Text

Talen Energy - Application to Revise Technical Specifications to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements PLA-7880
	ML20245E192
Person / Time
Site:	Susquehanna
Issue date:	09/01/2020
From:	Cimorelli K; Talen Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML20245E192 (123)
	v • d • e

Kevin Cimorelli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com September 1, 2020 Attn: Document Control Desk 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT TO LICENSES NPF-14 AND NPF-22: APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL (RPV WIC)

ENHANCEMENTS Docket No. 50-387 PLA-7880 and 50-388 Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), is submitting a request for an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License numbers NPF-14 and NPF-22.

Susquehanna requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The TS related to the RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. provides a description and assessment of the proposed changes. Enclosure 2 provides the existing TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides the existing TS Bases pages marked up to show revised text associated with the proposed TS changes and is provided for information only.

Susquehanna requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested by February 28, 2021, to support implementation into the TS in advance of the Unit 2 refueling outage scheduled for Spring 2021. Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, Susquehanna is providing a copy of this application, with enclosures, to the designated Commonwealth of Pennsylvania state official.

Document Control Desk PLA-7880 Both the Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed the proposed changes.

There are no new or revised regulatory commitments contained in this submittal.

Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager- Nuclear Regulatmy Affairs, at (570) 542-1818.

I declare under penalty of pe1jury that the foregoing is true and correct.

Executed on: 9/ [e2J

Enclosures:

1. Description and Assessment

2. Marked-Up Technical Specification Pages

3. Revised (Clean) Technical Specification Pages

4. Marked-Up Technical Specification Bases Pages (Provided for Information Only)

Copy: NRC Region I Mr. M. Hardgrove, NRC Senior Resident Inspector (Acting)

Ms. S. Goetz, NRC Project Manager Mr. M. Shields, PA DEP/BRP

Enclosure 1 to PLA-7880 Description and Assessment

1. DESCRIPTION

2. ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Optional Changes and Variations

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion

4. ENVIRONMENTAL EVALUATION

Enclosure 1 to PLA-7880 Page 1 of 8 SUSQUEHANNA ASSESSMENT

1. Description Susquehanna Nuclear, LLC (Susquehanna), requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

2. Assessment 2.1 Applicability of Safety Evaluation Susquehanna has reviewed the safety evaluation for TSTF-582 provided to the Technical Specifications Task Force in a letter dated August 13, 2020. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-582. Susquehanna has concluded that the justification presented in TSTF-582 and the safety evaluation prepared by the NRC staff are applicable to the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Operating License Nos. NPF-14 and NPF-22, and justify this amendment for the incorporation of the changes to the SSES TS.

Susquehanna verifies that the required ECCS injection/spray subsystems can be aligned and the pump started using relatively simple evolutions involving the manipulation of a small number of components. These actions can be performed in a short time (less than the minimum Drain Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) from the control room following plant procedures.

2.2 Optional Changes and Variations Susquehanna is proposing the following variations from the TS changes described in TSTF-582 or the applicable parts of the NRC staffs safety evaluation dated August 13, 2020.

2.2.1 TS 3.3.5.1, Emergency Core Cooling System (ECCS) Instrumentation During adoption of TSTF-542, an administrative error was introduced into the SSES Unit 1 TS (i.e., the Unit 2 TS do not contain the administrative error). In Table 3.3.5.1-1, Emergency Core Cooling System Instrumentation, Function 3.a, one instance of the word Low was inadvertently deleted. The Function should be titled Reactor Vessel Water Level - Low Low, Level 2. However, it is currently titled, Reactor Vessel Water Level -

Low Level 2. Susquehanna proposes correcting this administrative error in the Unit 1 TS during implementation of TSTF-582.

Enclosure 1 to PLA-7880 Page 2 of 8 2.2.2 TS 3.3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation

1. Table 3.3.5.2-1, Function 1.b The SSES TS do not contain a function commensurate to Function 1.b, Core Spray Pump Discharge Flow - Low (Bypass), in the Standard TS on which TSTF-582 was based. Therefore, the change is not required for the SSES TS.

2. Table 3.3.5.2-1, Function 2.b The SSES TS do not contain a function commensurate to Function 2.b, Low Pressure Coolant Injection Pump Discharge Flow - Low (Bypass), in the Standard TS on which TSTF-582 was based. Therefore, the change is not required for the SSES TS.

