NLS2016040, Nebraska Public Power District'S Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

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Nebraska Public Power District'S Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
ML16196A058
Person / Time
Site: Cooper Entergy icon.png
Issue date: 06/30/2016
From: Limpias O
Nebraska Public Power District (NPPD)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NLS2016040
Download: ML16196A058 (15)
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Text

JI Nebraska Public Power District Always there when you need us NLS2016040 June 30, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Nebraska Public Power District's Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated.June 6, 2013
2. NPPD letter to NRC, '~Nebraska Public Power District's Phase 1 Overall' -*

Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109),"

dated June 30, 2014 (NLS2014057)

3. NPPD letter to NRC, "Nebraska Public Power District's First Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Contairiment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 19, 2014 (NLS2014101)
4. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 and Phase 2 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 21, 2015 (NLS2015137)

On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 (Reference

1) to Nebraska Public Power District (NPPD). Reference 1 was immediately effective and directs NPPD to take certain actions to ensure that Cooper Nuclear Station (CNS) has a Hardened Containment Vent System to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe accident conditions resulting from an Extended Loss of AC Power. Specific requirements are outlined in Attachment 2 of Reference 1.

COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3811 /Fax: (402) 825-5211 www.nppd.com

NLS2016040 Page 2 of2 Reference 1 required submission of a Phase 1 overall integrated plan (OIP) pursuant to Section IV, Condition D, and status reports at six-month intervals thereafter. NPPD submitted an initial OIP for CNS by letter dated June 30, 2014 (Reference 2), Revision 1 to the OIP by letter dated December 19, 2014 (Reference 3), and Revision 2 which provided a combined Phase 1 and Phase

2) OIP (Reference 4).

The purpose of this letter is to provide the fourth six-month update for both Phase 1 and Phase 2 OIP implementation pursuant to Section IV, Condition D.3, of Reference 1.

This letter contains no new regulatory commitments. Should you have any questions concerning the content of this letter, please contact Jim Shaw, Licensing Manager, (402) 825-2788.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 0 G / 3° / I (,o r I

. Limpias Vice President - uclear and Chief Nuclear Officer

/bk

Attachment:

Nebraska Public Power District's Fourth Six-Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc: Regional Administrator, w/attachment USNRC - Region IV Director, w/attachment USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC - NRR Plant Licensing Branch IV-2 Senior Resident Inspector, w/attachment USNRC-CNS NPG Distribution, w/o attachment CNS Records, w/attachment

NLS2016040 Attachment Page 1 of 13 Attachment Nebraska Public Power District's Fourth Six-Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" Introduction Nebraska Public Power District (NPPD) developed an Overall Integrated Plan (OIP) for Cooper Nuclear Station (CNS) (Reference 1), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. Starting with this six-month status report, updates of milestone accomplishments will be based on the combined Phase 1 and 2 OIP (Reference 4).

NPPD developed an updated and combined Phase 1and2 OIP (Reference 4) in accordance with the guidance contained in Reference 3, documenting:

1. The installation of a HCVS that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2.
2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2.

This attachment provides an update of milestone accomplishments since submittal of the combined Phase 1and2 OIP including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments Operations procedure changes for Phase 1 have been developed.

Milestone Schedule Status The following table provides an update to Attachment 2 of the combined Phase 1and2 OIP. 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.

NLS2016040 Attachment Page 2of13 Target Comments Activity Milestone Completion (Include date Status Date changes)

Phase 1 and 2 HCVS Milestone Table Submit Phase 1 OIP June 2014 Complete Submit Six-Month Updates:

Update 1 December 2014 Complete Update 2 June 2015 Complete Update 3 with Phase 2 OIP December 2015 Complete Complete Update 4 June 2016 with this submittal Update 5 December 2016 Not Started Update 6 June 2017 Not Started Update 7 December 201 7 Not Started Update 8 June 2018 Not Started Phase 1 Specific Milestones Phase 1 Modifications:

