ML090690358

Issuance of Amendment No. 232, Revise Technical Specification 3.7.3, Reactor Equipment Cooling (REC) System

ML090690358
Person / Time
Site:	Cooper
Issue date:	03/20/2009
From:	Lyon C Plant Licensing Branch IV
To:	Minahan S Nebraska Public Power District (NPPD)
Lyon C Fred, NRR/DORL/LPL4, 301-415-2296
References
TAC MD8374
Download: ML090690358 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 20, 2009 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321 SUB~IECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE: REACTOR EQUIPMENT COOLING SYSTEM (TAC NO. MD8374)

Dear Mr. Minahan:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 232 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station.

The amendment consists of changes to the Technical Specifications in response to your application dated March 24, 2008, as supplemented by letters dated September 11 and 19, 2008, November 6, 2008, and February 26, 2009.

The amendment revises Technical Specification (TS) Section 3.7.3, "Reactor Equipment Cooling (REC) System," to allow credit for the ability to align the service water system to the REC system.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 232 to DPR-46

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COIVIMISSION WASHINGTON, D.C. 20555-0001 NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 232 License No. DPR-46

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Nebraska Public Power District (the licensee),

dated March 24, 2008, as supplemented by letters dated September 11 and 19, 2008, November 6,2008, and February 26,2009, complies with the standards and requirements of the Atomic Energy Act of '1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No. DPR-46 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 232, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael 1. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. DPR-46 and Technical Specifications Date of Issuance: March 20, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 232 FACILITY OPERATING LICENSE NO. DPR-46 DOCKET NO. 50-298 Replace the following pages of the Facility Operating License No. DPR-46 and Appendix A Technical Specifications with the enclosed revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License REMOVE INSERT Page 3 of 5 Page 3 of 5 Technical Specifications REMOVE INSERT 3.7-6 3.7-6 3.7-7 3.7-7

(5)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

C.

This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1 )

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).

(2)

Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 232, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3)

Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Cooper Nuclear Station Safeguards Plan," submitted by letter dated May 17, 2006.

(4)

Fire Protection The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Cooper Nuclear Station (CNS) Updated Safety Analysis Report and as approved in the Safety Evaluations dated November 29, 1977; May 23, 1979; November 21,1980; April 29, 1983; April 16, 1984; June 1,1984; January 3, 1985; August 21, 1985; April 10, 1986; September 9, 1986; November 7, 1988; February 3, 1989; August 15, 1995; and July 31, 1998, subject to the following provision:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

Amendment No. 232 Revised by letter dated March 5, 2007 3 of 5

3.7 PLANT SYSTEMS REC System 3.7.3 3.7.3 Reactor Equipment Cooling (REC) System LCO 3.7.3 Two REC subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

REC leakage exceeds limits AND One SW backup subsystem is inoperable A.1 Verify by administrative means one SW backup subsystem OPERABLE AND A.2.1 Restore the inoperable SW backup subsystem to OPERABLE status.

OR A.2.2 Restore REC leakage to within limits.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 14 days 14 days B.

One REC subsystem inoperable for reasons other than Condition A.

B.1 Restore the REC sUbsystem to OPERABLE status.

30 days C.

Required Actions and associated Completion Times of Conditions A or B not met.

C.1 Be in MODE 3.

AND 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR Leakage exceeds limits with both SW backup subsystems inoperable OR Both REC subsystems inoperable for reasons other than Condition A.

C.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Cooper 3.7-6 Amendment No. 232

3.7.3 REC System SURVEILLANcE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1

---

NOTES--------------------------

1.

SR 3.0.1 is not applicable when both Service Water backup subsystems are OPERABLE.

2.

REC system leakage beyond limits by itself is only a degradation of the REC system and does not result in the REC system being inoperable.

Verify the REC system leakage is within limits.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.7.3.2 Verify the temperature of the REC supply water is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

~ 100°F.

SR 3.7.3.3

---

NOTE---------------------------

Isolation of flow to individual components does not render REC System inoperable.

Verify each REC subsystem manual, power 31 days operated, and automatic valve in the flow paths servicing safety related cooling loads, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.7.3.4 Verify each REC subsystem actuates on an 18 months actual or simulated initiation signal.

