NLS2023029, License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks

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License Amendment Request to Revise Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks
ML23249A134
Person / Time
Site: Cooper Entergy icon.png
Issue date: 09/06/2023
From: Dia K
Nebraska Public Power District (NPPD)
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NLS2023029
Download: ML23249A134 (1)
v • d • e


Text

H Nebraska Public Power District "Alwuys there when you need us" 10 CFR 50.90 NLS2023029 September 6, 2023 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

License Amendment Request to Revise Cooper Nuclear Station Technical Specifications to Support Inspection of Diesel Fuel Oil Storage Tanks Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Dear Sir or Madam,

The purpose of this letter is for the Nebraska Public Power District (NPPD) to request an amendment to Facility Operating License DPR-46 in accordance with the provisions of 10 CFR 50.90 to revise the Cooper Nuclear Station Technical Specifications (TS). The proposed amendment would revise TS Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, to allow the use of temporary fuel oil storage tanks to supplement the required fuel oil storage inventory used by the emergency diesel generators. This TS change would be applicable during the 2024 Refuel Outage 33 while in Modes 4 or 5 to allow cleaning, inspection, and any needed repairs, of the permanent diesel generator fuel oil storage tanks. provides a description and assessment of the proposed change. Attachment 2 provides a list of compensatory measures. Attachment 3 provides the existing TS page marked up to show the proposed change. Attachment 4 provides the revised (clean) TS page. provides the existing TS Bases page marked up to show the associated TS Bases change and is provided for information only. Attachment 6 contains simplified system sketches.

Approval of the proposed amendment is requested by September 6, 2024. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments made in this submittal.

The proposed TS change has been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this application, with attachments, is being provided to the designated State of Nebraska Official. NPPD has concluded that the proposed change does not involve a significant hazards consideration and that it satisfies the categorical exclusion criterion of 10 CFR 51.22(c)(9).

If you should have any questions regarding this submittal, please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at (402) 825-5416.

COOPER NUCLEAR STATION 72676 648A Ave/ P.O. Box 98 / Brownville, NE 68321 http://www.nppd.com

NLS2023029 Page 2 of2 I declare under penalty of perjury that the foregoing is true and correct.

Executed On: q((,/ U '2- 3 Date Sincerely, Site Vice President

/dv Attachments: 1. Description and Assessment

2. Technical Specifications Compensatory Measures
3. Proposed Technical Specifications Change (Mark-up)
4. Revised Technical Specifications Page
5. Proposed Technical Specifications Bases Change (Mark-up) -

Information Only

6. Diesel Generator Fuel Oil Storage and Transfer System Simplified Sketches cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector w/ attachments USNRC- CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Li censure NPG Distribution w/ attachments CNS Records w/ attachments

NLS2023029 Page 1 of 17 Attachment 1 Description and Assessment Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 1.0 Summary Description 2.0 Detailed Description 2.1 System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change 3.0 Technical Evaluation 3 .1 Tank Maintenance Evolution Details 3.2 Temporary Fuel Oil Supply Configuration 3.3 Offsite Power System and Reliability 3.4 Defense-in-Depth Contingency Measures 3 .5 Seismic Considerations 3.6 Weather Considerations

3. 7 Beyond Design Basis FLEX Strategy Considerations 3.8 Safety/Security Evaluation 3.9 Human Factors Evaluation 3 .10 Compensatory Measures 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis 4.4 Conclusion 5.0 Environmental Consideration

NLS2023029 Attachment 1 Page 2 of 17 1.0

SUMMARY

DESCRIPTION Nebraska Public Power District (NPPD) requests to amend Operating License (OL) DPR-46 for Cooper Nuclear Station (CNS) on a one-time basis. The proposed change would amend the OL by revising the Technical Specifications (TS) to allow the use of temporary fuel oil storage tanks to supply part of the fuel oil inventory required for Diesel Generator (DG) operability. This change is desired to maintain operability of a DG with one diesel generator fuel oil (DGFO) storage tank drained in support of cleaning, inspection and any needed repairs of the permanent DGFO storage tanks. This activity is scheduled for the Fall 2024 Refuel Outage 33 and would only be allowed during Modes 4 or 5.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The CNS Standby AC Power System consists of two 4000 kW DGs. Each DG and its associated support systems is separated from the corresponding systems of the other DG. Each unit is operated independently of the other unit. The DGs provide a single failure proof source of onsite AC power adequate for maintaining the safe shutdown of the reactor following abnormal operational transients and postulated accidents.

A DG starts automatically on a loss of coolant accident signal or on a critical bus loss of voltage signal. After the DG has started, it automatically ties to its respective bus after offsite power has been lost to the critical bus. When the DG circuit breaker closes, loads are then sequentially connected to its respective critical bus. The emergency loads are divided between the two 4160 volt critical buses so that the failure of one DG or one 4160 critical bus does not prevent a safe shutdown of the reactor.

Each DG unit is supplied from its own fuel oil day tank. Cross-ties are provided such that both day tanks can be supplied from either of two DGFO storage tanks, each with its own transfer pump and piping connections. Each DG unit day tank provides enough fuel to allow a minimum of 3 .9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of full load operation. Both DGFO storage tanks combined contain sufficient fuel for seven days operation of one DG at its rated continuous load of 4000 kW. The fuel oil level equivalent to a 7-day supply is 49,500 gallons. The minimum volume was determined based on the recommendations of Regulatory Guide 1.13 7, Revision 1, regulatory position C.1.c and ANSI Nl 95-1976 and includes margin for the unusable volume in the DGFO storage tanks.

Each diesel fuel oil transfer pump provides sufficient fuel flow to one diesel engine to meet consumption requirements. To support continuous DG operation at full load, each transfer pump must be capable of delivering greater than or equal to 4.64 gallons per minute (gpm).

NLS2023029 Attachment 1 Page 3 of 17 2.2 Current Technical Specifications Requirements DG fuel oil requirements are in Limiting Condition for Operation (LCO) 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air. Specifically, Surveillance Requirement 3.8.3.1 verifies the DGFO storage tanks contain a combined volume of greater than or equal to a 7-day supply of fuel.