Hold preliminary/conceptual design June 2014 Complete meeting Design Engineering On-site/Complete September 2015 Complete Operations Procedure Changes August 2016 Complete Developed Site Specific Maintenance Procedure August 2016 In Progress Developed Training Complete September 2016 Not Started Procedure Changes Active November 2016 Not Started Walk Through November 2016 Not Started Demonstration/Functional Test

NLS2016040 Attachment Page 3of13 Phase 2 Specific Milestones Hold preliminary/conceptual design December 2015 Complete meeting Design Engineering On-site/Complete October 2017 In Progress Operations Procedure Changes May 2018 In Progress Developed Site Specific Maintenance Procedure May 2018 In Progress Developed Training Complete June 2018 In Progress Implementation Outage October 2018 Not Started Walk Through Demonstration/Functional October 2018 Not Started Test Procedure Changes Active October 2018 Not Started Submit Completion Report (60 days after January 2019 Not Started full site compliance)

Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phase 1 and 2 OIP.

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 Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the combined Phase 1 and 2 OIP, the Interim Staff Evaluation (ISE) (Reference 5), and the status of each item.

NLS2016040 Attachment Page 4of13 Combined Phase 1 and 2 OIP Open Item Phase 1 Open Items OIP Open Action Status/Comment Item#

Determine location ofHCVS ROS. Closed.

1 The mechanical remote operating station (ROS) will be located along the Reactor Building South exterior wall.

Evaluate accessibility of the Closed.

Mechanical ROS for radiological and environmental conditions. CED 6036742, Tab 6, Section 6.5.5 (E2 -

Address dose and temperature Environmental Features), discusses the items for the Mechanical ROS and temperature and radiological conditions, as non-MCR locations. FAQ-HCVS- well as CED 6036742, Tab 6, Section 6.5.7 01 (Reference 14) will be used as (E4 - Emergency Preparedness, Planning guidance. and Response).

NEDC 15-002, "Review of Tetra Tech Portable Equipment Calculations in support of CNS FLEX Strategy," calculates the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up temperature profile in 2

the Reactor Building and Control Building during an extended loss of AC power (ELAP).

The site-specific radiological conditions for the HCVS are evaluated in NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS ," based on the bounding CNS-specific in-containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").

Determine the location of the Closed.

Dedicated HCVS Battery transfer switch. The dedicated HCVS battery transfer 3

switch will be located at the 903' elevation in the Control Building along the west wall.

Determine the location of backup Closed.

nitrogen bottles and evaluate the 4 Nitrogen bottles will be installed and effects of radiological and temperature constraints on their pre-connected in the mechanical ROS.

NLS2016040 Attachment Page 5of13 Combined Phase 1 and 2 OIP Open Item Phase 1 Open Items OIP Open Action Status/Comment Item#

deployment. These bottles are sufficient for operation for seven days.

CED 6036742, Tab 6, Section 6.5 .5 (E2 -

Environmental Features), discusses the temperature and radiological conditions, as well as CED 6036742, Tab 6, Section 6.5.7 (E4 - Emergency Preparedness, Planning and Response).

NEDC 15-002, "Review of Tetra Tech Portable Equipment Calculations in support of CNS FLEX Strategy," calculates the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up temperature profile in the Reactor Building and Control Building during an ELAP.

The site-specific radiological conditions for the HCVS are evaluated in NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS," based on the bounding CNS-specific in-containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").

Evaluate the location of the Closed.

Portable DG for accessibility under Severe Accident HCVS use. The portable diesel generator (DG) 5 (FLEX 60KW DG) will be positioned North of the Reactor Building allowing the entire Reactor Building to act as shielding.

Confirm suppression pool heat Closed.

capacity.

1% of rated thermal power (R TP) is demonstrated in NEDC 15-020, 6

"Calculation of HCVS Flow Rate and Vent Size."

The MAAP Analysis was documented

NLS2016040 Attachment Page 6of13 Combined Phase 1 and 2 OIP Open Item Phase 1 Open Items OIP Open Action Status/Comment Item#

in EC 14-027, "Acceptance ofMAAP Analysis to Support Initial FLEX Strategy," which implements calculation NEDC 14-026, "MAAP Analysis to Support Cooper FLEX Strate12:v."