Cooper 3.7-7 Amendment No. 232

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 232 TO FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated March 24, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML080910062), as supplemented by letters dated September 11 and 19,2008, November 6,2008, and February 26,2009 (ADAMS Accession Nos. ML082730526, ML082700547, ML083170485, and ML090620723, respectively), Nebraska Public Power District (the licensee), requested changes to the Technical Specifications (TSs) for Cooper Nuclear Station (CNS).

The supplements dated September 11 and 19,2008, November 6,2008, and February 26, 2009, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 22, 2008 (73 FR 21660).

The proposed changes would revise TS Section 3.7.3, "Reactor Equipment Cooling (REC)

System," to allow credit for the ability to align the service water (SW) system to the REC system in order to provide required cooling to the essential loads of the REC system during mitigation of the design basis loss-of-coolant accident (LOCA).

Specifically, the licensee proposed the following changes to TS Section 3.7.3.

1.

The following is added as new Condition A:

"REC leakage exceeds limits AND One SW backup subsystem is inoperable" The following are the proposed Required Actions and Completion Times:

A.1 "Verify by administrative means one SW backup subsystem OPERABLE" The Completion Time is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

- 2 A2.1 "Restore the inoperable SW backup subsystem to OPERABLE status."

The Completion Time is 14 days.

OR A2.2 "Restore REC leakage to within limits." The Completion Time is 14 days.

2.

Renumber existing Condition A as Condition B and add "for reasons other than Condition A" Revised Condition B will then read:

"One REC subsystem inoperable for reasons other than Condition A" Renumber existing Required Action A1 to B.1. Revised Required Action B.1 will then read:

"Restore the REC subsystem to OPERABLE status." The Completion Time is 30 days.

3.

Renumber existing Condition B as Condition C, revise the existing provisions, and add a new provision. The new Condition C will read:

"Required Actions and associated Completion Times of Conditions A or B not met.

OR Leakage exceeds limits with both SW backup subsystems inoperable.

Both REC subsystems inoperable for reasons other than Condition A" Renumber eXisting Required Actions B.1, "Be in MODE 3," and B.2, "Be in MODE 4," as Required Actions C.1 and C.2.

4.

Revise Surveillance Requirement (SR) 3.7.3.1 from "Verify the REC surge tank water level is within limits" to "Verify the REC system leakage is within limits."

Add the following two new notes:

1.

"SR 3.0.1 is not applicable when both Service Water backup subsystems are OPERABLE."

2.

"REC system leakage beyond limits by itself is only a degradation of the REC system and does not result in the REC system being inoperable."

- 3

2.0 REGULATORY EVALUATION

The NRC staffs review focused primarily in the areas of balance-of-plant, environmental qualification, and human factors. The staff applied the following regulatory requirements during its review of the licensee's application:

In 10 CFR 50.36, "Technical specifications," the Commission established its regulatory requirements related to the contents of the TSs. This section states, "Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section." Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits (SLs), limiting safety system settings (LSSSs), and limiting control settings; (2) limiting conditions for operation (LCOs);

(3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

Specifically, 10 CFR 50.36(c)(2) defines an LCO as "the lowest functional capability or performance levels of equipment required for safe operation of the facility."

In addition, 10 CFR 50.36(c)(3) states, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The staff reviewed the proposed TS changes against these 10 CFR 50.36 requirements to ensure that there is reasonable assurance that the systems affected by the proposed TS changes will perform their required safety functions.

Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50), Section 50.49, "Environmental qualification of electric equipment important to safety for nuclear power plants," provides regulations related to the environmental qualification of electrical equipment located in a harsh environment to ensure that the equipment will be able to perform its intended safety function during all anticipated operating conditions, even after being degraded due to exposure to service conditions during its qualified life.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 4, "Environmental and dynamic effects design bases," requires that "Structures, systems, and components important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of coolant accidents." 1 1 The 1967 Proposed GDC as described in the CNS updated safety analysis report (USAR), Appendix F, are the licensing basis for CNS; however, the NRC staff concluded in its 1973 Safety Evaluation Report for CNS that the intent of the 1971 Final Rule for 10 CFR Part 50, Appendix A, had also been met.

