From: Criscione, Lawrence
Sent: Monday, December 10, 2012 6:53 PM
To: Ostendorff, William; Magwood, William
Cc: Boska, John; Hiland, Patrick; Evans, Michele; Pascarelli, Robert; Wilson, George; Bartley,
Jonathan; Cook, Christopher; Miller, Ed; Cheok, Michael; Chen, Yen-Ju; Beasley,
Benjamin; Merzke, Daniel; Coffin, Stephanie; Skeen, David; See, Kenneth; Monninger,
John; Perkins, Richard; Bensi, Michelle; Philip, Jacob; Sancaktar, Selim; Galloway,
Melanie; Mitman, Jeffrey; Ferrante, Fernando; Bubar, Patrice; Tappert, John
Subject: Your Meeting Today Concerning Flooding at Oconee from Jocassee Dam
Attachments: 2012-12-10_Briefing_on_Oconee_Flooding.pdf.pdf; Lack of Transparency Impeding
Resolution of Flooding Concerns at Oconee.pdf.pdf; 2009-04-06.pdf
It came to my attention today that you and Commissioner Magwood were being briefed by NRR on the flooding
vulnerabilities posed to the reactors at Oconee from a catastrophic failure of Jocassee Dam. Attached to this email are
the “Commissioner Briefing Notes” prepared by NRR. Also attached are a 2012‐11‐14 letter from me to the Senate
Committee on the Environment & Public Works (E&PW) and an April 6, 2009 Non‐Concurrence Form which a Deputy
Division Director at NRR/DRA (Melanie Galloway) submitted against NRR’s pusillanimous treatment of the
I do not know exactly what you were told during your briefing today, but if it was limited to the “Commissioner Briefing
Notes” then you did not receive all the pertinent facts.
A major concern of mine, which I addressed in my attached letter to the E&PW, is that, in all the internal documents I
have uncovered regarding NRR briefings of the Commissioners on the Jocassee/Oconee flooding issue, the actual risk
numbers calculated by NRR/DRA are never mentioned and neither is the 2008‐09‐26 Duke Energy timeline concerning
the predicted failure sequence which would occur at Oconee following a catastrophic failure of the Lake Jocassee Dam
(for the context of the quote below, see p. 10 of Attachment 2 of ML082750106):
The following flood timeline is based on the results of the 1992 Inundation Study. In this scenario the dam is
assumed to fail at time zero. Notification from Jocassee would occur before a total failure of the dam; however,
for purposes of this timeline, notification is assumed to be at the same time the dam fails. Following notification
from Jocassee, the reactor(s) are shutdown within approximately 1 hour. The predicted flood would reach ONS in
approximately 5 hours, at which time the SSF walls are overtopped. The SSF is assumed to fail, with no time
delay, following the flood level exceeding the height of the SSF wall. The failure scenario results are predicted
such that core damage occurs in about 8 to 9 hours following the dam break and containment failure in about 59
to 68 hours. When containment failure occurs, significant dose to the public would result.
Hopefully you recognize that the above scenario is very similar to what occurred at Fukushima when a tsunami
overtopped their inadequately sized flood wall and disabled their standby shutdown equipment. Why the above
scenario does not ever appear in Commissioner briefing packages, I do not understand. This seems to me like something
you would want to know.
Another thing you should know is the annual probability of failure calculated by NRR/DRA for Jocassee Dam. That
number is 2.8E‐4/year, which is of the same order of magnitude of a 49 foot tsunami striking the Japanese coast at
Fukushima. Given this calculated probability of dam failure and the Duke Energy timeline quoted above, it appears that
the inadequately sized flood wall at Oconee presents a very similar hazard to the American public as the inadequately
sized flood wall at Fukushima presented to the Japanese public. Is this not something of which NRR should be informing
As noted by Dr. Ferrante in the email trail below, NRR is not a monolithic institution. Specifically, NRR/DRA has a very
different position on the Jocassee/Oconee issue as NRR/DORL. See the attached Non‐Concurrence from Melanie
Galloway as an example.
I do not know who was at your briefing today, but from the invitation attached to this letter it appears that neither were
the key personnel from NRR/DRA (Galloway, Mitman, Ferrante) nor were the authors of the GI‐204 Screening Report
(Perkins, Bensi, Philip, Sancaktar) invited to attend. It might be helpful to your understanding of the Jocassee/Oconee
issue if you were to speak to Ms. Galloway regarding her 2009‐04‐06 Non‐Concurrence, Dr. Ferrante and Mr. Mitman
regarding their 2010‐03‐15 Generic Failure Rate Evaluation for Jocassee Dam, and Richard Perkins regarding his ordeal in
routing and releasing the screening analysis for GI‐204 on flooding due to upstream dam failures.
After over 60 years of military service, Admiral Rickover noted:
A major flaw in our system of government, and even in industry, is the latitude to do less than is necessary. Too
often officials are willing to accept and adapt to situations they know to be wrong. The tendency is to downplay
problems instead of actively trying to correct them.
The NRC first identified the undersized flood wall at Oconee Nuclear Station in March 1994. It is my concern that the
reason this issue is taking more than two decades to address is that Division Directors at NRR have been willing to accept
and adapt to situations they know to be wrong. As noticed by Ms. Galloway in April 2009, the tendency in NRR was to
downplay the Jocassee/Oconee problem instead of actively trying to correct it. The public looks to the NRC
Commissioners to curtail this “latitude to do less than is necessary” and to ensure the NRC staff transparently addresses
concerns in a timely manner.
I appreciate you taking an interest in this issue and requesting a briefing by NRR. I am concerned, however, that your
briefing might not have adequately detailed the vulnerabilities faced at Oconee.
Lawrence S. Criscione
Reliability & Risk Analyst
If a subordinate always agrees with his superior, he is a useless part of the organization.
From: Ferrante, Fernando
Sent: Thursday, November 15, 2012 1:58 PM
To: Criscione, Lawrence
Cc: Mitman, Jeffrey
Subject: RE: Lack of Transparency Impeding Resolution of Flooding Concerns at Oconee
In understand, and I think the folks who were involved in it understand as well. I just worry that other folks will
look at our affiliations and assume “NRR” means the specific folks listed in the letter.
From: Criscione, Lawrence
Sent: Thursday, November 15, 2012 11:42 AM
To: Ferrante, Fernando
Cc: Mitman, Jeffrey
Subject: RE: Lack of Transparency Impeding Resolution of Flooding Concerns at Oconee
Thanks Fernando. Jeff sent me the PSA and PSAM papers last month.
