ML12310A200

Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049)

ML12310A200
Person / Time
Site:	Cooper
Issue date:	10/29/2012
From:	O'Grady B J Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NLS2012109
Download: ML12310A200 (3)

Text

N Nebraska Public Power District Always there when you need us NLS2012109 October 29, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001.

Subject:

Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049)Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Nuclear Regulatory Commission Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 2. Nuclear Regulatory Commission Interim Staff Guidance JLD-ISG-2012-01,"Compliance with Order EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 3. Nuclear Energy Institute Letter to Nuclear Regulatory Commission "Industry Initiative on Procurement of Equipment for the Diverse and Flexible Coping Strategy (FLEX)," dated February 24, 2012 4. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference

1) to Nebraska Public Power District (NPPD). Reference I was immediately effective and directs NPPD to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 requires submission of an initial status report 60 days following issuance of the final interim staff guidance (ISG). The final ISG (Reference

2) was issued August 29, 2012. The purpose of this letter is to provide the initial status report pursuant to Section IV, Condition C.2, of Reference I within 60 days following issuance of Reference

2. This report confirms NPPD has received Reference 2 and is in the process of evaluating the guidance for the purpose of COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone:

(402) 825-3811 / Fax: (402) 825-5211 www.nppd.com NLS2012109 Page 2 of 3 establishing mitigation strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event as described in Attachment 2 of Reference 1.Major activities completed during this reporting period: " Additional portable equipment was ordered, as described in a Nuclear Energy Institute (NEI) letter to the NRC (Reference 3). Recent re-evaluation of Reference 3 determined that more portable equipment would need to be ordered to fully comply with the request.This additional portable equipment has been ordered." A site-specific evaluation is in progress to establish the coping capabilities as defined in NEI 12-06 (Reference 4).* Resources are being identified and project plans initiated, including development of milestones, to assure compliance with Reference 1.Planned activities for the next six months:* Development and submittal of the overall integrated plan.Technical difficulties encountered that could affect the ability to provide the licensee's February 28, 2013, submittal:

9 None at this time.Project milestones schedule through completion of installation and testing: " A project milestones schedule will be provided with the overall integrated plan." Implementation of the order will be completed for Cooper Nuclear Station pnor to startup from Refueling Outage 29 (Fall 2016).This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.I declare under penalty of perjury that the foregoing is true and correct.Executed On ?(Date)Sincerely, Brian J. O'Grady Vice President

-Nuclear and Chief Nuclear Officer/bk NLS2012109 Page 3 of 3 cc: Regional Administrator USNRC -Region IV Director USNRC -Office of Nuclear Reactor Regulation Cooper Project Manager USNRC -NRR Project Directorate IV-I Senior Resident Inspector USNRC -CNS Jessica A. Kratchman USNRC -NRR Eric E. Bowman USNRC -NRR Eileen M. McKenna USNRC -NRO NPG Distribution CNS Records