View source for NLS2012112, Nebraska Public Power District'S Response to the March 12, 2012, Information Request Pursuant to 10 CFR 50.54(f) Recommendation 9.3 for Completing Emergency Communication Assessments

{{Adams
| number = ML12312A131
| issue date = 10/31/2012
| title = Nebraska Public Power District'S Response to the March 12, 2012, Information Request Pursuant to 10 CFR 50.54(f) Recommendation 9.3 for Completing Emergency Communication Assessments
| author name = O'Grady B
| author affiliation = Nebraska Public Power District (NPPD)
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000298
| license number = DPR-046
| contact person = 
| case reference number = NLS2012112
| document type = Letter type:NLS
| page count = 41
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:H Nebraska Public Power District Always there when you need us NLS2012112 October 31, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

==Subject:==
Nebraska Public Power District's Response to the March 12, 2012, Information Request Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency Communication Assessments Cooper Nuclear Station, Docket No. 50-298, DPR-46

==References:==
: 1. Nuclear Regulatory Commission Letter to Nebraska Public Power District, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012
: 2. Nebraska Public Power District Letter to Nuclear Regulatory Commission, "Nebraska Public Power District's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments,"
dated May 9, 2012
: 3. Nebraska Public Power District Letter to Nuclear Regulatory Commission, "Nebraska Public Power District's 90-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments,"
dated June 7, 2012
: 4. Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0 (May 2012)

==Dear Sir or Madam:==

On March 12, 2012, the Nuclear Regulatory Commission issued a letter (Reference 1) entitled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2012112 Page 2 of 3 Review of Insights from the Fukushima Dai-ichi Accident." Enclosure 5 of the letter contained specific requested actions and requested information associated with Recommendation 9.3 for Emergency Preparedness Communications. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days or provide a response within 60 days of the date of the letter and describe the alternative course of action that it proposes to take.
Nebraska Public Power District (NPPD) responded within 60 days (Reference 2) proposing to take the alternative course of action for communications that was described in Attachment I of Reference 2. NPPD implemented the first part of this alternate course of action with the submittal of Reference 3 which described interim actions or planned actions to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete. The letter completes the alternate course of action by summarizing the results of the communications assessment and the potential enhancements that could be made.
The communications assessment was performed using the guidance of NEI 12-01 (Reference 4) and identified enhancements that may be appropriate for the emergency plan with respect to communications requirements of 10 CFR 50.47, Appendix E to 10 CFR 50, and the guidance in NUREG-0696. The current planned enhancements are discussed in Attachment 1. The new regulatory commitment is identified in Attachment
: 2. These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements.
If you have any questions concerning the content of this letter, please contact David Van Der Kamp, Licensing Manager, (402) 825-2904.
I declare under penalty of perjury that the foregoing is true and correct.
Executed On               3-  k 1 10 (Date)
Brian J. O'Gy Vice President - Nulr Chief Nuclear Officer
/bk Attachments:     1. Cooper Nuclear Station Communications Assessment
: 2. List of Regulatory Commitments

NLS2012112 Page 3 of 3 cc:    Regional Administrator w/attachments USNRC - Region IV Director w/attachments USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager w/attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/attachments USNRC - CNS NPG Distribution w/o attachments CNS Records w/attachments

NLS2012112 Attachment I Page 1 of 36 NLS2012112 ATTACHMENT 1 COOPER NUCLEAR STATION COMMUNICATIONS ASSESSMENT

NLS2012112 Attachment I Page 2 of 36
: 1. Executive Summary The purpose of this report is to document the performance of a Nuclear Regulatory Commission (NRC) requested assessment of the current communications systems and equipment used at the Cooper Nuclear Station (CNS) site during an emergency event as defined by Nuclear Energy Institute (NEI) 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities." Power supplies for the existing communications equipment credited have been assessed to determine power availability during a prolonged Station Blackout (SBO) event.
The beyond design basis events assumed in this assessment introduce conditions that could render a significant portion of existing installed site communications capabilities inoperable. The assessment identifies proposed enhancements to maintain the minimum communications capabilities for responding to emergency events, as well as enhancements to improve the survivability of currently installed communications systems (see Table 11). These enhancements include:
* Addition of extra batteries, chargers, and uninterruptible power supply (UPS) units in support of extended use of handheld satellite phones
             "   Addition of dry-cell type battery packs in support of extended use of portable radios (walkie-talkies)
* Evaluation of options to support indoor (remote) access to satellite-based communications
* Correction of identified issues related to potential seismic concerns
* Evaluation and probable enhancement of battery-based power to critical communications systems
: 2. Methodology This report is based on the recommended criteria from NEI 12-01, for use in identifying enhancements that will ensure the availability of critical communications capabilities during an extended loss of AC power, including evaluation of power sources for communications equipment. This approach provided the flexibility to accommodate specific site needs while, at the same time, ensuring consistency with industry-developed standards, and NRC regulations and guidance.
The assessment focused first on the communication systems to be credited. These required communication links were assumed to be established via satellite phones (offsite) and the use of the existing site handheld radios (onsite). Existing installed communications were assumed to be inoperable and therefore were not credited in this assessment. However, walkdowns to evaluate both portable and installed equipment, locations, and function were performed.
Enhancements identified from the assessment will be further developed as implementation progresses. Alternate approaches will be utilized if prudent (e.g.,
alternate/new technology, improved capability, cost savings, etc.).