Determine which approach or Closed.

combination of approaches Cooper Nuclear Station (CNS) will take to Hydrogen control will be addressed 7 address the control of flammable using a check valve combined with gases, clearly demarcating the limiting the run-up distance so a purging segments of vent system to which system is not required.

an approach applies.

Identify qualification method used Closed.

for HCVS instruments.

CED 6036742, Section 6.5.14 (12 -

Instrumentation & Control (I&C) describes instrumentation and controls (existing and planned) necessary to implement this Order.

8 The majority of the equipment for the HCVS is non-essential. Environmental Qualification is limited to those components in the electrical system that interface with and provide isolation between Class IE and non-Class 1E circuits.

Evaluate HCVS monitoring Closed.

location for accessibility, habitability, staffing sufficiency, The Main Control Room (MCR) is the and communication capability with normal monitoring and operating 9 vent-use decision makers. location for HCVS. The mechanical ROS has the capability to operate the HCVS if needed. Hand held radios will be used for communications between the MCR and ROS .

Determine the number of required Closed.

valve cycles during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Size the electrical and CED 6036742, Tab 4, Section 4.2.1.3 10 pneumatic supplies accordingly. ("Control Valve PC-AOV-A032, Accumulator IA-ACC-A032, and new Pressure Switch IA-PS04") determines 8 valve cycles during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based

NLS2016040 Attachment Page 7of13 Combined Phase 1 and 2 OIP Open Item Phase 1 Open Items OIP Open Action Status/Comment Item#

on NEI White Paper HCVS-WP-02 and the MAAP analysis results (EC 14-027, "Acceptance of MAAP Analysis to Support Initial FLEX Strategy" and NEDC 14-026, "MAAP Analysis to Support Cooper FLEX Strategy").

CED 6036742, Tab 6, Section 6.5.5 (E2

- Environmental Features), states that NEDC 92-073 , "Accumulator Sizing and Recharge Time for PC-237AV and PC-A032," performs the calculation that sizes the accumulators, and accounts for leakage for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Evaluate the impact of SA Closed.

environmental conditions for post-24 hour actions supporting the The mechanical ROS has the capability implementation of power and to operate the HCVS for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> pneumatic supplies. independent of power and has its own pneumatics.

The site-specific radiological conditions 11 for the HCVS are evaluated in NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS," based on the bounding CNS-specific in-containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").

Determine the control document In progress.

12 for HCVS out of service time criteria.

Phase 2 Open Items None.

NLS2016040 Attachment Page 8of13 Phase 1 Interim Staff Evaluation Open Item ISE Open Action I ISE Section Reference Status Item #

Make available for NRC staff audit Complete.

analyses demonstrating that HCVS has the capacity to vent the 1% ofRTP is demonstrated in NEDC 15-steam/energy equivalent of one 020, "Calculation of HCVS Flow Rate and percent of licensed/rated thermal Vent Size."

power (unless a lower value is justified), and that the suppression The MAAP Analysis was documented in pool and the HCVS together are able EC 14-027, "Acceptance of MAAP 1

to absorb and reject decay heat, such Analysis to Support Initial FLEX that following a reactor shutdown Strategy," which implements calculation from full power containment pressure NEDC 14-026, "MAAP Analysis to is restored and then maintained below Support Cooper FLEX Strategy."

the primary containment design pressure and the primary containment pressure limit.

Sections 3.2.2.1 , 3.2.2.2 Make available for NRC staff audit Complete.

the seismic and tornado missile final design criteria for the HCVS stack. NEDC 15-028, "Analysis of the HCVS Section 3.2.2.3 Piping," performed the pipe stress analysis for the HCVS pipe, including the seismic and tornado wind design analysis.

2 CED 6036742, Tab 6, Section 6.5.6 (E3 -

External Hazard), "E3.4 - Tornado and Tornado-Generated Missile," evaluated the tornado missile for the HCVS pipe. The evaluation was written in the CED (and not in a calculation), since the vast majority of the pipe is inside a Class I structure.