3. Table 3.3.5.2-1, All Functions.

Susquehanna proposes to retain the numbering for Function 3.a, RHR [Residual Heat Removal] System Isolation, Reactor Vessel Water Level - Low, Level 3, and Function 4.a, Reactor Water Cleanup (RWCU) System Isolation Reactor Vessel Water Level - Low Low, Level 2. Specifically, rather than deleting Functions 1 and 2 in their entirety and re-numbering Functions 3 and 4, Susquehanna proposes revising Functions 1 and 2 to state, Not Used. This deviation from TSTF-582 eliminates the need to revise existing Surveillance Procedures for the sole purpose of a changed function number within Table 3.3.5.2-1.

2.2.3 TS 3.3.7.1, Control Room Emergency Outside Air Supply (CREOAS) System Instrumentation During adoption of TSTF-542, an administrative error was introduced into the SSES Unit 1 TS (i.e., the Unit 2 TS do not contain the administrative error). In Table 3.3.7.1-1, Control Room Emergency Outside Air Supply System Instrumentation, Function 3, the words High Exhaust Duct were inadvertently deleted. Function 3 should be titled, Unit 1 Refuel Floor High Exhaust Duct Radiation - High. However, it is currently titled, Unit 1 Refuel Floor Radiation - High. Susquehanna proposes correcting this administrative error in the Unit 1 TS during implementation of TSTF-582.

2.2.4 TS 3.3.8.1, Loss of Power (LOP) Instrumentation TSTF-582 revised TS 3.8.2 to no longer require automatic start and loading of a diesel generator (DG) on a loss of offsite power signal. TS 3.3.8.1 is applicable in Modes 1, 2,

Enclosure 1 to PLA-7880 Page 3 of 8 and 3 and when the associated DG is required to be operable by Limiting Condition for Operation (LCO) 3.8.2. Currently TS 3.3.8.1 still requires the LOP instrumentation to be operable in Modes 4 and 5 to support DG operation. However, TS 3.5.2 does not assume an automatic start and load of the DGs in Modes 4 and 5 in response to a draining event.

Consequently, the LOP instrumentation that generates the loss of offsite power signal should not be required to be operable when the DG is required to be operable by TS 3.8.2. The Applicability of LCO 3.3.8.1 is revised to not include the specified condition, When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources -

Shutdown.

2.2.5 TS 3.5.2, RPV Water Inventory Control

1. Susquehanna proposes to modify the title of TS 3.5.2. Specifically, Susquehanna proposes to drop the words Reactor Pressure Vessel from the title and just use the acronym RPV. RPV is defined in the title of Chapter 3.5 of the TS; it is redundant to re-define the acronym in the title of TS 3.5.2. This administrative change aligns TS 3.5.2 with TS 3.5.1 and TS 3.5.3.

2. Susquehanna proposes to retain the numbering for the existing Surveillance Requirements (SRs) in TS 3.5.2. Specifically, rather than deleting SR 3.5.2.5 in its entirety and re-numbering SR 3.5.2.6, SR 3.5.2.7, and SR 3.5.2.8, Susquehanna proposes revising SR 3.5.2.5 to state, Not Used and leave the remaining SRs as their current number. This deviation from TSTF-582 eliminates the need to revise existing Surveillance Procedures for the sole purpose of a changed SR number within TS 3.5.2.

2.2.6 TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs)

Changes in TSTF-582 were incorporated into the SSES TS as variations during adoption of TSTF-542. Therefore, the TSTF-582 changes are not needed.

2.2.7 TS 3.8.2, AC Sources - Shutdown

1. SR 3.8.2.1, Note 2 The SSES TS do not contain a commensurate Note to Note 2 in the Standard TS on which TSTF-582 was based. Therefore, the change is not required for the SSES TS.