- 4 GDC 44, "Cooling water," requires that "A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions. Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."

The NRC staff also used the following regulatory guidance in its review:

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP), Section 9.2.1, "Station Service Water System,"

describes an acceptable method of reviewing amendment requests involving SW systems. The SRP guidance is used by the staff to ensure that the SW system continues to perform its function of providing essential cooling to safety-related equipment and cooling non safety-related auxiliary components used for normal plant operation.

SRP Section 9.2.2, "Reactor Auxiliary Cooling Water System," describes an acceptable method of reviewing amendment requests involving reactor auxiliary cooling water systems. The SRP guidance is used by the staff to ensure that the capability remains intact to provide adequate cooling water to safety-related emergency core cooling system (ECCS) components and reactor auxiliary equipment for all planned operating conditions.

SRP Sections 13.2.1, "Reactor Operator Requalification Program; Reactor Operator Training," 13.2.2, "Non-licensed Plant Staff Training," 13.5.2.1, "Inadvertent Operation of ECCS and Chemical and Volume Control System Malfunction that Increases Reactor Coolant Inventory," and Chapter 18.0, "Human Factors Engineering," provide review guidance to the staff in the area of human performance. The area of human performance deals with programs, procedures, training, and plant design features related to human performance during normal and accident conditions. The staff's evaluation was conducted to ensure that human performance would not be adversely affected as a result of the proposed changes. The staff's review covered the licensee's evaluation of changes to operator actions, human-system interfaces, and procedures and training.

NRC Information Notice (IN) 97-78, "Crediting of Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times." The licensee addressed the NRC staff recommendations of IN 97-78 in its application, so the staff formatted its human factors evaluation consistent with the IN.

- 5 Regulatory Guide 1.89, "Environmental Qualification of Certain Electric Equipment Important to Safety in Nuclear Power Plants," provides guidance for implementing the requirements of 10 CFR 50.49 for environmental qualification of electrical equipment that is important to safety and located in a harsh environment.

3.0 TECHNICAL EVALUATION

3.1 Background

3.1.1 REC System In its submittal, the licensee described the REC system as a means of providing cooling for the non-essential (non-safety related) and essential (safety-related) heat loads during normal plant operation, and cooling for the essential heat loads during accidents, such as a LOCA, and transients. The non-essential heat loads include equipment located in the drywell (primary containment), the Reactor Building (secondary containment), the Control Building, Radwaste Building, and Augmented Radwaste Building. The REC system also provides cooling water for the removal of heat from equipment required for a safe shutdown following a design-basis accident or a transient. These essential heat loads are the room coolers in the rooms, in which the ECCS pumps are located. The following are the safety design-basis provisions of the REC system:

The system shall be designed with sufficient redundancy so that no single, active system component failure can prevent the system from achieving its safety objective.

The system shall be designed to provide an adequate supply of cooling water to the ECCS areas under all accident and transient conditions.

The REC system consists of a non-critical loop and two critical loops. The non-essential heat loads are cooled by water supplied by the non-critical loop. The essential heat loads are cooled by water supplied by the critical loops. After removing heat from the components, the water is recirculated back to the suction of the REC pumps. The REC heat exchangers are cooled by the SW system. A 550-gallon surge tank is located at the highest point of the REC system. The purpose of this tank is to:

Accommodate system volume changes.

Maintain static pressure in the system.

Provide a point to monitor system inventory, thereby detecting gross leaks in the system.

Provide a means of adding makeup water to the system.

- 6 3.1.2 SW System In its submittal, the licensee described the SW system as a means of providing a heat sink for the REC, Residual Heat Removal (RHR), and Diesel Generator (DG) cooling systems under accident and transient conditions. The safety design basis of the SW system currently includes the following provisions:

The ability to continuously provide a supply of cooling water directly to the DGs and the secondary side of the REC heat exchangers and to the RHR Service Water Booster (SWB) pumps adequate for both normal and transient and accident conditions.

The capability to provide direct cooling to essential REC heat loads following a 7-day post-accident time period or after a passive REC failure.