Make available for NRC staff audit Complete.

descriptions of all instrumentation and controls (existing and planned) CED 6036742, Section 6.5.14 (12-necessary to implement this order Instrumentation & Control (I&C))

including qualification methods. describes the instrumentation and controls 3 Section 3 .2.2.10 (existing and planned) necessary to implement this Order.

The majority of the equipment for the HCVS is non-essential. Environmental Qualification is limited to those

NLS2016040 Attachment Page 9of13 Phase 1 Interim Staff Evaluation Open Item ISE Open Action I ISE Section Reference Status Item #

components in the electrical system that interface with and provide isolation between Class 1E and non-Class 1E circuits.

Make available for NRC staff audit a Complete.

determination of the number of required valve cycles during the first CED 6036742, Tab 4, Section 4.2.1.3 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ("Control Valve PC-AOV-A032, Section 3.2.3.1 Accumulator IA-ACC-A032, and new Pressure Switch IA-PS04") determines 8 valve cycles during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, based on NEI White Paper HCVS-WP-02 and the MAAP analysis results (EC 14-027, "Acceptance of MAAP Analysis to 4 Support Initial FLEX Strategy" and NEDC 14-026, "MAAP Analysis to Support Cooper FLEX Strategy").

CED 6036742, Tab 6, Section 6.5.5 (E2 -

Environmental Features), states that NEDC 92-073 , "Accumulator Sizing and Recharge Time for PC-237 AV and PC-A032,"

performs the calculation that sizes the accumulators, and accounts for leakage for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Make available for NRC audit the In Progress.

control document for HCVS out of 5

service time criteria.

Section 3.4.1 Make available for NRC staff to In Progress.

audit, an evaluation verifying the existing containment isolation valves, relied upon for the HCVS , will open 6

under the maximum expected differential pressure during severe accident wetwell venting.

Section 3.2.2.9 Make available for NRC staff audit Complete.

documentation that demonstrates 7

adequate communication between the The Main Control Room (MCR) is the remote HCVS operation locations normal monitoring and operating location

NLS2016040 Attachment Page 10of13 Phase 1 Interim Staff Evaluation Open Item ISE Open Action I ISE Section Reference Status Item#

and HCVS decision makers during for HCVS . The Mechanical ROS has the ELAP and severe accident conditions. capability to operate the HCVS if needed.

Section 3.2.2.5 Hand held radios will be used for communications between the MCR and ROS.

The communications assessment performed in response to Near Term Task Force Recommendation 9.3 (NLS2013028) documented the acceptability of this communications channel.

Make available for NRC staff audit Complete.

an evaluation of temperature and radiological conditions to ensure that CED 6036742, Tab 6, Section 6.5.5 (E2 -

operating personnel can safely access Environmental Features), discusses the and operate controls and support temperature and radiological conditions, as equipment. well as CED 6036742, Tab 6, Section 6.5.7 Sections 3.2.1, 3.2.2.3 , 3.2.2.4, (E4 - Emergency Preparedness, Planning 3.2.2.5 , 3.2.2.10, 3.2.4.1, 3.2.4.2, and Response).

3.2.5.2, 3.2.6 NEDC 15-002, "Review of Tetra Tech

- Portable Equipment Calculations in support of CNS FLEX Strategy," calculates 8

the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up temperature profile in the Reactor Building and Control Building during an ELAP.

The site-specific radiological conditions for the HCVS are evaluated in NEDC 15-024, "Radiological Conditions Resulting from the Operation of the HCVS," based on the bounding CNS-specific in-containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").

Make available for NRC staff audit Complete.

the final sizing evaluation for HCVS batteries/battery charger and CED 6036742, Tab 6, Section 6.5.4 (El -

9 incorporate into FLEX DG loading Electrical Features), discusses the electrical calculation. power requirements and sizing.

