ML20314A235

Issuance of Amendment No. 268 Revision to Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, Using the Consolidated Line Item Improvement Process

ML20314A235
Person / Time
Site:	Cooper
Issue date:	12/02/2020
From:	Thomas Wengert Plant Licensing Branch IV
To:	Dent J Nebraska Public Power District (NPPD)
Wengert T, NRR/DORL/LPLIV, 415-4037
References
EPID L-2020-LLA-0074
Download: ML20314A235 (17)

Text

December 2, 2020 Mr. John Dent, Jr.

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. 268 RE: REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATONS TASK FORCE (TSTF) TRAVELER TSTF-566, REVISE ACTIONS FOR INOPERABLE RHR SHUTDOWN COOLING SUBSYSTEMS, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2020-LLA-0074)

Dear Mr. Dent:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 268 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 April 1, 2020.

The amendment revises TS actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation. The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, dated January 19, 2018, using the consolidated line item improvement process.

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

Sincerely,

/RA/

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

Enclosures:

1. Amendment No. 268 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. 268 Renewed License No. DPR-46

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nebraska Public Power District (the licensee),

dated April 1, 2020, 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.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-46 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 268, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jennifer Jennifer L. L. Dixon-Herrity Date: 2020.12.02 12:51:47 Dixon-Herrity -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-46 and the Technical Specifications Date of Issuance: December 2, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 268 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 3.4-15 3.4-15 3.4-16 3.4-16 3.4-18 3.4-18 3.4-19 3.4-19

(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. 268, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: Cooper Nuclear Station Safeguards Plan, submitted by letter dated May 17, 2006.

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

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

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if Amendment No. 268

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS)

. 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillances.

APPLICABILITY: MODE 3, with reactor steam dome pressure less than the shutdown cooling permissive pressure.

ACTIONS

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NOTE------------------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> cooling subsystems of decay heat removal is inoperable. available for each inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter (continued)

Cooper 3.4-15 Amendment No. 268

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Initiate action to restore Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one AND recirculation pump to operation.

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from circulation by an alternate discovery of no method. reactor coolant circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

Cooper 3.4-16 Amendment No. 268

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE, and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

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

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the performance of Surveillances.

APPLICABILITY: MODE 4.

ACTIONS

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*----------------------NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A One or two RHR shutdown A.1 Verify.an alternate method 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> cooling subsystems of decay heat removal is inoperable. available for each AND inoperable RHR shutdown cooling subsystem. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter B. Required Action and 8.1 Initiate action to restore

• Immediately associated Completion Time RHR shutdown cooling of Condition A not met. subsystem(s) to OPERABLE status.

(continued)

Cooper 3.4-18 Amendment No. 268

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C. 1 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from subsystem in operation. circulating by an alternate discovery of no method. reactor AND coolant circulation No recirculation pump in AND operation.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program Cooper 3.4-19 Amendment No. 268

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 268 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-46 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298

1.0 INTRODUCTION

By application dated April 1, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20101H298), Nebraska Public Power District (the licensee) submitted a license amendment request (LAR) for Cooper Nuclear Station (Cooper). The amendment would revise technical specification (TS) actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation.

The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, dated January 19, 2018 (ADAMS Accession No. ML18019B187). The U.S. Nuclear Regulatory Commission (NRC, the Commission) issued a final safety evaluation approving TSTF-566, Revision 0, on February 21, 2019 (ADAMS Accession No. ML19028A287), using the consolidated line item improvement process.

The licensee has proposed variations from the TS changes described in TSTF-566, Revision 0.

The variations are described in Section 2.2.3 and evaluated in Section 3.3 of this safety evaluation.

2.0 REGULATORY EVALUATION

2.1 Description of Residual Heat Removal Shutdown Cooling System Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to less than or equal to 200 degrees Fahrenheit.

This decay heat is removed by the RHR shutdown cooling system in preparation for performing refueling or maintenance operations, or for keeping the reactor in the hot shutdown condition or cold shutdown condition.

