View Showing The Relationship of the Oconee Site Environment and Lake Keowee 5 ý2U.S.NRC STATES UNIhJTED NU~CLEAR REGULATORYCOMMSSION Protecting People and the Environment

Aerial View of the Oconee Site Use 6 US.NRC UrotMTATESNUCLnARg UkoLpe tEvir oe ha61ProetiSepkand the Entvironment

The Flood Barrier Finding o Licensee opened an access cover uncovering a previously cut hole in the wall on August 13, 2003.

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- Should have done a 10CFR50.65 U

(a)(4) assessment immediately.

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- Should have done a 10CFR50.59 U

evaluation after 90 days.

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  • Licensee opportunities to identify issue

- June 2,2005 NRC inspectors notified the licensee of condition.

Licensee issued PIP (condition report intheir corrective action system). Corrective action not taken.

- August 3,2005 NRC inspectors questioned lack of corrective action Five-foot flood wall and licensee issued a further PIP.

protecting the doorway.

. Opening sealed on August 3,2005.

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Interior and Exterior Walls of SSF 1~

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The Flood Scenario Rupture of Jocassee Dam

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Aerial View of Jocassee Dam. Upstream of the Oconee Site Jrn or-1  ? S.NRC N1JcIFR UNTDSTATES REGJL&.TURY OMMISSiON

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SSF Catastrophic Flood Heights Given Rupture of Jocassee Dam Licensee study in1980s established a resultant flood height of approximately 5feet.

- Justification for erection of the 5-ft wall around the doorway.

- Study isunavailable.

- Flood height almost matches that of overtopping of Keowee dam.

@Licensee commissioned additional study by FERC in 1992.

- Established a higher resultant flood height range of 12-16 feet.

- Licensee still used the 5-ft height for their IPEEE submittal developing a 20% split fraction apportioning the Jocassee Dam rupture frequencies to account for these higher FERC flood heights.

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Background Summary

, August 17, 2006 - SERP meeting assessed as preliminary WHITE based on a blended qualitative and quantitative risk-informed approach (pre-IMC 0609 App M).

, August 31, 2006 -Choice letter sent to licensee.

, October 5,2006 - Licensee provided written response to choice letter and waived regulatory conference.

, Nov. 22, 2006 -Final significance determination issued. WHITE based on qualitative erosion of defense-in-depth, but includes quantitative CDF based on apportioning flood frequency to flood height.

, December 20, 2006 -Licensee appeals the final significance determination.

Requests NRC to accept incomplete, un-docketed new information on Jocassee dam seismic failure.

. Appeal panel convened on January 9,2007.

  • Licensee contractor seismic fragility analysis of Jocassee issued January 29, 2007.
  • March 1,2007- Appeal panel upheld the WHITE finding.
  • May 3,2007 - Licensee requests reassessment of final significance determination.

. June, 2007 - Assembled ateam to review new information. Flooding expert review of data on random dam failure.

  • June 28, 2007 -Follow up telecom with Licensee on dam failure questions and comments,
  • July 17, 2007 -Licensee response to analysis questions by email.
  • September 5,2007 - Final SERP split vote forces upper management resolution.
  • November 20, 2007 -Final determination letter released to licensee.

- 12 0 US.NRC Sr&TE UNrTED NtCLL&RREGqATORY CONMION ProtectingPeopLe and the Environment

Jocassee Dam Random Failure Frequency Licensee developed random dam failure frequency for IPEEE submittal based on rockfill dam failures per population of earthen, rockfill, and composite dams.

- Severely underestimated frequency by an order of magnitude at 1,4E-5 per year.

As part of the second appeal, James Vail of NRR/

DRA/APOB investigated the derivation of this frequency.

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Process Lessons Learned

  • Process did not account for situations where licensee did not communicate to the regional office and waived participation ina regulatory conference.

. Process did not accept new information prior to final determination.

Without a regulatory conference, communication was impacted to program office and regional management of potential greater-than-green SDP findings.

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Actions Taken IIMC0609 indraft revision to account for:

- Licensees may present new information provided that they informed the agency either during a regulatory conference or inwriting before the final significance determination ismade.

- New information has to be submitted within the 30-day appeal period.

- Using best available information to determine final significance inatimely manner.

- NRR concurrence with regional management on accepting an appeal.

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Actions Taken (cont'd)

, Training conducted to regional Senior Reactor Analysts (SRAs) inOctober 2007 counterparts meeting.

, Met with NSIR to inform DHS on potential dam and other outside infrastructure vulnerability.

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Draft Action Plan to Consider Future Actions

, NRR Program Office Director and/or Deputy Director should be informed of all greater-thanogreen findings.

, Exploration of licensing and potential backfit requirement for protection against most likely flood.

, Generic communication to licensees on flooding.

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Draft Action Plan to Consider Future Actions (Cont'd)

  • Update of RASP manual for additional external flood guidance, s Consider an update to NUREG/CR-6928 to include rupture frequencies, s NRO Licensing and Design Bases Review for New Reactor Licensing to incorporate lessons learned on new applications.

e Develop a Temporary Instruction to assess licensee performance inthis area.

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