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#REDIRECT [[NLS2016008, Sixth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)]]
| number = ML16054A799
| issue date = 02/16/2016
| title = Cooper - Sixth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
| author name = Limpias O A
| 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 = EA-12-049, NLS2016008
| document type = Letter, Status Report
| page count = 7
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:NNebraska Public Power DistrictAlways there when :you need usNLS2016008 February 16, 2016U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-000 1
 
==Subject:==
 
==References:==
 
Nebraska Public Power District's Sixth Six-Month Status Report in Response toMarch 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049)
Cooper Nuclear Station, Docket No. 50-298, DPR-461. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"
dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events,"
Revision 0,dated August 29, 20123. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 20124. NPPD Letter, "Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"
datedOctober 29, 20125. NPPD Letter, "Overall Integrated Plan in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049),"
dated February 28, 2013
 
==Dear Sir or Madam:==
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference
: 1) toNebraska Public Power District (NPPD). Reference 1 was immediately effective and directs NPPDto develop, implement, and maintain guidance and strategies
,to maintain or restore core cooling,containment, and spent fuel pooi cooling capabilities in the event of a beyond-design-basis externalevent. Specific requirements are outlined in Attachment 2 of Reference 1.COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321 -0098Telephone:
(402) 825-3811
/ Fax: (402) 825-5211wwnp~o NLS20 16008Page 2 of 2Reference 1 required submission of an initial status report 60 days following issuance of the finalinterim staff guidance (Reference
: 2) and an overall integrated plan pursuant to Section IV,Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute 12-06,Revision 0 (Reference
: 3) with clarifications and exceptions identified in Reference
: 2. Reference 4provided NPPD's initial status report for Cooper Nuclear Station (CNS) regarding mitigation strategies.
Reference 5 provided CNS' Overall Integrated Plan for diverse and flexible copingstrategies (FLEX).Reference 1 requires submission of a status report at six-month intervals following submittal of theoverall integrated plan. Reference 3 provides direction regarding the content of the status reports.The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV,Condition C.2, of Reference 1, that delineates progress made in implementing the requirements ofReference
: 1. The attachment provides an update of milestone accomplishments since the last statusreport, including any changes to the compliance method, schedule, or need for relief and the basis, ifany.This letter contains no new regulatory commitments.
Should you have any questions regarding this report, please contact Jim Shaw, Licensing Manager,at (402) 825-2788.
I declare under penalty of perjury that the foregoing is true and correct.Executed on: 0 7_.3/1 ,/(,,'icreySo~s ear A. LimpiasVice President
-Nuclear andChief Nuclear Officer/bk
 
