ML19352G194

Issuance of Amendment No. 264 Elimination of Technical Specification Requirements for Hydrogen/Oxygen Monitors Using the Consolidated Line Item Improvement Process

ML19352G194
Person / Time
Site:	Cooper
Issue date:	01/28/2020
From:	Thomas Wengert Plant Licensing Branch IV
To:	Dent J Nebraska Public Power District (NPPD)
Wengert T, NRR/DORL/LPLIV, 415-4037
References
EPID L-2019-LLA-0128
Download: ML19352G194 (16)

Text

UNITED STATES WASHINGTON, D.C. 20555-0001 January 28, 2020 Mr. John Dent, Jr.

Vice President and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 264 RE: ELIMINATION OF TECHNICAL SPECIFICATION REQUIREMENTS FOR HYDROGEN/OXYGEN MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2019-LLA-0128)

Dear Mr. Dent:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 264 to Renewed Facility Operating License No. DPR-46 for Cooper Nuclear Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 23, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19171A268).

The amendment deletes the TS requirements related to hydrogen and oxygen monitoring. The TS changes support implementation of the revisions to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, "Combustible gas control for nuclear power reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of the NRC-approved Industry/Technical Specifications Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." This operating license improvement was made available by the NRC on September 25, 2003 (68 FR 55416), as part of the consolidated line item improvement process.

J. Dent, Jr. A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RAJ Thomas J. Wengert, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298

Enclosures:

1. Amendment No. 264 to DPR-46

2. Safety Evaluation cc: Listserv

UNITED STATES WASHINGTON, D.C. 20555.0001 NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 264 Renewed 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 May 23, 2019, 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 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.

Enclosure 1

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 Renewed 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. 264, 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. Implementation of the amendment shall also include revision of the Technical Requirements Manual (TRM) as described in the licensee's letter dated May 23, 2019.

FOR THE NUCLEAR REGULATORY COMMISSION

/RAJ Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: January 28, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 264 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 COOPER NUCLEAR STATION DOCKET NO. 50-298 Replace the following pages of the Renewed 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.

Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.3-24 3.3-24 3.3-25 3.3-25

(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. 264, 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.

NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p ). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.

( 4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if Amendment No. 264

PAM Instrumentation 3.3.3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.3.1.1 Perform CHANNEL CHECK on each required PAM In accordance with Instrumentation channel. the Surveillance Frequency Control Program SR 3.3.3.1.2 [DELETED] [DELETED]

SR 3.3.3.1.3 Perform CHANNEL CALIBRATION of each required In accordance with PAM Instrumentation channel. the Surveillance Frequency Control Program Cooper 3.3-24 Amendment No. 264

PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED REQUIRED FROM REQUIRED FUNCTION CHANNELS ACTION 0.1

1. Reactor Pressure 2 E

2. Reactor Vessel Water Level

a. Fuel Zone 2 E

b. Wide Range 2 E

c. Steam Nozzle F

3. Suppression Pool Level (Wide Range) 2 E

4. Primary Containment Gross Radiation Monitors 2 F

5. PCIV Position 2 per penetration E flow path(a)(b)

6. [DELETED]

7. Primary Containment Pressure

a. Drywell Narrow Range 2 E

b. Drywell Wide Range 2 E

c. Suppression Chamber Wide Range 2 E

8. Suppression Pool Water Temperature 2(c) E (a) Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(c) A channel requires a minimum of four resistance temperature detectors (RTDs) to be OPERABLE with no two adjacent RTDs inoperable.

Cooper 3.3-25 Amendment No. 264

UNITED STATES WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 264 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated May 23, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19171A268), Nebraska Public Power District (the licensee) requested changes to the technical specifications (TSs) for Cooper Nuclear Station (Cooper or CNS). The proposed changes would delete the TS requirements related to the containment hydrogen and oxygen monitors. The proposed change supports implementation of the revisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, "Combustible gas control for nuclear power reactors," that became effective on October 16, 2003. This operating license improvement was made available by the U.S. Nuclear Regulatory Commission (NRC or the Commission) on September 25, 2003 (68 FR 55416) as part of the consolidated line item improvement process (CLIIP).

The NRC has revised 10 CFR 50.44. The amended standards eliminated the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002 (ADAMS Accession No. ML023530110), and May 12, 2003 (ADAMS Accession No. ML031350006), the Nuclear Energy Institute (NEI) Technical Specifications Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STS)

(NUREGs 1430-1434) on behalf of the industry to incorporate the amended standards. This proposed change is designated TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors."

The NRC staff prepared a model safety evaluation (SE) for the elimination of requirements regarding containment hydrogen recombiners and the removal of requirements from the TSs for containment hydrogen and oxygen monitors and solicited public comment as published in the Federal Register on August 2, 2002 (67 FR 50374), in accordance with the CLIIP. The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiner and hydrogen and oxygen monitor requirements from the TSs. Licensees of nuclear power reactors, to which this model SE applies, were Enclosure 2

informed in the Federal Register (68 FR 55416), that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of this SE to their reactors and provide the requested plant-specific verifications and commitments.