When I use “NRR” I mean the dominant position that won out. Hopefully most people understand that in an
agency of 4000 people there is no one true NRC position or one true NRR position. Over the past five years it
has bothered me to no end that a legitimate FOIA exemption is “pre-decisional information” and that the NRC
is able to use it to conceal the internal debate process. I think the public should be able to FOIA the varying
NRC positions on issues and to understand how things are internally debated and decisions arrived at.
From: Ferrante, Fernando
Sent: Thursday, November 15, 2012 8:04 AM
To: Criscione, Lawrence
Cc: Mitman, Jeffrey
Subject: RE: Lack of Transparency Impeding Resolution of Flooding Concerns at Oconee
Thanks for the opportunity to review this letter. For the most part, the facts related to activities I am directly
aware of are correct. Regarding the Information Notice (IN) that NRR authored on dam failure probabilities, I
will give you some more background information that will hopefully help further clarify the discussion.
The IN came as a direct result of the Oconee/Jocassee issue. Jim Vail, a retired NRR/DRA/APOB staff, was in
charge of developing it (with support from the NRR staff in charge of releasing generic communications in
NRR/DPR/PGCB) under guidance from Melanie Galloway, then NRR/DRA Deputy Director. Sometime in 2009,
I took over the responsibility of re-writing and issuing the IN (in the same manner I was tasked with rewriting
NRR’s original submittal to RES regarding the creation of what would eventually become GI-204). Since the
beginning, there was a lot of resistance and internal struggle regarding this IN. In order to have the IN released
I made sure to build consensus between NRR/DRA, NRR/DE, RES/DRA (which had produced an internal dam
failure report which supported the information that eventually went into the IN), and others. As more NRC
Offices lined up to be included in the IN, the concurrence process started to take longer and this ended up
indeed being an exceedingly long turnover for a generic communication. The GI-204 process continued in
parallel until it became bogged down with some of the issues you described in the letter. At some point a
presentation was made in an NRR LT/ET meeting, and the directive for the IN became to coordinate its release
with the release of the GI-204 report. Because of the delays in the GI-204 report, this added another 6 months
to a year of the release of the IN itself. At some point, when it became clear both releases were imminent, I
was asked if the IN should be reclassified as “NON-PUBLIC/SECURITY RELATED,” which I rejected on the
basis that no information was contained in the IN which was covered in both NRR and NRC guidance
regarding the withholding of information. Hence, the IN was eventually released publicly.
I should add that, as part of an effort to publicly release and discuss information that was created during the
development of the dam failure report by RES/DRA, two papers were submitted, accepted, and presented at
PRA conferences (the most recent in Helsinki, 2012) with concurrence from both NRR/DRA and RES/DRA
staff (I can send these papers to you if you are interested). Both papers were reviewed internally and, similar to
the IN, contained no information that went against guidance regarding withholding of information. Both papers
relied in part on data developed by the US Army Corps of Engineers (USACE) which does restrict public
release of certain portions of their dam databases, but we followed their guidelines and contacted USACE to
make sure no inadvertent release was made. This papers follow the same methodology discussed in the
internal NRR/DRA document you referred to in the letter (ML100780084) which, to my knowledge, is the
closest we have come to a more official position on the dam failure rate issue (which was, at least in part, the
intent I had when the document was created).
I’m sharing the above information to make sure that readers who are totally unfamiliar with the issue (inside or
outside of NRC), get a clear picture of how NRR/DRA dealt with some of the issues we were faced during the
Oconee/Jocassee issue. In several parts of the letter, certain positions regarding the release of information or
level of importance the issue deserved are attributed to “NRR” as a whole (e.g., “…there was a strong push by
NRR to force RES to remove all OUO‐SRI material from the screening report for GI‐204.”) which I don’t think
were shared by all staff or Divisions within NRR. I am concerned this may be misconstrued by readers who are
completely unaware of the challenges the Oconee/Jocassee issue presented to the technical staff to mean all
staff within NRR shared these positions.
Fernando Ferrante, Ph.D.
Office of Nuclear Reactor Regulation (NRR)
Division of Risk Assessment (DRA)
PRA Operational Support Branch (APOB)
Mail Stop: 0-10C15
From: Criscione, Lawrence
Sent: Wednesday, November 14, 2012 10:23 AM
To: Zimmerman, Jacob; Vrahoretis, Susan
Cc: Beasley, Benjamin; Coe, Doug; Correia, Richard; Galloway, Melanie; Mitman, Jeffrey; Ferrante, Fernando; Wilson,
George; Leeds, Eric
Subject: FW: Lack of Transparency Impeding Resolution of Flooding Concerns at Oconee
Jacob/Susan: Please forward the attached letter to the Commission staff whom you believe should be aware
I have copied on this email some of the NRR staff mentioned in the letter. Please let me know if I am misportraying
any of your positions. Please feel free to forward this letter to whomever you believe needs to see
From: Criscione, Lawrence
Sent: Wednesday, November 14, 2012 9:15 AM
To: ‘[email protected]’; ‘[email protected]’
Subject: Lack of Transparency Impeding Resolution of Flooding Concerns at Oconee
Please see the attached letter to the Senate Committee on the Environment & Public Works.
Subject: Commissioner briefing on Oconee external flood protection
Start: Mon 12/10/2012 2:00 PM
End: Mon 12/10/2012 3:00 PM
Meeting Status: Accepted
Organizer: Boska, John
Required Attendees: Hiland, Patrick; Evans, Michele; Pascarelli, Robert; Wilson, George; Bartley, Jonathan;
Cook, Christopher; Miller, Ed; Cheok, Michael; Chen, Yen-Ju; Beasley, Benjamin;
Merzke, Daniel; Coffin, Stephanie; Skeen, David; See, Kenneth; DORLCAL Resource
Optional Attendees: Monninger, John
When: Monday, December 10, 2012 2:00 PM-3:00 PM (GMT-05:00) Eastern Time (US & Canada).
Note: The GMT offset above does not reflect daylight saving time adjustments.
Updated on 12/6/12. The briefing handout is attached below. It is now revision 2, dated 12/6/12. The
revision was to the section on NRC Interagency Work, to more accurately describe the NRC’s interaction
with other federal agencies (my thanks to George Wilson).
This briefing was requested by Commissioner Ostendorff. He may be joined by Commissioner Magwood.
The briefing will provide information on the flood risk to Oconee from a failure of the Jocassee dam. In
particular, it will cover the following:
• background with a summary timeline of the issue
• overview of the staff’s efforts to resolve the issue
• summary of NRC interagency work (e.g., FERC, DHS)
• summary of the licensee actions including interim compensatory measures
• treatment as sensitive unclassified information
• NRC public communication efforts
John Boska will maintain the master copy of the presentation materials.