==Attachment:==
 
Nebraska Public Power District's Sixth Six-Month Status Report for theImplementation of Order EA- 12-049, Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Eventscc: Regional Administrator, w/attachment USNRC -Region IVDirector, w/attachment USNRC -Office of Nuclear Reactor Regulation Senior Resident Inspector, w/attachment USNRC -CNSCooper Project Manager, w/attachment USNRC -NRR Plant Licensing Branch IV-2NPG Distribution, w/attachment CNS Records, w/attachment NLS2016008 Attachment Page 1 of 5Attachment Nebraska Public Power District's Sixth Six-Month Status Report for theImplementation of Order EA-12-049, Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External EventsIntroduction Nebraska Public Power District (NPPD) developed an overall integrated plan (OIP) for CooperNuclear Station (CNS) (Reference 1), documenting the diverse and flexible coping strategies (FLEX), in response to Reference
: 2. This attachment provides an update of milestone accomplishments since submittal of the fifth status report to the OIP (Reference 3), including anychanges to the compliance method, schedule, or need for relief/relaxation and the basis, if any.Milestone Accomplishments The following milestone(s) have been completed since the submittal of the fifth status report forthe OIP, and are current as of February 1, 2016:* The final Site Response Plan has been approved by NPPD from the National SAFERResponse Center (NSRC) and the NSRC has been declared operational for CNS.Milestone Schedule StatusThe following table provides an update to Attachment 2 of the OIP. It provides the activity statusof each item, and whether the expected completion date has changed.
The dates are planningdates subject to change as design and implementation details are developed.
The revised milestone target completion dates do not impact the Order implementation date.Target Revised TargetMilestone Completion Status CopeinDtDateCopeinDt 60-day Status Update October 2012 CompleteSubmit Overall Integrated Plan February 2013 Complete6-month Status Update August 2013 Complete6-month Status Update February 2014 CompleteRegional Response Center September 2014 CompleteOperations Develop Storage Plan May 2014 CompletePurchase FLEX Equipment December 2015 Started June 2016Refine Strategies December 2015 Started March 2016(post-NRC review)_______________________
NLS201 6008Attachment Page 2 of 5Target Revised TargetMilestone Completion Status CopeinDtDateCopeinDt Issue Maintenance Procedures (fr LX qupen)June 2016 Not Started6-month Status Update August 2014 CompleteDevelop Strategies
/ Contract Setm r205 C plewith Regional Response Center Setm r205 C pleDevelop Training Plan December 2015 Started March 2016Implementation Outage 1 Fall 2014 CompleteDevelop Online Mods and September 2015 Started March 2016Implementing Procedures 6-month Status Update February 2015 CompleteWak-hrugs rOctober 2015 Not Started June 2016Demonstrations Implement Training June 2016 Not Started6-month Status Update August 2015 CompleteDeeo uag osadOctober 2015 Started March 2016Implementing Procedures Implemefrt Online Mods and Jue21Strd ProceduresJue21Strd 6-month Status Update February 2016 CompletePerform Staffing Assessment May 2016 Not Started6-month Status Update August 2016 Not StartedImplementation Outage 2 Fall 2016 Not StartedImplement Outage Mods and Fal21NoStre ProceduresFal21NoStre Implement Training Updates Fall 2016 Not StartedSubmit Completion Report Fall 2016 Not StartedChanges to Compliance MethodThe figure on Page 53 of CNS' OIP, "Potential FLEX Storage Locations and Travel Routes,"
wasreplaced with two aerial photos showing the finalized locations of the storage buildings andtravel routes. Excerpts from the OIP with these photos have been placed on CNS' Fukushima e-portal.
NLS20 16008Attachment Page 3 of 5Need for Relief/Relaxation and Basis for the Relief/Relaxation NPPD expects to comply with the Order implementation date and no relief/relaxation is requiredat this time.Open and Confirmatory Items in the Interim Staff Evaluation In Reference 4, the Nuclear Regulatory Commission (NRC) issued the Interim Staff Evaluation (ISE) for CNS relating to the OIP. The following table provides a summary of the confirmatory items documented in the ISE and the status of each item. There were no open items identified inthe ISE.ISE Confirmatory ItemsItem Number Description Status3.1.1.2.A Confirm that the required debris removal equipment remains Openfunctional and deployable to clear obstructions from pathwaysbetween the FLEX storage locations and deployment locations, after the FLEX storage building locations are finalized.
3.1.1 .4.A Confirm the location(s) of the staging area(s) for equipment from Openthe RRC, and the licensee's plans for transportation from theRRC, staging, and on-site deployment is in accordance with theguidance in NEI 12-06, Sections 5.3.4, 6.3.4, 7.3.4, and 8.3.4, orprovide an acceptable alternative to that guidance.
3.1.3.1 .A Confirm that when the FLEX equipment storage building Openlocations are finalized, separation distance and axis of separation is reviewed to confirm that the building locations are consistent