2.0 REGULATORY EVALUATION

2.1 System Description The hydrogen monitors are required to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered. The hydrogen monitors are needed to implement these severe accident management strategies.

Combustible gases produced by beyond design-basis accidents involving both fuel-cladding oxidation and core-concrete interaction would be risk-significant for plants with Mark I and II containments if not for the inerted containment atmospheres. If an inerted containment was to become de-inerted during a beyond design-basis accident, then other severe accident management strategies, such as purging and venting, would need to be considered. The oxygen monitors are needed to implement these severe accident management strategies.

Oxygen concentration also appears extensively in the emergency procedure guidelines/severe accident guidelines of plants with inerted containment atmospheres.

Post-accident hydrogen recombiners are not installed at Cooper. Therefore, that portion of TSTF-447 is not applicable to this amendment request.

2.2 Proposed TS Changes Surveillance Requirement (SR) 3.3.3.1.2 states "Perform CHANNEL CALIBRATION of the Primary Containment H2 [Hydrogen] and 02 [Oxygen] Analyzers." The licensee proposed deleting this SR SR 3.3.3.1.3 states "Perform CHANNEL CALIBRATION of each required PAM [Post-Accident Monitoring] Instrumentation channel except for the Primary Containment H2 and 02 Analyzers."

The licensee proposed deleting the phrase "except for the Primary Containment H2 and 02 Analyzers" from this SR Table 3.3.3.1-1, Function 6 is listed as "Primary Containment H2 & [and] 02 Analyzer." The licensee proposed deleting the title of the Function as well as the associated number of required channels and referenced conditions from the table.

Regulatory Issue Summary 2000-06, "Consolidated Line Item Improvement Process for Adopting Standard Technical Specifications Changes for Power Reactors" (ADAMS Accession No. ML003693442) was issued on March 20, 2000. The CLIIP is intended to improve the efficiency of NRC's licensing processes. This is accomplished by processing proposed changes to the STS in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STS following and either reconsiders the change or proceeds with announcing the availability of the change for proposed a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a

proposed change to the STS adoption by licensees. Those licensees opting to apply for the subject change to the TSs are responsible for reviewing the NRC staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information.

Each amendment application made in response to the notice of availability would be processed and noticed in accordance with applicable rules and NRC procedures.

The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. This regulation requires that the TSs include items in five specific categories.

These categories include ( 1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation (LCOs), (3) SRs, (4) design features, and (5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plant's license.

Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TS. These criteria are as follows:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

2. A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Existing LCOs and related surveillances included as TS requirements, which satisfy any of the criteria stated above, must be retained in the TSs. Those TS requirements, which do not satisfy these criteria, may be relocated to other licensee-controlled documents.

The NRC's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," was published in the Federal Register on July 22, 1993 (58 FR 39132). In reference to the four criteria listed in 10 CFR 50.36( c)(2)(ii), the Final Policy statement states, in part:

LCOs which do not meet any of the criteria below may be proposed for removal from the Technical Specifications and relocation to licensee-controlled documents, such as the FSAR [Final Safety Analysis Report].

The Final Policy statement further states, in part:

If a licensee elects to apply these criteria, the requirements of the removed specifications will be relocated to the FSAR or other licensee-controlled

documents. Licensees are to operate their facilities in conformance with the descriptions of their facilities and procedures in their FSAR. Changes to the facility or to procedures described in the FSAR are to be made in accordance with 10 CFR 50.59.

As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements for ensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from a metal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark Ill and ice condenser containments. The Commission eliminated the design-basis loss-of-coolant accident (LOCA) hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.

3.0 TECHNICAL EVALUATION

The ways in which the requirements and recommendations for combustible gas control were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the Three Mile Island (TMI), Unit 2 accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, "Clarification of TMI Action Plan Requirements," dated November 1980 (ADAMS Accession No. ML051400209), as obligations. The issuance of plant-specific amendments to adopt these changes, which would remove hydrogen recombiner and hydrogen and oxygen monitoring controls from the TSs, supersede the combustible gas control-specific requirements imposed by post-TMI confirmatory orders.

3.1 Hydrogen Monitoring Equipment Section 50 .44(b )( 1) of 10 CFR, the STS prior to incorporation of TSTF-447 changes and the plant-specific TSs, currently contain requirements for monitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item 11.F.1, of NUREG-0737 and NRC Regulatory Guide (RG) 1.97, Revision 5, "Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants," dated April 2019 (ADAMS Accession No. ML18136A762). 1 The hydrogen monitors are required to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered. The hydrogen monitors are needed to implement these severe accident management strategies.