2. SR 3.8.2.1

SSES SR 3.8.2.1 differs in format from that of SR 3.8.2.1 in the Standard TS. For both the SSES TS and the Standard TS, SR 3.8.2.1 specifies which SRs from LCO 3.8.1, AC Sources - Operating, are applicable in the Mode of Applicability

Enclosure 1 to PLA-7880 Page 4 of 8 for LCO 3.8.2. SSES SR 3.8.2.1 explicitly lists each LCO 3.8.1 SR that is required to be met for LCO 3.8.2. The Standard TS SR 3.8.2.1 states that all LCO 3.8.1 SRs are required to be met for LCO 3.8.2 with noted exceptions. The SSES TS ultimately require meeting the same list of LCO 3.8.1 SRs for LCO 3.8.2 as the Standard TS.

Susquehanna proposes modifying SR 3.8.2.1 by eliminating SRs 3.8.1.11, 3.8.1.12, 3.8.1.13, and 3.8.1.19 from the list of required LCO 3.8.1 SRs in SSES SR 3.8.2.1.

This change is equivalent to the change in TSTF-582 of adding the four SRs to the list of exceptions within SR 3.8.2.1.

SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 10 seconds. The 10 second start requirements supports the assumptions in the design basis LOCA analysis. This capability is not required during a manual DG start to respond to a draining event, which has a minimum Drain Time of one hour. Therefore, SR 3.8.1.7 and SR 3.8.1.15 are also removed from the list of required LCO 3.8.1 SRs in SSES SR 3.8.2.1.

SR 3.8.1.18 states, Verify each sequenced load is within required limits of the design interval. TSTF-582 retained SR 3.8.1.18 as a test that must be met but not performed. The load sequencer is only used for the automatic start and loading of the DG and is not used during a manual DG start. Therefore, SR 3.8.1.18 is also removed from the list of required LCO 3.8.1 SRs in SSES SR 3.8.2.1.

The change to the list of required LCO 3.8.1 Surveillances necessitates a change to the Note modifying SSES SR 3.8.2.1. The Note provides a list of SRs that must be met but are not required to be performed, which includes SR 3.8.1.11, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19. Because these SRs are eliminated from the list of LCO 3.8.1 SRs that are required to be met for LCO 3.8.2, they no longer need to be included in the list of SRs in the Note.

3. Unit 2 SR 3.8.2.2 The SSES, Unit 2 TS contain an additional SR 3.8.2.2. This SR requires that certain SRs from Unit 1 LCO 3.8.1 are met for Unit 2. This accounts for the fact that the Safety Analyses for Unit 2 assumes the operability of some equipment that receives power from Unit 1 AC Sources. Therefore, the SSES Unit 2 TS establish requirements for Unit 1 AC Sources that are necessary to support the operation of Unit 2 equipment.

Susquehanna proposed modifying Unit 2 SR 3.8.2.2 by eliminating SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 from the list of required Unit 1, LCO 3.8.1 SRs in SSES, Unit 2, SR 3.8.2.2. This change is equivalent to the changes

Enclosure 1 to PLA-7880 Page 5 of 8 made to SR 3.8.2.1 for each Units TS. This change is required to align the operability requirements for Unit 1 AC sources powering Unit 2 equipment with the operability requirements for Unit 1 AC Sources powering only Unit 1 equipment. Regardless of the offsite power source (i.e., from a Unit 1 source or a Unit 2 source), LCO 3.5.2 does not assume that the onsite electrical power source (i.e., the DGs) will start automatically on an ECCS or loss of power signal. Thus, it is appropriate to remove the SRs which test the ability of the DGs to start on a loss of power signal or ECCS initiation signal, regardless of the offsite power source (Unit 1 source or a Unit 2 source).

2.2.8 TS Bases Changes Susquehanna will make changes to the TS Bases in accordance with its TS Bases Control Program. Not all changes described in TSTF-582 are applicable to the SSES TS Bases, and additional changes are required to support deviations from the TSTF described previously.

The proposed TS Bases markups are provided in Enclosure 4 to this application for information only.

The above variations do not impact the conclusion that TSTF-582 is applicable to the SSES TS, nor do they preclude the NRCs conclusion that the change is acceptable as documented in the NRC staffs safety evaluation dated August 13, 2020. Therefore, Susquehanna concludes these administrative variations are acceptable.

3. Regulatory Analysis 3.1 No Significant Hazards Considerations Analysis Susquehanna Nuclear, LLC (Susquehanna), requests adoption of TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements. The Technical Specifications (TS) related to RPV WIC are revised to incorporate operating experience and to correct errors and omissions that were incorporated into the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License Nos. NPF-14 and NPF-22, TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. TSTF-582 includes the following changes to the TS:

1. The TS are revised to eliminate the requirement for a manual Emergency Core Cooling System (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start.

2. The Drain Time definition is revised to move the examples of common mode failure mechanisms to the Bases and seismic events are no longer considered a common mode failure mechanism.

Enclosure 1 to PLA-7880 Page 6 of 8

3. The Drain Time definition exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are locked, sealed, or otherwise secured is revised to apply the exception for manual or automatic valves that are closed and administratively controlled.

4. The TS are revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.

5. A Surveillance Requirement (SR) that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, is modified to permit crediting normal operation of the system to satisfy the SR and to permit operation through the test return line.

6. SSES Units 1 and 2 share secondary containment structures between units. The TS Actions are revised to recognize that an operable secondary containment and operable secondary containment isolation valves satisfy the Required Actions.

7. TS 3.8.2, AC Sources - Shutdown, SR 3.8.2.1 is revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. Automatic ECCS initiation in Modes 4 and 5 was eliminated in TSTF-542. This was an oversight in TSTF-542.

8. The TS are revised to use wording and to define acronyms in a manner consistent with the remainder of the TS. These changes are made for consistency and have no effect on the application of the TS.

Susquehanna 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, 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 incorporates operating experience and corrects errors and omissions that were incorporated into the SSES TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. Draining of RPV water inventory in Mode 4 (i.e.,

cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is

Enclosure 1 to PLA-7880 Page 7 of 8 not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.

Therefore, the proposed change does 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 incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control. The event of concern under the current requirements and the proposed change is an unexpected draining event during shutdown. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (FSAR) for any plant or in the NRCs Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing basis that would have been considered a design basis accident in the FSAR had it been previously identified.

None of the equipment affected by the proposed change has a design function described in the FSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose. Therefore, the proposed change will affect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event. However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.

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 incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.

Enclosure 1 to PLA-7880 Page 8 of 8 The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the FSAR or the license.

Therefore, the proposed change does not significantly reduce the margin of safety.

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

Based on the above, Susquehanna 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 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 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.

4. 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. The proposed change 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 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.

Enclosure 2 of PLA-7880 Marked-Up Technical Specification Pages Revised Technical Specifications Pages Unit 1 TS Pages 1.1-3, 3.3-44, 3.3-47a, 3.3-47b, 3.3-47c, 3.3-71, 3.3-72, 3.5-8, 3.5-8a, 3.5-9, 3.5-9a, 3.5-10, 3.5-11, and 3.8-19 Unit 2 TS Pages 1.1-3, 1.1-3a, 1.1-4, 3.3-47a, 3.3-47b, 3.3-47c, 3.3-72, 3.5-8, 3.5-8a, 3.5-9, 3.5-9a, 3.5-10, 3.5-11, 3.8-21, and 3.8-22

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I-131 Concentration and Dose Conversion Factors for Inhalation, (continued) Submersion, and Ingestion, EPA, 1988, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the CEDE. The conversion factors that are used for the calculation of EDE (or DDE) from external exposure (submersion) shall be those listed in Table III.1 of Federal Guidance Report 12, External Exposure to Radionuclides in Air, Water, and Soil, EPA, 1993, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the EDE.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

SUSQUEHANNA - UNIT 1 1.1-3 Amendment 178, 239, 271, XXX

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER FUNCTION ACTION A.1 REQUIREMENTS VALUE

2. LPCI System (continued)

f. Manual Initiation 1, 2, 3 2 C SR 3.3.5.1.5 NA 1 per Subsystem

3. High Pressure Coolant Injection (HPCI) System

a. Reactor Vessel 1, 4 B SR 3.3.5.1.1 -45 inches Water Level - Low 2(d), 3(d) SR 3.3.5.1.2 Low, Level 2 SR 3.3.5.1.4 SR 3.3.5.1.5

b. Drywell Pressure - 1, 4 B SR 3.3.5.1.2 1.88 psig High 2(d), 3(d) SR 3.3.5.1.3 SR 3.3.5.1.5

c. Reactor Vessel 1, 2 C SR 3.3.5.1.2 55.5 inches Water Level - High, 2(d), 3(d) SR 3.3.5.1.3 Level 8 SR 3.3.5.1.5

d. Condensate 1, 2 D SR 3.3.5.1.2 40.5 inches Storage Tank Level 2(d), 3(d) SR 3.3.5.1.3 above tank

- Low SR 3.3.5.1.5 bottom (d) With reactor steam dome pressure > 150 psig.

SUSQUEHANNA - UNIT 1 3.3-44 Amendment 178, 204, 254, 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

AB.One or more channels A.1 Initiate action to place Immediately inoperable.As required by channel in trip.

Required Action A.1 and referenced in OR Table 3.3.5.2-1.

BA.12.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND BA.2.2 Initiate action to Ccalculate Immediately DRAIN TIME.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

SUSQUEHANNA - UNIT 1 3.3-47a Amendment 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

SUSQUEHANNA - UNIT 1 3.3-47a Amendment 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 -------------------------------NOTE--------------------------------

A test of all required contacts does not have to be performed.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.3-47b Amendment 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray SystemNot Used

a. Reactor Steam 4, 5 4 (a) C SR 3.3.5.2.2 433 psig (upper)

Dome Pressure - SR 3.3.5.2.3 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per subsystem D SR 3.3.5.2.3 NA (a)

2. Low Pressure Coolant Injection (LPCI)

SystemNot Used

a. Reactor Steam 4, 5 4 (a) C SR 3.3.5.2.2 433 psig (upper)

Dome Pressure - SR 3.3.5.2.3 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per subsystem D SR 3.3.5.2.3 NA (a)

3. RHR System Isolation

a. Reactor Vessel (ba) 2 in one trip B SR 3.3.5.2.1 11.5 inches Water Level - Low, system SR 3.3.5.2.2 Level 3 SR 3.3.5.2.3

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (ba) 2 in one trip B SR 3.3.5.2.1 -45 inches Water Level - Low system SR 3.3.5.2.2 Low, Level 2 SR 3.3.5.2.3 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

(ba) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

SUSQUEHANNA - UNIT 1 3.3-47c Amendment 271, XXX

CREOAS System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of 1)

Control Room Emergency Outside Air Supply System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION A.1 REQUIREMENTS VALUE

1. Reactor Vessel Water 1, 2, 3 2 B SR 3.3.7.1.1 -45 inches Level - Low Low, SR 3.3.7.1.2 Level 2 SR 3.3.7.1.4 SR 3.3.7.1.5

2. Drywell Pressure - 1, 2, 3 2 B SR 3.3.7.1.2 1.88 psig High SR 3.3.7.1.3 SR 3.3.7.1.5

3. Unit 1 Refuel Floor High (a) 1 B SR 3.3.7.1.1 25 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

4. Unit 2 Refuel Floor High (a) 1 B SR 3.3.7.1.1 25 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

5. Unit 1 Refuel Floor Wall (a) 1 B SR 3.3.7.1.1 28 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

6. Unit 2 Refuel Floor Wall (a) 1 B SR 3.3.7.1.1 28 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

7. Railroad Access Shaft (b) 1 B SR 3.3.7.1.1 7 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

8. Main Control Room 1, 2, 3, 1 C SR 3.3.7.1.1 5 mR/hr Outside Air Intake (a) SR 3.3.7.1.2 Radiation - High SR 3.3.7.1.4 SR 3.3.7.1.5

9. Manual Initiation 1, 2, 3, 1 B SR 3.3.7.1.5 NA (a)

(a) During CORE ALTERATIONS and during movement of irradiated fuel assemblies in the secondary containment.

(b) During movement of irradiated fuel assemblies within the Railroad Access Shaft, and above the Railroad Access Shaft with the Railroad Access Shaft Equipment Hatch open.

SUSQUEHANNA - UNIT 1 3.3-71 Amendment 178, 271, XXX

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, and When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Enter the Condition Immediately channels inoperable. referenced in Table 3.3.8.1-1 for the channel.

B. As required by Required B.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.8.1-1.

C. As required by Required C.1 Restore the inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and Channel.

referenced in Table 3.3.8.1-1.

SUSQUEHANNA - UNIT 1 3.3-72 Amendment 178, XXX

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating without met. offsite electrical power.

SUSQUEHANNA - UNIT 1 3.5-8 Amendment 178, 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

SUSQUEHANNA - UNIT 1 3.5-8a Amendment 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ----------- NOTE ---------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND Immediately D.4 Initiate action to verify one standby gas treatmentSGT subsystem is capable of being placed in operation.

SUSQUEHANNA - UNIT 1 3.5-9 Amendment 178, 266, 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance 20 ft 0 inches. Frequency Control Program SUSQUEHANNA - UNIT 1 3.5-9a Amendment 271, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is 20 ft 0 inches; Program.

or

b. Condensate storage tank water level is 49% of capacity.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, the piping is filled with water from the the Surveillance pump discharge valve to the injection valve. Frequency Control Program SR 3.5.2.5 Verify for the required ECCS injection/spray subsystem, In accordance with each manual, power operated, and automatic valve in the the Surveillance flow path, that is not locked, sealed, or otherwise secured Frequency Control in position, is in the correct position.Not Used Program SUSQUEHANNA - UNIT 1 3.5-10 Amendment 178, 266, 271, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 -----------------------------NOTES--------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem through the recirculation line for 10 the Surveillance minutes. Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance with penetration flow path actuates to the isolation position the Surveillance on an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.8 -------------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance with can be manually operated. actuates on a manual the Surveillance initiation signal. Frequency Control Program SUSQUEHANNA - UNIT 1 3.5-11 Amendment 178, 266, 271, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------------NOTE-------------------------------

The following SRs must be met but are not required to be performed:

SR 3.8.1.3; SR 3.8.1.14; and SR 3.8.1.9; SR 3.8.1.15; SR 3.8.1.10; SR 3.8.1.16.;

SR 3.8.1.11; SR 3.8.1.18; and SR 3.8.1.13; SR 3.8.1.19.

For required Unit 1 AC sources, the following SRs of In accordance with Unit 1 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.11; SR 3.8.1.3; SR 3.8.1.12; SR 3.8.1.4; SR 3.8.1.13; SR 3.8.1.5; SR 3.8.1.14; and SR 3.8.1.6; SR 3.8.1.15; SR 3.8.1.7; SR 3.8.1.16.;

SR 3.8.1.9; SR 3.8.1.18; and SR 3.8.1.10; SR 3.8.1.19.

SUSQUEHANNA - UNIT 1 3.8-19 Amendment 178, XXX

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I-131 actually present. The conversion factors that are used for this (continued) calculation of committed effective dose equivalent (CEDE) from inhalation shall be those listed in Table 2.1 of Federal Guidelines Report 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, EPA, 1988, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the CEDE. The conversion factors that are used for the calculation of EDE (or DDE) from external exposure (submersion) shall be those listed in Table III.1 of Federal Guidance Report 12, External Exposure to Radionuclides in Air, Water, and Soil, EPA, 1993, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the EDE.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error), for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled locked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or SUSQUEHANNA - UNIT 2 1.1-3 Amendment 151, 216, 253, XXX

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Definitions 1.1 1.1 Definitions DRAIN TIME 3. Penetration flow paths with isolation devices that can (continued) be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval from SYSTEM (ECCS) RESPONSE when the monitored parameter exceeds its ECCS initiation TIME setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

END OF CYCLE The EOC RPT SYSTEM RESPONSE TIME shall be that time RECIRCULATION PUMP TRIP interval from initial signal generation by the associated turbine (EOC RPT) SYSTEM stop valve limit switch or from when the turbine control valve RESPONSE TIME hydraulic oil control oil pressure drops below the pressure switch setpoint to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. Times shall SUSQUEHANNA - UNIT 2 1.1-3a Amendment 253, XXX

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Definitions 1.1 1.1 Definitions ISOLATION SYSTEM include diesel generator starting and sequence loading delays, RESPONSE TIME where applicable. The response time may be measured by (continued) means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE;

d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per unit length of RATE (LHGR) fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all TEST required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

SUSQUEHANNA - UNIT 2 1.1-4 Amendment 151, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Enter the Condition Immediately inoperable. referenced in Table 3.3.5.2-1 for the channel.

BA.One or more channels A.1 Initiate action to place Immediately inoperable.As required by channel in trip.

Required Action A.1 and referenced in OR Table 3.3.5.2-1.

BA.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND BA.2.2 Initiate action to Ccalculate Immediately DRAIN TIME.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.5.2-1.