The SW system contains four vertical pumps and two strainers, piping, valves, and instrumentation. The two SW pumps in each division discharge to a common header, from which independent piping supplies two seismic Class 1S cooling water loops and one Turbine Building loop. Each seismic Class 1S loop supplies cooling water to one DG, one REC heat exchanger, and one RHR heat exchanger through two RHR SWB pumps. Either loop can supply cooling water to the REC critical loops, the RHR SWB pump room fan coil unit, and control room air conditioning units.

3.1.3 SW Backup to REC Cross-Connection In its submittal, the licensee described the SW system and REC system cross-connection as an alternative path for allowing cooling water to the REC critical loops from the SW system in the event that the REC system cannot provide the required cooling water. Two separate subsystems of this SW cross-connection are available, either one of which is capable of supplying cooling water to both of the two REC critical loops. Each of the two SW backup sub systems has one valve that admits water from the SW system to the REC critical loops, and another valve that returns the water to the SW system. A cross-tie between the two REC critical loops allows the components on either or both of the loops to be supplied with cooling water from the SW system.

3.1.4 Current Design Basis The current design basis for the REC system, as approved by the I\\IRC in Amendment 1\\10. 185, dated March 13, 2001 (ADAMS Accession No. ML010740220), is that it must fulfill its safety function for at least 7 days following a LOCA. For the duration of an event beyond the initial 7-day period out to 30 days (the required mission time), the SW system is credited for performing the REC cooling function if the REC system should become unavailable. The proposed change reflects a change to the design basis for the REC system, since it credits the SW system for performing the REC function from the initial time of the LOCA.

- 7 3.2 Balance-of-Plant Evaluation Amendment No. 185 credited the use of the SW system as a backup cooling source for the REC system 7 days after a LOCA. The licensee's calculations supporting Amendment No. 185 assumed that it would be at least 7 days after a LOCA before the SW system would be utilized in place of an unavailable REC system.

In its November 6, 2008, supplemental letter, the licensee provided a summary of its calculations used to support Amendment No. 185. The NRC staff reviewed the summary to determine whether or not the calculations were applicable for the SW system to support the REC system essential heat loads from immediately following a LOCA to 30 days, rather than from 7 days to 30 days following a LOCA. The licensee stated that:

The earlier calculations performed in support of the Amendment 185 amendment request...remain valid based on the fact that the changes made to them since issuance of Amendment 185 have not invalidated any of the assumptions made in them, they are consistent with the current licensing basis, and they have no conflicts with the REC Margin amendment request currently under review.... The calculations were revised to maintain them consistent with the design and licensing basis of CNS.

The assumptions used in the calculations considered the usage of the SW system for cooling the REC essential heat loads for 30 days after a LOCA. The licensee analyzed the amount of SW flow needed for the full 30 days and found that cooling would still be sufficient for the REC essential heat loads. The licensee also stated that the operators would be expected to align the SW system to the REC essential heat loads within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as needed using the cross connection.

In response to a request for additional information from the NRC staff regarding the adverse impact over the additional time period of any additional amount of silt from the Missouri River, the source for SW, the licensee stated in its supplemental letter dated November 6, 2008, that the calculations do not explicitly address the silt intake. However, the licensee's calculations demonstrate that, since the SW system flow velocity exceeds 1 foot per second, the flow velocity will prevent debris trapping, settling, and/or precipitation from occurring in the piping and associated heat exchanger tubes within the SW system flow path for cooling the REC essential heat loads. The licensee also stated that the cross-tie piping arrangement, as described in the licensee's submittal for Amendment No. 185. was in place to provide return flow to flush out, as needed, any silt in the SW system during an emergency in which SW backup would be needed. No physical modifications to CNS are needed to support the TS changes. Therefore, the proposed changes to the TSs will continue to meet GDC 44.

The NRC staff finds the licensee's revised calculations to support utilizing the SW system earlier than the eighth day after a LOCA to be acceptable, since the revised calculations reflect the current CNS plant conditions and do not invalidate the earlier assumptions used for Amendment No. 185. With one SW subsystem capable of supporting the REC essential heat loads for 30 days after a LOCA and the arrangement of the SW system providing for very minimal-to negligible buildup of silt, the staff finds that adequate cooling will be available to continue to meet GOC 44 and 10 CFR 50.36(c)(2) for the REC essential heat loads.