LCO 3.8.3, Condition A is entered when fuel oil supply is less than 7 days but greater than 6 days. The Required Action is to restore fuel oil level to within limits with the Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. If the Completion Time is not met, Condition F is entered which requires immediately declaring both DGs inoperable.

Both DGs are immediately declared inoperable per Condition F, when fuel oil supply is less than a 6-day supply.

LCO 3.8.2, AC Sources - Shutdown, requires one offsite transmission network and one DG to be operable in Modes 4 and 5, and during movement of irradiated fuel assemblies in the secondary containment. If the fuel oil inventory requirements are not met, the required DG would be declared inoperable. Per Condition B, core alterations and movement of irradiated fuel assemblies are suspended, and immediate action initiated to restore DG to operable status.

Per Surveillance Requirement 3.8.2.1, the automatic start feature of the required DG is not required to be operable. Manual start is allowed for an operable DG in Modes 4 and 5. This was approved for CNS in Amendment 270 that adopted TSTF-582, Reactor Pressure Vessel Water Inventory Control Enhancements. However, standard practice in past outages has been to maintain the automatic start feature operable for the required DG.

2.3 Reason for the Proposed Change The DGFO storage tanks require periodic cleaning and examination under the License Renewal Buried Piping and Tanks Inspection Program (ADAMS Accession Number ML101310605) and Diesel Fuel Monitoring Program (ADAMS Accession Number ML083030225) to manage aging effects regarding the potential for loss of material due to various forms of corrosion. CNS Engineering Evaluation 11-037, Revision 0, establishes a 20-year inspection interval based on vendor tank thickness and corrosion rate evaluations. The previous inspection was completed in 2004.

CNS plans to perform the next DGFO storage tank internal inspection during Refuel Outage 33.

Activities to drain, clean, inspect and potentially repair the DGFO storage tanks will reduce the stored diesel fuel oil in the permanent storage tanks to below the current CNS TS limits for an operable DG. It is estimated the required draining, cleaning, inspection, and refilling of both DGFO storage tanks will take approximately fourteen days. The requested change is to support completion of the required DGFO storage tank examinations concurrent with the planned and scheduled execution of Refuel Outage 33.

NLS2023029 Attachment 1 Page 4 of 17 2.4 Description of the Proposed Change A temporary note is added to TS 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air to allow the use of temporary fuel oil storage tanks, in conjunction with the permanent DGFO storage tanks, to meet the fuel oil inventory requirements specified in SR 3.8.3.1. The note would require a temporary transfer pump, hoses and appropriate fittings be available during the maintenance activity. This one-time TS change is applicable only during the 2024 Refuel Outage 33 with the reactor in Mode 4 or 5.

The TS Bases Change for TS 3.8.3 is included in Attachment 5 for information only and will be implemented in accordance with the TS Bases Control Program.

3.0 TECHNICAL EVALUATION

3 .1 Tank Maintenance Evolution Details During Refuel Outage 33, each of the two buried DGFO storage tanks will be taken out-of-service one at a time and drained to perform License Renewal committed inspections. At least one of the two tanks will remain in-service at all times.

Technical Specification 3 .8.2, AC Sources - Shutdown, requires one qualified offsite circuit and one DG to be operable and capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem in Modes 4 and 5. During Refuel Outage 33, at separate times, each DG will be removed from service for a planned maintenance window. At all times at least one DG will remain operable during the DGFO storage tank inspection evolution. Both qualified offsite power sources are planned to remain operable during the tank cleaning evolution which is one more offsite source than required by TS 3 .8.2.

During each individual tank cleaning and inspection activities, the affected storage tank and transfer pump will be isolated from the system. Part of the fuel will be transferred from the isolated tank to the in-service permanent storage tank to establish a minimum volume which supports at least 4 days of DG operation at full load. The remaining fuel will be transferred to a temporary storage tank and as necessary, a temporary overflow tank.

By maintaining one permanent DGFO storage tank in-service at all times, with additional temporary storage tanks and fuel oil transfer equipment, and implementation of compensatory measures, CNS will maintain one required DG operable and ensure shutdown risk is maintained at an acceptable level during the DGFO storage tank inspection evolution.

3 .2 Temporary Fuel Oil Supply Configuration During the tank maintenance evolution, which includes draining and refilling the permanent DGFO storage tanks, the TS' minimum 49,500 gallons of diesel fuel oil will be available in the two permanent DGFO storage tanks and the temporary storage tanks. The operable DG will be supported by an in-service diesel fuel oil system consisting of one permanent safety related DGFO storage tank and one divisional fuel oil transfer pump connected to the associated

NLS2023029 Attachment 1 Page 5 of 17 divisional DG day tank located within the Diesel Generator Building. This configuration will maintain at least 4 days of diesel fuel oil. An additional 3 days of fuel oil will be maintained in a combination of the out-of-service permanent DGFO storage tank and temporary DGFO storage tanks with associated fuel transfer equipment located inside the CNS Protected Area (PA). , Figure 1 is a site sketch which shows the laydown areas for the temporary equipment. Attachment 6, Figure 4 is a simple sketch of the temporary storage tank/equipment configuration.

The temporary tanks are called FRAC tanks and are nominally rated at 18,000 gallons each and are of double-walled construction. The FRAC tanks will supplement the in-service permanent DGFO storage tank to provide sufficient capacity for the operation of one DG for 7 days at rated load.

Prior to removing either permanent DGFO storage tank from service, CNS will verify the temporary fuel oil storage system is staged and can contain and provide at least a 3-day supply of fuel oil to the permanent DGFO storage tank. In addition, CNS will verify the in-service fuel oil storage tank contains at least a 4-day supply of fuel oil prior to transferring fuel oil from the tank to be cleaned/inspected to the temporary storage tanks.