NLS2012112 Page 3 of 36
: 3. Assumptions (Derived from NEI 12-01) 0    Extended loss of AC power event 0    Successful plant shutdown
* No hostile action
* 6 hours post event - no site access
* 6 - 24 hours post event - limited site access
* 24+ hours post event - access restored to near normal status
* Installed sources of AC power not available 0 Non-essential loads from DC battery sources are stripped per station procedures 0 Installed inverters and battery chargers remain available provided they are protected from external events
* Onsite diesel fuel oil is available provided it is stored in a protected manner from external events
* Portable equipment may be used provided it is stored onsite and protected from seismic, wind, and flooding events. Includes portable AC and DC power sources
            & Onsite communications infrastructure remains available provided it is protected from seismic, wind, and flooding events 0 Offsite communications infrastructure is inoperable out to 25 miles
* Communications equipment located at an offsite response facility and supplied from a backup power source is assumed to be functional
: 4. Communications During an Extended Loss of AC Power NEI 12-01 Section 4, "Communications During an Extended Loss of AC Power" provides the basis for the following assessment.
4.1   Required Emergency Communication Capabilities (NEI 12-01 Section 4.1)
Nebraska Public Power District (NPPD) has reviewed the minimum required communications links and has determined the method of communications (i.e.,
radio or satellite phone) to be credited for each defined link and the overall number of satellite phones and radios needed (see Table 10). NPPD determined that some additional satellite phones or radios may be required, at the Offsite Response Organization (ORO) end, to establish the required links with OROs.
Area for enhancement (see Table 11, item #3).
NPPD recognizes that portable satellite telephones do not work indoors. Their antennas must have a clear direct view of the sky. Therefore, portable satellite phones have to be taken outdoors to establish the required communications link(s). This is not considered adequate for the long term.
These same communications links must be established from within the boundaries of areas within the plant which are very difficult to modify. Making penetrations to route antenna coaxial cable may require design changes, habitability considerations, regulatory reviews, and the revision of supporting documentation.

NLS2012112 Page 4 of 36 NPPD will evaluate options and select method(s) to support indoor (remote) access to satellite-based communications. Area for enhancement (see Table 11, item #4).
4.2  Plant Paging (Announcement) System (NEI 12-01 Section 4.2)
NEI 12-01 Section 4.2 requires notification of the plant staff at the onset of the event. The CNS plant paging system provides public address capability over a large portion of the site. Considering the assumptions defined by NEI 12-01, the system was not credited as available for notification of plant personnel. Alternative measures now used for inoperable paging coverage areas will be assessed for use site-wide. Area for enhancement (see Table 11, item #6).
4.3  Communications Equipment at ORO Facilities (NEI 12-01 Section 4.3)
Per NEI 12-01, "Some communications capability should be available at the ORO facilities that normally receive licensee notifications of an emergency declaration or a Protective Action Recommendation." NPPD assessed capabilities at their ORO facilities. All five ORO facilities (Nebraska State Patrol, Nemaha County Sheriff, Richardson County Sheriff, Missouri State Patrol, and Atchison County 911 Center) have backup power. Additional communication capabilities (i.e., satellite phones) are recommended at some of these facilities. Area for enhancement (see Table 11, item #3).
4.4  Notification of the Emergency Response Organization (ERO) (NEI 12-01 Section 4.4)
NEI 12-01 offers two potential options to promote timely staff augmentation by the ERO. CNS will ensure that "ERO members are trained to automatically respond to their assigned facilities or a designated staging area when made aware of a wide loss-of-grid (e.g., by direct observation, media reports, word-of-mouth, etc.)." This expectation has been established with the ERO. This expectation will also be included in annual ERO requalification training. Area for enhancement (see Table 11, item #7).
4.5  Equipment Location Requirements (NEI 12-01 Section 4.5)
Communication equipment to be used or considered operable, "...should be in a location and maintained in a manner that maximizes survivability following a beyond design basis external event. In particular, the location or manner should reasonably preclude wetting from flooding or impact damage from a seismic event." The communication links as defined by NEI 12-01 will be established using satellite phones and handheld radios. Assessments were performed, including walkdowns, of the existing installed radio equipment. Enhancements have been identified associated with installed equipment's support/mounting as well as potential impact from adjacent equipment and/or stored material. One issue associated with wetting from flooding was identified related to the Meteorological Tower (MET) enclosure. See Sections 4.13.2 for details. Area for enhancement (see Table 11, item #1).

NLS2012112 Page 5 of 36 4.6  Performance Characteristics (NEI 12-01 Section 4.6)
The performance characteristics as identified in this section of NEI 12-01 require that communication pathways (e.g., radio channels, satellite phones) designated to support multiple functions must be analyzed to demonstrate that they can simultaneously support both functions. NPPD assessed capabilities on a radio channel by channel and satellite phone device basis and did not identify any instances where a single communication pathway was assigned to support multiple functions. No further action is required.
4.7  Other Assessment Considerations (NEI 12-01 Section 4.7)
Enhancements (physical and programmatic) are recommended to ensure considerations, as identified in this section of NEI 12-01, are met. Provisions for portable backup power sources and batteries for battery operated equipment need to be established. Area for enhancement (see Table 11, item #5).
4.8  Quality and Maintenance-Related Requirements (NEI 12-01 Section 4.8)
The requirements identified in this section of NEI 12-01 need to be incorporated into the program for ensuring the credited equipment is maintained in a manner that maximizes survivability. Programmatic controls need to be established to ensure that equipment remains available and operable. This may include documenting inventories and adding preventive maintenance for periodic testing of the satellite phones and chargers. Area for enhancement (see Table 11, item #7).
4.9  National Communications System (NCS) Services (NEI 12-01 Section 4.9)
NPPD assessed the NCS services. NPPD recommends that additional Government Emergency Telecommunications Service (GETS) access cards be acquired for key CNS site positions or Emergency Response Facilities (ERFs).
Area for enhancement (see Table 11, item #8).
4.10 Communication Provider Emergency Services (NEI 12-01 Section 4.10)
NPPD contacted the major communications service providers for CNS (Verizon and AT&T). Neither company has a separate emergency services priority other than government telecommunications service priority. No further action is recommended.
4.11 Personnel Training (NEI 12-01 Section 4.11)
The requirements identified in this section of NEI 12-01 are recommended to be incorporated into the CNS Emergency Planning program. NPPD will evaluate existing training to determine if the adequacy and periodicity of training is sufficient. Area for enhancement (see Table 11, item #7).