If you can’t come to the conference room, you may participate by calling 800-619-7596, code
Oconee Project Manager, NRR/DORL
U.S. Nuclear Regulatory Commission
Email: [email protected]
November 14, 2012
1412 Dial Court
Springfield, IL 62704
Barbara Boxer, Chairman
US Senate Committee on the Environment & Public Works
410 Dirksen Senate Office Bldg.
Washington, DC 20510‐6175
Dear Senator Boxer:
There are three reactors in Oconee County, South Carolina which face a risk of meltdown and
containment failure that is highly similar to the accident which occurred in Japan in March
2011. The staff of the US Nuclear Regulatory Commission has known about these risks since
2007 but has yet to adequately address the issue. I am writing to you because the
Commissioners of the NRC failed to bring up the three Oconee Nuclear Station reactors during
their March 15, 2012 testimony at the US Senate Committee on the Environment & Public
Works hearing and because it is unclear to me whether or not the Commissioners are fully
aware of the vulnerabilities at Oconee.
The vulnerability posed to the reactors concerns a catastrophic failure of Jocassee Dam, which
is upstream of the Oconee Nuclear Station. The NRC has known since 20061 that the flood wall
at Oconee Nuclear Station is 7 to 12 feet too low to protect against the predicted flood height
that would occur were Jocassee Dam to catastrophically fail. Like the reactors at Fukushima
Dai‐ichi, the reactors themselves at Oconee and their containment buildings are designed to
survive earthquakes and flooding. However, their support systems – that is, the emergency
standby equipment needed to safely shut them down and remove decay heat from their cores
– are vulnerable to failure due to flooding which overtops their flood walls. The difference
between Oconee and Fukushima is the source of the flood: a dam break instead of a tsunami.
Aside from that difference, the predicted accidents are eerily similar in both their timing
sequence and their probability of an unmitigated release of radioactivity to the surrounding
On September 18, 2012 I wrote a letter to NRC Chairman Macfarlane detailing my concerns
regarding the vulnerability posed by Jocassee Dam to the Oconee reactors. Three days after
sending my letter, I was informed by my branch chief that he was directed to fill out a NRC
Form 183 on me for not adequately designating my letter as “Official Use Only – Security‐
Related Information”. Four weeks after sending my letter I was informed by the Chairman’s
1 See pp. 5‐9 of the “Oconee Nuclear Station Integrated Inspection Report 05000269/2006002, 05000270/200602,
05000287/2006002”. This report is in the NRC’s Agencywide Documents Access and Management System
(ADAMS) under “Accession Number” ML061180451. Most of the documents I refer to in this letter are non‐public
and the most efficient way to request them from the NRC is to refer to the ADAMS Accession Number.
legal counsel that my letter had been referred to the NRC’s Office of the Inspector General.
Other than these two instances, I have not had any other discussions regarding my letter and
am unsure if the Chairman or any of the other Commissioners have read my letter or are aware
of the details of my concerns.
I have been directed by the NRC not to further distribute my 2012‐09‐18 letter because it is not
properly designated. I have also been directed to no longer send NRC documents to
Congressional staffers without going through my chain of command and the NRC’s Office of
Congressional Affairs. However, I did copy you on that 2012‐09‐18 letter, and Valerie Manak
and Nathan McCray of the E&PW staff should have electronic copies of it.
Since becoming involved in the Jocassee/Oconee issue in 2007, the NRC’s Office of Nuclear
Reactor Regulation (NRR) has designated all internal and external correspondence regarding
this issue as “Official Use Only – Security‐Related Information”. This designation not only
prohibits the American public from knowing about the grave risks which Jocassee Dam poses to
the reactors at Oconee, but, as I will explain below, this designation has also inhibited internal
discussion of these concerns within the NRC.
In a September 26, 2008 letter to the US Nuclear Regulatory Commission (ML082750106), Duke
Energy provided a harrowing timeline of what would occur at the Oconee Nuclear Station (ONS)
were Jocassee Dam to catastrophically fail. Despite the fact that this time line appears in a
Wikipedia article on Oconee Nuclear Station, since the NRC considers the Duke Energy letter to
be “Official Use Only – Security‐Related Information” I cannot quote the letter here. But the
scenario provided in the 2008‐09‐26 Duke Energy letter is essentially the scenario that occurred
at Fukushima Dai‐ichi except, instead of a tsunami being the source of water overtopping the
known inadequately sized flood wall, the source of water at ONS is a flood resulting from the
failure of Jocassee Dam.
Prior to the 2011‐03‐11 tsunami, it was believed that the annual probability of a 45 foot tall
tsunami reaching Fukushima Dai‐ichi was on the order of once in every 100,000 years. It is now
widely held that the annual probability is more likely around once in every 1,000 years.
In the 1980’s it was believed the annual probability of Jocassee Dam failing was on the order of
one chance in 100,000.2 However, by 2007 the US NRC believed the actual number was more
on the order of one chance in 10,000.3
When the five Commissioners testified before your committee on March 15, 2012, members of
the staff at the US NRC believed that the three reactors at the Oconee Nuclear Station faced a
risk eerily similar to what occurred at Fukushima Dai‐ichi. Yet none of the Commissioners
mentioned that fact when Senator Barrasso brought up the Union of Concerned Scientists’
2 1.3E‐5/year was the failure frequency Duke Energy used in some of its risk assessments.
3 2.9E‐4/year is the failure rate the NRC has calculated for large rock‐filled dams similar to Jocassee.
report on the vulnerability of US plants to Fukushima type disasters. Were the Commissioners
withholding information from your committee? I don’t believe so. I think what actually has
happened is that crucial information has been withheld from them. They cannot testify before
Congress about vulnerabilities of which they themselves have not been made fully aware.
To me, the most important tool the public has for ensuring good regulation and safety is
accurate information. In a democratic republic such as ours, openness and transparency are
essential in providing our citizens and their elected officials with the accurate information they
need to make informed decisions.
To my knowledge, concerns that the flood wall at the Oconee Nuclear Station was too small
first surfaced internally at Duke Energy in late 1993 and first made it to the NRC’s attention in
February 1994. The NRC dismissed the concerns in September 1994 as “not credible” because
of an inappropriately low assumption regarding the failure rate of Jocassee Dam.