During the period of time a permanent DGFO storage tank is not in service because of cleaning and inspection activities, elective maintenance and testing that affects operability of the required DG is not permitted. In addition, every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during this time period, CNS will verify the permanent DGFO storage tanks and temporary DGFO storage tanks combined contain at least a 7-day supply of fuel oil.

Pressure-tested hoses are to be used for fuel transfers to minimize the possibility of a hose rupture. Filtering equipment will remove particulates to ensure the Specification 5.5.9, Diesel Fuel Oil Testing Program, fuel oil total particulate concentration requirement ofless than or equal to 10 mg/I is met. The fuel oil will be filtered when the permanent storage tank is drained and when it is refilled.

In the event of a DG start during the tank cleaning evolution, temporary pump/filter equipment, independent of electrical power sources, that is in place to perform the maintenance activities, will be configured to transfer the off-loaded fuel oil to the in-service permanent storage tank. If a DG start occurs during the draining or refilling evolution, some fuel oil may reside in the out-of-service storage tank. In this event, the temporary pump/filter equipment can be configured to transfer remaining fuel oil from the temporary storage tanks to the in-service permanent storage tank or configured to transfer fuel oil from the out-of-service storage tank to the in-service permanent storage tank. The temporary equipment will have a transfer capacity in excess of the DG fuel consumption rate. A back-up pump with a similar capacity will be pre-staged in the event of a failure of the primary pump/filter equipment. The vendor equipment to be used for this project have a capacity sufficiently greater than 100 gpm.

Work instructions to restore fuel oil to the permanent storage tank, in the event of a DG start, will be incorporated into an approved procedure. Training, briefings, and walkthroughs in accordance with station procedures, as appropriate, to implement the work instructions will be

NLS2023029 Attachment 1 Page 6 of 17 provided prior to the start of the tank cleaning and inspection activities. The tank cleaning and inspection activities will be worked on a 24 hour/day, seven day/week basis. Personnel will be continuously available to implement actions necessary to ensure adequate fuel oil is supplied to the DG, if needed. Station processes will be utilized for shutdown risk, foreign material control and protected equipment.

3.3 Offsite Power System and Reliability (Attachment 6, Figures 2 and 3)

The offsite power sources at CNS are a startup station service transformer (SSST) which connects to the CNS 161 kV switchyard and the 345/161 kV, 300 MVA auto-transformers connected to the 345 kV switchyard, and a separate emergency station service transformer (ESST) energized by a 69 kV line connected to a 161/69 kV, 56 MVA auto-transformer in the 161 kV switchyard or the 69 kV subtransmission system.

The 161 kV switchyard is connected to one 161 kV line which terminates in a switchyard near Auburn, Nebraska, and two 345/161 kV, 300 MVA auto-transformers which connect to the CNS 345 kV switchyard. The 345 kV switchyard has five (5) lines which terminate in switchyards near Tarkio, Missouri; Hallam, Nebraska; St. Joseph, Missouri; Fairport, Missouri, and Nebraska City, Nebraska.

During plant Modes 4 and 5, the station is normally supplied from the SSST, which energizes 4160 volt buses lA and 1B (non-critical buses) as well as their connected loads, including the critical buses. If the SSST fails to energize the critical buses, the ESST, which is normally energized, will automatically energize both critical buses. If the ESST were also to fail, the DGs would automatically start or be manually started, to energize their respective buses.

The unavailability of the ESST and the SSST are monitored by Maintenance Rule functions over the previous 36 months. As of June 2023, the ESST unavailability was 0.68 percent, and the SSST unavailability was 0.12 percent. A review of the previous 20 years identified one event where both offsite power sources were inoperable. CNS Licensee Event Report 2010-003 documents the event where both the ESST and SSST were declared inoperable. During scheduled maintenance that involved the SSST, a low voltage condition occurred on 8/24/2010 on the 69 kV offsite power supply to the ESST. At the same time that the low voltage occurred, personnel were isolating the T2 Auto Transformer from the grid. Subsequently, offsite voltage to the ESST dropped below the level where the essential 4160 volt buses are automatically prevented from loading on the ESST. The event lasted 2 minutes. Voltage response was monitored and adjusted by Doniphan Control Center. A review of internal operating experience found the voltage drop in the 69 kV line was an expected consequence of switching over from the 161 kV line. No evidence was found that indicates this was a grid perturbation caused by any unusual activities on the grid, such as storms, malfunctioning equipment, dropped line, etc.

During that period the emergency buses were supplied by normal power and the unit did not trip.

The CNS 161 kV switchyard and 69 kV supplies have since been upgraded to a more robust design with added redundancy.

NLS2023029 Attachment 1 Page 7 of 17 3.4 Defense-In-Depth Contingency Measures Both qualified offsite power sources are planned to remain operable during the tank cleaning evolution which is one more offsite source than required by TS 3.8.2.

A mobile fuel tanker with approximately 7000 gallons of fuel is maintained on the CNS Owner Controlled Area as a holding tank for fuel deliveries. This tanker has the capability to supply fuel to the in-service permanent storage tank and supports greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of full load operation for one DG. Work instructions for off-loading the mobile tanker into the permanent storage tanks exist in an approved procedure. Additionally, work instructions exist in an approved procedure to off-load the mobile tanker directly into the DG day tank when the fuel transfer system is unavailable concurrent with a loss of offsite power. This fuel tanker is considered available as an additional defense in depth fuel source for the DGs.

The permanent DGFO storage tanks and the temporary DGFO storage tanks associated with the tank cleaning and inspection activities are located in the southeast comer of the PA. The mobile fuel tanker which is currently maintained on site to support refilling of the DGFO storage tanks is located outside the southwest comer of the PA. This provides a diversity of locations for fuel supporting a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of full load DG operation.

Replenishment of fuel oil from offsite, if necessary, can be accomplished in approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using existing fuel oil suppliers.

The manual actions required to ensure a 7-day supply of fuel oil are performed outside the reactor building. The additional defense-in-depth strategies ensure that fuel oil will be supplied to the DGs for the required 7 days.