NLS2012112 Attachment I Page 6 of 36 4.12 Emergency Plan (E-Plan) Identified Systems Overview and Assumptions The following sections summarize the communications systems discussed in the CNS E-Plan.
The E-Plan Section 7.3 notes that communications may be provided by different means (telephone system, plant paging system, alternate intercom, FM radio, and sound power). For the purposes of this assessment, the communications capabilities in E-Plan Section 7.3 were assumed to be successfully met only if they were judged to be continuously available for 24 hours after the loss of onsite and offsite AC power. The majority of the installed emergency preparedness (EP) communication systems have been assumed (by this assessment) to have deficiencies which would prevent their survival in the beyond design basis external event.
However, the assumptions underlying this assessment were conservative. Although the assessment identified areas for enhancement, it also established that the communications systems at CNS are well designed, installed, and maintained. They are diverse both in their locations, their primary and backup power sources, and their supporting infrastructures. NPPD feels confident that by making the enhancements identified by this assessment, these same communications systems may be more likely to survive a beyond design basis event. See Sections 4.13.1 - 4.13.5 for details concerning proposed enhancements.
4.13 Equipment Locations and Capabilities The communications function, radio reception/transmission equipment, and protection of each location from seismic, wind, and flooding are discussed below. Specifically, the capacity of the equipment in its current configuration was evaluated as to its ability to withstand the identified external hazards. These hazards include seismic, flooding, and high winds. The structural evaluation was based on engineering judgment developed by a consensus of two engineers experienced in structural design and construction.
The maximum probable flood elevation is 903'. Because no EP communications equipment, except for the MET and equipment enclosure (refer to Section 4.13.2 for further explanation), exists below this elevation, most EP communications equipment is not at risk of flooding due to a design basis flooding event.
The sections below provide more detail of the area walkdowns and their potential configuration concerns that could present challenges to communications systems in the event one or more of the identified environmental hazards occur.
4.13.1 Elevated Release Point (ERP) Tower and Equipment Location and General Description EP communications equipment is located inside the ERP Tower communications enclosure. The ERP Tower is located inside the Protected Area (PA) southeast of the Reactor Building and is 325' tall. The communications enclosure is a pre-fabricated trailer-like structure constructed of a metal frame covered with fiberglass panels. This

NLS2012112 Attachment I Page 7 of 36 enclosure is attached to the ERP Tower structural steel members, at an elevation of approximately 920' mean sea level (MSL).
Equipment & Functionality Radio System Base #1 Repeater is located in the ERP Tower communications enclosure. The radio system for Base #1 is comprised of a Motorola model MSF5000 transceiver with charger, and is connected to receive and transmit antennas mounted near the top of the ERP Tower. Base #1 radio provides repeater coverage to portable radios (walkie-talkies) and mobile units at the plant site and the Emergency Operations Facility (EOF), located in Auburn, Nebraska (approximately 11 miles to the west). This radio equipment is also hardwired to desksets (Motorola model MC2500) and consoles (Motorola MCC5500) at various locations at CNS and the EOF. A simplified block diagram shows interconnections for Radio System Base #1. See Figure 1.
Power 120V AC power to the Base #1 radio system is supplied from a lighting panel LP-ERP (Shack) Comm Box. This panel gets AC power from switchboard MSB located in the Machine Shop via step down transformer EE-XFMR-LPERP (Shack). Switchboard MSB gets its feed from non-essential 480V switchgear 1 B via switchboard MSA.
This panel is also permanently wired to an outside emergency generator receptacle via transfer switch CC-SW-LPERP (Shack).
A battery charger for Base #1 is integrated into the radio unit itself. There are two 90 amp-hour batteries tied in parallel to power the radio in the event of loss of AC power.
The backup batteries are capable of providing power to the Base #1 radio equipment for approximately 30 hours (Receive) and 6 hours (Transmit) respectively.
Base #1 radio transceiver will be replaced with a new narrow-band transceiver (Federal Communications Commission (FCC) requirement) before the end of 2012. As part of this replacement, a new battery bank and charger will also be installed. The new battery bank duration will be at least that listed above. After installation, the new radio system battery life will be assessed to determine if additional batteries are required to provide adequate capacity. Area for enhancement (see Table 11, item #2).
Structural Assessment The ERP Tower communications enclosure, attached to the ERP Tower at approximately 920' elevation, provides reasonable assurance that the EP communications equipment is protected during a flooding event, as defined in NEI 12-01.
The communications enclosure has been designed (per the manufacturer) to withstand 3 second bursts of 100 mph wind. The ERP Tower itself is described by the Updated Safety Analysis Report (USAR) as being designed in accordance with Class 1 seismic loadings and includes a dynamic analysis. This does not include tornadic winds as this structure is not required for safe shutdown. Therefore, the ERP Tower and

NLS2012112 Page 8 of 36 communications enclosure itself (notwithstanding the communications rack itself) provides reasonable assurance that the EP communications equipment is protected during a seismic or wind event, as defined in NEI 12-01.
Communication Equipment and Racks Seismic Protection - Enhancement identified. See Table 11, item #1.
    " Anchorages o The rack that supports the Radio Repeater (Base #1) is anchored to the floor but is unsupported at the free (upper) end. The free end of this rack may require a brace. An additional evaluation is required.
o Some electrical equipment is missing hardware that fastens it to the rack.
For example, the two batteries located on the bottom shelf of the Radio Repeater rack are not attached to the shelf.
* Spatial Interactions o Adjacent to the rack is an unanchored box fan and an unanchored metal stand. These items should be removed or anchored.
* Housekeeping o There are several miscellaneous items in the room that should be removed.
o The entire room needs to be cleaned up. Box fans and unused chairs should be removed.
Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Antennas Seismic Protection - ACCEPTABLE
* Anchorages o No concerns
* Spatial Interactions o No concerns
* Housekeeping o No concerns Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE

NLS2012112 Attachment I Page 9 of 36 4.13.2      MET Tower Location and General Description EP communications equipment is located outside the PA in an enclosure adjacent to the MET Tower. This enclosure is a pre-fabricated trailer-like structure constructed of a metal frame covered by fiberglass panels that rests on an at-grade concrete slab. The MET Tower is a 100-meter commercial radio tower. The tower is heavily guyed with substantial guy anchors and the tower base is anchored to the concrete slab.
Equipment & Functionality Radio System Base #2 Repeater is located in the MET Tower equipment enclosure.
The radio system Base #2 is comprised of a Motorola model MSR2000 transceiver with charger, and is connected to receive and transmit antennas mounted near the top of the tower. Base #2 radio provides repeater coverage to portable radios (walkie-talkies) and mobile units at the plant site and the EOF in Auburn, Nebraska. The radio equipment is also hardwired to desksets (Motorola model MC2500) and consoles (Motorola MCC5500) at various locations at CNS and the EOF. A simplified block diagram shows interconnections for Radio System Base #2. See Figure 2.
A Radio System (Low Band) transceiver is also located in MET Tower equipment enclosure. This radio system (Low Band) is a Vertex FTL-1011H transceiver connected to receive and transmit antennas mounted near the top of MET Tower. The Low Band radio provides access to the NPPD state-wide radio system. The Low Band radio equipment is hardwired to desksets (Motorola model T1600) and consoles (Motorola MCC5500) at various locations at CNS and the EOF in Auburn, Nebraska. A simplified block diagram shows interconnections for Radio System (Low Band). See Figure 3.
Power 120V AC power to the radio system equipment is supplied from a local power panel Ml-PNL-100M. The Base #2 and Low Band radio system's battery charger is a Power Conversion Products, Part #915510060. It supplies 12V DC to the DC bus and charges the backup batteries. Panel MI-PNL-100M gets primary power from 480V AC switchboard EE-SWBD-NLDC via step-down transformer MI-XFMR-100M. Alternate power is supplied from critical bus MCC-L via an ASCO 7000 transfer switch MI-SW-1 OM (Trans). The backup batteries are capable of supplying power to this radio equipment for at least 8 hours.
Base #2 radio transceiver will be replaced with a new narrow-band transceiver (FCC requirement) before the end of 2012. As part of this replacement, a new battery bank and charger will also be installed. The new battery bank duration will be at least that listed above. After installation, the new radio system battery life will be assessed to determine if additional batteries are required to provide adequate capacity. Area for enhancement (see Table 11, item #2).

NLS2012112 Attachment I Page 10 of 36 Structural Assessment The MET Tower equipment enclosure is similar to the ERP Tower communications enclosure, and is bolted to a supporting concrete slab a few feet from the MET Tower.
The tower and enclosure are located on the non-river side of the Missouri River protective dike at an elevation higher than the surrounding ground, but lower than the nominal top of levee elevation of 902'. Therefore, if the protective dike was breached, and the surrounding area flooded to a level of several feet, there is a potential for the enclosure to be flooded.
CNS experienced near-design flooding in 2011, and previously in 1993. In both cases the protective levee north of the plant failed on the Missouri side, and caused flooding into the 4-5 mile wide River basin.
The MET Tower (and enclosure) is one of the locations/equipment listed in CNS Emergency Procedure 5.1 FLOOD to consider when protecting the site from the effects of flooding. In 2011, the MET Tower was sandbagged. A portable gas-powered pump was staged on the inside of the sandbagged area to facilitate pumping out any in-leakage or precipitation accumulation. It was not needed.
River level increases gradually and predictably if due to precipitation. The USAR describes the most critical acute flooding event to be the failure of a major flood control dam; either the Oahe or Fort Randall dam. The closer of the two is almost 350 miles upstream from the CNS site. The waters released by failure of this dam would require at least three days to reach the CNS site. This would be ample time for protective measures to be taken to protect this equipment.
This equipment is located below protective levee height, and is therefore assessed as
'questionable' that the EP communications equipment within the enclosure is protected during a severe flooding event, as defined in NEI 12-01.
The MET Tower is designed for 90 mph wind with no ice buildup on the structure, or a 40 mph wind with W"ice buildup on the structure. The tower structure provides reasonable assurance that it is protected during a seismic or wind event, as defined in NEI 12-01.
A metal stair case is lying on the ground approximately 3' from the tower base. The stair case is judged to have no adverse effect to the tower function during a seismic, wind, or flooding event. However it should be relocated away from the tower or secured.
Communication Equipment and Racks Seismic Protection - Enhancement identified. See Table 11, item #1.
Anchorages o 

==Enclosure:==
The backup batteries are located on a metal stand housed in a small room attached to the enclosure. The metal stand is anchored to the floor but is unsupported at the upper end. The batteries should be fastened to the metal stand shelf and the upper end of the metal stand

NLS2012112 Page 11 of 36 may require a brace. An additional evaluation is required. Outside the communications enclosure is a low profile transformer. The transformer anchorage could not be verified because of a build-up of silt. It is recommended that the silt be removed to inspect anchorage adequacy.
* Spatial Interactions o 

==Enclosure:==
Inside the enclosure, adjacent to the equipment racks, are an unanchored pump and hoses, a 55-gallon trash barrel, and a metal tool box. These items should be removed or secured.
    "   Housekeeping o The entire room needs to be cleaned up. The portable pump, hoses, tool box and trash barrels should be removed.
Flood Protection - QUESTIONABLE High Winds Protection - ACCEPTABLE Antennas - MET Tower Seismic Protection - ACCEPTABLE
* Anchorages o No concerns
* Spatial Interactions o No concerns
* Housekeeping o No concerns Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE 4.13.3      Emergency Operations Facility Location and General Description The EOF is one of several dedicated rooms within the NPPD Offsite Response Center, located in Auburn, Nebraska. The Offsite Response Center is one of several interconnected buildings making up part of the downtown district. It is a one-story commercial block building, with a partial basement.
Equipment & Functionality The EOF communications equipment room (Telecom Room 117) contains the Base #1 and #2 link radio, Motorola model M1225 and a control circuit to the Low Band radio transceiver located at the site. The Base #1 and #2 link radio is connected to antennas mounted on the roof of the building. The Low Band radio console is connected via redundant telecom circuits to the Low Band radio base in the MET Tower radio equipment enclosure at the site. The telecom circuit is provided by a private fiber optic