The issue regarding the inadequately sized flood wall resurfaced in March 2006. While
attempting to defend a violation he had written against Duke Energy for inadequately
controlling a two year breach in the flood wall (ML061180451), one of the NRC Resident
Inspectors at Oconee Nuclear Station began researching the regulatory requirements for the
In 2007 NRR’s Division of Risk Assessment (NRR/DRA) determined that the annual failure
probability of dams similar in construction to Jocassee is around 2.5E‐4/year, which equates to
a chance of once in every 4000 years (ML100780084).4 These might seem like good odds, but,
given that a catastrophic failure of Jocassee Dam will lead to a Fukushima scenario in South
Carolina, these odds make the risk of a significant accident and radiation release at Oconee
Station about 100 times greater than the risks associated with a typical US commercial nuclear
In 2008 the NRC sent Duke Energy a 10CFR50.54(f) request (ML081640244) to obtain the
necessary information to adequately determine if the risks posed to Oconee Nuclear Station by
Jocassee Dam were acceptable. A 10CFR50.54(f) request is a rare occurrence and it
undoubtedly got the attention of the Commissioners. However, because by this time the NRC
was stamping all documents concerning Jocassee Dam as “Official Use Only – Security‐Related
Information” (OUO‐SRI), it did not get the attention of the public.
My primary reason for bringing the Jocassee/Oconee issue to your attention is because, to me,
it is an example of how lack of discipline regarding transparency has allowed a significant issue
to go uncorrected for over six years and counting, with the current deadline for resolution still
four years away. I believe that NRR’s stamping of all documents concerning Jocassee Dam as
4 ML100780084 is dated 2010‐03‐15. This is the formalized version of research and calculations performed in 2007
by Ferrante and Mitman of NRR/DRA.
“OUO‐SRI” has not only prevented the public scrutiny necessary for our democratic and
republican institutions to properly function, but has also inhibited the internal flow of
information within the NRC and thereby has been detrimental to both public safety and
Duke Energy’s response to the NRC’s 10CFR50.54(f) request was, like the original request,
withheld from the public under the guise of security. This response is the document which
contains the Fukushima‐style timeline regarding what would occur to the three reactors at
Oconee were Jocassee Dam to catastrophically fail.5 It is unclear to me whether or not any of
the Commissioners reviewed this document. It is ludicrous to expect the Commissioners to
review every piece of correspondence received by the NRC – they have a staff of over 4,000
federal employees to assist with that. But I would assume that all important issues make it to
their attention during their periodic briefings. However, based on the documents I have
reviewed, I question the exact level of detail which they have received regarding the
Jocassee/Oconee issue during their briefings from NRR.
On February 3, 2009 Commissioner Peter Lyons traveled to South Carolina to tour Jocassee
Dam and Oconee Nuclear Station. In the briefing book prepared from him by NRR
(ML090280474) there is a 25‐line summary detailing the flooding issues. The 2008‐08‐15
10CFR50.54(f) request is mentioned in this summary. However, what did not make it into this
summary is NRR/DRA’s estimate that the failure rate of Jocassee Dam is about 2.5E‐4/year and
that in their 2008‐09‐26 response to the 20CFR50.54(f) request Duke Energy admitted that a
catastrophic failure of Jocassee Dam would likely lead to the meltdown of all three reactor
cores at the Oconee Nuclear Station and possibly the failure of the containment structures.
On February 20, 2009 two engineers from NRR’s Division of Risk Assessment, Fernando
Ferrante and Jeffrey Mitman, began routing an Information Notice (IN 2012‐02) concerning the
risks posed to some nuclear reactor sites due to dam failures. The purpose of this information
notice (ML090510269) was:
… to alert addressees of a potentially nonconservative screening value for dam failure
frequency that originated in 1980’s reference documents which may have been
referenced by licensees in their probabilistic risk assessment (PRA) for external events.
Using a nonconservative screening value for dam failure frequency to evaluate the need
for an additional detailed analysis may result in underestimating the risks to the plant
associated with external flooding or loss of heat sink from the failure of upstream and
5 I cannot quote from Duke Energy’s 2008‐09‐26 letter without the NRC claiming that this letter to you is now
“Official Use Only – Security‐Related Information” which must only be provided through their Office of
Congressional Affairs (NRC/OCA). I respectfully suggest that your staff request ML082750106 and ML112430114
from NRC/OCA. The Fukushima‐style timeline appears on p. 10 of attachment 2 of ML082750106 and on pp. 8‐9 of
ML112430114. It is also quoted on the fourth page of my 2012‐09‐18 letter to NRC Chairman Macfarlane.
downstream dams or levees. The NRC expects that recipients will review the information
for applicability to their facilities and consider actions, as appropriate, to avoid similar
Please note that this Information Notice was being routed more than two years prior to
Fukushima occurring. That is, two years prior to the 2011‐03‐11 flooding‐induced triple reactor
accident at Fukushima, the NRC was aware that certain US plants might face a similar scenario
were dams upstream of them to fail. However, this information notice was not released until
more than three years later (March 5, 2012 which was nearly a year after Fukushima). The
reason this information notice took more than three years to route was because of the
controversial nature of NRR’s indecisiveness regarding how to address the flooding
vulnerabilities at Oconee and also because of the debate over whether dam break effects on
nuclear reactors is a security concern which needs to be withheld from the American public.
In the past year, I have encountered many people, both within the NRC and external, who are
adamant that the vulnerability which a failure of Jocassee Dam poses to the reactors at Oconee
is a security liability which must be kept from the public. Although I am sympathetic to the
desire not to broadcast our security liabilities, I have no tolerance for using concerns over
security as a pretext for withholding important safety vulnerabilities from the public. When the
Jocassee/Oconee issue first came to light in an April 28, 2006 publicly available inspection
report, the issue was not being withheld. At some point in 2007 the NRC, either at the request
of Duke Energy or on their own accord, decided to begin withholding from the public all
correspondence regarding the safety liability posed by a failure of Jocassee Dam.
Is Jocassee Dam a credible target for terrorists and/or saboteurs? I don’t know. But it does
make sense to me that, in 2007, the NRC might reasonably want to withhold information
regarding Jocassee/Oconee while they determined whether or not a security vulnerability
existed and whether or not security measures were required to be put into place to protect it.
What does not make sense to me, however, is that in 2012 we are still withholding from the
public information on a vital safety concern under the guise of “Security‐Related Information”.
After five years, have we not addressed the security concerns?
It is unreasonable to me that a government agency is allowed to withhold a significant public
safety concern from the public under the guise of security, yet then not, after 5 years, do any
meaningful study of the issue to determine if, in fact, a security vulnerability does exist and
what must be done to remove it. Is there a security concern or isn’t there? If there is, why,
after five years, has it not been addressed? If there is not, then why, after five years, are we
still withholding vital information from the public under the guise of security?
In April 2009, NRR was in the process of responding to Duke Energy regarding resolution of the
Jocassee/Oconee issue. As part of the routing of that response, NRR’s Division of Risk
Assessment was asked for their concurrence. The Deputy Director of NRR/DRA, Melanie
Galloway, refused to initial her concurrence block and instead submitted a Non‐Concurrence
form (ML09117010) on April 6, 2009. Like all documents regarding Jocassee/Oconee, Ms.
