ML25343A098
| ML25343A098 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/12/2025 |
| From: | Byrd T Plant Licensing Branch IV |
| To: | Dent J Nebraska Public Power District (NPPD) |
| References | |
| EPID L-2025-LLA-0098 | |
| Download: ML25343A098 (0) | |
Text
December 12, 2025 Mr. John Dent, Jr.
Executive Vice President and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - ISSUANCE OF AMENDMENT NO. 280 REGARDING ADOPTION OF TSTF-522, REVISION 0, REVISE VENTILATION SYSTEM SURVEILLANCE SYSTEM REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2025-LLA-0098)
Dear Mr. Dent:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 280 to Renewed Facility Operating License No. DPR-46 for Cooper Nuclear Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated June 24, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25177A030).
The amendment revises a surveillance requirement (SR), which currently requires operating the ventilation system for at least 10 continuous hours with the heaters operating at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP). The SR is changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP.
The amendment is consistent with NRC-approved Technical Specifications Task Force (TSTF)
Traveler 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 (ML100890316), dated March 30, 2010.
J. Dent, Jr.
A copy of the related safety evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Thomas J. Byrd, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosures:
- 1. Amendment No. 280 to DPR-46
- 2. Safety Evaluation cc: Listserv
NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 COOPER NUCLEAR STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 280 Renewed License No. DPR-46
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Nebraska Public Power District (the licensee) letter dated June 24, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-46 is hereby amended to read as follows:
(1)
Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 280, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION Tony Nakanishi, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: December 12, 2025 TONY NAKANISHI Digitally signed by TONY NAKANISHI Date: 2025.12.12 12:26:33 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 280 RENEWED FACILITY OPERATING LICENSE NO. DPR-46 COOPER NUCLEAR STATION DOCKET NO. 50-298 Replace the following pages of Renewed Facility Operating License No. DPR-46 and the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Renewed Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.6-41 3.6-41
Amendment No. 280 (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 280, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Cooper Nuclear Station Safeguards Plan, submitted by letter dated May 17, 2006.
NPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NPPD CSP was approved by License Amendment No. 238 as supplemented by changes approved by License Amendments 244 and 249.
(4) Fire Protection NPPD shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated April 24, 2012 (and supplements dated July 12, 2012, January 14, 2013, February 12, 2013, March 13, 2013, June 13, 2013, December 12, 2013, January 17, 2014, February 18, 2014, and April 11, 2014), and as approved in the safety evaluation dated April 29, 2014.
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if
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 k 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. 280
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 280 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION
By letter dated June 24, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25177A030), Nebraska Public Power District (NPPD, the licensee) requested changes to the technical specifications (TSs) for Cooper Nuclear Station (Cooper).
Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC, the Commission) approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler 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, dated March 30, 2010 (ML100890316).
The proposed change would revise a surveillance requirement (SR), which currently requires operating the ventilation system for at least 10 continuous hours with the heaters operating at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP).
The SR would be changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP.
Additionally, the licensee stated that 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 Cooper 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. This variation does not affect the applicability of TSTF-522 to Cooper.
The licensee stated that the license amendment request is consistent with NRC-approved Traveler TSTF-522. The availability of this TS improvement was announced in the Federal Register on September 2, 2025 (90 FR 42453) as part of the consolidated line item improvement process.
2.0 REGULATORY EVALUATION
One of the reasons air filtration and adsorption systems are required at nuclear power plants is to lower the concentration of airborne radioactive material that may be released from the site to the environment due to a design basis event. Lowering the concentration of airborne radioactive materials can mitigate doses to plant operators and members of the public in the event of a design basis event. A typical system consists of ventilation ductwork, fans, dampers, valves, instrumentation, prefilters or demisters, high efficiency particulate air (HEPA) filters, heaters, and activated charcoal adsorbers. These systems are tested by operating the systems and monitoring the response of the overall system as well as individual components. Laboratory tests of charcoal adsorbers are also performed to ensure the charcoal adsorbs an acceptable amount of radioactive gasses.
Current testing requirements for the air filtration and adsorption systems state that the systems should be operated for at least 10 continuous hours with heaters operating every 31 days at a frequency controlled by the SFCP. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that has been superseded. New NRC staff guidance states at least 15 continuous minutes of ventilation system operation with heaters operating every 31 days is acceptable for those plants that test ventilation system adsorption at a relative humidity of less than 95 percent. Plants that test ventilation system adsorption at a relative humidity of 95 percent do not require heaters for the ventilation system to perform its specified safety function and the bracketed phrase with heaters operating is not included in the SRs.
The licensee has proposed revising the SR, which currently requires operating the ventilation system for at least 10 continuous hours with the heaters operating at a frequency controlled in accordance with the SFCP. The SR would be changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP.
The regulatory requirements for design and testing of these systems are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67, Accident source term; 10 CFR Part 100, Reactor Site Criteria; as well as 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criteria (GDC) 19, Control room; GDC 41, Containment atmosphere cleanup; GDC 42, Inspection of containment atmosphere cleanup systems; GDC 43, Testing of containment atmosphere cleanup systems; and GDC 61 Fuel Storage and handling and radioactivity control.
