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

ENERGYNORTHWEST David A. SwankColumbia Generating StationP.O. Box 968, PE23Richland, WA 99352-0968 Ph. 509-377-2309 1 F. 509-377-2354 daswank @ energy-northwest.com March 10, 2014G02-14-036 10 CFR 50.54(f)U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

COLUMBIA GENERATING

STATION, DOCKET NO. 50-397EXTENSION REQUEST REGARDING THE FLOODING HAZARDREEVALUATION REPORT REQUIRED BY NRC REQUEST FORINFORMATION 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 PowerReactor Licensees and Holders of Construction Permits in Active orDeferred Status, "Request for Information Pursuant to Title 10 of theCode 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 theFukushima Dai-ichi Accident" (ML12053A340)

2) Letter dated May 11, 2012, from E. J. Leeds (NRC) to All Power ReactorLicensees and Holders of Construction Permits in Active or DeferredStatus, "Prioritization of Response Due Dates for Request forInformation 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 ReactorLicensees and Holders of Construction Permits in Active or DeferredStatus, "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 ofthe 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 TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTPage 2 of 3

Dear Sir or Madam:

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

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

Recommendation 2.1 of thereferenced letter requested a reevaluation of all appropriate external flooding sources andthe submittal of a Flood HRR. In Reference 2, Columbia was identified as a Category 2site with a submittal date of March 12, 2014.In Reference 3, the NRC provided supplemental information stating incomplete FloodHRRs that only contain an analysis of some flooding hazard mechanisms would not be ofsubstantive 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 thesubmittal due date. Reference 3 also provided guidance in requesting extensions of thereporting requirement, in that the following information should be included:

1) the reasonfor 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, andthe basis for the acceptability of the revised schedule.

Attachment 2 contains a list of therevised commitments.

If you have any questions or require additional information, please contact Ms. L. L. Williamsat (509) 377-8148.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on thedate of this letter.Respectfully, D. A. SwankAssistant Vice President, Engineering Attachments:

1. Reason for the Delay and Basis for the Acceptability of the RevisedFlood HRR Schedule2. List of Revised Commitments EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTPage 3 of 3cc: NRC Region IV Administrator NRC NRR Project ManagerNRC Senior Resident Inspector/988C MA Jones -BPA/1 399 EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTATTACHMENT 1Reason 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 TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTAttachment 1Page 1 of 3Introduction:

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

Recommendation 2.1 of thereferenced letter requested a reevaluation of all appropriate external flooding sourcesand the submittal of a Flood Hazard Reevaluation Report (HRR). In Reference 2,Columbia Generating Station (Columba) was identified as a Category 2 site with asubmittal 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 floodinghazard mechanisms would not be of substantive benefit for staff review and would notbe acceptable.

Therefore, licensees were advised not to submit partial reports, butrather 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 forthe Columbia Flood HRR.Reason for the Delay:The overarching reason for the additional time is based on the significant number ofdams upstream and downstream of Columbia that must be evaluated in order to fullyassess the flood hazard. Specifically, based on the location of Columbia, EnergyNorthwest must evaluate the impact of failure of several potentially critical upstream anddownstream 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 whichalso must be evaluated because of potential backwater effects caused by their failure.On October 4, 2013, Energy Northwest submitted Reference 4 to request NRC engagethe U.S. Army Corps of Engineers (USACE) to provide these analyses.

During ateleconference on January 22, 2014, between Energy Northwest and members of theNRC staff, it was stated that Energy Northwest would require an extension of thesubmittal date if USACE input was necessary for completing the Columbia Flood HRR.Proposed Submittal ScheduleAt 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 ofreceiving 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 TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTAttachment 1Page 2 of 3Basis for the Acceptability of the DelayThe Energy Northwest proposed schedule extension is acceptable based on thefollowing discussion.