- 8 The NRC staff evaluated the proposed changes to the Conditions and associated Required Actions and Completion Times of TS 3.7.3. The staff determined that the proposed changes described the remedial actions necessary to ensure continued safe operation of the plant when the LCO for the REC system is not met, when taking credit for the SW cross-tie. Since the proposed design change is acceptable, the proposed changes to the Conditions and associated Required Actions and Completion Times of LCO 3.7.3 are acceptable.

In its supplemental letter dated November 6, 2008, the licensee stated that the means of verifying the REC system leakage within limits can only be performed by observing the REC surge tank for level changes. Decreases in the surge tank level reflect leakage from the REC system and represent a degradation of the REC system. The current TS requirement is that the REC system be declared inoperable if the REC surge tank water level cannot be maintained within limits. The licensee proposes to revise SR 3.7.3.1 to more accurately reflect that REC system leakage is being monitored for potential degradation and to coincide with the revised LCO 3.7.3. Since REC system leakage will continue to be monitored, the proposed change continues to meet the intent of the SR and the requirements of 10 CFR 50.36(c)(3). Therefore, the proposed change to SR 3.7.3.1 is acceptable.

The licensee also proposed adding NOTES 1 and 2 above SR 3.7.3.1. Note 1 would read "SR 3.0.1 is not applicable when both Service Water backup subsystems are OPERABLE."

Note 2 would read "REC system leakage beyond limits by itself is only a degradation of the REC system and does not result in the REC system being inoperable." SR 3.0.1 states that failure to meet an SR shall be failure to meet the LCO (i.e., failure of the equipment to meet the lowest functional capability or performance level required for safe operation of the facility). Since the proposed design changes for the REC include changes to take credit for the ability of the SW system to perform the safety function of the REC system, SR 3.0.1 would only apply when the SW backup subsystem is unable to perform the safety function of the associated REC system.

The proposed Notes provide guidance to the operators regarding when SR 3.0.1 is applicable.

Therefore, the proposed Notes are acceptable.

Based on the above, the proposed changes comply with the requirements of 10 CFR 50.36(c)(2) and (c)(3) and GDC 44, and are acceptable.

3.3 Environmental Qualification CNS is a boiling-water reactor (BWR) Qf General Electric design BWR4, with a Mark 1 containment. The ECCS at CNS consists of the High Pressure Coolant Injection (HPCI) system, the low-pressure Core Spray (CS) system, the Low Pressure Coolant Injection (LPCI) mode of the Residual Heat Removal (RHR) system, and the Automatic Depressurization system. The pumps in the CS and RHR systems are motor-driven. The pumps for these ECCS subsystems are located in four rooms in the basement of the Reactor Building (RB).

The licensee stated that the environmental qualification (EQ) zones that will be most affected by the proposed changes are the four rooms in the RB where the RHR and CS pumps are located (referred to as the Quad Rooms). plus the HPCI pump room. The operations of these pump motors and the steam turbines, along with the recirculation of the hot reactor coolant in the piping, add heat to the ECCS pump rooms, resulting in an increase in the temperature of the

- 9 rooms. These rooms are cooled by fan coil units with cooling water supplied by the REC system or the SW system through cross-connections between the two systems.

The licensee's proposed amendment would allow the alignment of the SW system to the REC system within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> only when the leakage in the REC system would result in less than 30 days of inventory in the REC surge tank. In its March 24, 2008, submittal, the licensee identified the worst-case scenario, in terms of the resulting higher temperature in the ECCS pump rooms, to be when the loss of REC occurs at 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> following occurrence of a LOCA event. In this scenario, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> would be needed to align the SW system with the REC system.

During this time, no cooling would be provided to the pump room electrical equipment. The licensee further stated that during the 1-hour time frame when no cooling is provided, the resulting peak temperatures may exceed the existing value for post-LOCA. However, the safety-related electrical equipment i'n the ECCS rooms is qualified for the High Energy Line Break accident peak temperatures. The licensee stated that the resulting peak temperatures in the ECCS pump rooms would be bounded by the EO bounding temperature profile. Therefore, the EO of the affected electrical equipment would continue to be maintained. After aligning the SW system to the REC system in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, SW would resume removing excess heat from the ECCS pump rooms.