CNS has a Supplemental Diesel Generator (SDG) that provides another level of defense-in-depth. The SDG is rated at 3250 kW, 4160 volts, and can be connected to one of the two essential busses within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The SDG is available as a defense-in-depth alternate source of AC power to one emergency bus to mitigate a station blackout event during a loss of offsite power. The SDG has its own separate fuel system and can carry the selected loads for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without refueling.

3 .5 Seismic Considerations The temporary tank installation is not intended to be a Class I Safety-Related installation and is not intended to be capable of functioning during a seismic event. The temporary equipment is located such that the temporarily stored volume of fuel oil will remain available after a seismic event, as the tank is not expected to suffer catastrophic damage due to an earthquake because the expected seismic input is judged insufficient to result in a rupture of the tank. The pumping equipment will not be connected to Safety-Related power supplies. Transfer hoses will not be connected to the in-service permanent DGFO storage tank, unless needed to mitigate a loss of power event. If necessary, flexible transfer hoses will be connected between the temporary storage tank and the in-service permanent DGFO storage tank to replenish the in-service supply

NLS2023029 Attachment 1 Page 8 of 17 to an operating DG. The volume of fuel oil in the temporary tanks represents a portion of the total stored volume of the fuel required to support the 7-day fuel oil mission time for an in-service DG under Design Basis Accident conditions. This portion of fuel is not required to be available to the operating DG for at least 4 days since the in-service permanent DGFO storage tank will be filled to maximum capacity.

The temporary tanks and pumping equipment will be placed within the PA of the site. The general location will be between the Missouri River and Turbine Building. This area of the plant during construction has been excavated and replaced with engineered fill material up to the 902 mean sea level elevation. The lower portion of the fill is general fill, which consist of a clean mineral soil compacted to 90% density utilizing a modified proctor test. The location where the tanks will be positioned has a layer of structural fill. This structural fill is what has been utilized around CNS' s Class I structures and has been shown to resist liquefaction and seismic amplification during a hypothetical earthquake. The compacted general fill is expected to behave similarly in an earthquake as cohesive soils have smaller particle size and lower void ratios. Due to the lack of seismic amplification, the expected seismic input to the temporary equipment is expected to be low, such that the temporary components are not expected to be significantly damaged by hypothetical seismic events.

Since the engineered fill does not amplify ground motion, the maximum seismic input to the temporary equipment would be the .20g safe shutdown earthquake condition.

The temporary storage tanks are not planned to be anchored to the ground. The input seismic accelerations are judged to be insufficient to cause significant lateral displacement of the tanks.

No horizontal accelerations sufficient to cause overturning of the tank is expected to occur.

There will be no hard piping connections that could be damaged by differential movements by an earthquake. As such, no anchorage of the temporary tanks is considered necessary.

3 .6 Weather Considerations The DGFO storage cleaning and inspection will be performed during Refuel Outage 33 which is scheduled for October 2024. During this time of year, the area around CNS generally experiences moderate weather conditions. Thunderstorms are not frequent but are possible during October, with tornados and ice storms being rare. The permanent fuel oil storage tanks and transfer pumps are located in bunkers, therefore, are protected from severe weather hazards.

The temporary storage tanks are made of a double-wall design but are not considered missile-protected. CNS will monitor the local area for severe thunderstorm and tornado warnings prior to commencing the offload of fuel oil from each DGFO storage tank.

The temporary storage tanks will be located on the grade level of the reactor site. Local flooding is not normally an issue during October, however, this elevation is sufficient to protect the temporary equipment from any challenges presented by local flood waters.

NLS2023029 Attachment 1 Page 9 of 17 If a DG start occurs, local weather conditions will be frequently monitored to identify appropriate timeframes within the weather forecast to refill the in-service permanent DGFO storage tank. Actions will be taken to secure the fuel transfer equipment filter/pump systems, hoses, etc., in the event of severe weather. Duplicates of key pieces of equipment, e.g., fuel transfer pumps and hoses, will limit the impact of the effects of any potential severe weather on the pumping circuit between the temporary tanks and the in-service permanent DGFO storage tank.

In the unlikely event of severe weather that causes a loss of offsite power and damage to the temporary storage equipment, the operable DG would automatically start or be manually started, to provide power to the associated essential bus for a period of four days. During the four days post-event, action would be taken to restore the temporary storage equipment, and to implement defense-in-depth strategies which include the SDG, 7000-gallon mobile fuel tanker, and the replenishment of fuel from an offsite vendor.

3. 7 Beyond Design Basis FLEX Strategy Considerations The Diverse and Flexible Coping Strategies (FLEX) Equipment are required in all modes of reactor operation. The coping strategies do rely on the DGFO as a source of fuel. However, by maintaining one DGFO storage tank in service at all times, the fuel oil inventory needed and the process for transferring the fuel oil to FLEX equipment, are not impacted.

The temporary fuel oil storage tanks and equipment will be located in the southeast comer of the PA. This location is a travel path around the CNS Machine Shop and south Turbine Building.

Severe accident guidelines include this area as an injection path using the Condensate Storage Tank as a source of water. The location of the temporary fuel oil storage tanks and associated equipment will not block this pathway. In the case of a beyond design basis event, there is sufficient space to allow for debris removal and setup of the injection path hoses and pump.

3.8 Safety/Security Evaluation 10 CFR 73.58 requires licensees to assess and manage the potential adverse effects on safety and security, including the site emergency plan, before implementing changes to plant configurations, facilities conditions, or security. CNS Procedure 0-SEC-INTERFACE was used to assess the impact of this maintenance activity on safety and security.

CNS License Renewal commitment requires periodic visual inspections and cleaning of the DGFO Storage Tanks. Vendors will be assisting CNS with this project. The equipment to be staged includes two temporary tanks and a laydown area for pumps, hoses, filters, and other support equipment. Three areas will be needed of approximately 12'X 50' and 12.5' high in size and located in the Southeast comer and East side of the plant contained within the PA boundary near the DGFO Storage Tanks. Each DGFO Storage Tank will be offloaded, fuel filtered, and stored in two nearby double-walled temporary tanks (8'W X 35'L X 12.5'H) (18,000-gal capacity ea.). The fuel oil will be stored in the temporary tanks for approximately 7 days per each divisional window. The DGFO Storage Tanks will then be cleaned, inspected by the

NLS2023029 Attachment 1 Page 10 of 17 vendor, repaired as necessary, and refilled. This evolution will be performed for each tank during their respective maintenance windows during Refuel Outage 33.