NLS2012112 Page 12 of 36 system with a backup leased T1. Desktop radio consoles are hardwired to their respective radio transceiver or Low Band control circuit. Wireless headsets are used by the EOF Director, EOF Radiological Control Manager, and the Health Physics Network (HPN) Bridge for offsite communications. There are three satellite phones in the EOF used to communicate with the plant, offsite agencies, and downwind survey field teams.
Power Primary power to the EOF (Offsite Response Center) is supplied from the local utility.
120V AC power supply to communications equipment is provided from distribution panel MBP through a 10KVA, EATON model 10, System 9355-10, UPS. Backup power is supplied by a Diesel Generator (DG) via an auto-transfer switch. As an enhancement, the UPS batteries should be sized to provide adequate amp hour capacity as required.
Enhancement identified (see Table 11, item #2).
Structural Assessment The Offsite Response Center is a one-story commercial block building, with a partial basement. There are no streams or rivers nearby and the land slopes to the rear of the building providing sufficient runoff during rain storms. Therefore, the building structure provides reasonable assurance that the EP communications equipment is protected during a seismic, wind, or flooding event, as defined in NEI 12-01.
Antennas are attached to a robust steel structural member located on the roof. This provides reasonable assurance that the EP communications equipment is protected during a seismic, wind, or flooding event, as defined in NEI 12-01.
Diesel Generator Room Seismic Protection - Enhancement identified. See Table 11, item #1.
* Anchorages o No concerns
* Spatial Interactions o Fluorescent lights in the overhead could fall out of the light fixture and could be secured.
* Housekeeping o Combustible materials such as a storage bin, trash barrel, vacuum cleaner, and mop are stored near the DG and should be removed.
Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Telecom Room 117 Communications Equipment and Racks Seismic Protection - Enhancement identified. See Table 11, item #1.

NLS2012112 Attachment I Page 13 of 36
    "    Anchorages o Rack 1 is anchored to the floor but is unsupported at the free (upper) end. The free end of this rack may require an additional brace. An additional evaluation may be required. The Siren Encoder Radio and CNS base components are not attached to Rack 1 shelf.
o The nearby UPS is unanchored. This unit should be anchored.
* Spatial Interactions o No concerns
    "    Housekeeping o Telecom Room 117 could use a cleaning of papers, miscellaneous unused hardware, and other items.
Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE Antennas Seismic Protection - ACCEPTABLE
* Anchorages o No concerns
* Spatial Interactions o No concerns
    " Housekeeping o No concerns Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE 4.13.4      Technical Support Center/Operational Support Center (TSC/OSC)
Location and General Description The TSC/OSC is located inside the PA on the ground floor of the Administration Building at 903' 6" elevation. The TSC and OSC exterior walls, floor and ceiling are constructed of reinforced concrete. Interior walls are similar to an office style environment.
Equipment & Functionality The TSC contains several PBX-dependent communications bridges. If the site PBX is inoperable (as assumed by this assessment) these bridges would be unavailable. Other installed communications (Central Office lines, Alternate intercom, Sound power, Plant paging) were also assumed to be inoperable.
The TSC/OSC inventory includes portable, handheld multi-channel radios which provide point-to-point onsite communications for the OSC and TSC. This includes in-plant

NLS2012112 Page 14 of 36 operations, radiation protection, and maintenance/repair teams. This is the method credited by this assessment.
The TSC inventory also includes portable satellite telephones, providing communications between key TSC personnel and offsite response organizations.
Power Installed communication equipment located in the TSC and OSC are powered from lighting panel LP-TSC. Primary power to this panel is fed from the plant 12.5Kv system.
On loss of the primary power source, power to panel LP-TSC may be transferred to an alternate power supply (MCC-CA). Backup power to MCC-CA comes from a station DG. During an SBO, the TSC and OSC will have no AC power available.
Structural Assessment The desktop communication equipment and handheld radios with battery chargers are light weight, and would not ordinarily be affixed to a desk. Therefore from a structural perspective, this equipment is judged as acceptable.
The Administration Building is constructed of concrete and steel. The TSC and OSC are more substantial rooms within the Administration Building and meet regulatory requirements for Emergency Response Facilities (ERF). The Administration Building is built at elevation 903' 6" and has sufficient drainage. Therefore, the building structure provides reasonable assurance that the EP communications equipment is protected during a seismic, wind, or flooding event, as defined in NEI 12-01.
TSC/OSC Seismic Protection - ACCEPTABLE
     " Anchorages o No concerns
     " Spatial Interactions o No concerns
     " Housekeeping o No concerns Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE

NLS2012112 Page 15 of 36 4.13.5      Central Alarm Station (CAS)
Location and General Description The CAS enclosure is located inside the PA interior to the Security Building, not exposed to the outside environment. The CAS enclosure itself is fabricated from plate steel with steel intermediate members. The CAS communications antenna is located outside and adjacent to the Communications Building.
Equipment & Functionality Radio System Base #3 repeater is installed in a security equipment rack in the CAS enclosure. The radio system Base #3 repeater is a Motorola Quantar repeater, and is connected to an antenna on a tower adjacent to the north wall of the Communications Building. Additional details on these radios and their use is classified as Safeguards Information.
Power The CAS radio base is powered from a critical MCC, with a UPS as a backup.
Structural Assessment The CAS structure is an enclosure fabricated from plate steel and steel supporting members. This enclosure is internal to the Security Building at elevation 903' 6". The CAS enclosure provides reasonable assurance that the EP communications equipment is protected during a seismic, wind, or flooding event, as defined in NEI 12-01.
The antenna tower is anchored to a concrete slab and is laterally braced to the Security Building. A less than 1/16" wide crack exists in this slab; however this crack is outside the anchor bolt locations and is judged not to affect the anchor capacity or slab.
The antenna structure provides reasonable assurance that the EP communications equipment is protected during a seismic, wind, or flooding event, as defined in NEI 12-01.
Communication Equipment and Racks Seismic Protection - ACCEPTABLE
* Anchorages o No concerns
* Spatial Interactions o No concerns
* Housekeeping o No concerns Flood Protection - ACCEPTABLE

NLS2012112 Page 16 of 36 High Winds Protection - ACCEPTABLE Antenna Seismic Protection - ACCEPTABLE
* Anchorages o No concerns
    " Spatial Interactions o No concerns
    " Housekeeping o No concerns Flood Protection - ACCEPTABLE High Winds Protection - ACCEPTABLE