Galloway’s Non Concurrence form is stamped “OUO‐SRI” and I cannot quote from it. But a
deputy division director submitting a Non‐Concurrence is rare; this is a process that is mainly
used by lower level staff, and even for them it is rare. Had Ms. Galloway’s Non‐Concurrence
form – which in no way concerns security vulnerabilities – been publicly available, it would have
likely gained the attention necessary to get the Jocassee/Oconee issue resolved in a timely
Had intervener groups such as the Union of Concerned Scientists been given access to Melanie
Galloway’s Non‐Concurrence form via publicly available ADAMS, then they would have likely
been able to counter the pressure which Duke Energy was placing on NRR. With dozens of their
own engineers, lawyers and hired contractors, Duke Energy was able to convince NRR that, in
order for improvements to Oconee’s flooding defenses to be required, the NRC needed to
probabilistically show that Jocassee Dam placed an inordinate risk upon the three reactors at
Oconee. Pressure from the Union of Concerned Scientists and other intervener groups,
however, would have likely convinced NRR that, per Duke Energy’s operating license for the
Oconee reactors, in order for Duke Energy to be allowed to continue to operate the three
reactors at Oconee they needed to deterministically show that these reactors were adequately
protected from a catastrophic failure of Jocassee Dam.
On April 9, 2009 Chairman Jaczko was briefed by NRR on the Jocassee/Oconee issue. I don’t
exactly know what was said at this briefing. The briefing slides (ML091030172) mentioned that
new calculations concerning the failure frequency of Jocassee Dam suggested that core damage
frequency (i.e. the annual probability that a meltdown will occur) for the reactors at Oconee
might be non‐conservative by an order of magnitude. What is not mentioned in the slides is
Duke Energy’s Fukushima‐style scenario (contained in their 2008‐09‐26 letter) of what would
occur at Oconee Nuclear Station were Jocassee Dam to catastrophically fail.
On January 6, 2010 the leadership of NRR met to discuss the Jocassee/Oconee issue
(ML100280954). The purpose of the meeting was whether NRR should issue an order to
Oconee requiring them to, in a timely manner, mitigate the risks posed by a failure of Jocassee
Dam, or whether NRR should merely issue another 10CFR50.54(f) request for information and
potentially follow up with an order later. The “Cons” listed for the “10CFR50.54(f) option” were
that it was not as enforceable as an order and that it had a slower response time for resolution
of the external flooding issue. The “Cons” listed for the “order option” were that there was the
potential for a public hearing and that an order required signature authority. In other words, to
go the route of an order, the Commission and the public would need to be made aware of the
risks which Jocassee Dam posed to Oconee. Despite the slower response time, NRR opted to go
the route of the 10CFR50.54(f) letter and avoid the Commission and public scrutiny an order
In February 2010 – using information provided by Ferrante and Mitman of NRR/DRA – George
Wilson submitted an informal memorandum to the NRC’s Office of Nuclear Regulatory
Research (RES) requesting that a Generic Issue be assigned to investigate whether external
flooding concerns, similar to those posed by Jocassee Dam to the three reactors at Oconee,
existed elsewhere in our nation’s fleet of 104 commercial reactor plants. George Wilson was
the Dam Safety Officer in NRR’s Division of Engineering (NRR/DE). At the time, we (i.e.
RES/DRA/OEGIB) deemed Mr. Wilson’s February 2010 memo to be too speculative and
inflammatory to make it an official agency record; however, I have a copy of it if your
committee staff requires it. This memo is an example of just how serious mid‐level staffers in
the various divisions of NRR viewed the Jocassee/Oconee issue. Keep in mind, this is over a
year prior to the Fukushima accidents, yet the staff within NRR were presciently predicting the
nuclear catastrophe that could occur were an inadequately sized flood wall to be overtopped
allowing the flooding of the standby shutdown equipment necessary to remove decay heat
from the reactor cores and containment buildings. Unfortunately it does not appear the
managers at NRR were providing the Commissioners all the details of the NRR staff’s concerns.
On June 22, 2010 NRR issued a Confirmatory Action Letter to Duke Energy (ML101730329)
requiring them to (1) by August 2, 2010 provide an estimate of the volume of water impounded
by the Lake Jocassee Dam to be used for flood height analyses at Oconee Nuclear Station, (2) by
November 30, 2010 provide a list of modifications to be made at Oconee to adequately protect
the plant from flooding due to a failure of the Lake Jocassee Dam, and (3) by November 30,
2011 have the provided modifications in place.
On July 19, 2010, NRR sent a formal memo to RES requesting a Generic Issue on flooding of
nuclear power plant sites following upstream dam failures (ML101900305). In August 2010, the
Operating Experience and Generic Branch (RES/DRA/OEGIB) of the Division of Risk Assessment
in the NRC’s Office of Nuclear Regulatory Research began working on a screening analysis
report for what would become GI‐204 (Generic Issue 204). In my opinion, the 2010‐07‐19
memo and the attendant screening report are evidence of the NRC staff identifying a significant
vulnerability and striving to get it addressed. Please note that this issue was being forwarded
without the hindsight of the Fukushima accident and entirely due to the analysis of the NRR
staff and their determination to pro‐actively address an issue significant to the safety of about a
fifth of our nation’s nuclear reactor plants.
On August 2, 2010, Duke Energy provided the NRC with an estimated volume of water to be
assumed impounded by the Lake Jocassee Dam. Their estimate was a “sunny day” estimate.
For reasons not understood by myself and other staff engineers at the NRC, Duke Energy
believes that a failure of Jocassee Dam during an inordinately heavy rainfall (such as the one
experienced in Senator Sanders’ state in 2011 as the remnants of Hurricane Irene blew over
parts of Vermont and New York) is not a credible scenario. In January 2011, Jeff Mitman of
NRR/DRA challenged this assumption through the Non‐concurrence process (ML110260443).
On November 29, 2010, Duke Energy informed the NRC that it was giving itself an additional 6
months to provide the list of modifications needed to protect the three reactors at Oconee
from a failure of the Lake Jocassee Dam (ML103490330). Despite this issue being over four
years old in its current incarnation (and over 16½ years old from its 1994 incarnation), NRR did
not object to Duke’s 6 month extension.