The project to clean and inspect the DGFO Storage tanks, including all equipment laydown areas will be located within the PA boundary. The two temporary tanks and associated equipment will be located an estimated distance of 21 feet from the adjacent buildings to provide sufficient standoff distances. The determined standoff distance for all structures using the guidance of NFPA 30-2015 is five feet. The five-foot minimum standoff distance will also be applied to the adjacent bullet resistant enclosures (BRE), as current staging locations are approximately fifteen feet from the BREs. Each temporary tank is also a double-walled carbon steel tank. Both tanks and the associated equipment will be placed in a berm system to contain fuel in the event that a leak does occur. CNS' work document includes steps to notify security prior to staging equipment inside the PA and in the potential event of a fuel leak or fire in order to evaluate the condition.

Each of the two tanks and the associated equipment will be arranged to best support the project but also to minimize impact on both the field of fire and normal security operations. The proposed locations of the temporary tanks and the associated equipment will be located within the PA boundary in a manner to not affect normal security operations. At the identified locations, no disruption to field of fire and no impacts to intrusion detection monitoring capability will occur.

The Fire Protection group has reviewed the placement of temporary above ground storage tanks that will be used to store diesel fuel near the southeast comer of the Turbine Building. The storage tanks are double-walled, have an approximate volume of 18,000 gallons and are provided with a relief valve that has relief setting of 1.0 psi and 0.025 psi vacuum setting. Using the guidance ofNFPA 30-2015, it is recommended the storage tank be maintained a minimum of five feet from other structures. This guidance is per NFP A 30, section 22.4, "Location of Aboveground Storage Tanks", using tables 22.4.1.1 (a) and 22.4.1.1 (b ). The minimum standoff distances account for the Owner Controlled administrative fire protection controls to prevent ignition in the area of the storage tanks as well as fire brigade mitigation. The permanent fuel tank cleaning activity will be performed continuously, i.e. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, and therefore the temporary tanks will be monitored by project personnel while filled in the PA. Planned work processes will ensure adequate industrial safety measures are taken to minimize the risk of fires during the inspection and eliminate ignition sources through activities such as properly grounding temporary equipment to prevent fuel oil fires and utilizing a berm or catch basin around the temporary tanks. Therefore, placing the subject temporary tanks at or beyond the NFP A 30-2015 recommended standoff distance of five feet provides assurance the temporary tanks do not create a substantial increase in risk to Security structures or protective strategies.

The subject tanks will retain a volume of standard #2 diesel fuel oil at approximately atmospheric pressure, as controlled by the described relief valve settings. Diesel fuel oil develops combustible vapor above the flashpoint of l 25°F to 180°F. The activity will be performed in October 2024 and thus during cooler fall temperatures during which the tank contents will not reach temperatures of 125°F. Therefore, the subject tanks will not develop

NLS2023029 Attachment 1 Page 11 of 17 significant vapors and as such, a tank BLEVE or explosion are not credible events during the proposed activity.

Security conducted a walkdown with Engineering and verified that the laydown will not change or decrease the effectiveness of the NRC approved Security Plan. It will not invalidate the security protective strategy (e.g., communications, response timelines and pathways), equipment and systems (particularly target sets), or protected fighting positions and fields of fire. Current laydown of the tanks and equipment will not impact interior and exterior sensors, zone of detection and field of view, alarm communications, or access control systems or assessment functions. Laydown of the tanks and equipment will not impact the PA or Isolation Zone from a hardened security defensive position or obstruct security.

In summary, placing the subject temporary tanks beyond the NFPA 30-2015 recommended standoff distance of five feet provides assurance the temporary tanks and equipment do not create a substantial increase in risk to Security structures or protective strategies. The staging of the tanks and equipment will not disrupt field of view for BREs and there will be no impact to intrusion detection monitoring capability, vital areas, target sets and security protective strategy.

Implementation of the Emergency Plan is not impacted by the proposed temporary change. The ability to assess and classify events is not impacted. The emergency response functions of the Main Control Room and primary Technical Support Center, including offsite communications, are not affected. The proposed temporary change does not affect emergency response necessary to prevent or mitigate postulated design basis accidents, and to protect public health and safety.

3.9 Human Factors Evaluation CNS has two interconnected permanent DGFO Storage Tanks, each with capacity for approximately four days of diesel engine operation. One permanent storage tank will be isolated and removed from service for the inspection evolution while the other permanent DGFO storage tank remains in service with at least four days of diesel fuel oil. Temporary fuel oil storage tank( s) and a portable fuel oil transfer pump will be staged to allow offloading the temporary tank into the in-service permanent DGFO storage tank.

The inspection evolution will be conducted in accordance with work documents and special procedures implementing maintenance and operator actions. These actions will include:

  • Monitoring fuel level (volume) in the permanent and temporary storage tanks (FRAC tanks). Monitoring the permanent DGFO storage tank level is performed by Operations once per shift while a DG is in standby and DG day tank level is checked approximately every two hours while a DG is in service. Temporary storage tank level will be monitored in accordance with station procedure for confirming diesel fuel oil availability.

As this is passive monitoring and effectively the same action that currently exists, no timing analysis is performed.