____________with the recommendations in NEI 12-06, Section 7.3.1.3.1.4.2.A Confirm that obtaining makeup water from the Missouri River Openduring an ELAP event adequately addresses NEI 12-06, Section____________8.3.2, consideration 3.3.2.1.1 .A Benchmarks must be identified and discussed which demonstrate Openthat Modular Accident Analysis Program (MAAP) is anappropriate code for the simulation of an ELAP event at CNS,consistent with the NRC endorsement (ADAMS Accession No.ML13275A3
: 18) of the industry position paper on MAAP.3.2.1.1 .B The licensee should demonstrate that the collapsed reactor Openpressure vessel level remains above Top of Active Fuel and thereactor coolant system cool down rate is within technical specifications limits.3.2.1.1 .C The licensee should demonstrate that MAAP is used in Openaccordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June2013 position paper (ADAMS Accession No. ML 13190A201).
3.2.1.1 .D The licensee must identify, in using MAAP, the subset of key Openmodeling parameters cited from Tables 4-1 through 4-6 of the___________"MAAP Application
: Guidance, Desktop Reference for Using NLS20 16008Attachment Page 4 of 5ISE Confirmatory ItemsItem Number Description StatusMAAP Software, Revision 2" (Electric Power Research Institute Report 1020236, available at www.epri.com).
This shouldinclude response at a plant-specific level regarding specificmodeling options and parameter choices for key models thatwould be expected to substantially affect the ELAP analysisperformed for CNS.3.2.1.2.A Confirm that the analysis for a long-duration ELAP event shows Openthat the reactor recirculation pump seal leakage value does notexceed the value used in analysis of a 4-hour station blackoutevent.3.2.1.3 .A Confirm that the method for transferring water from the hotwells Opento the ECSTs, including flow path, valves, pumps, and relatedequipment, when developed, is reliable.
3.2.1 .3.B Confirm that the RCIC room heatup evaluation and RCIC room Open___________flooding time evaluation are completed with acceptable results.3.2.1.3.C Confirm that the licensee's staffing assessment is completed and Openit shows that proposed actions from the FLEX strategies can be_____________completed within the specified time constraints.______
3.2.1 .4.A Confirm that the Phase 2 FLEX equipment performance Opencriterion, when developed, supports the licensee's mitigation strategies.
3.2.2.1.A Confirm that modifications to the reactor building roof hatch Openprovide the ability to maintain adequate SFP area ventilation.
_____3.2.3.A Confirm that CNS's containment venting strategy is finalized and Openthat the strategy supports both containment pressure protection and proposed RCIC and Phase 2 FLEX pump operation._____
3.2.3.B With regard to maintaining containment, the implementation of OpenBWROG Emergency Procedure Guideline/Severe AccidentGuideline, Revision 3, including any associated plant-specific evaluations, must be completed in accordance with theprovisions of NRC letter dated January 9, 2014 (ADAMSAccession No. ML13358A206).
3.2.4.2.A Confirm that fan sizing evaluations support adequate ventilation Openin the main control room, in the RCIC room, and in otherapplicable plant areas.3.2.4.6.A Confirm that analyses addressing heat up in areas that might Openhave personnel habitability considerations conform to theguidance in NEI 12-06, Section 3.2.2, Guideline 11, or providean acceptable alternative to that guidance.
3.2.4.7.A Confirm that the design provisions, as well as operational and Openprotection requirements for the new on-site well/water treatment equipment used for Phase 2 water sources adequately support___________CNS's proposedELAP strategies.
_____
NLS2016008 Attachment Page 5 of 5ISE Confirmatory ItemsItem Number Description Status3 .2.4.8.A Confirm that adequate electrical interaction and isolation Openconsiderations are adequately addressed.
3.2.4.8.B Confirm that the sizing of the portable FLEX diesel generators Openadequately supports CNS's ELAP mitigation strategy.
3.2.4.8.C Provide single-line diagrams showing the proposed connections Openof Phase 2 and Phase 3 electrical equipment and showingprotection information (e.g., breaker, relay, or fuse) and ratingfor the equipment used when available.
3.2.4.10.A Confirm that the minimum dc voltage and dc load profile for the OpenELAP have been determined, the minimum dc bus voltage andthe associated load profile supports CNS's proposed ELAPmitigation strategy.
References The following references support the status update to the OIP described in this attachment:
: 1. NPPD Letter, "Overall Integrated Plan in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"
dated February 28, 20132. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"
dated March 12, 20123. NPPD Letter, "Nebraska Public Power District's Fifth Six-Month Status Report inResponse to March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA- 12-049),"
dated August 27, 20154. NRC Letter, "Cooper Nuclear Station -Interim Staff Evaluation Relating to OverallIntegrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
(TAC No.MF0972),"
dated February 11, 2014 NNebraska Public Power DistrictAlways there when :you need usNLS2016008 February 16, 2016U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-000 1
 