Enclosure 2

The two redundant, manually controlled shutdown cooling subsystems of the RHR system provide decay heat removal. Each of the two shutdown cooling subsystems of the RHR system can provide the required decay heat removal. Each RHR shutdown cooling subsystem consists of one or two motor-driven pumps, a heat exchanger, and associated piping and valves. The RHR heat exchangers transfer heat to the service water system. Some piping and heat exchangers that are passive components may be common to both subsystems.

Cooper TS 3.4.7, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable in Mode 3, with the reactor steam dome pressure less than the shutdown cooling permissive pressure. Cooper TS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown, is applicable in Mode 4. They both require two operable RHR shutdown cooling subsystems and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem in operation.

2.2 Proposed Changes to the Technical Specifications The licensee proposed to revise TS actions for inoperable RHR shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation, consistent with TSTF-566, Revision 0.

The proposed changes would revise TSs 3.4.7 and 3.4.8 for Cooper. The proposed changes are described below.

2.2.1 Proposed Changes to Cooper TS 3.4.7 Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of Cooper TS 3.4.7, require the operators to initiate action to restore RHR shutdown cooling subsystem(s) to operable status (Required Action A.1) immediately, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.2) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and be in Mode 4 (Required Action A.3) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The licensees proposed changes to Cooper TS 3.4.7 move Required Action A.1 to new Condition B (as Required Action B.1) and delete Required Action A.3. The licensee proposed to add a recurring completion time (CT) to current Required Action A.2 of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter. The licensees proposed changes renumber current Required Action A.2 as A.1 since Required Actions A.1 and A.3 are removed from Condition A.

The licensees proposed changes add a new Condition B for when the required action and associated CT of Condition A are not met. New Condition B, Required Action B.1 would be moved from current Required Action A.1, which requires operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Current Condition B and its required actions would be renamed C, C.1, C.2, and C.3, respectively, since a new Condition B is added.

2.2.2 Proposed Changes to Cooper TS 3.4.8 Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of Cooper TS 3.4.8, require the operators to verify that an alternate method of decay heat removal

is available for each inoperable RHR shutdown cooling subsystem (Required Action A.1) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.

The licensees proposed changes to Cooper TS 3.4.8 would add a new Condition B for when the required action and associated CT of Condition A are not met, which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystem(s) to operable status immediately.

Current Condition B and its required actions would be renamed C, C.1, and C.2, respectively, since a new Condition B is added.

2.2.3 Variations from TSTF-566 The Cooper TSs utilize different numbering than the Standard Technical Specifications (STSs) in NUREG-1433,1 on which TSTF-566 is based. Specifically, STS 3.4.8, Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown is TS 3.4.7 in the Cooper TSs and STS 3.4.9, Residual Heat Removal (RHR) Shutdown Cooling System -Cold Shutdown is TS 3.4.8 in the Cooper TSs. These differences are editorial and do not affect the applicability of TSTF-566 to the proposed LAR.

2.3 Applicable Regulatory Requirement and Guidance Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application the proposed TSs.

The regulation in 10 CFR 50.36(b) states, in part:

Each license authorizing operation of a . . utilization facility . . will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation in 10 CFR 50.40(a) states, in part, that the TSs shall provide reasonable assurance that the health and safety of the public will not be endangered.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), dated March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers.

1 NUREG-1433, Standard Technical Specifications, General Electric BWR [Boiling Water Reactor]/4 Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively),

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to Cooper TS 3.4.7 In the LAR, the licensee proposed changes to revise Cooper TS 3.4.7. The NRC staffs evaluation of the licensees changes to Cooper TS 3.4.7 is described below.

3.1.1 Evaluation of Changes to Condition A The licensees proposed changes would add a recurring CT to current Required Action A.2 of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter, to Cooper TS 3.4.7, Condition A. Current Required Action A.2 requires verification that an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The NRC staff finds this change is acceptable, since it requires continuous verification of alternate methods of decay heat removal every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provides assurance of continued heat removal capability.