NLS2023029 Attachment 1 Page12of17

  • Receiving new fuel oil shipments to the in-service permanent DGFO storage tanks. This is the normal process performed by Operations for both standby and emergency conditions. No timing analysis is performed as it is mostly dependent upon the travel time of the fuel oil supplier.
  • Transferring fuel oil from the temporary storage tanks to the required DG in-service permanent DGFO storage tank to ensure an onsite 7-day fuel supply will be accomplished by routing a discharge hose from a portable fuel oil transfer pump which takes suction on the temporary tanks, or the out-of-service tank, to transfer fuel oil to the required DG in-service permanent DGFO storage tank. The fuel tank cleaning vendor will provide personnel for continuous support of fuel oil transfer from the temporary tanks at CNS Operations direction.
  • A timing analysis for transferring fuel oil from the temporary tanks to the in-service permanent DGFO storage tank using the planned special procedures and temporary equipment staging resulted in the following timeline:

o Two operators and vendor personnel report to the temporary tanks where the portable fuel oil transfer pump and transfer hoses are located - approximately 5 minutes. During a refuel outage, additional operators are available to assist the operating crew.

o The operators work with vendor personnel to route the transfer hoses from the transfer pump to the in-service permanent DGFO storage tank connection -

approximately 30 minutes.

o In parallel, one operator proceeds to the required DG room to monitor permanent DGFO storage tank level while the second operator prepares to operate or direct operation of the portable fuel oil transfer pump - approximately 10 minutes.

o The portable fuel oil transfer pump is started, and filling commences -

approximately 5 minutes.

o Therefore, approximately 50 minutes will be needed to commence filling the in-service permanent DGFO storage tank.

The fuel transfer evolution will be directed when the in-service permanent DGFO storage tank level is at approximately 7 feet and will continue until level is raised above 9.5 feet, equating to approximately 8100 gallons. This is estimated to take approximately 81 minutes based on conservatively assuming 100 gpm flow rate from a portable transfer pump. The CNS permanent diesel fuel oil transfer pumps fill the required DG day tank at less than 15 gpm, therefore the storage tank fill time will not significantly differ in standby versus engine operating conditions.

Permanent DGFO storage tank level of 7 feet equates to 18,910 gallons usable volume or approximately three days of DG full load operation. Therefore, based on the above

NLS2023029 Page 13 of 17 considerations, the time duration to refill the in-service permanent DGFO storage tank is within the approximately three-day supply of fuel oil available for the required DG and provides sufficient time to recover from potential errors and unexpected equipment failure.

3 .10 Compensatory Measures The proposed Note to the Specification 3.8.3 ACTIONS states, "This allowance is contingent upon meeting the compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029." The project for cleaning, inspection, and potential repair of the DGFO storage tanks, has identified certain compensatory measures to be implemented to ensure operability and maintain safety. These compensatory measures are listed in Attachment 2.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

1. CNS was licensed to the 1967 Proposed General Design Criteria (GDC). However, as described in the Updated Safety Analysis Report, Appendix F, CNS is committed to the GDC 17, "Electric Power Systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," which requires, in part, that nuclear power plants have onsite and an offsite electric power systems to permit functioning of structures, systems, and components important to safety. In addition, Criterion 17 contains requirements concerning system capacity, capability, independence, redundancy, availability, and testability.
2. Regulatory Guide (RG) 1.137, "Fuel-Oil Systems for Standby Diesel Generators,"

Revision 1, indicates that the requirements for the design of fuel-oil systems for diesel generators that provide standby electrical power included in ANSI Nl 95-1976, "Fuel Oil Systems for Standby Diesel Generators," provide a method acceptable to the NRC staff for complying with the pertinent requirements of GDC 17.

3. RG 1.13 7 provides a discussion of the two methods for calculation of fuel oil storage requirements set forth in Section 5.4 of ANSI Nl 95-1976. The two methods are (1) calculations based on the assumption that the diesel generator operates continuously for 7 days at its rated capacity, and (2) calculations based on the time-dependent loads of the diesel generator. For the time-dependent load method, the minimum required capacity should include the capacity to power the engineered safety features.
4. 10 CFR 73.55(e)(7)(i)(B) requires the isolation zone to be monitored with intrusion detection equipment and be capable of detecting both attempted and actual penetration of the protected area perimeter barrier before completed penetration of the protected area perimeter barrier.

NLS2023029 Attachment 1 Page 14 of 17

5. 10 CFR 73.55(e)(9)(ii), "Vital areas," states the licensee shall protect all vital area access portals and vital area emergency exits with intrusion detection equipment and locking devices ... "
6. 10 CFR 73.55(f)(l), "Target sets," requires the licensee to document and maintain the process used to develop and identify target sets, to include site-specific analyses and methodologies used to determine and group the target set equipment or elements.
7. 10 CFR 73.55(0), "Compensatory measures," states the licensee shall identify criteria and measures to compensate for degraded or inoperable equipment, systems, and components. The compensatory measures must provide a level of protection that is equivalent to the protections that was provided by the degraded or inoperable equipment, system or components and must be implemented within specific time frames.
8. 10 CFR 73.58(b) and (d) require licensees to assess and manage the potential adverse effects on safety and security, including site emergency plan, before implementing changes to plant configurations, facilities conditions, or security. Where potential conflicts are identified, the licensee shall communicate them to appropriate personnel and take compensatory and/or mitigative actions to maintain safety and security.

4.2 Precedent

1. Letter to Northern States Power Company - Minnesota, from USNRC, dated December 27, 2022, "Monticello Nuclear Generating Plant - Issuance of Amendment No. 209 RE:

IO-Year Inspection of the Diesel Generator Fuel Oil Storage Tank (EPID L-2021-LLA-0231 )"

This letter issued Amendment 209 to Operating License DPR-22. The amendment allowed the common DGFO storage tank to be out of service for up to 14 days to complete the inspection of the tank. It also approved the use of temporary storage tanks to maintain operability of the required emergency diesel generator during DGFO storage tank maintenance.

2. Letter to Nebraska Public Power District, from USNRC, dated October 15, 2004, "Cooper Nuclear Station - Issuance of Amendment RE: One-Time Extension of Diesel Generator Allowed Outage Time From 7 Days to 14 Days (TAC No. MC3770)"

This letter issued Amendment 207 to Operating License DPR-46. This amendment approved a one-time extension of the allowed outage time for one DG inoperable from 7 days to 14 days for the purpose of cleaning and recoating the permanent DGFO storage tanks. It also approved the use of temporary fuel oil storage tanks to supply the required fuel oil storage inventory to maintain a DG operable.