NLS2012112 Page 17 of 36 Table 1: Offsite Response Organization Notifications to, and communications with, OROs [per 10 CFR 50 Appendix E.IV.D and E.9.a]
Emergency           Minimum              Primary       Primary         Backup             Backup    Planned or Potential Response            Communications       Method        Method          Method(s)          Method(s) Enhancement Facility            Links                Described     Available       Described in       Available Identified?
in Site       Following       site E-Plan        Following E-Plan        Assumed                            Assumed Large Scale                        LSEE?
External Event (LSEE)?
Control Room         1 per Control Room  CNS State     NO              Two-Way FM         NO        YES (CR)                for Communicator     Notification                  Radio System                 Assure CR and OROs Telephone                     (High Band)                  have satellite System's                                                   telephone capability.
dedicated line Technical            1 for Key TSC       CNS State     NO              Two-Way FM         NO        YES Support Center      Communicator         Notification                  Radio System                 Assure TSC and Telephone                     (High Band)                  OROs have satellite System's                                                   telephone capability.
dedicated line

NLS2012112 Page 18 of 36 Emergency     Minimum        Primary      Primary        Backup       Backup    Planned or Potential Response      Communications Method       Method         Method(s)    Method(s) Enhancement Facility      Links          Described    Available      Described in Available Identified?
in Site      Following      site E-Plan  Following E-Plan       Assumed                     Assumed Large Scale                 LSEE?
External Event (LSEE)?
Emergency     1 for Key EOF  State        NO             Two-Way FM   NO        YES Operations    Communicator   Notification                Radio System           Assure EOF and Facility                     Telephone                   (High Band)            OROs have satellite System's                                           telephone capability.
dedicated line

NLS2012112 Attachment I Page 19 of 36 Table 2: Nuclear Regulatory Commission Notifications to, and communications with, the NRC Headquarters Incident Response Center and the appropriate NRC Regional Office Operations Center [per 10 CFR 50 Appendix E.IV.D and E.9.d]
Emergency           Minimum             Primary       Primary            Backup          Backup             Planned or Potential Response            Communications      Method        Method             Method(s)       Method(s)          Enhancement Facility            Links               Described in  Available          Described in    Available          Identified?
Site E-Plan   Following          Site E-Plan     Following Assumed                            Assumed LSEE?                              LSEE?
Control Room         1 per Control      ENS           NO                 Plant           NO                 YES - satellite phone Room for            Dedicated                        Telephone Emergency           Phone Line                       (PBX)
Notification System (ENS)
Communicator Technical            1 for ENS          ENS           NO                 PBX             NO                 YES - satellite phone Support Center      Communicator        Dedicated Phone Line Location(s)          1 for HPN          HPN           NO                 PBX             NO                 YES - satellite phone where HPN           Communicator        Dedicated communications                          Phone Line are performed (TSC, EOF)

NLS2012112 Attachment I Page 20 of 36 Table 3: Licensee Emergency Response Facilities Communications between licensee emergency response facilities [per 10 CFR 50 Appendix E.9.c. Additional links that support performance of critical response functions are also specified]. The minimum communications links to support this function are listed below by facility. For example, if the normally used telephone system cannot be restored to service, these links could rely upon some combination of radio, sound-powered, and satellite-based communications systems.
Emergency         Minimum                Primary         Primary Method      Backup            Backup                 Planned or Response          Communications        Method           Available           Method(s)         Method(s)              Potential Facility          Links                  Described in    Following           Described in      Available              Enhancement Site E-Plan      Assumed LSEE?       Site E-Plan       Following              Identified?
Assumed LSEE?
Control Room       1 per Unit            PBX             NO                  Two-Way FM        NO                     YES - satellite Radio System                             phone (High Band)

NLS2012112 Page 21 of 36 Emergency       Minimum                 Primary        Primary Method   Backup         Backup          Planned or Response        Communications          Method         Available        Method(s)      Method(s)       Potential Facility        Links                   Described in   Following        Described in   Available       Enhancement Site E-Plan    Assumed LSEE?    Site E-Plan    Following       Identified?
Assumed LSEE?
Technical        1 each for:            PBX            NO               Two-Way FM     NO              YES - satellite Support         - Senior/Lead TSC       (ALL)                           Radio System                   phones or Center          Manager                                                 (High Band)                    handheld radios
                - Operations                                            (ALL)
Coordination
* Maintenance Coordination
                - Engineering Coordination
                - Radiological Support Additional response coordination links for multi-unit site:
                - 1 for each position providing Unit Response Coordination I                      1.              A                A              A               I

NLS2012112 Page 22 of 36 Emergency     Minimum              Primary      Primary Method Backup       Backup        Planned or Response      Communications       Method       Available      Method(s)    Method(s)     Potential Facility      Links                Described in Following      Described in Available     Enhancement Site E-Plan  Assumed LSEE?  Site E-Plan  Following     Identified?
Assumed LSEE?
Operations    1 each for:          PBX          NO             Two-Way FM   NO            YES - satellite Support
* Senior/Lead OSC    (ALL)                       Radio System               phones or Center        Manager                                          (High Band)                handheld radios
* Radiological                                   (ALL)
Support Additional response coordination links for multi-unit site:
              - 1 for each position providing Unit In-Plant Team Coordination

NLS2012112 Page 23 of 36 Emergency     Minimum           Primary      Primary Method Backup       Backup        Planned or Response      Communications    Method       Available      Method(s)    Method(s)     Potential Facility      Links             Described in Following      Described in Available     Enhancement Site E-Plan  Assumed LSEE?  Site E-Plan  Following     Identified?
Assumed LSEE?
Emergency     1 each for:       PBX          NO             Two-Way FM   NO            YES - satellite Operations
* Senior/Lead     (ALL)                       Radio System               phones Facility      Manager                                       (High Band)
* Key Protective                              (ALL)
Measures
              - Operations or Technical Support (as needed to support performance of dose projections, formulation of PARs and plant status updates to ORO authorities)
Joint         1 for Senior      PBX          NO             Alternate    NO            YES - satellite Information   Manager                                       Intercom                   phone Center                                                      system