With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are no longer required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. RG 1.97 Category 1 is intended 1 Prior to the issuance of Revision 4, RG 1.97 was entitled "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident."

for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events and, therefore, are items usually addressed within the TSs. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents. Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198, "Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)," found that the hydrogen monitors were not risk-significant. Therefore, the NRC staff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36( c)(2)(ii) for retention in Cooper's TSs and, therefore, may be relocated to other licensee-controlled documents.

The elimination of Post-Accident Sampling System requirements from some plant-specific TSs (and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.

On page 3 of Attachment 1 of the LAR, the licensee states that it "has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at CNS .... "

The licensee stated that the hydrogen monitor will be included in the Technical Requirements Manual (TRM) upon implementation of the license amendment. The NRC staff determined that any changes to the TRM will be adequately controlled under the provisions of 10 CFR 50.59, "Changes, tests and experiments." Therefore, removal of the hydrogen monitoring equipment from TSs and placement in the TRM is an acceptable change.

The deletion of the requirements for the hydrogen monitors resulted in deletion of TS Bases content for hydrogen monitors. The NRC staff has confirmed that the related changes are appropriate and do not affect the TS requirements.

3.2 Oxygen Monitoring Equipment The Cooper TSs currently require oxygen monitoring to verify the status of the inert containment. Combustible gases produced by beyond design-basis accidents involving both fuel-cladding oxidation and core-concrete interaction would be risk-significant for plants with Mark I and II containments if not for the inerted containment atmospheres. If an inerted containment was to become de-inerted during a beyond design-basis accident, then other severe accident management strategies, such as purging and venting, would need to be considered. The oxygen monitors are needed to implement these severe accident management strategies. Oxygen concentration also appears extensively in the emergency procedure guidelines/severe accident guidelines of plants with inerted containment atmospheres.

With the elimination of the design-basis LOCA hydrogen release, the oxygen monitors are no longer required to mitigate design-basis accidents and, therefore, the oxygen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends that, for inerted containment plants, the oxygen monitors be Category 1, which is intended for key variables that most directly indicate the accomplishment of a safety function for

design-basis accident events. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that Category 2, as defined in RG 1.97, is an appropriate categorization for the oxygen monitors, because the monitors are required to verify the status of the inert containment. Oxygen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Oxygen monitors have not been shown by a probabilistic risk assessment to be risk-significant. Therefore, the NRC staff finds that oxygen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and, therefore, may be relocated to other licensee-controlled documents.

On page 3 of Attachment 1 of the LAR, the licensee states that it "has verified that an oxygen monitoring system capable of verifying the status of the inert containment is installed at CNS .... "

The licensee also stated that the oxygen monitor will be included in the TRM upon implementation of the license amendment. The NRC staff determined that any changes to the TRM will be adequately controlled under the provisions of 10 CFR 50.59. In addition, requirements for primary containment oxygen concentration will be retained in TS 3.6.3.1, "Primary Containment Oxygen Concentration." The basis for retention of this requirement in TS is that it meets Criterion 2 of 10 CFR 50.36(c)(2)(ii) in that it is a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This is based on the fact that calculations included in the Cooper Updated Safety Analysis Report assume that the primary containment is inerted, that is, oxygen concentration less than 4.0 volume percent, when a design-basis LOCA occurs. Therefore, based on the placement of requirements for the oxygen monitoring system in the TRM and maintenance of primary containment oxygen concentration requirements in the TSs, removal of the oxygen monitoring equipment from Cooper's TSs is an acceptable change.

3.3 Variations from TSTF-447 In its application, the licensee identified five variations from the NRG-approved TSTF-447, due to differences between the Cooper TSs and the model TS in NUREG-1433, "Standard Technical Specifications, General Electric Plants BWR [Boiling Water Reactor]/4," Revision 2, which was in effect at the time. The variations are described on page 4 of Attachment 1 of the licensee's application. The NRC staff reviewed the variations and determined that they are editorial or administrative in nature and are, therefore, 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 on January 7, 2020. 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 and changes surveillance requirements. 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 Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on September 10, 2019 (84 FR 47548), and there has been no public comment on

such finding. 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) there is reasonable assurance that 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: M. Hamm T. Wengert Date: January 28, 2020

J. Dent, Jr.

SUBJECT:

COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 264 RE: ELIMINATION OF TECHNICAL SPECIFICATION REQUIREMENTS FOR HYDROGEN/OXYGEN MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2019-LLA-0128) DATED JANUARY 28, 2020 DISTRIBUTION:

PUBLIC PM File Copy RidsACRS_MailCTR Resource RidsNrrDssStsb Resource RidsNrrDorllpl4 Resource RidsNrrPMCooper Resource RidsNrrLAPBlechman Resource RidsRgn4MailCenter Resource MHamm, NRR ADAMS Access1on No. ML19352G194 *B*Y e-ma1 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/STSB/BC*

NAME TWengert PBlechman VCusumano DATE 1/10/20 1/13/20 11/22/19 OFFICE OGC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME Not required JDixon-Herrity TWengert DATE 1/27/2020 1/28/2020 OFFICIAL RECORD COPY