NLS2025003, Application to Revise Technical Specification to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Revision 0

Application to Revise Technical Specification to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Revision 0

ML25177A030
Person / Time
Site:	Cooper
Issue date:	06/24/2025
From:	Dia K Nebraska Public Power District (NPPD)
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NLS2025003
Download: ML25177A030 (1)

Text

NLS2025003 June 24, 2025 H

Nebraska Public Power District "Always there when you need us" Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," Revision 0 Cooper Nuclear Station, Docket No. 50-298, Renewed License No. DPR-46 50.90 Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Nebraska Public Power District (NPPD) is submitting a request for an amendment to the Technical Specifications (TS) for Cooper Nuclear Station (CNS).

The proposed amendment would modify the CNS TS requirement to operate the Standby Gas Treatment system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month." provides a description and assessment of the proposed change. Attachment 2 provides the existing TS page marked to show the proposed change. Attachment 3 provides revised (clean) TS page. Attachment 4 provides existing TS Bases page marked up to show the proposed change for information only.

NPPD requests the proposed amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within six months of acceptance. Once approved, the amendment shall be implemented within 60 days.

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.

There are no regulatory commitments made in this submittal.

NPPD has determined there are no significant hazards considerations associated with the proposed change and the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions 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

NLS2025003 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed On:

6/.Jtl1o *is:

ate Sincerely, alil Dia Site Vice President

/bs Attachments: 1.

2.

3.

4.

Description and Assessment Proposed Technical Specifications Change (Mark-Up)

Revised Technical Specifications Page Proposed Technical Specifications Bases Change (Mark-Up) - For Information Only 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 Licensure NPG Distribution w/ attachments CNS Records w/ attachments

NLS2025003 Page 1 of 4 ATTACHMENT 1 DESCRIPTION AND ASSESSMENT Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 4.0 ENVIRONMENTAL EVALUATION

NLS2025003 Page 2 of 4

1.0 DESCRIPTION

The proposed change revises the Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," Surveillance Requirement to operate the SGT System with electric heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period in accordance with the Surveillance Frequency Control Program (SFCP). The Surveillance Requirement is revised to require operation of the system for 15 continuous minutes in accordance with the SFCP.

The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation Nebraska Public Power District (NPPD) has reviewed the model safety evaluation for TSTF-522, Revision O (accession number ML12158A464). The review included a review of the Nuclear Regulatory Commission (NRC) staff's evaluation, as well as the information provided in TSTF-522. NPPD has concluded the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to Cooper Nuclear Station (CNS) and justify this proposed amendment for the incorporation of the change to the CNS Technical Specifications (TS).

2.2 Optional Changes and Variations CNS has implemented the SFCP. The frequency for TS Surveillance Requirement 3.6.4.3.1 states, "In accordance with the Surveillance Frequency Control Program." The current frequency for Surveillance Requirement 3.6.4.3.1 in the SFCP is 31 days. Additionally, CNS TS 3.7.4, "Control Room Emergency Filter (CREF) System" relates to the TSTF-522 Section 3.7.4, "Main Control Room Environmental Control (MCREC) System." The CNS CREF system does not have installed heaters and the current duration required by SR 3. 7.4.1 is already consistent with TSTF-522. As a result, no change is being made to TS 3. 7.4. These variations do not affect the applicability of TSTF-522 to CNS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Nebraska Public Power District requests adoption of an approved change to the standard technical specifications and plant specific technical specifications, to revise Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," Surveillance Requirement to operate the SGT System with electric heaters operating for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period in accordance with the Surveillance Frequency Control Program (SFCP). The Surveillance Requirement is revised to require operation of the system for 15 continuous minutes in accordance with the SFCP.

As required by 10 CFR 50.91 (a), an analysis of the issue of no significant hazards consideration is presented below:

NLS2025003 Page 3 of 4

1.

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

Response: No The proposed change replaces an existing Surveillance Requirement to operate the SGT System equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period per the SFCP with a requirement to operate the system for 15 continuous minutes with heaters operating.

The system is not an accident initiator and therefore, the change does not involve a significant increase in the probability of an accident. The proposed system and filter testing change is consistent with current regulatory guidance for the system and will continue to assure that the system performs its design function which may include mitigating accidents. Thus, the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this 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 accident previously evaluated?

Response: No The proposed change replaces an existing Surveillance Requirement to operate the SGT system equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period per the SFCP with a requirement to operate the system for 15 continuous minutes with heaters operating.

The change proposed for the ventilation system does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this 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 replaces an existing Surveillance Requirement to operate the SGT System equipped with electric heaters for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> period per the SFCP with a requirement to operate the system for 15 continuous minutes with heaters operating.

NLS2025003 Page 4 of 4 The design basis for the ventilation system's heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

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

Based on the above, Nebraska Public Power District concludes the proposed change presents no 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 change.

NLS2025003 Page 1 of 2 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGE (MARK-UP)

Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Page 3.6-41

ACTIONS CONDITION REQUIRED ACTION D. Two SGT subsystems D.1 Enter LCO 3.0.3 inoperable in MODE 1, 2, or

3.

E. Two SGT subsystems E.1 NOTE---

inoperable during movement LCO 3.0.3 is not of recently irradiated fuel applicable.

assemblies in the secondary containment.

Suspend movement of recently irradiated fuel assemblies in secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SR 3.6.4.3.4 Cooper SURVEILLANCE Operate each SGT subsystem for~ 4-0-15 continuous hours minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each SGT subsystem actuates on an actual or simulated initiation signal.

Verify the SGT units cross tie damper is in the correct position, and each SGT room air supply check valve and SGT dilution air shutoff valve can be opened.

3.6-41 SGT System 3.6.4.3 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No. ~

NLS2025003 Page 1 of 2 ATTACHMENT 3 REVISED TECHNICAL SPECIFICATIONS PAGE Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Page 3.6-41

ACTIONS CONDITION REQUIRED ACTION D. Two SGT subsystems D.1 Enter LCO 3.0.3 inoperable in MODE 1, 2, or

3.

E. Two SGT subsystems E.1 NOTE-------

inoperable during movement LCO 3.0.3 is not of recently irradiated fuel applicable.

assemblies in the secondary containment.

Suspend movement of recently irradiated fuel assemblies in secondary containment.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 SR 3.6.4.3.2 SR 3.6.4.3.3 SR 3.6.4.3.4 Cooper SURVEILLANCE Operate each SGT subsystem for ~ 15 continuous minutes with heaters operating.

Perform required SGT filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each SGT subsystem actuates on an actual or simulated initiation signal.

Verify the SGT units cross tie damper is in the correct position, and each SGT room air supply check valve and SGT dilution air shutoff valve can be opened.

SGT System 3.6.4.3 COMPLETION TIME Immediately Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.

NLS2025003 Page 1 of 2 ATTACHMENT 4 PROPOSED TECHNICAL SPECIFICATIONS BASES CHANGE (MARK-UP)- FOR INFORMATION ONLY Cooper Nuclear Station, Docket No. 50-298, Renewed Operating License No. DPR-46 Revised Page B 3.6-86

BASES SGT System B 3.6.4.3 ACTIONS (continued)

When two SGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position.

Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE REQUIREMENTS SR 3.6.4.3.1 Cooper Operating each SGT subsystem, including each filter train fan, for~ 40--15 continuous fiOOf&-minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Gf:)eration with the neaters on for > 1 Q continuous hoofs-elifninates moisture on the adsorbers and HEPA filters. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

B 3.6-86 09/19/18