LIC-13-0019, Omaha Public Power District'S Overall Integrated Plan 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-12-04

Omaha Public Power District'S Overall Integrated Plan 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)

ML13064A298
Person / Time
Site:	Fort Calhoun
Issue date:	02/28/2013
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML130920289	List: LIC-13-0019, Omaha Public Power District'S Overall Integrated Plan 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-12-04
References
EA-12-049, LIC-13-0019
Download: ML13064A298 (3)

Text

ým Mmý Onu~u lFdikPm~wOil1d 444 South 1 6 n Street Mall Omaha, NE 68102-2247 LIC-13-0019 February 28, 2013 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12054A736) (NRC-1 2-0020)

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ML12242A378)

4. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA 049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ML12229A174)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPD 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)," dated October 27, 2012 (LIC-12-0154)

SUBJECT:

Omaha Public Power District's Overall Integrated Plan 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)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 2) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was immediately effective and requires the Omaha Public Power District (OPPD) 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 (BDBEE). Specific requirements are outlined in Attachment 2 of Reference 2.

This letter provides the enclosed OPPD Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 2. The Nuclear Energy Institute (NEI) has provided guidance (Reference 3) to the industry for compliance with the Order. The NEI guidance was endorsed by the NRC (with exceptions and clarifications) in the Interim Staff Guidance (ISG) (Reference 4), which describes methods acceptable to the NRC for complying with the Order.

This letter confirms OPPD has received Reference 4 and has an Overall Integrated Plan developed in accordance with the guidance for defining and deploying strategies that will enhance the ability to cope with conditions resulting from BDBEEs. Reference 5 provided OPPD's initial status report regarding mitigation strategies, as required by Reference 2.

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LIC-13-0019 Page 2 The enclosed Overall Integrated Plan for mitigation strategies is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 2.

Table 1 provides the list of open items associated with the FCS FLEX integrated plan. The following open items are defined as items which must be completed before a FLEX mitigation strategy can be established or confirmed. Table 1 identifies the FLEX integrated plan section, sub-section, and associated open items.

FLEX No. Integrated Plan FLEX Integrated Plan Sub-Section Open Item Section 1 General Key Site Assumptions to Implement NEI 12- Communicate exceptions related to Integrated Plan 06 Strategies Site Security Plan or Other License Elements requirements 2 General Provide a Sequence of Events and Identify Complete Control Room Heatup Integrated Plan Any Time Constraint Required for Success Calculation Elements Including the Technical Basis for the Time Constraint 3 General Provide a Sequence of Events and Identify Complete Reactor Coolant System Integrated Plan Any Time Constraint Required for Success (RCS) Makeup Evaluation with RCP Elements Including the Technical Basis for the Time CBO Modification Constraint 4 General Identify How Strategies Will Be Deployed in Develop Playbook Integrated Plan All Modes Elements 5 Maintain Core Provide a Brief Description of Complete Water Chemistry Impact Cooling & Heat Procedures/Strategies/ Guidelines Analysis and review impact on the Removal strategies 6 Maintain RCS General Description Complete Core Uncovery Time Inventory Evaluation with RCP CBO Isolation.

Control (This is subtask of open item #3.)

7 Maintain Spent General Description Evaluate Auxiliary Building Fuel (SFP) Ventilation Requirements with SFP Cooling Evaporation 8 Safety Functions General Description Evaluate Environmental Conditions Support after ELAP in critical FLEX deployment areas

U. S. Nuclear Regulatory Commission LIC-13-0019 Page 3 There are no regulatory commitments contained in this submittal.

If you should have any questions regarding this submittal, please contact Mr. Bill R. Hansher at (402) 533-6894.

I declare under penal of perjury that the foregoing is true and correct. Executed on February 28, 20A3.

Lo*s P. Cortopasssi Site Vice President and CNO

Enclosure:

Fort Calhoun Station EA-12-049 (FLEX) Overall Integrated Plan c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. M. Sebrosky, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector