NLS2012025, Answer to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

Answer to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA-12-050)

ML12094A107
Person / Time
Site:	Cooper
Issue date:	03/30/2012
From:	O'Grady B Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NLS2012025, EA-12-050
Download: ML12094A107 (3)

Text

N Nebraska Public Power District Always there when you need us NLS2012025 2.202 March 30, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Nebraska Public Power District's Answer to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Order Number EA- 12-050)

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

Reference:

Letter from Eric J. Leeds, U.S. Nuclear Regulatory Commission, to All Operating Boiling-Water Reactor Licensees with Mark I and Mark II Containments, dated March 12, 2012, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents"

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an immediately effective order in the Reference letter entitled Order Modifying Licenses with Regard to Reliable Hardened Containment Vents (Effective Immediately) ("Order") to, inter alia, Nebraska Public Power District. The Order states that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Dai-ichi in March 2011, the NRC had decided to direct nuclear power plant licensees and construction permit holders to take certain actions. Specifically with respect to this Order, the NRC has decided to require Boiling Water Reactors (BWRs) with Mark I and Mark II containments to take certain actions to ensure the operability of a reliable hardened vent system to remove decay heat and maintain control of containment pressure following events that result in loss of active containment heat removal capability or prolonged Station Blackout (SBO). Specific requirements for reliable hardened vents are outlined in Attachment 2 to the Order.

The Order requires submission of an overall integrated plan, including a description of how compliance with the requirements described in Attachment 2 will be achieved, to the NRC for review by February 28, 2013. In addition, the Order requires submission of an initial status report 60 days following issuance of the final interim staff guidance and at six month intervals following submittal of an oyerall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim staff guidance containing specific details on implementation of the requirements of this Order in August 2012. Finally, the Order requires full implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

The Order also states that the Commission also intends to decide, after receipt of a Policy Paper from the NRC staff, whether to also require installation of filtration systems on these hardened COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Dt Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2012025 Page 2 of 2 vent systems (Order,Section II). The Policy Paper is scheduled to be delivered by July 2012.

The full extent of work necessary to implement this Order cannot be known until after Commission action after review of the staff s July 2012 Policy Paper.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, Nebraska Public Power District hereby submits its answer to the Order. Nebraska Public Power District consents to the Order and does not request a hearing. Based on information currently available, Nebraska Public Power District has not identified any circumstances of the type described in Sections IV.B. 1 and IV.B.2 of the Order requiring relief at this time. In addition, Nebraska Public Power District has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever is earlier. Nebraska Public Power District will provide further responses as required by Section IV.C in accordance with the specified deadlines. However, given the uncertainties associated with the ultimate scope of required work caused by the unavailability of implementing guidance until August 2012, and the impact on the ability of Nebraska Public Power District to comply with the specific compliance deadline dates based on the probable availability of that guidance, Nebraska Public Power District's future responses may include requests for schedule relief as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

If you have any questions regarding this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

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

Executed On _________

(Date)

Sincerely, Brian J. OG~y Vice President - Nuclear and Chief Nuclear Officer

/bk cc: Regional Administrator Senior Resident Inspector USNRC - Region IV USNRC - CNS Director NPG Distribution USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager CNS Records USNRC - NRR Project Directorate IV-1

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©Q Correspondence Number: NLS2012025 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None I I I I PROCEDURE 0.42 REVISION 27 PAGE 21 OF28