2012-08-21 – NRC – Jocassee Dam – Options for Revising Oconee Flood CAL Due Dates

2012-08-21-nrc-jocassee-dam-options-for-revising-oconee-flood-cal-due-dates

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Bartley, Jonathan
From:
Sent:
To:
Cc:
Subject:
Attachments:
Len,
Bartley, Jonathan
Tuesday, August 21, 2012 8:42 AM
Wert, Leonard
Mccree, Victor; Jones, William; Croteau, Rick
Options for Revising Oconee Flood CAL Due Dates.docx-teffioial Use-enty-=”Sensitive
Jf:ltemaHnformatiertJ–·
Options for Revising Oconee Flood CAL Due Dates.docx
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 ,., . .., ‘
:1
~————————–~ , Compliments of
C. GREENPEACE
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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 RAls were resolved. The modifications would be
complete by February 28, 2016, assuming the RAls 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 reevaluation
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 RAl’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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-9ffieial U11e Onl~’ Sensitive Internal Info1111aiiea
6/22/2010 4/30/2011
CAL issued Submit Mods
6/22/2010
CAL issued
L
Offieittl Tise Only Sensitive [email protected] lnfurmation
9/14/2012* Start 30
months + RRP**
Current CAL
3/12/2013
Complete
updated
evaluron
Licensee Proposed Timeline
6/12/2013
3/12/2015
Complete
integrated
re po[
3/14/2016
Complete Mods
I
8/12/2015
Submit
mods
2/12/2019
Complete
Mods***
Complete 3/12/2015
integrated Complete 8/12/2015
3/12/2013 repo~ and integrated Submit 12/12/2016
Complete submit rt fo mods for
6/22/201 o mods for repo r other Complete
updated other Jocassee Mods
CALL~-s_ued~~~~~~~~~~~e-v-a-lu~r-ti-o~n~’-J–oc-_a-_s_s-ee~~~-h-az_ar~~~~~hLa~-zard~s ~~~__,~
NRC Proposed Timeline
* Assume RAI letter issued 9/14/2012
** Assume RRP to be 12 months
***Assumes 42 months (30 + RRP)
Figure 1: Timelines
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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 NRG 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 Nei.ieA=11::leF 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 Ne1.ieA=11::leF N
mitigate the inundation of the Oconee site to a potential 30, 2911
failure of Jocassee dam. 30 Months+
RRP after
resolution of
all RAl’s for
CAL 2-10-
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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Table 3: NRC Staff Proposed External Fukushima Response Flooding Commitments
No. External Flooding Commitments Due Date Complete.
(Y/N)
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. June 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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