==Subject:==
 
==References:==
 
Nebraska Public Power District's Sixth Six-Month Status Report in Response toMarch 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order Number EA-12-049)
Cooper Nuclear Station, Docket No. 50-298, DPR-461. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis ExternalEvents,"
dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with OrderEA-12-049, Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events,"
Revision 0,dated August 29, 20123. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 20124. NPPD Letter, "Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"
datedOctober 29, 20125. NPPD Letter, "Overall Integrated Plan in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Requirements forMitigation Strategies for Beyond-Design-Basis External Events (Order NumberEA-12-049),"
dated February 28, 2013
 
==Dear Sir or Madam:==
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference
: 1) toNebraska Public Power District (NPPD). Reference 1 was immediately effective and directs NPPDto develop, implement, and maintain guidance and strategies
,to maintain or restore core cooling,containment, and spent fuel pooi cooling capabilities in the event of a beyond-design-basis externalevent. Specific requirements are outlined in Attachment 2 of Reference 1.COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321 -0098Telephone:
(402) 825-3811
/ Fax: (402) 825-5211wwnp~o NLS20 16008Page 2 of 2Reference 1 required submission of an initial status report 60 days following issuance of the finalinterim staff guidance (Reference
: 2) and an overall integrated plan pursuant to Section IV,Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute 12-06,Revision 0 (Reference
: 3) with clarifications and exceptions identified in Reference
: 2. Reference 4provided NPPD's initial status report for Cooper Nuclear Station (CNS) regarding mitigation strategies.
Reference 5 provided CNS' Overall Integrated Plan for diverse and flexible copingstrategies (FLEX).Reference 1 requires submission of a status report at six-month intervals following submittal of theoverall integrated plan. Reference 3 provides direction regarding the content of the status reports.The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV,Condition C.2, of Reference 1, that delineates progress made in implementing the requirements ofReference
: 1. The attachment provides an update of milestone accomplishments since the last statusreport, including any changes to the compliance method, schedule, or need for relief and the basis, ifany.This letter contains no new regulatory commitments.
Should you have any questions regarding this report, please contact Jim Shaw, Licensing Manager,at (402) 825-2788.
I declare under penalty of perjury that the foregoing is true and correct.Executed on: 0 7_.3/1 ,/(,,'icreySo~s ear A. LimpiasVice President
-Nuclear andChief Nuclear Officer/bk
 