The cover letter of the NRC's March 12, 2012, Request for Information states that thecurrent regulatory approach and the resultant plant capabilities provide confidence thatan accident with consequences similar to the Fukushima accident is unlikely to occur inthe United States. The NRC letter concluded that continued plant operation and thecontinuation of licensing activities do not pose an imminent risk to public health andsafety.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 theColumbia Final Safety Analysis Report, the recorded history of the Columbia Basinindicates that no historical floods have exceeded plant grade. The current license basisevaluations of upstream dam failures also show that flood waters to not reach plantgrade. The limiting flooding event is currently the Probable Maximum Precipitation event. The water from this event also does not reach the plant grade. The FloodingWalkdown Report (Reference

5) submitted on November 12, 2012, found that the plantwas 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 forInformation, interim evaluations and actions will be taken or planned to address anyreevaluated higher flooding hazards relative to the design basis. These interimevaluations and actions, if any, will be included in the Columbia Flood HRR. EnergyNorthwest's position is that, assessed qualitatively, the reevaluated flooding hazard is avery low probability event and the probability of such events occurring within theextension 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 forInformation 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 ForceReview 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 ofResponse Due Dates for Request for Information Pursuant to Title 10 of the Code ofFederal Regulations 50.54(f)

Regarding Flooding Hazard Reevaluations for EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTAttachment 1Page 3 of 3Recommendation 2.1 of the Near-Term Task Force Review of Insights from theFukushima 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 ofFederal Regulations 50.43(f)

Regarding Flooding Hazard Reevaluations forRecommendation 2.1 of the Near-Term Task Force Review of Insights from theFukushima Dai-ichi Accident" (ML13044A561)

4) Letter GO2-13-141, dated October 4, 2013, from D. A. Swank (Energy Northwest) toNRC, "Energy Northwest's Request for NRC Assistance to Obtain Information fromthe US Army Corps of Engineers (USACE) related to Dam Failure Analysis"

5) Letter G02-12-164, dated November 12, 2012, from D. A. Swank (EnergyNorthwest) to NRC, "Flooding Walkdown Report" (ML12319A476)

EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTATTACHEMENT 2List of Revised Commitments EXTENSION REQUEST REGARDING THE FLOODING HAZARD REEVALUATION REPORT REQUIRED BY NRC REQUEST FOR INFORMATION PURSUANT TO10 CFR 50.54(f)

REGARDING RECOMMENDATION 2.1, FLOODING, OF THE NEAR-TERM TASK FORCE REVIEW OF GNSIGHTS FROM THE FUKUSHIMA DAI-ICHIACCIDENTAttachment 2Page 1 of 1The following table identifies the changes to the scheduled completion dates of previousregulatory commitments to support the extension request date in Attachment

1. Thesecommitments were originally made in letter G02-13-012 dated January 22, 2013, fromD. A. Swank (Energy Northwest) to NRC, "Energy Northwest's Response to the March12, 2012 Information Request-Flooding Integrated Assessment Approach."

Any otherstatements in this submittal, including intended or planned actions, are provided forinformation purposes and are not considered to be regulatory commitments.

Commitment Scheduled Completion DateFollowing completion of the FloodingHazard Reevaluation Report, EnergyNorthwest will utilize the guidance in theNRC letter dated December 3, 2012, fromDL Skeen (NRC) to JE Pollock (NEI),"Trigger Conditions for Performing anIntegrated Assessment and Due Date forResponse,"

to determine if an Integrated Assessment or limited evaluation isrequired.

If a limited evaluation is performed, theresults will be submitted along with theFlooding Hazard Reevaluation Report.Ma-rch 12, 2014Energy Northwest will submit the requiredFlood Hazard Reevaluation Report within60 days of receiving the U.S. Army Corpsof Engineering's (USACE's) final analysis.

If an Integrated Assessment is required, March 12, 2016Energy Northwest will perform theassessment utilizing the guidance in JLD- Energy Northwest will complete theISG-12-05, "Guidance for Performing the Integrated Assessment (if required) withinIntegrated Assessment for External two years of the Flood HazardFlooding."

Reevaluation Report date.