Regulatory Guide (RG) 1.52, Revision 2, Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants (ML003740139), was published in March 1978 to provide guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR related to air filtration and adsorption systems.
Regulatory Position 4.d of RG 1.52, Revision 2 of RG 1.52 states that Each ESF [engineered-safety-feature] atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA filters.
The purpose of this position is to minimize the moisture content in the system and thereby enhance efficiency in the event the system is called upon to perform its design basis function.
SR 3.6.4.3.1 currently requires operating the heaters in the respective ventilation and filtering systems for at least 10 continuous hours every 31 days. The current STS Bases explain that operation of heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would eliminate moisture on the charcoal adsorbers and HEPA filters.
Subsequently, the NRC staff was informed that 10 continuous hours of system operation would dry out the charcoal adsorber for a brief period of time but, following heater de-energization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level. The NRC staff found this information persuasive and subsequently issued NRC Generic Letter (GL) 99-02: Laboratory Testing of Nuclear-Grade Activated Charcoal, dated June 3, 1999 (ML082350935) and Errata sheet dated August 23, 1999 (ML031110094). GL 99-02 requested licensees to confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability. GL 99-02 also requested the licensees to account for the effects of moisture accumulation in adsorbers.
Therefore, the NRC staff updated RG 1.52 to include the new information (ML011710176).
RG 1.52, Revision 3, Regulatory Position 6.1 states, that Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components.
One of the reasons for the previous 10-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorbers ability to capture gaseous activity. However, these effects are already accounted for in the Ventilation Filter Testing Program by performing testing at a relative humidity of 95 percent. The Cooper TS 5.5.7, Ventilation Filter Testing Program (VFTP), requires testing charcoal adsorbers in a manner to account for the effects of moisture on the adsorbers ability to capture gaseous activity. Therefore, the licensee proposed to remove the requirement to operate heaters from SR 3.6.4.3.1.
The NRCs regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. The regulations at 10 CFR 50.36 require that the TS include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. The regulation in 10 CFR 50.36(c)(3) states that SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The NRCs guidance for the format and content of STS applicable to Cooper can be found in NUREG-1433, Standard Technical Specifications General Electric Plants BWR [Boiling Water Reactor]/4, Revision 5, Volume 1, Specifications, and Volume 2, Bases, September 2021 (ML21272A357 and ML21272A358).
3.0 TECHNICAL EVALUATION
The NRC staff evaluated the licensees proposed change against the applicable regulatory guidance in RG 1.52, Revision 3, guidance in the STS as modified by TSTF-522, and the regulatory requirements of 10 CFR 50.36.
The NRC staff evaluated the licensees proposed change against the applicable regulatory guidance in RG 1.52, Revision 3. The proposed change would require at least 15 minutes of system operation. The NRC staff found that the proposed change is consistent with guidance in RG 1.52, Revision 3.
The NRC staff evaluated the licensees proposed change against the applicable regulatory guidance in the STS, as modified by TSTF-522. The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433, by TSTF-522. The NRC staff found that the proposed change is consistent with guidance in the STS, as modified by TSTF-522.
The NRC staff compared the proposed change to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36. The existing SRs provide assurance that the necessary quality of ventilation systems and components will be maintained and that the LCOs will be met. The proposed change reduces the amount of required system operational time from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes. The 10-hour operational requirement for heaters was based on using the SR to eliminate moisture in the adsorbers and thus ensure the adsorbers would capture gaseous activity. As discussed in section 2.0 of this safety evaluation, the effects of moisture on the adsorbers ability to capture gaseous activity are now accounted for in the licensees VFTP by performing testing at a relative humidity of 95 percent. Since the SRs are no longer relied upon to ensure the effects of moisture on the adsorbers ability to capture gaseous activity are accounted for, the 10-hour heater operational requirement is unnecessary. The NRC staff found that reducing the required minimum system operation time to 15 minutes, consistent with RG 1.52, Revision 3, in conjunction with the VFTP, is sufficient to justify operability of the system and all its components. The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of ventilation systems and components will be maintained and that the LCOs will be met.
Therefore, the NRC staff finds the proposed change acceptable.
The regulation at 10 CFR 50.36(a)(1) states, in part: A summary statement of the bases or reasons for such specifications shall also be included in the application, but shall not become part of the technical specifications. The licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with TS 5.5.10, Technical Specifications (TS) Bases Control Program. Accordingly, along with the proposed TS change, the licensee also submitted TS Bases change corresponding to the proposed TS change. The NRC staff determined that TS Bases change is consistent with the proposed TS change and provides the purpose for each requirement in the specification consistent with the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Nebraska State official was notified, on December 9, 2025, of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (90 FR 42453) dated September 2, 2025. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: A. Russell Date: December 12, 2025
- via eConcurrence NRR-058 OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA*
NRR/DSS/STSB/BC*
NRR/DORL/LPL4/BC*
NAME TByrd PBlechman SMehta TNakanishi DATE 12/9/2025 12/10/2025 12/11/2025 12/12//2025 OFFICE NRR/DORL/LPL4/PM*
NAME TByrd DATE 12/12/2025