Both precedents approved the use of temporary fuel oil storage tanks to meet the inventory requirements of TS Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, for Diesel

NLS2023029 Page 15 of 17 Generator operability. This license amendment request is proposing to use a similar temporary fuel oil storage tank and transfer system design as that approved in Amendment 207 for CNS.

The main difference is that NPPD is performing the tank maintenance during a refuel outage, whereas Amendment 207 approved the use of temporary storage tanks during Mode 1. Since this license amendment request is proposing a temporary note that limits the applicability to Modes 4 or 5, an extension of the allowed outage time for a DG in Mode 1 is not required.

4.3 No Significant Hazards Consideration Determination Analysis Nebraska Public Power District (NPPD) is requesting to amend Operating License (OL) DPR-46 for Cooper Nuclear Station (CNS) on a one-time basis. The proposed change would amend the OL by revising the Technical Specifications (TS) to allow the use of temporary diesel generator fuel oil (DGFO) storage tanks to supply part of the fuel oil inventory required by TS Section 3.8.3, "Diesel Fuel Oil, Lube Oil, and Starting Air" for Diesel Generator (DG) operability. This change is desired to maintain operability of a required DG with one permanent DGFO storage tank drained in support of cleaning, inspection, and any needed repairs of the permanent DGFO storage tanks. This activity is scheduled for Fall 2024 during Refuel Outage 33 and would only be allowed during Modes 4 or 5.

NPPD has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change will allow the use of temporary fuel oil storage tanks to supply part of the fuel oil inventory required for DG operability. This is needed to support the cleaning, inspection, and any needed repairs of the permanent DGFO storage tanks.

The DGs provide onsite electrical power to vital systems should offsite electrical power be interrupted.

The DGs are used to mitigate the consequences of an accident and are not accident initiators. Since the DGs are not accident initiators, the proposed change does not increase the probability of an accident previously analyzed.

The proposed change does not affect the function of equipment assumed in the plant safety analyses for accident mitigation. The required DG in Modes 4 and 5 is still available to be started with a four-day supply of fuel oil in the available permanent storage tank supplemented by a three-day supply of fuel oil in the temporary tanks and out-of-service tank. Manual actions contained in approved procedures will be implemented to provide fuel oil from the temporary tanks to the operable DG. The

NLS2023029 Page 16 of 17 probability of failure to implement the contingency action is sufficiently low that it does not adversely impact the availability of the required DG.

The vulnerability to external events, seismic, high winds, and fire, was judged to be not significant due to the low probability of these events occurring during the period of time this proposed change will be in effect, and the defense in depth strategies being put in place during the tank maintenance activities.

In the event fuel stored in the temporary tanks is not available to support full load operation of the DG beyond four days, replenishment of fuel oil from offsite can be accomplished in approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using existing purchase orders for fuel oil and diesel fuel analysis.

During the use of temporary fuel oil storage tanks, there is no significant increase in the consequences of an accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change will allow the use of temporary fuel oil storage tanks to supply part of the fuel oil inventory required for DG operability. The required DG in Modes 4 and 5 is still available to be started as designed with a four-day supply of fuel oil in the available permanent storage tank supplemented by a three-day supply of fuel oil in the temporary tanks and out-of-service tank. Operation in this configuration does introduce proceduralized contingency actions to supply fuel oil from the temporary storage tanks.

These actions can be accomplished within the four days of full load diesel operation from fuel stored in the in-service fuel oil storage tank. The probability of failure to implement the contingency actions is sufficiently low that it does not adversely impact the ability of the DG to perform its design function. There are no new accident precursors generated due to the use of temporary fuel oil storage tanks.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change will allow the use of temporary diesel fuel oil storage tanks to supply part of the fuel oil inventory required for DG operability. The required DG in

NLS2023029 Attachment 1 Page 17 of 17 Modes 4 and 5 is still available to be started as designed with a four-day supply of fuel oil in the available permanent storage tank supplemented by a three-day supply of fuel oil in the temporary tanks and out-of-service tank.

The proposed change does not adversely affect any current plant safety margins, or the reliability of equipment assumed in the safety analysis. There are no changes being made to any safety analysis assumptions, safety limits, or limiting safety systems that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NPPD concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92( c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (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.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22( c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

NLS2023029 Page 1 of 1 Attachment 2 Technical Specifications Compensatory Measures Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Description Due Date/Event

1. Work instructions to restore off-loaded fuel oil Prior to removing either permanent to the permanent diesel generator fuel oil DGFO storage tank from service.

(DGFO) storage tank, in the event of a DG start, and work instructions to accomplish the defense in depth measures are incorporated into an approved procedure.

2. Training, briefings and walkthroughs, in Prior to removing either permanent accordance with station procedures, to DGFO storage tank from service.

implement the work instructions are provided.

3. Verify the temporary fuel oil storage system is Prior to removing either permanent staged and can contain at least a 3-day supply of DGFO storage tank from service.

fuel oil to the permanent DGFO storage tank.

4. Verify the in-service fuel oil storage tank Prior to transferring fuel oil from contains at least a 4-day supply of fuel oil. tank to be cleaned/inspected to the temporary storage tanks.
5. Verify both qualified offsite power sources Prior to removing either permanent operable. DGFO storage tank from service.
6. Evaluate weather forecast for thunderstorm Prior to removing either permanent warnings and tornado warnings. DGFO storage tank from service.
7. Elective maintenance and testing that affects During period of time a permanent operability of the required DG are not permitted. DGFO storage tank is not in service because of cleaning and inspection acti vi ti es.
8. Personnel that have been briefed on the During period of time a permanent procedures are continuously available to DGFO storage tank is not in service implement actions necessary to ensure transfer because of cleaning and inspection of fuel oil, as needed, in the case of a DG start. acti vi ti es.
9. Verify the DGFO storage tanks and temporary Every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, during period of storage tanks combined contain at least a 7-day time a permanent DGFO storage supply of fuel oil. tank is not in service because of cleaning and inspection activities.

