ML25300A005
| ML25300A005 | |
| Person / Time | |
|---|---|
| Site: | Cooper  (DPR-046) |
| Issue date: | 10/23/2025 |
| From: | Dia K Nebraska Public Power District (NPPD) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| N1S2025047 | |
| Download: ML25300A005 (1) | |
Text
N Nebraska Public Power District "Alway thcre wlvn you neu) us" 50.90 N1S2025047 October 23,2025 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Application to Revise Technical Specifications to Adopt TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement" Cooper Nuclear Station, Docket 50-298, Renewed License No. DPR-46 Pursuant to 10 CFR 50.90, Nebraska Public Power District (NPPD) is submitting a request for an amendment to the Technical Specifications (TS) for Cooper Nuclear Station (CNS). NPPD requests adoption of Technical Specification Task Force Traveler (TSTF)-597, "Eliminate LCO 3.0.3 Mode 2 Requirement," which is an approved change to the Standard Technical Specifications (STS), into the CNS TS. TSTF-597 revises Limiting Condition for Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2. provides a description and assessment of the proposed changes. Attachment 2 provides the existing TS pages marked to show the proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.
NPPD requests that the amendment be reviewed under the Consolidated Line ltem lmprovement Process. Approval of the proposed amendment is requested within six months of completion of the Nuclear Regulatory Commission's acceptance review. Once approved, the amendment shall be implemented within 60 days.
There are no regulatory commitments made in this submittal.
The proposed TS changes have been reviewed by the necessary safety review committees (Station Operations Review Committee and Safety Review and Audit Board). ln 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 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) lf you should have any questions regarding this submittal, please contact Linda Dewhirst, Regulatory Affairs and Compliance Manager, at (402) 825-5416.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 I Fax: (402) 825-5211 http://www.nppd.com
N1S2025047 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed On: Io z z
Date Sincerely, lil Dia Site Vice President
/sn Attachments: 1. Description and Assessment
- 2. Proposed Technical Specification Changes (Mark-Up)
- 3. Revised Technical Specification Pages
- 4. Proposed Technical Specification Bases Changes (Mark-Up) -
For lnformation Only cc Regional Administrator M attachments USNRC - Region lV Cooper Project Manager w/ attachments USNRC - NRR Plant Licensing Branch lV Senior Resident lnspector M attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution M attachments CNS Records w/ attachments
N1S2025047 Page 1 of4
1.0 DESCRIPTION
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation 2.2 Variations 3.0 REGULATORYANALYSIS 3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion 4.0 ENVIRONMENTAL CONSIDEMTION ATTACHMENT 1 Description and Assessment Gooper Nuclear Station, Docket No. 50-298, Renewed License No. DPR-46
N1S2025047 Page 2 of 4
1.0 DESCRIPTION
Nebraska Public Power District (NPPD) requests adoption of Technical Specification Task Force Traveler (TSTF)-597, "Eliminate LCO 3.0.3 Mode 2 Requirement," which is an approved change to the Standard Technical Specifications (STS), into the Cooper Nuclear Station (CNS)
Technical Specifications (TS). TSTF-597 revises Limiting Condition for Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2.
2.0 ASSESSMENT
2.1 Applicabilitv of Safetv Evaluation NPPD has reviewed the safety evaluation for TSTF-597 provided to the Technical Specifications Task Force in a letter dated December 26,2024 (Accession #ML24358A226 &ML24358A228).
This review included the Nuclear Regulatory Commission (NRC) staff's evaluation, as well as the information provided in TSTF-597. NPPD has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to CNS and justify this amendment for the incorporation of the changes to the CNS TS.
2.2 Variations NPPD is not proposing any variations from the TS changes described in TSTF-597 or the applicable parts of the NRC staff's safety evaluation.
3.0 REGULATORY ANALYSIS
3.1 No Siqnificant Hazards Consideration Analvsis Nebraska Public Power District (NPPD) requests adoption of Technical Specification Task Force Traveler (TSTF)-597, "Eliminate LCO 3.0.3 Mode 2 Requirement," which is an approved change to the Standard Technical Specifications (STS), into the Cooper Nuclear Station (CNS)
Technical Specifications (TS). TSTF-597 revises Limiting Condition for Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2.
NPPD has evaluated if a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of amendment," as discussed below:
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode
- 2. The time required to shut down the plant after entering LCO 3.0.3 is not an initiator of any accident previously evaluated. Under the proposed change, the TS continue to require the plant to shut down and enter Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The consequences of any accident previously evaluated during the revised LCO 3.0.3 shutdown requirements are no different than the consequences of the same accident during the existing times.
1
N152025047 Page 3 of 4 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode
- 2. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the current plant operating practice for all other TS required shutdowns.
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 amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode
- 2. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings 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 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.
3.2 Conclusion ln 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.
4.0 ENVIRONMENTALCONSIDERATION 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 2
N152025047 Page 4 of 4 proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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.
N1S2025047 Page 1 of 2 ATTACHMENT 2 Proposed Technical Specifi cations Ghanges (Mark-up)
Gooper Nuclear Station, Docket No. 50-298, Renewed License No. DpR-46 Revised Paqe 3.0-1
LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
lf the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless othenruise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:
- a. ffi; b,a. MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and e-b. MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1,2, and 3 LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
(continued)
Amendment 233Cooper 3.0-1 ori{/0gAmendment No.
I
N1S2025047 Page 1 of 2 ATTACHMENT 3 Revised Technical Specifications Page Cooper Nuclear Station, Docket No. 50-298, Renewed License No. DPR-46 Revised Paqe 3.0-1
LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 and LCO 3.0.7.
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
lf the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless othenrvise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within t hour to place the unit, as applicable, in:
- a. MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
- b. MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1,2, and 3 LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
(continued)
Cooper 3.0-1 Amendment No.
I
N1S2025047 Page 1 of2 ATTACHMENT 4 Proposed Technical Specifications Bases Ghanges (Mark-up) - For lnformation Only Cooper Nuclear Station, Docket No. 50-298, Renewed License No. DpR-46 Revised Paqe B 3.0-4
LCO Applicability B 3.0 BASES LCO 3.0.3 (continued) a.
b.
c.
A unit shutdown required in accordance with LCO 3.0.3 may be terminated and LCO 3.0.3 exited if any of the following occurs:
The LCO is now met.
The LCO is no longer aPPlicable.
A Condition exists for which the Required Actions have now been performed.
ACTIONS exist that do not have expired Completion Times.
These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.
The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 4 when a shutdown is required during MODE 1 operation. lf the unit is in a lower MODE of operation when a shutdown is required, the time limit for entering the next lower MODE applies. lf a lower MODE is entered in less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 23 is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering MODE 34 is the next 1-135 hours, because the total time for entering MODE 34 is not reduced from the allowable limit of 1337 hours0.0155 days <br />0.371 hours <br />0.00221 weeks <br />5.087285e-4 months <br />.
Therefore, if remedial measures are completed that would permit a return to MoDE 1, a penalty is not incurred by having to enter a lower MQDE of operation in less than the total time allowed.
ln MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1,2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.
Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.6, "Spent Fuel Storage Pool Water Level." LCO 3.7.6 has an Applicability of "During movement of irradiated fuel d
Cooper B 3.0-4 xx/xx/xx