==Attachment:==
 
Nebraska Public Power District's Sixth Six-Month Status Report for theImplementation of Order EA- 12-049, Order Modifying Licenses withRegard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Eventscc: Regional Administrator, w/attachment USNRC -Region IVDirector, w/attachment USNRC -Office of Nuclear Reactor Regulation Senior Resident Inspector, w/attachment USNRC -CNSCooper Project Manager, w/attachment USNRC -NRR Plant Licensing Branch IV-2NPG Distribution, w/attachment CNS Records, w/attachment NLS2016008 Attachment Page 1 of 5Attachment Nebraska Public Power District's Sixth Six-Month Status Report for theImplementation of Order EA-12-049, Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External EventsIntroduction Nebraska Public Power District (NPPD) developed an overall integrated plan (OIP) for CooperNuclear Station (CNS) (Reference 1), documenting the diverse and flexible coping strategies (FLEX), in response to Reference
: 2. This attachment provides an update of milestone accomplishments since submittal of the fifth status report to the OIP (Reference 3), including anychanges to the compliance method, schedule, or need for relief/relaxation and the basis, if any.Milestone Accomplishments The following milestone(s) have been completed since the submittal of the fifth status report forthe OIP, and are current as of February 1, 2016:* The final Site Response Plan has been approved by NPPD from the National SAFERResponse Center (NSRC) and the NSRC has been declared operational for CNS.Milestone Schedule StatusThe following table provides an update to Attachment 2 of the OIP. It provides the activity statusof each item, and whether the expected completion date has changed.
The dates are planningdates subject to change as design and implementation details are developed.
The revised milestone target completion dates do not impact the Order implementation date.Target Revised TargetMilestone Completion Status CopeinDtDateCopeinDt 60-day Status Update October 2012 CompleteSubmit Overall Integrated Plan February 2013 Complete6-month Status Update August 2013 Complete6-month Status Update February 2014 CompleteRegional Response Center September 2014 CompleteOperations Develop Storage Plan May 2014 CompletePurchase FLEX Equipment December 2015 Started June 2016Refine Strategies December 2015 Started March 2016(post-NRC review)_______________________
NLS201 6008Attachment Page 2 of 5Target Revised TargetMilestone Completion Status CopeinDtDateCopeinDt Issue Maintenance Procedures (fr LX qupen)June 2016 Not Started6-month Status Update August 2014 CompleteDevelop Strategies
/ Contract Setm r205 C plewith Regional Response Center Setm r205 C pleDevelop Training Plan December 2015 Started March 2016Implementation Outage 1 Fall 2014 CompleteDevelop Online Mods and September 2015 Started March 2016Implementing Procedures 6-month Status Update February 2015 CompleteWak-hrugs rOctober 2015 Not Started June 2016Demonstrations Implement Training June 2016 Not Started6-month Status Update August 2015 CompleteDeeo uag osadOctober 2015 Started March 2016Implementing Procedures Implemefrt Online Mods and Jue21Strd ProceduresJue21Strd 6-month Status Update February 2016 CompletePerform Staffing Assessment May 2016 Not Started6-month Status Update August 2016 Not StartedImplementation Outage 2 Fall 2016 Not StartedImplement Outage Mods and Fal21NoStre ProceduresFal21NoStre Implement Training Updates Fall 2016 Not StartedSubmit Completion Report Fall 2016 Not StartedChanges to Compliance MethodThe figure on Page 53 of CNS' OIP, "Potential FLEX Storage Locations and Travel Routes,"
wasreplaced with two aerial photos showing the finalized locations of the storage buildings andtravel routes. Excerpts from the OIP with these photos have been placed on CNS' Fukushima e-portal.
NLS20 16008Attachment Page 3 of 5Need for Relief/Relaxation and Basis for the Relief/Relaxation NPPD expects to comply with the Order implementation date and no relief/relaxation is requiredat this time.Open and Confirmatory Items in the Interim Staff Evaluation In Reference 4, the Nuclear Regulatory Commission (NRC) issued the Interim Staff Evaluation (ISE) for CNS relating to the OIP. The following table provides a summary of the confirmatory items documented in the ISE and the status of each item. There were no open items identified inthe ISE.ISE Confirmatory ItemsItem Number Description Status3.1.1.2.A Confirm that the required debris removal equipment remains Openfunctional and deployable to clear obstructions from pathwaysbetween the FLEX storage locations and deployment locations, after the FLEX storage building locations are finalized.
3.1.1 .4.A Confirm the location(s) of the staging area(s) for equipment from Openthe RRC, and the licensee's plans for transportation from theRRC, staging, and on-site deployment is in accordance with theguidance in NEI 12-06, Sections 5.3.4, 6.3.4, 7.3.4, and 8.3.4, orprovide an acceptable alternative to that guidance.
3.1.3.1 .A Confirm that when the FLEX equipment storage building Openlocations are finalized, separation distance and axis of separation is reviewed to confirm that the building locations are consistent