The NRC staff requested the licensee to provide (1) the numerical values of any changes (e.g.,

changes in temperature, humidity, or radiation during normal operation and during postulated LOCA events); (2) the details of EO equipment replacement, if any; and (3) the detailed EO evaluation, including justifications, calculations, and comparisons of changes in temperature, humidity, or radiation resulting from the proposed changes. In its September 11, 2008, supplemental letter, the licensee stated that there will not be any change in normal environmental parameters, including temperature, humidity, and radiation due the proposed changes. For a postulated LOCA condition, the licensee stated that the change in temperature and humidity will be negligible and that the resulting temperatures would be bounded by the existing EO profiles. The licensee further stated that the change would not impact the EO of the affected electrical equipment.

The NRC staff reviewed the documentation provided by the licensee in its supplement and confirmed that the impact on the affected electrical equipment due to this license amendment will be negligible, and that the EO of the affected electrical equipment will continue to be maintained. Furthermore, the staff finds the licensee's justification and EO analysis to be consistent with 10 CFR 50.49, GDC 4, and the guidance provided in Regulatory Guide 1.89.

Based on the above, the NRC staff finds that the impact on electrical equipment as a result of this license amendment will be negligible and that the existing EO analysis will continue to remain valid and meet the applicable regulatory requirements. Therefore, the proposed changes are acceptable.

3.4 Human Factors Evaluation As noted in IN 97-78 and SRP Chapter 18.0, proposed changes that substitute manual action for automatic system actuation or modify existing operator actions, including operator response times, must be evaluated under the criteria of 10 CFR 50.59, "Changes, tests, and experiments." The NRC staff provided regulatory guidance for evaluating additions or changes

- 10 to operator actions in IN 97-78. As described in IN 97-78, the NRC's reviews of licensees' analyses for crediting operator actions typically include, but are not limited to:

the specific operator actions required; the potentially harsh or inhospitable environmental conditions expected; a general discussion of the ingress/egress paths taken by the operators to accomplish functions; the procedural guidance for required actions; the specific operator training necessary to carry out actions, including any operator qualifications required to carry out actions; any additional support personnel and/or equipment required by the operator to carry out actions; a description of information required by the control room staff to determine whether such operator action is required, including qualified instrumentation used to diagnose the situation and to verify that the required action has successfully been taken; the ability to recover from credible errors in performance of manual actions, and the expected time required to make such a recovery; and consideration of the risk significance of the proposed operator actions.

The NRC staffs evaluation below addresses each of the review elements.

3.4.1 Specific Operator Actions Required The licensee stated in its submittals that no new operator actions or changes to existing operator actions will be required as a result of the proposed changes. The proposed changes to the TSs revise the timing for taking an action involved in mitigating a LOCA; that is, the SW system may need to be aligned to the REC system sooner than 7 days following a LOCA, as currently allowed by license requirements. The licensee demonstrated that this alignment can be completed sooner than the current required 7 days. In fact, the licensee stated that simulator scenarios demonstrated that a sample of two crews of operators could successfully perform the alignment in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. All actions are performed from the Main Control Room except for the lifting of a single lead in the Cable Spreading Room (to close the SW outlet valve on the REC heat exchangers).

3.4.2 Potentially Harsh or Inhospitable Environmental Conditions Expected The Control Room Envelope (CRE) at CNS is comprised of the Main Control Room and the Cable Spreading Room. It is maintained suitable for human occupancy at all times. Because the actions to align SW to the REC system can be performed from within the CRE, potentially harsh or inhospitable environmental conditions are not expected.

- 11 3.4.3 Ingress/Egress Paths Taken by Operators to Accomplish Functions The licensee stated that the travel path does not require passing through radiation areas, steam/hot environment, and is not congested or difficult to traverse. There is minimal increased risk to the operator in traversing this pathway (through the Computer Room and down one set of stairs) and taking the required action in the Cable Spreading Room.

3.4.4 Procedural Guidance for Required Actions Procedural guidance on when SW backup is needed and actions to take to align SW to the REC system is contained in the licensee's Emergency Procedure 5.2REC, including:

Entry conditions for when Procedure 5.2REC is to be entered.