NLS2012112 Page 24 of 36 Table 4: Field / Offsite Monitoring Teams Communications with field/offsite monitoring teams [per 10 CFR 50 Appendix E.9.c].
Emergency         Minimum               Primary         Primary         Backup       Backup    Planned or Potential Response          Communications        Method          Method          Method(s)    Method(s) Enhancement Facility          Links                 Described in    Available       Described in Available Identified?
Site E-Plan     Following       Site E-Plan  Following Assumed                      Assumed LSEE?                        LSEE?
Primary location  Field/offsite         Two-Way FM      NO              Two-Way FM   NO        YES - satellite phone where             monitoring team       Radio                           Radio System field/offsite     coordination          System (Low                     (High Band) monitoring team                         Band) coordination is performed (EOF)
Primary location  1 for each            Two-Way FM      NO              Two-Way FM   NO        YES - satellite phones from which        field/offsite         Radio                           Radio System field/offsite     monitoring team       System (Low                     (High Band) monitoring                              Band) teams are deployed (TSC)

NLS2012112 Attachment I Page 25 of 36 Table 5: Other Federal Agencies Communications with other Federal agencies as described in the site E-Plan (e.g., the US Coast Guard) [per 10 CFR 50 Appendix E.9.b]
Emergency        Minimum             Primary         Primary             Backup            Backup             Planned or Potential Response         Communications      Method          Method              Method(s)         Method(s)          Enhancement Facility         Links               Described in    Available           Described in      Available          Identified?
Site E-Plan     Following           Site E-Plan       Following Assumed                               Assumed LSEE?                                 LSEE?
Primary location Coordination with   FTS 2001        NO                  Commercial        NO                 YES - satellite phone where            Federal agencies -  Network                             Telephone communication    CR, TSC, EOF with Federal agencies is performed

NLS2012112 Page 26 of 36 Table 6: On-site and In-plant Response Teams Coordination and direction of on-site and in-plant response teams. This includes teams necessary to affect emergency repairs, firefighting, search and rescue, radiological monitoring, and implementation of Transition Phase coping and severe accident management strategies. To accommodate the timeline associated with NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (as discussed in Section 1).
Emergency           Minimum                Primary        Primary         Backup            Backup           Planned or Potential Response            Communications         Method         Method          Method(s)         Method(s)        Enhancement Facility            Links                  Described      Available       Described in      Available        Identified?
in Site E-     Following       Site E-Plan       Following Plan           Assumed                           Assumed LSEE?                             LSEE?
On-shift staff      Number necessary       Station        NO              Two-Way FM        YES              YES - additional for the on-shift staff Intercom/                      Radios                             batteries for radios to perform Initial     Gaitronics Phase coping actions (reflecting current staff &
strategies)

NLS2012112 Page 27 of 36 Emergency         Minimum                   Primary       Primary      Backup          Backup     Planned or Potential Response          Communications            Method        Method       Method(s)       Method(s)  Enhancement Facility          Links                     Described     Available    Described in    Available  Identified?
in Site E-    Following    Site E-Plan     Following Plan          Assumed                      Assumed LSEE?                        LSEE?
Operational       1 each for:               Station       NO           Two-Way FM      YES        YES - additional Support Center
* On-site radiological    Intercom/                  Radios                     batteries for radios and other site-   monitoring                Gaitronics specific locations as      2 each for:
necessary         - Firefighting (1 for brigade leader and 1 for the brigade) 2 each per unit for:
                  - In-plant radiological monitoring
                  - Search and Rescue
                  - Emergency repairs Site-specific number needed to implement any 2 severe accident mitigation strategies S                        .4            .4           .4              .4           __________________________

NLS2012112 Page 28 of 36 Table 7: Plant Paging (Announcement) System Emergency Response        Minimum                  Is This System Available Planned or Potential Enhancement Facility                  Communications Links     Following Assumed        Identified?
LSEE?
N/A (Site-wide)           See assumptions and      NO                       YES - alternate approach see Section 4.2 discussion in NEI 12-01.

NLS2012112 Page 29 of 36 Table 8: Communications Equipment at ORO Facilities Emergency           Minimum           Primary      Primary Method Backup     Backup        Planned or Response            Communications    Method      Available       Method(s)  Method(s)     Potential Facility            Links             Described   following       Described  Available     Enhancement in site E-  Assumed LSEE?   in site E- following     Identified?
Plan                        Plan       Assumed LSEE?
Location where      At least one. See OROs receive        assumptions and notifications of an discussion in NEI emergency           12-01.
declaration or a Protective Action   ORO FACILITY Recommendation                        Commercial                  NONE       NO (as described in    Nebraska State    Telephone    NO             (ALL)                    YES - satellite the site            Patrol            (ALL)                                                phones emergency plan)
Nemaha County Sheriff Richardson County Sheriff Missouri State Patrol Atchison County 911 Center

NLS2012112 Page 30 of 36 Table 9: Equipment Locations and Protection System /     Primary System     Equipment protected from the below hazards Equipment    Component Location Protected from         Protected from      Protected from Seismic                Flooding            Wind as defined in this     as defined in this  as defined in this document               document            document UHF Radio    ERP Tower &        NO                     YES                 YES                See Section 4.13.1 Base         Enclosure                                                                        for details of Repeaters                                                                                     protection and Radio                                                                                     conclusions Link MET Tower &        NO                     NO                  YES                See Section 4.13.2 Enclosure                                                                        for details of protection conclusions EOF                NO                     YES                 YES                See Section 4.13.3 for details of protection conclusions CAS                YES                    YES                 YES                See Section 4.13.5 for details of protection conclusions

NLS2012112 Page 31 of 36 System /     Primary System Equipment protected from the below hazards Equipment    Component Location Protected from         Protected from      Protected from     Comments Seismic                Flooding            Wind as defined in this     as defined in this  as defined in this document               document            document UHF Radio    TSC/OSC        YES                    YES                 YES                See section 4.13.4 Base                                                                                      for details of Repeaters                                                                                 protection and Radio                                                                                 conclusions Link