By March 10, 2011 (the eve of the earthquake and tsunami in Japan), RES/DRA/OEGIB had
drafted its screening analysis report for GI‐204 and submitted it for routing. As you are well
aware, on March 11, 2011 flooding induced from a tsunami disabled the emergency equipment
at the Fukushima Dai‐ichi reactors leading to the meltdowns of three reactor cores and the
destruction of the buildings housing their containments. In the NRC’s Office of Nuclear
Regulatory Research, we assume that the accident in Japan would add a sense of urgency to the
approval of GI‐204 and the addressing of the flooding concerns at Oconee. Instead, it
inordinately delayed both. I am in no position to completely understand what occurred, but
from my second‐hand vantage point it appears that the management at NRR viewed the true
vulnerability exposed by Fukushima not to be the flooding issue at Oconee but rather their
multi‐year mismanagement of getting it addressed.
On April 29, 2011 Duke Energy provided the NRC the list of modifications it intended to do at
Oconee to protect against a failure of Jocassee Dam (ML111460063). In this letter, Duke Energy
extended the NRC’s due date for implementation of the modifications from Nov. 30, 2011 to a
nebulous commitment of 30 months after the approval of the modification plans by the NRC
and FERC (the Federal Energy Regulatory Commission).
So, as of April 29, 2011 – seven weeks after the Fukushima accidents – the NRC’s deadline for
adequately protecting the Oconee reactors from a failure of Jocassee Dam had slid from
November 30, 2011 to some indefinite time in roughly mid‐2014.
As noted many times to your committee, the NRC has issued orders to all 104 reactor plants to
make modifications based on the lessons learned from the Fukushima accident. What has likely
not been noted to your committee is that the NRC has allowed Duke Energy to slide their mid‐
2014 due date for protecting Oconee from a Jocassee Dam failure to 2016 in order to conform
with the Fukushima deadlines given to the other US reactor plants. But the three reactors at
Oconee are different from the rest of the US fleet. Unlike the other 101 reactors, the three
reactors at Oconee had a known external flooding concern that, over nine months prior to the
Fukushima accident event occurring, had a November 30, 2011 deadline set (i.e. the
2011‐11‐30 deadline was established in a 2010‐06‐22 letter which was delivered to Duke
Energy nearly 9 months prior to the 2011‐03‐11 tsunami occurring). The 2016 deadline is
reasonable for the other 101 reactors because this was a new issue for them. But for the three
reactors at Oconee, by the time the post‐Fukushima orders came out they were already 5 years
into the external flooding issue and had a deadline for modifications already set. Does it make
sense that their already generous deadline be extended to match everyone else’s?
The history I have provided you is little known within the NRC. Because of supposed security
concerns, the Jocassee/Oconee issues are not discussed at All Hands Meetings. The issues are
not discussed in sessions at the NRC’s annual Regulatory Information Conference (RIC). The
issues do not appear in articles of Platts, or at American Nuclear Society conferences, or in
online nuclear discussion groups, or in Union of Concerned Scientists blogs. Because of the
OUO‐SRI designation of all correspondence regarding this issue, there is virtually no internal
oversight within the NRC to make sure NRR is properly handling this issue. And because of the
OUO‐SRI designations there was a strong push by NRR to force RES to remove all OUO‐SRI
material from the screening report for GI‐204.
Like briefing packages for the Commissioners, Generic Issue screening reports are typically
released to the public as part of the NRC’s commitment to transparency. But it must be
remembered that these reports are not written for public consumption – they are written for
internal use. Briefing packages to the Commissioners are written to concisely inform the
Commissioners of important points on key issues. Generic Issue screening reports are written
to inform the screening panel members of the issues. Being that the Commissioners and the
NRC staff are all authorized to view OUO‐SRI documents, why would we water down our
internal reports by removing all OUO‐SRI material and thereby share less information with
ourselves? I do not know the answer to that, but I have a suspicion.
When NRR knows a document – such as a Generic Issue screening report or a Commissioner
briefing package – is going to eventually be released to the public, they prefer it be released
without redactions. Redactions are a “red flag” for intervener groups like Greenpeace and the
Union of Concerned Scientists. If the Fukushima‐style timeline from Duke Energy’s 2008‐09‐26
letter were to appear in a briefing book for Commissioner Apostolakis’ trip to Oconee, then
NRR knows that, when that briefing book is eventually released with a paragraph from the
“External Flooding” section redacted, David Lochbaum will be asking his connections on Capitol
Hill to request the redacted section. To avoid this, NRR essentially “pre‐redacts” it by not even
including it in the first place. Unfortunately, in doing this they keep the Commissioners from
obtaining vital information that the Commission needs to know to make important decisions.
And likewise for the screening panel for Generic Issue 204. Richard Perkins, the lead author of
the “Screening Analysis Report for the Proposed Generic Issue on Flooding of Nuclear Power
Plant Sites Following Upstream Dam Failures” (ML112430114), was under constant pressure
from NRR to remove the 2008‐09‐26 Duke Energy timeline from his report (he has a foot tall
stack of internal NRC email correspondence to document it). Richard Perkins came to the NRC
from the Department of Energy where he worked on the annual certification process for
assuring the safety and reliability of America’s nuclear weapons. He is a graduate of the
National War College and was used to working with Top Secret and Special Compartmentalized
Information (TS‐SCI) on a daily basis. To him, the notion that the screening panel for GI‐204 did
not have a “need to know” the accident timeline from Duke Energy’s 2008‐09‐26 letter was
absolutely ludicrous. He has rhetorically asked me on many occasions, “Why would we want to
redact this information from our internal report?”
On September 14, 2012 Richard Perkins submitted a letter to the NRC’s Inspector General
alleging that the NRC had “intentionally mischaracterized relevant and noteworthy safety
information as sensitive, security information in an effort to conceal the information from the
public.” I assume the NRC’s Office of the Inspector General (OIG) is investigating his complaint
but am unaware of their findings. Given the NRC OIG’s proclivity for narrowly focusing on
procedural processes and not questioning the broader intent of those processes, I am doubtful
that the OIG investigation will be conducted with a broad enough questioning attitude to
adequately investigate Mr. Perkins’ claims.
On September 12 & 13, 2011, Commissioner Apostolakis visited Jocassee Dam. In the NRR
prepared briefing book for that visit (ML11244A024), the 25 line description of the External
Flood section provided to Commissioner Lyons had shrunk to 9 lines. Although Commissioner
Apostolakis’ visit was a mere six months after Fukushima, no mention of Duke Energy’s
Fukushima‐style timeline from their 2008‐09‐26 letter was made in the briefing book. Nor was
there any mention of the failure probability of Jocassee Dam being in the same range as the
probability of a 45 foot tsunami hitting the Fukushima Dai‐ichi site.