Automatic actions that the plant will take.

Immediate actions to be taken by the operators, i.e., starting available REC pumps and closing two valves, if automatic actions do not restore REC header pressure.

Subsequent actions to be taken by the operators. These include initiating SW to REC flow, if required. The four actions that the operators must take to align SW to REC are specified in an attachment to the procedure.

3.4.5 Specific Operator Training Necessary to Carry Out Actions, Including Any Operator Qualifications Required Licensed operators at CNS receive initial and requalification training on aligning SW to REC.

This task is trained and evaluated both in the classroom and in the simulator. Additionally, in requalification training, operators are trained on the simulator to recognize and respond to a loss of all REC.

3.4.6 Any Additional Support Personnel or Equipment Needed by the Operator(s) to Carry Out Actions The licensee stated in its submittals that no additional support personnel or special equipment is needed to align SW to REC during a LOCA scenario.

3.4.7 Information Required by the Control Room Staff to Determine Whether Operator Action is Required, Including Qualified Instruments Used to Diagnose the Situation and to Verify that the Required Action Has Successfully Been Taken Sufficient controls, displays, and alarms have been provided to allow operators to recognize when the REC system is degraded or inoperable, and to allow them to take mitigative actions as required by procedures. Annunciators for REC low system pressure, low surge tank level, REC pump failures, and low REC discharge pressure alert the operators to any problems with the readiness or integrity of the REC system. Similarly, controls, displays, and alarms have been provided to allow operators to recognize when the SW system is ready and able to back up the REC system, and to make the alignment with REC when appropriate. No changes are needed to existing instrumentation currently used by operators.

- 12 3.4.8 The Ability to Recover from Credible Errors in the Performance of Manual Actions, and the Expected Time Required to Make Such a Recovery The licensee determined that the credible error of interest to this evaluation is an operator aligning REC to Division I of SW instead of Division II. Division II of SW is preferred because Division I is vulnerable to single failure. Assuming this error is made, there would be no need to recover (no action required, time required= 0) because each Division is capable of performing the required cooling function. However, if there was an additional failure of Division I, Emergency Procedure 5.2REC provides direction to the operator to re-align to Division II, if Division II power is available. Ultimately, if both REC and SW are unavailable, the plant must be shut down in accordance with Emergency Procedures.

3.4.9 The Risk Significance of the Proposed Actions The licensee performed a human reliability analysis (HRA) to address the reliability of operator actions needed to align the SW system to the REC system following a LOCA. The HRA focused on the existing alarms in the control room, the operating procedures, the system design features, and the results of scenarios performed on the CNS simulator. The simulator was used to validate the timing of operator response to a LOCA with loss-of-offsite power and degraded conditions in the REC system, requiring that the SW system be aligned to the REC critical loops.

Because the actions proposed by the licensee have not changed from the currently required actions (only the timing has changed) and because the licensee has demonstrated that the actions can be performed within the 1-hour time assumed, the NRC staff agrees with the licensee's conclusion that the overall change in risk significance is negligible.

3.4.10 Conclusion for Section 3.4 The NRC staff has reviewed the licensee's proposed changes related to the human factors area and concludes that the licensee has adequately considered the impact on operator actions, procedures, control room components, plant simulator and operator training programs to ensure that the operators' performance is not adversely affected. Therefore, the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The

- 13 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on April 22, 2008 (73 FR 21660). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: G. Armstrong N. Patel M. Hamm G. Lapinsky Date: March 20, 2009

March 20, 2009 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321 SUB~IECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT RE: REACTOR EQUIPMENT COOLING SYSTEM (TAC NO. MD8374)

Dear Mr. Minahan:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 232 to Facility Operating License No. DPR-46 for the Cooper Nuclear Station.

The amendment consists of changes to the Technical Specifications in response to your application dated March 24, 2008, as supplemented by letters dated September 11 and 19, 2008, November 6, 2008, and February 26, 2009.

The amendment revises Technical Specification (TS) Section 3.7.3, "Reactor Equipment Cooling (REC) System," to allow credit for the ability to align the service water system to the REC system.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, IRA!

Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 232 to DPR-46

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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