SUSQUEHANNA - UNIT 2 3.3-47a Amendment 253, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. As required by Required D.1 Restore channel to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Action A.1 and OPERABLE status.

referenced in Table 3.3.5.2-1.

E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 -------------------------------NOTE--------------------------------

A test of all required contacts does not have to be performed.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.3-47b Amendment 253, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER FUNCTION ACTION A.1 REQUIREMENTS VALUE

1. Core Spray System Not Used

a. Reactor Steam 4, 5 4 (a) C SR 3.3.5.2.2 433 psig (upper)

Dome Pressure - SR 3.3.5.2.3 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per subsystem D SR 3.3.5.2.3 NA (a)

2. Low Pressure Coolant Injection (LPCI) System Not Used

a. Reactor Steam 4, 5 4 (a) C SR 3.3.5.2.2 433 psig (upper)

Dome Pressure - SR 3.3.5.2.3 Low (Injection Permissive)

b. Manual Initiation 4, 5 1 per subsystem D SR 3.3.5.2.3 NA (a)

3. RHR System Isolation

a. Reactor Vessel (ba) 2 in one trip B SR 3.3.5.2.1 11.5 inches Water Level - Low, system SR 3.3.5.2.2 Level 3 SR 3.3.5.2.3

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel (ba) 2 in one trip B SR 3.3.5.2.1 -45 inches Water Level - Low system SR 3.3.5.2.2 Low, Level 2 SR 3.3.5.2.3 (a) Associated with an ECCS subsystem required to be OPERABLE by LCO 3.5.2, Reactor Pressure Vessel (RPV) Water Inventory Control.

(ba) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

SUSQUEHANNA - UNIT 2 3.3-47c Amendment 253, XXX

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, and When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Enter the Condition Immediately channels inoperable for referenced in reasons other than Table 3.3.8.1-1 for the Condition B. channel.

B. One or more required B.1 Restore the inoperable 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months channels associated with channels.

Unit 1 4.16 kV ESS Buses in one Division inoperable for the performance of Unit 1 SR 3.8.1.19.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.8.1-1.

SUSQUEHANNA - UNIT 2 3.3-72 Amendment 151, 208, XXX

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating without met. offsite electrical power.

SUSQUEHANNA - UNIT 2 3.5-8 Amendment 151, 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

SUSQUEHANNA - UNIT 2 3.5-8a Amendment 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ----------- NOTE ---------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND Immediately D.4 Initiate action to verify one standby gas treatmentSGT subsystem is capable of being placed in operation.

SUSQUEHANNA - UNIT 2 3.5-9 Amendment 151, 247, 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance 20 ft 0 inches. Frequency Control Program SUSQUEHANNA - UNIT 2 3.5-9a Amendment 253, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is 20 ft 0 inches; Program or

b. Condensate storage tank water level is 49% of capacity.

SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, the piping is filled with water from the the Surveillance pump discharge valve to the injection valve. Frequency Control Program SR 3.5.2.5 Verify for the required ECCS injection/spray In accordance with subsystem, each manual, power operated, and the Surveillance automatic valve in the flow path, that is not locked, Frequency Control sealed, or otherwise secured in position, is in the Program correct position.Not Used SUSQUEHANNA - UNIT 2 3.5-10 Amendment 151, 247, 253, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 ------------------------------NOTES-------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem through the recirculation line for the Surveillance 10 minutes. Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance with penetration flow path actuates to the isolation position the Surveillance on an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.8 -------------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance with can be manually operatedactuates on a manual the Surveillance initiation signal. Frequency Control Program SUSQUEHANNA - UNIT 2 3.5-11 Amendment 151, 247, 253, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------------NOTE-------------------------------

The following SRs must be met but are not required to be performed:

SR 3.8.1.3; SR 3.8.1.14; and SR 3.8.1.9; SR 3.8.1.15; SR 3.8.1.10; SR 3.8.1.16.;

SR 3.8.1.11; SR 3.8.1.18; and SR 3.8.1.13; SR 3.8.1.19.