NLS2012112 Page 32 of 36 Table 10         CNS Analysis of Required EP Communications Links Reference NEI 12-01 Section 4, Communications During An Extended Loss of AC Power Total number          Total number              Additional required required              on-hand Satellite phones                   13                     13                        0 Radios                             22           26 are available in                 0 CR and TSC/OSC*
* Additional radios are available from Security and Fire Brigade but were not credited.
Several of the reporting requirements listed above are performed by one individual.
Below is a list of satellite phones and radios credited for establishing critical communications links.
Facility                                                       Satellite phones        Radios Control Room                                                                             13
    " Shift Manager                                                     1
* Shift Communicator                                                1
    " Shift Rad. Tech.                                                  1 Technical Support Center/Operational Support Center                                      13
    " TSC Director                                                      1
    " ENS Communicator                                                  1 Emergency Operations Facility
* Emergency Director                                                1
    " Offsite Communicator                                              1
    " Field Team Coordinator                                            1 Field Monitoring Teams                                                  2 Joint Information Center
* Designated Spokesperson                                           1 Fire Brigade                                                            2 Total                                                                  13                26

NLS2012112 Page 33 of 36 Table 11        Summary of Enhancements
   #                                        Description 1    Resolve issues identified related to anchorages, spatial interactions, and housekeeping.
2    Evaluate and assure that batteries supporting installed radio systems are sized to provide adequate capacity.
3    Ensure that primary OROs have satellite communications capabilities.
4    Evaluate options and select method(s) to support indoor (remote) access to satellite-based communications.
5    Ensure adequate battery-based power is available to handheld communications devices credited to support prolonged SBO conditions.
6    Determine if alternative measures now used for inoperable paging coverage areas can be used for site-wide notification.
7    Ensure enhancements implemented include programmatic support (procedures, inventories, training, testing).
8    Obtain additional GETS cards for key personnel or ERFs.
The enhancements identified above may be modified or changed as implementation progresses. Alternate approaches may be utilized if prudent (e.g., alternate/new technology, improved capability, cost savings, etc.).

NLS2012112 Page 34 of 36 Figure 1              Block diagram of the CNS radio system, repeater system Base #1
(,'Fk- Jdrlky Lse)
T'-                                                            17)Auburn C,                -F MC2500 0C,-ksets I) Control Acorn ROD &#xa3;esk 2 Control Room Seisrn'c Monitor 3)Sim*auotor RO Desk 7r8nsmit 8aose 1    = 451.250 MHz                                          4   Simulator Se'smic Monitor
[Reeie     - 456.250  MHz                                             5Simulator Control Booth 7   0SC TSC AI .pAl  gdab     & Mobiles Are Equipped With F1, r2. F3. F4, & F5.
Security Radios Also Include F6 & F7 Tronsmnit F1    -  456.075 MHz        45n.075 Ml-z F2    = 451-075 MHz         451.075 MHz F3    = 456.250 MHz         451.250 MHz F4     - 451,250 MHz        451.250 MHz F5    - 451.5375 MHz        451.5375 MHz F6    = 469.2 MHz           464.2 MHz F7    = 464.2 MHz           464-2 Ml-z F, 260070 I,                     -     ~L~JL~
COOPER            NUCLEAR      t'-L STATION               ,1              N Ndwm~ka P~uhbvi Fow l*r lt wDiw4 RADIO SYSTEM                          INA              87l       "
06                                       ERP TOWER
      -r    L                                        BASE #1               .          -INA587S671 4
* i          II

NLS2012112 Attachment I Page 35 of 36 Figure 2         Block diagram of the CNS radio system, repeater system Base #2 "Manto-,nce. R.P. Use) 4:---      -*   .      .  .     *F3                                     ..   "    Contro*
SStation FI3                                       1)
Abur LEOF
                                                                          '41  A--uF4 IA Operational      Li 1)Co~tcIRom RO Desk 2)0r10 Room Seismic Mon~tor
: 21) Cn'o1 Baso 2                                                                       3 3)Simulator I0C oesk-Transmit = 451 250     M4iz                                                  41 )Simnulator Seismic Mon~itor Receive    =456.250 MAHz                                                          Simulator Control flooth 7FAC 7    6sC a    8TSC All _Eortabl     & Mobiles Are Equipped With Fl. F2, F3. F4. & F5.
Security Radios Nso Include F6 & F7 i&#xfd; C AcSS~ o~o Transmit 3Telecom Shop F1     456.075 Mtz           451.075 MHz F2  =  49%1 n7.5 M147        4; 1 .fl-7.3 MHz F3  = 456,250 Mlz            451.250 MHz F4  = 451.250 MHz            451.250 M4z F5   - 451.5375 MHz          451.5'375 MHz F6  - 469.2 MHz              464.2 MHz F7  = 464.2 MHz              464.2 MHz 1,        I-6150   1-I MDB. I/J/DI
                                               -R NUCLEAR STATION                             Dw~m , grt RADIO SYSTEM MET TOWER BASE #2

NLS2012112 Page 36 of 36 Figure 3       Block diagram of the CNS radio system, repeater system Low-Band
: 2)   Control 3)Auburn
: 5) Sim-.,t System Operates On F1 Or F2 As Assigned.
Cooper Normally On F2 Maintenance, R.P. On F1 Tronsmit & Receive F1 : 48.180 MHz F2 =47-960  M.4z CtAMW  rA sta I -       LA.8,   /-1/0' COOPER NUCLEAR STATION            ohaam  DAT1E RADIO SYSTEM (LOW BAND)
MET TOWER

NLS2012112 Page 1 of 2 NLS2012112 ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS

NLS2012112 Page 2 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Nebraska Public Power District in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Check One)               COMPLETION COMMITMENT                       ONE-                                  DATE TIME       CONTINUING             (If Required)
ACTION       COMPLIANCE Enhancements identified within the               X                           Prior to Startup assessment (Attachment 1, Table 11)                                          from Refueling will be further developed as                                                 Outage 29 implementation progresses. Alternate approaches will be utilized if prudent                                       (Fall 2016)
(e.g., alternate/new technology, improved capability, cost savings, etc.).
These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements.
NLS2012112-01}}