NLS2023029 Page 1 of2 Attachment 3 Proposed Technical Specifications Change (Mark-up)

Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Page 3.8-13

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

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

1. Separate Condition entry is allowed for each DG, except for Conditions A, C, and D.
2. A combination of fuel oil volumes in temporary storage tanks and permanent storage tanks may be utilized to support OPERABILITY of a DG during tank cleaning and inspection maintenance activities. Equipment (temporary transfer pump, hoses, and appropriate fittings) capable of supplying fuel oil to the in-service permanent tank aligned to the operable DG must be available. The fuel oil in the temporary tanks, in conjunction with the fuel oil in the permanent tanks, must be within the limits of Condition A and Condition C. This temporary note is applicable only to the DG aligned to the in-service permanent tank. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5. This allowance is contingent upon meeting the compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil level less than a 7 A. 1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> day supply and greater than within limits.

a 6 day supply in storage tanks.

B. One or more DGs with lube 8.1 Restore lube oil inventory 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> oil inventory less than a 7 to within limits.

day supply and greater than a 6 day supply.

C. Stored fuel oil total C. 1 Restore stored fuel oil total 7 days particulates not within limit. particulates to within limit.

( continued)

Cooper 3.8-13 Amendment No. XXX

NLS2023029 Page 1 of2 Attachment 4 Revised Technical Specifications Page Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Page 3.8-13

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

--------------------------NOTE S-------------------------------- -------------------

1. Separate Condition entry is allowed for each DG, except for Conditions A, C, and D.
2. A combination of fuel oil volumes in temporary storage tanks and permanent storage tanks may be utilized to support OPERABILITY of a DG during tank cleaning and inspection maintenance activities. Equipment (temporary transfer pump, hoses, and appropriate fittings) capable of supplying fuel oil to the in-service permanent tank aligned to the operable DG must be available. The fuel oil in the temporary tanks, in conjunction with the fuel oil in the permanent tanks, must be within the limits of Condition A and Condition C. This temporary note is applicable only to the DG aligned to the in-service permanent tank. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5. This allowance is contingent upon meeting the compensatory measures contained in Attachment 2 of Nebraska Public Power District letter NLS2023029.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil level less than a 7 A.1 Restore fuel oil level to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> day supply and greater than within limits.

a 6 day supply in storage tanks.

B. One or more DGs with lube 8.1 Restore lube oil inventory 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> oil inventory less than a 7 to within limits.

day supply and greater than a 6 day supply.

C. Stored fuel oil total C. 1 Restore stored fuel oil total 7 days particulates not within limit. particulates to within limit.

( continued)

Cooper 3.8-13 Amendment No. XXX

NLS2023029 Page 1 of2 Attachment 5 Proposed Technical Specifications Bases Change (Mark-up) -

Information Only Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 Revised Page B3.8-31

Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 BASES ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each DG except for Conditions A, C, and D.

This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DG subsystem.

Complying with the Required Actions for one inoperable DG subsystem may allow for continued operation, and subsequent inoperable DG subsystem(s) governed by separate Condition entry and application of associated Required Actions. The Note does not apply to Conditions A, C and D since the CNS design has two fuel oil storage tanks that supply fuel oil to both DGs.

Note 2 is a temporary note indicating temporary tanks may be used on a one-time basis during tank cleaning and inspection maintenance activities. Fuel oil stored in the temporary tanks, in conjunction with the fuel oil in the permanent storage tanks, may be utilized to satisfy SR 3.8.3.1 and maintain the DG aligned to the permanent storage tank OPERABLE. A temporary transfer pump with a capacity greater than 15 gpm must be pre-staged and available to transfer the temporary storage tank fuel oil and out-of-service permanent storage tank fuel oil. This is considered sufficient based on fuel in the in-service permanent tank providing a minimum of 4 days full load operation of the DG, contingency measures which pre-stage equipment necessary to supply fuel oil to the in-service permanent tank or directly to the DG day tank, and the initiation of action to obtain replenishment fuel. This temporary note is applicable only during Refuel Outage 33 while in MODES 4 or 5. Compensatory measures that must be met, before and during the maintenance activity, are listed in Attachment 2 of NLS2023029.

In this Condition, the 7 day fuel oil supply for both DGs is not available.

The 49,500 gallon limit is a conservative estimate of the required fuel oil based on worst case fuel consumption. However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply.

The fuel oil level equivalent to a 6 day supply is 42,800 gallons. These circumstances may be caused by events such as:

a. Full load operation required for an inadvertent start while at minimum required level; or
b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.

This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring Cooper B 3.8-31 xx/xx/xx

NLS2023029 Page 1 of 5 Attachment 6 Diesel Generator Fuel Oil Storage and Transfer System Simplified Sketches Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46 List of Figures Figure 1 Site/DGDO System Layout Figure 2 345 KV Switchyard Figure 3 161 KV Distribution Figure 4 Fuel Oil Storage Tank Temporary Configuration During Fuel Transfer

MISSOURI RIVER

,~~~-..-.~~~~~__.__.~

INTAKE STRUCTURE GENERATORS BOILERS FANS WATER TREATMENT MAIN.

SHOP E

TURBINE BUILDING N RTH MATER Al 1 STORA.GE BLDG CONTROL BLDG~ ( I o* 1 FIGURE/

~ N

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Q)

L..

~

~

SUBSTATION UNE TO COOPER 161KV START-UP TRANSFORMEJl:

OPPD TO AUBURN, NE 196,U TO COOPER EY.,.;~fRGENO' TRANSFORMfJl PfRU 69KV 161 KV DISTRIBUTION Figure 3

Fuel Oil Storage Tank Temporary Configuration During Fuel Transfer Out-01~Service Tiirik

.. -----. ~

to

~ valve,

'\

I lnoperabie DG I

FUEL OIL DAf I I

I ToEDG To EDG I

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Figure 4

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