Sections 3.2.2.4, 3.2.3.1 , 3.2.3.2,

NLS2016040 Attachment Page 11of13 Phase 1 Interim Staff Evaluation Open Item ISE Open Action I ISE Section Reference Status Item#

3.2.4.1, 3.2.4.2, 3.2.5.1 , 3.2.5.2, 3.2.6 NEDC 15-030, "HCVS UPS Inverter, Battery, and Battery Charger Sizing Analysis," documents the load and sizing analysis for the HCVS UPS (EE-UPS-HCVS) and distribution panel.

NEDC 15-033, "HCVS PC233MV UPS Sizing Analysis," documents the size of the UPS for PC-MOV-233MV, which is located near MCC-RA on RB elevation 958' -3".

The FLEX diesel generator (DG) is discussed in: CED 6036742, Tab 4, Section 4.4.3. l (Hardened Containment Venting System Uninterruptable Power Supply (HCVS UPS)); CED 6036742, Tab 6, Section 6.5.14 (I2 - Instrumentation &

Control (I&C)), 12.3 (System/Controls);

and CED 6036742, Tab 6, Section 6.5.26 (S3 - System Interfaces). The hardened vent modification (CED 6036742) interfaces with CED 6037041 , "FLEX Electrical Connections," with respect to the use of the FLEX DG (per Tab 11) to power the HCVS UPS after the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event.

Make available for NRC staff audit Complete.

documentation of the HCVS nitrogen pneumatic system design including The nitrogen station is located in the sizing and location. mechanical ROS enclosure. NEDC 15-Sections 3.2.1 , 3.2.2.4, 3.2.3 .1, 025 , "Mechanical ROS Civil I Structural 3.2.3.2, 3.2.4.1 , 3.2.4.2, 3.2.5.1, Design," documents the MROS design.

3.2.5.2, 3.2.6 The mechanical ROS enclosure is located 10 in the yard adjacent to the south wall of the Reactor Building.

NEDC 15-026, "Mechanical ROS Nitrogen Calculation," determines the amount of nitrogen required to support operation of PC-AOV-237 AV and PC-AOV-A032 for

NLS2016040 Attachment Page 12of13 Phase 1 Interim Staff Evaluation Open Item ISE Open Action I ISE Section Reference Status Item#

operation between 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 7 days following a beyond design basis external event (BDBEE).

Make available for NRC staff audit Complete.

the descriptions of local conditions (temperature, radiation and humidity) CED 6036742, Tab 6, Section 6.5.5 (E2 -

anticipated during ELAP and severe Environmental Features), provides a accident for the components (valves, description of the local conditions instrumentation, sensors, transmitters, (temperature, radiation, and humidity) for indicators, electronics, control the HCVS components.

devices, and etc.) required for HCVS venting including confirmation that NEDC 15-002, "Review of Tetra Tech the components are capable of Portable Equipment Calculations in performing their functions during support of CNS FLEX Strategy," calculates ELAP and severe accident conditions. the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> room heat-up temperature Sections 3.2.2.3 , 3.2.2.5, 3.2.2.9, profile in the Reactor Building and Control 3.2.2.10 Building during an ELAP.

11 The site-specific radiological conditions for the HCVS are evaluated in NEDC 15-024,"Radiological Conditions Resulting from the Operation of the HCVS," based on the bounding CNS-specific in-containment source term during the first seven days following an ELAP (NEDC 15-047, "HCVS Radiological Source Term").

NEDC 15-023, "Calculation of the Pressure Gradient Across the HCVS Line and HCVS Maximum Operational Temperature," determines the HCVS pressure and temperature conditions for the HCVS pipe.

Phase 2 Interim Staff Evaluation Open Item None identified at the time of this submittal.

NLS2016040 Attachment Page 13of13 Interim Staff Evaluation Impacts There are no potential impacts to the ISEs identified at this time.

References

1. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 Overall Integrated Plan in Response to June 6, 2013 , Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014
2. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013
3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, ' To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April 2015
4. Nebraska Public Power District's Phase 1 and Phase 2 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 21 , 2015
5. NRC letter to NPPD, "Cooper Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA 109 (Severe Accident Capable Hardened Vents) (TAC NO. MF4384)," dated February 11, 2015
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