NLS2013079, Stations First Six-Month 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)
| ML13247A283 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/27/2013 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-049, NLS2013079 | |
| Download: ML13247A283 (7) | |
Text
N Nebraska Public Power District Always there when you need us NLS2013079 August 27, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Cooper Nuclear Station's First Six-Month 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:
I. NRC 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. NRC 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. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012
- 4. Nebraska Public Power District's 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 29, 2012
- 5. Cooper Nuclear Station'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), dated February 28, 2013
- 6. NRC Order Number EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012
- 7. NRC Order Number EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013 COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com 0-
NLS2013079 Page 2 of 3
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 1 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 I required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided NPPD's initial status report for Cooper Nuclear Station (CNS) regarding mitigation strategies.
Reference 5 provided CNS' overall integrated plan.
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.
The strategies in the overall integrated plan currently rely on the conceptual design of the reliable hardened vent system that was developed in response to NRC Order EA-12-050 (Reference 6).
NRC Order EA-13-109 (Reference 7) issued June 6, 2013, rescinds the requirements of NRC Order EA-12-050. Compliance with the requirements of NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required. The industry, through the Nuclear Energy Institute and the owners' group, is addressing the new requirements on the schedule outlined in NRC Order EA-13-109. Because of the new Order, the design of the hardened containment vent is being reevaluated. Any design changes resulting from the revised hardened vent order will be reflected in a future six-month update.
This letter contains no new regulatory commitments.
Should you have any questions regarding this report, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
NLS2013079 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
_/Z-7_
Sincerel(
Os r A. Lim pias (
Vice President -clear and Chief Nuclear Officer
/bk
Attachment:
Cooper Nuclear Station's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc:
Regional Administrator, w/attachment USNRC - Region IV Director, w/attachment USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC - NRR Project Directorate IV-1 Ms. Jessica A. Kratchman, w/attachment USNRC - NRR Senior Resident Inspector, w/attachment USNRC - CNS NPG Distribution, w/attachment CNS Records, w/attachment
NLS2013079 Attachment Page 1 of 4 Attachment Cooper Nuclear Station's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Introduction Nebraska Public Power District (NPPD) developed an overall integrated plan for Cooper Nuclear Station (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
Milestone Accomplishments The following milestone(s) have been completed since the development of the overall integrated plan (Reference 1), and are current as of July 30, 2013:
None; no milestones were scheduled to be completed, with the exception of this first six-month update.
Milestone Schedule Status The following table provides an update to Attachment 2 of the overall integrated plan. It provides the activity status of each item, and whether the expected completion date has changed.
The dates are planning dates subject to change as design and implementation details are developed.
A new milestone has been added for walk-throughs or demonstrations with a target completion date of April 2015. This new milestone and initial target date do not impact the Order implementation date.
Milestone Target Status Revised Target Completion Date Completion Date 60-day Status Update October 2012 Complete Submit Overall Integrated Plan February 2013 Complete 6-month Status Update August 2013 Complete Refine Strategies September 2013 Not Started (post-NRC review)
Develop Strategies / Contract with Regional Response Center January 2014 Not Started 6-month Status Update February 2014 Not Started
NLS2013079 Attachment Page 2 of 4 Regional Response Center TBD Not Started Operations Develop Storage Plan May 2014 Not Started Purchase FLEX Equipment June 2014 Not Started Issue Maintenance Procedures August 2014 Not Started (for FLEX equipment) 6-month Status Update August 2014 Not Started Develop Training Plan October 2014 Not Started Implementation Outage I Fall 2014 Not Started Develop Online Mods and December 2014 Not Started Implementing Procedures 6-month Status Update February 2015 Not Started Walk-throughs or Not Started April 2015 Demonstrations Implement Training May 2015 Not Started 6-month Status Update August 2015 Not Started Develop Outage Mods and October 2015 Not Started Implementing Procedures Implement Online Mods and December 2015 Not Started Procedures 6-month Status Update February 2016 Not Started Perform Staffing Assessment May 2016 Not Started 6-month Status Update August 2016 Not Started Implementation Outage 2 Fall 2016 Not Started Implement Outage Mods and Fall 2016 Not Started Procedures Implement Training Updates Fall 2016 Not Started Submit Completion Report Fall 2016 Not Started Changes to Compliance Method There are no changes to the compliance method as documented in the overall integrated plan at this time.
NLS2013079 Attachment Page 3 of 4 The FLEX strategies in the overall integrated plan (Reference 1) currently rely on the conceptual design of the reliable hardened vent system that was developed in response to NRC Order EA-12-050 (Reference 3). NRC Order EA-13-109 (Reference 4) issued June 6, 2013, rescinds the requirements of NRC Order EA-12-050. Compliance with the requirements of NRC Order EA-12-050, including applicable schedule deadlines for submittals or implementation, is no longer required. The industry, through the Nuclear Energy Institute and the owners' group, is addressing the new requirements on the schedule outlined in NRC Order EA-13-109. Because of the new Order, the design of the hardened containment vent is being reevaluated. Any design changes resulting from the revised hardened vent order will be reflected in a future six-month update.
Need for Relief/Relaxation and Basis for the Relief/Relaxation NPPD expects to comply with the Order implementation date and no relief/relaxation is required at this time.
Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the overall integrated plan or the Draft Safety Evaluation (SE) and the status of each item.
Overall Integrated Plan Open Item Status Primary and secondary storage locations have not been Started selected yet. Once locations are finalized implementation routes will be defined.
The location and sizing of the new raw water well has not Not Started been determined.
The method of transferring water from the hotwell to the Not Started ECSTs has not been determined.
The staging area for the Regional Response Center Not Started (RRC) equipment has not been determined.
Exceptions for the site security plan or other (license/site Not Started specific) requirements of 10 CFR may be required.
Coordination of site FLEX integrated Plan with security personnel is required.
Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft SE identified at this time.
NLS2013079 Attachment Page 4 of 4 References The following references support the updates to the overall integrated plan described in this attachment:
- 1. Cooper Nuclear Station's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requiremenits for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013
- 2. NRC 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
- 3. NRC Order Number EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," dated March 12, 2012
- 4. NRC Order Number EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions,"
dated June 6, 2013