On February 1, 2012 Commissioner Svinicki visited Jocassee Dam. NRR’s briefing book for that
visit (ML12026A549) contains a whole page on the External Flooding issue, yet does not
mention the facts that (1) the issue has gone on for six years, (2) the Duke Energy accident
timeline is very similar to Fukushima, (3) the flooding probability is similar to Fukushima, (4)
NRR had assigned Duke Energy a 2011‐11‐30 deadline nine months prior to Fukushima, (5)
seven weeks after Fukushima that 2011‐11‐30 deadline was extended by Duke Energy to mid‐
2014, and (6) the deadline for Duke Energy’s propose modifications to their flooding defenses
was later moved to 2016 to match the Fukushima action plan for all the plants without known
flooding hazards. These are things that, were I Commissioner Svinicki, I would like to know
before visiting Oconee – and, for that matter, before testifying before your committee on
March 15, 2012.
On February 16, 2012 Duke Energy came to NRC headquarters for a “Drop‐in Visit” with Bill
Borchardt, the NRC’s Executive Director for Operations (EDO). NRR’s briefing book for that visit
(ML12039A217) contains a page on the External Flooding issue which is similar to the one
provided to Commissioner Svinicki. I do not know if Mr. Borchardt is aware of the true risk that
Jocassee Dam poses to the three reactors at Oconee, but if all he knows is the summary in his
briefing book, then there is much which he is unaware of yet needs to know.
On March 15 all five Commissioner testified before your committee at the Hearing on Post‐
Fukushima U.S. Reactor Safety. None of the Commissioners mentioned the fact that three
reactors in Oconee County, South Carolina face a similar risk as was faced by the reactors at
Fukushima Dai‐ichi on March 11, 2011. I believe they did not mention it to your committee
because it has been kept from them themselves.
On July 11, 2012 Duke Energy again visited Mr. Borchardt for a “Drop‐in Visit” and on August 7,
2012 they dropped in on the Commissioners. As before, the briefing books supplied for these
visits (ML12188A071 & ML12206A325) did not mention the true risks posed by Jocassee Dam
or the delays in resolving these risks.
If you believe the issues I have brought forward in this letter are of interest to your committee,
then I respectfully suggest your staff seek answers to the following:
1. What is the official NRC determination as to the best estimate of the annual failure
frequency of Jocassee Dam? How does this failure frequency compare to the annual
frequency of a tsunami similar to the one in Japan on 2011‐03‐11 which caused the
flooding induced nuclear accident at Fukushima Dai‐ichi?
2. What is the official NRC position regarding whether or not a catastrophic failure of
Jocassee Dam is a credible risk for which Duke Energy must deterministically show that
the three reactors at Oconee Nuclear Station are adequately protected?
3. What is the official NRC position regarding whether or not the current flooding defenses
at Oconee are adequate and what, if any, improvements need to be made?
4. What is the official NRC position regarding the most likely accident sequence at Oconee
Nuclear Station were Jocassee Dam to catastrophically fail? How does this accident
sequence compare to the March 2011 accident at Fukushima?
5. Assuming the catastrophic failure of Jocassee Dam, what is the NRC’s best estimate of
the likelihood that the operators at Oconee Nuclear Station would be able to restore
cooling to the reactors prior to the containment buildings failing? What are the
differences between the Oconee reactors and the Fukushima reactors that leads the
NRC to believe the Oconee operators will be able to successfully restore cooling prior to
containment failures? Has the NRC conducted any formal studies to estimate the
success rate of Duke Energy’s mitigation strategies to prevent containment failures in
the event of a catastrophic failure of Jocassee Dam? If so, when were these studies
conducted and what were the results?
6. Has the US NRC or any federal agency conducted an assessment to determine if
Jocassee Dam is adequately protected from terrorist threats? If so, what were the
results of the assessments? Is access to Jocassee Dam adequately guarded from
terrorist attack? Are the employees at the Jocassee Hydro‐Electric Facility screened for
inside saboteurs to the same level at which nuclear workers at the Oconee reactors are
screened? Is it necessary to continue to withhold from the public vital safety
information concerning the risks which a failure of Jocassee Dam poses to the three
reactors at the Oconee Nuclear Station?
7. Do the Commissioners believe that, prior to their March 15, 2012 testimony before the
US Senate Committee on the Environment & Public Works, they were adequately
informed of the vulnerability which Jocassee Dam poses to the reactors at the Oconee
8. When does the US NRC intend to release to the public their correspondence concerning
Jocassee Dam and Oconee Nuclear Station? What is the justification for continuing to
withhold this information from the American public and from public intervener groups
such as the Union of Concerned Scientists? Does the NRC believe it would benefit from
a review of its handling of the Jocassee/Oconee issue conducted by intervener groups?
Enclosed with this letter is a list of NRC correspondence, memos and studies regarding the
Jocassee/Oconee issue. As can be seen from the enclosed list, this issue has festered in its
current incarnation since 2006 and was originally brought forward to the NRC in 1994. Please
note that most of the documents on the enclosed list are being withheld from the American
Although I am convinced the risks of a nuclear accident at Oconee are at least an order of
magnitude greater than at a typical US reactor plant, I am not yet convinced that these risks are
unacceptable. And although I do not know enough about nuclear security to judge whether or
not all the security issues have been adequately addressed, at this time I do not believe a
credible security threat to Jocassee Dam exists. I am not appealing to your committee with
safety or security concerns. My concern is transparency, and how the lack of it has not only
impeded this issue from getting the public scrutiny which it requires but may also be impeding
this issue from getting the appropriate scrutiny from the Commissioners of the US Nuclear
Lawrence S. Criscione, PE
Reliability & Risk Engineer
Operating Experience & Generic Issues Branch
Division of Risk Assessment
Office of Nuclear Regulatory Research
US Nuclear Regulatory Commission
Cc: Senator James Inhofe, Ranking Member, Committee on Environment & Public Works
Senator Thomas Carper, Chairman, E&PW Subcommittee on Clean Air & Nuclear Safety
Senator John Barrasso, Ranking Member, E&PW Subcom. on Clean Air & Nuclear Safety
Senator Sheldon Whitehouse, Chairman, E&PW Subcommittee on Oversight
Senator Mike Johanns, Ranking Member, E&PW Subcommittee on Oversight
Chairman Allison Macfarlane, US Nuclear Regulatory Commission
Date ADAMS Title
?2006?APR?28 ML061180451 OCONEE?NUCLEAR?STATION???INTEGRATED?INSPECTION?REPORT?
?2006?AUG?31 ML080780143 IR?05000269?06?016,?IR?05000270?06?016,?IR?05000287?06?016,?on?03/31/2006,?