____________with the recommendations in NEI 12-06, Section 7.3.1.3.1.4.2.A Confirm that obtaining makeup water from the Missouri River Openduring an ELAP event adequately addresses NEI 12-06, Section____________8.3.2, consideration 3.3.2.1.1 .A Benchmarks must be identified and discussed which demonstrate Openthat Modular Accident Analysis Program (MAAP) is anappropriate code for the simulation of an ELAP event at CNS,consistent with the NRC endorsement (ADAMS Accession No.ML13275A3
: 18) of the industry position paper on MAAP.3.2.1.1 .B The licensee should demonstrate that the collapsed reactor Openpressure vessel level remains above Top of Active Fuel and thereactor coolant system cool down rate is within technical specifications limits.3.2.1.1 .C The licensee should demonstrate that MAAP is used in Openaccordance with Sections 4.1, 4.2, 4.3, 4.4, and 4.5 of the June2013 position paper (ADAMS Accession No. ML 13190A201).
3.2.1.1 .D The licensee must identify, in using MAAP, the subset of key Openmodeling parameters cited from Tables 4-1 through 4-6 of the___________"MAAP Application
: Guidance, Desktop Reference for Using NLS20 16008Attachment Page 4 of 5ISE Confirmatory ItemsItem Number Description StatusMAAP Software, Revision 2" (Electric Power Research Institute Report 1020236, available at www.epri.com).
This shouldinclude response at a plant-specific level regarding specificmodeling options and parameter choices for key models thatwould be expected to substantially affect the ELAP analysisperformed for CNS.3.2.1.2.A Confirm that the analysis for a long-duration ELAP event shows Openthat the reactor recirculation pump seal leakage value does notexceed the value used in analysis of a 4-hour station blackoutevent.3.2.1.3 .A Confirm that the method for transferring water from the hotwells Opento the ECSTs, including flow path, valves, pumps, and relatedequipment, when developed, is reliable.
3.2.1 .3.B Confirm that the RCIC room heatup evaluation and RCIC room Open___________flooding time evaluation are completed with acceptable results.3.2.1.3.C Confirm that the licensee's staffing assessment is completed and Openit shows that proposed actions from the FLEX strategies can be_____________completed within the specified time constraints.______
3.2.1 .4.A Confirm that the Phase 2 FLEX equipment performance Opencriterion, when developed, supports the licensee's mitigation strategies.
3.2.2.1.A Confirm that modifications to the reactor building roof hatch Openprovide the ability to maintain adequate SFP area ventilation.
_____3.2.3.A Confirm that CNS's containment venting strategy is finalized and Openthat the strategy supports both containment pressure protection and proposed RCIC and Phase 2 FLEX pump operation._____
3.2.3.B With regard to maintaining containment, the implementation of OpenBWROG Emergency Procedure Guideline/Severe AccidentGuideline, Revision 3, including any associated plant-specific evaluations, must be completed in accordance with theprovisions of NRC letter dated January 9, 2014 (ADAMSAccession No. ML13358A206).
3.2.4.2.A Confirm that fan sizing evaluations support adequate ventilation Openin the main control room, in the RCIC room, and in otherapplicable plant areas.3.2.4.6.A Confirm that analyses addressing heat up in areas that might Openhave personnel habitability considerations conform to theguidance in NEI 12-06, Section 3.2.2, Guideline 11, or providean acceptable alternative to that guidance.
3.2.4.7.A Confirm that the design provisions, as well as operational and Openprotection requirements for the new on-site well/water treatment equipment used for Phase 2 water sources adequately support___________CNS's proposedELAP strategies.
_____
NLS2016008 Attachment Page 5 of 5ISE Confirmatory ItemsItem Number Description Status3 .2.4.8.A Confirm that adequate electrical interaction and isolation Openconsiderations are adequately addressed.
3.2.4.8.B Confirm that the sizing of the portable FLEX diesel generators Openadequately supports CNS's ELAP mitigation strategy.
3.2.4.8.C Provide single-line diagrams showing the proposed connections Openof Phase 2 and Phase 3 electrical equipment and showingprotection information (e.g., breaker, relay, or fuse) and ratingfor the equipment used when available.
3.2.4.10.A Confirm that the minimum dc voltage and dc load profile for the OpenELAP have been determined, the minimum dc bus voltage andthe associated load profile supports CNS's proposed ELAPmitigation strategy.
References The following references support the status update to the OIP described in this attachment:
: 1. NPPD Letter, "Overall Integrated Plan in Response to March 12, 2012, Commission OrderModifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"
dated February 28, 20132. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"
dated March 12, 20123. NPPD Letter, "Nebraska Public Power District's Fifth Six-Month Status Report inResponse to March 12, 2012, Commission Order Modifying Licenses with Regard toRequirements for Mitigation Strategies for Beyond-Design-Basis External Events (OrderNumber EA- 12-049),"
dated August 27, 20154. NRC Letter, "Cooper Nuclear Station -Interim Staff Evaluation Relating to OverallIntegrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
(TAC No.MF0972),"
dated February 11, 2014}}

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