The licensee also proposed to delete current Required Action A.3, which requires the plant to be in Mode 4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when one or two RHR shutdown cooling subsystems are inoperable.

Current Required Action A.3 requires operators to reduce the reactor coolant system temperature to the point where Mode 4 is entered, due to the potentially reduced reliability of the alternate methods of decay heat removal. However, if there is no operable RHR shutdown cooling subsystem and the plant is in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition (typically less than 200 degrees Fahrenheit) within the CT. In addition, in a typical BWR design, the RHR shutdown cooling system has a heat rejection capability many times greater than alternate methods available. Therefore, for periods in which there is high decay heat load, the BWR design does not include any system which can satisfy Required Action A.3. The NRC staff finds the deletion of current Required Action A.3 is acceptable because, at below the RHR cut in permissive pressure, the remaining required action will continue to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Current Required Action A.2 would be renumbered as A.1, since Required Actions A.1 and A.3 are removed from Condition A. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.1.2 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met. New Condition Bs Required Action B.1, would be moved from current Required Action A.1 and would require operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately. The NRC staff finds that relocating the required action from A.1 to new Required Action B.1 is acceptable because other ways of removing decay heat are available, such as natural circulation, the spent fuel pool cooling system, the reactor water cleanup system and an inoperable, but functional, RHR shutdown cooling subsystem.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the Cooper

TSs as, the Required Action should be pursued without delay and in a controlled manner.

New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B, with its Required Action B.1, provides an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.1.3 Evaluation of Changes to Existing Condition B Current Required Action A.2 would be renumbered as A.1, since Required Actions A.1 and A.3 are deleted. Current Condition B and its required actions would be renamed C, C.1, C.2, and C.3, respectively, since new Condition B is added. The NRC staff finds these changes are acceptable since it provides the correct number sequence.

3.1.4 Conclusion of Proposed Changes to Cooper TS 3.4.7 The NRC staff concludes that the proposed changes are acceptable since the TSs continue to meet the requirements of 10 CFR 50.40(a) because they provide reasonable assurance that the health and safety of the public will not be endangered.

3.2 Proposed Changes to Cooper TS 3.4.8 In the LAR, the licensee proposed changes to revise Cooper TS 3.4.8. The NRC staffs evaluation of the licensees changes to Cooper TS 3.4.8 is described in the following sections.

3.2.1 Evaluation of New Condition B The licensee proposed a new Condition B to Cooper TS 3.4.8 for when the required action and associated CT of Condition A is not met which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT immediately is defined in Section 1.3 of the TSs as, the Required Action should be pursued without delay and in a controlled manner. New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds that this change is acceptable because new Condition B with its Required Action B.1 provide an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.2.2 Evaluation of Changes to Existing Condition B Current Condition B and its required actions would be renamed C, C.1, and C.2, respectively, since new Condition B is added. The NRC staff finds this change is acceptable because it provides the correct number sequence.

3.2.3 Conclusion of Proposed Changes to Cooper TS 3.4.8 The NRC staff concludes that the proposed changes are acceptable since the TS continues to meet the requirements of 10 CFR 50.40(a) because it provides reasonable assurance that the health and safety of the public will not be endangered.

3.3 Variations from TSTF-566 The Cooper TSs utilize different numbering than the STSs in NUREG-1433 on which TSTF-566 is based. The NRC staff determined that these differences are editorial and do not affect the applicability of TSTF-566 to the proposed LAR.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Nebraska State official was notified of the proposed issuance of the amendment on November 6, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published in the Federal Register on June 30, 2020 (85 FR 39222), and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the 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: J. Wilson, NRR Date: December 2, 2020

ML20314A235 *by e-mail **by memorandum OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DSS/STSB/BC**

NAME TWengert PBlechman VCusumano DATE 11/16/2020 11/10/2020 10/20/2020 OFFICE OGC* NLO NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME CCarson JDixon-Herrity TWengert DATE 11/24/2020 12/1/2020 12/2/2020