?2006?OCT?5 ML062890206 Oconee,?Units?1,?2?&?3???Response?to?Preliminary?White?Finding
?2006?NOV?22 ML063260282 IR?05000269?06?017,?IR?05000270?06?017,?IR?05000287?06?017,?Final?Significance?
?2006?DEC?20 ML063620092 Oconee,?Units?1,?2,?&?3,?Appeal?of?Final?Significance?Determination?for?White?
?2007?JAN?29 ML070440345 Summary?of?Revised?Fragility?Evaluation?Results?for?Jocassee?Dam
?2007?FEB?22 ML070590329 Manual?Chapter?0609.02?Appeal?Panel?Recommendations?(Oconee?Reply?to?a?
?2007?MAR?1 ML070610460 Oconee?Appeal?Panel?Review?of?Manual?Chapter?0609.02?Appeal?Panel?Review?of?
?2007?MAY?3 ML072970510 Oconee,?Units?1,?2?and?3???Request?for?NRC?to?Review?Appeal?of?Final?Significance?
?2007?JUN?22 ML071580259 Consideration?of?New?Information?Associated?with?a?Final?Significance?
?2007?OCT?1 ML072770765 10/01/2007,?Slides?with?Notes?for?Final?Regulatory?Assessment?of?Oconee?Flood?
?2007?OCT?1 ML072770775 Dam?Failure?Information
?2007?OCT?1 ML072770777 Questions?and?Answers?Related?to?Oconee?Flood?Barrier
?2007?NOV?20 ML073241045 Reconsideration?of?Final?Significance?Determination?Associated?with?Standby?
?2008?MAY?19 ML081350689 Briefing?Package?For?Drop?In?Visit?By?Duke?Energy?Chief?Nuclear?Officer?With?
?2008?JUN?23 ML082390669 Proposal?for?a?Risk?Analysis?of?the?Failure?of?the?Jocassee?and?Keowee?Dams?to?
?2008?JUL?28 ML082120390 Oconee?Nuclear?Station???Revisions?to?the?Selected?Licensee?Commitments?Manual?
Date ADAMS Title
?2008?AUG?15 ML081640244 Information?Request?Pursuant?to?10?CFR?50.54(F)?Related?to?External?Flooding,?
?2008?AUG?26 ML082390690 Kick?Off?for?Risk?Analysis?of?the?Failure?of?the?Jocassee?and?Keowee?Dams?to?Assess?
?2008?AUG?28 ML083300427 08/28/2008???Summary?of?Closed?Meeting?to?with?Duke?Energy?Carolinas,?LLC?to?
?2008?AUG?28 ML082550290 Meeting?with?Duke?Energy?Carolinas,?Oconee?Flood?Protection?and?the?Jocassee?
?2008?SEP?6 ML082250166 Oconee?Nuclear?Station???Communication?Plan?for?Information?Request?Related?to?
?2008?SEP?26 ML082750106 Oconee,?Units?1,?2?and?3???Response?to?10?CFR?50.54(f)?Request
?2008?NOV?5 ML091060761 11/05/08?Summary?of?Closed?Meeting?with?Duke?on?External?Flooding?Issues,?
?2008?NOV?5 ML083390650 11/05/2008?Meeting?Slides,?”Oconee?Site?Flood?Protection,”?NRC?Meeting?with?
?2008?DEC?4 ML091420319 12/04/2008?Meeting?Summary,?Meeting?to?Discuss?External?Flooding?at?Oconee?
?2008?DEC?4 ML090480044 Oconee?Nuclear?Station,?External?Flood?NRR?Meeting,?Rockville,?MD,?December?4,?
?2009?FEB?3 ML090280474 Briefing?Package?for?Commissioner?Lyons?Visit?to?Oconee?on?February?4,?2009
?2009?APR?6 ML091170104 Oconee?Nuclear?Station,?Units?1,?2?And?3???Non?concurrence?on?Evaluation?of?Duke?
?2009?APR?9 ML091030172 Oconee?External?Flooding?Briefing?for?Commissioner?Jaczko
?2009?APR?30 ML090570779 Oconee?Nuclear?Station?Units?1,?2,?and?3,?Evaluation?of?Duke?Energy?Carolinas?
?2009?MAY?11 ML092940769 05/11/2009?Summary?of?Closed?Meeting?with?Duke?Energy?Carolinas,?LLC,?to?Discuss?
?2009?MAY?11 ML090820470 5/11/2009?Notice?of?Forthcoming?Closed?Meeting?with?Duke?Energy?Carolinas,?LLC,?
?2009?MAY?11 ML091380424 Oconee?Nuclear?Station,?Slides?for?Closing?Meeting?May?11,?2009?with?Duke?on?the?
?2009?MAY?20 ML091470265 Oconee,?Units?1,?2?&?3,?Request?for?Extension?of?Duke?Response?Time?to?Referenced?
?2009?MAY?26 ML091480116 E?mail?re?Briefing?Package?for?Visit?to?Jocassee?Dam?on?June?23,?2009
?2009?JUN?1 ML091590046 Oconee,?Units?1,?2,?and?3,?Request?to?Withhold?Sensitive?Information?in?
?2009?JUN?10 ML091680195 Oconee,?Units?1,?2,?and?3???Interim?30?Day?Response?to?Reference?2.
Date ADAMS Title
?2009?JUN?11 ML091620669 6/11/09?Summary?of?Closed?Meeting?with?Duke?Carolina?to?Discuss?External?
?2009?JUN?25 ML091760072 NRC?Site?Visit?to?the?Oconee?Nuclear?Station?on?June?15,?2009
?2009?JUL?9 ML092020480 Oconee,?Units?1,?2,?&?3,?Final?60?Day?Response?to?Reference?2
?2009?JUL?28 ML092230608 Oconee,?Submittal?of?Selected?Licensee?Commitments?Manual?SLC?Revision
?2009?AUG?12 ML090570117 Oconee?Flood?Protection?and?the?Jocassee?Dam?Hazard?Basis?for?NRC?Allowing?
?2009?AUG?27 ML092380305 Oconee,?Slides?for?Closed?Meeting?Regarding?External?Flood?Technical?Meeting?On?
?2009?SEP?25 ML092710344 Site?Visit?Observation?on?09/25/2009?by?Joel?Munday?for?Oconee
?2009?OCT?28 ML093080034 10/28/09?Slides?for?Oconee?Nuclear?Station,?Units?1,?2,?and?3???Meeting?Slides???
?2009?NOV?30 ML093380701 Oconee?Nuclear?Station,?Units?1,?2,?and?3,?Oconee?External?Flood?Analyses?and?
?2009?DEC?4 ML090680737 12/04/09?Summary?of?Closed?Meeting?to?Discuss?the?Duke?Energy?Carolinas,?LLC.,?