For required Unit 2 AC sources, the following SRs of In accordance with Unit 2 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.11; SR 3.8.1.3; SR 3.8.1.12; SR 3.8.1.4; SR 3.8.1.13; SR 3.8.1.5; SR 3.8.1.14; and SR 3.8.1.6; SR 3.8.1.15; SR 3.8.1.7; SR 3.8.1.16.;

SR 3.8.1.9; SR 3.8.1.18; and SR 3.8.1.10; SR 3.8.1.19.

SUSQUEHANNA - UNIT 2 3.8-21 Amendment 151, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.2.2 --------------------------------NOTE-------------------------------

When Unit 1 is in MODE 4 or 5, the Note to Unit 1 SR 3.8.2.1 is applicable for the performance of required Unit 1 SRs.

For required Unit 1 AC sources, the following SRs of In accordance with Unit 1 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.10; SR 3.8.1.3; SR 3.8.1.11; SR 3.8.1.4; SR 3.8.1.14; SR 3.8.1.5; SR 3.8.1.15; SR 3.8.1.6; SR 3.8.1.16; SR 3.8.1.7; SR 3.8.1.18; SR 3.8.1.9; SR 3.8.1.19; and SR 3.8.1.8 (when more than one Unit 1 offsite circuit is required).

SUSQUEHANNA - UNIT 2 3.8-22 Amendment 151, XXX

Enclosure 3 of PLA-7880 Revised (Clean) Technical Specification Pages Revised Technical Specifications Pages Unit 1 TS Pages 1.1-3, 3.3-44, 3.3-47a, 3.3-47b, 3.3-47c, 3.3-71, 3.3-72, 3.5-8, 3.5-8a, 3.5-9, 3.5-10, 3.5-11, and 3.8-19 Unit 2 TS Pages 1.1-3, 1.1-3a, 1.1-4, 3.3-47a, 3.3-47b, 3.3-47c, 3.3-72, 3.5-8, 3.5-8a, 3.5-9, 3.5-10, 3.5-11, 3.8-21, and 3.8-22

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I-131 Concentration and Dose Conversion Factors for Inhalation, (continued) Submersion, and Ingestion, EPA, 1988, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the CEDE. The conversion factors that are used for the calculation of EDE (or DDE) from external exposure (submersion) shall be those listed in Table III.1 of Federal Guidance Report 12, External Exposure to Radionuclides in Air, Water, and Soil, EPA, 1993, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the EDE.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or

3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

SUSQUEHANNA - UNIT 1 1.1-3 Amendment 178, 239, 271, XXX

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 3 of 6)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS PER FUNCTION ACTION A.1 REQUIREMENTS VALUE

2. LPCI System (continued)

f. Manual Initiation 1, 2, 3 2 C SR 3.3.5.1.5 NA 1 per Subsystem

3. High Pressure Coolant Injection (HPCI) System

a. Reactor Vessel 1, 4 B SR 3.3.5.1.1 -45 inches Water Level - Low 2(d), 3(d) SR 3.3.5.1.2 Low, Level 2 SR 3.3.5.1.4 SR 3.3.5.1.5

b. Drywell Pressure - 1, 4 B SR 3.3.5.1.2 1.88 psig High 2(d), 3(d) SR 3.3.5.1.3 SR 3.3.5.1.5

c. Reactor Vessel 1, 2 C SR 3.3.5.1.2 55.5 inches Water Level - High, 2(d), 3(d) SR 3.3.5.1.3 Level 8 SR 3.3.5.1.5

d. Condensate 1, 2 D SR 3.3.5.1.2 40.5 inches Storage Tank Level 2(d), 3(d) SR 3.3.5.1.3 above tank

- Low SR 3.3.5.1.5 bottom (d) With reactor steam dome pressure > 150 psig.

SUSQUEHANNA - UNIT 1 3.3-44 Amendment 178, 204, 254, 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.

SUSQUEHANNA - UNIT 1 3.3-47a Amendment 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 -------------------------------NOTE--------------------------------

A test of all required contacts does not have to be performed.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.3-47b Amendment 271, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES REQUIRED OR OTHER SPECIFIED CHANNELS PER ALLOWABLE FUNCTION CONDITIONS FUNCTION VALUE

1. Not Used

2. Not Used

3. RHR System Isolation

a. Reactor Vessel Water Level - Low, Level 3 (a) 2 in one trip system 11.5 inches

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water Level - Low Low, (a) 2 in one trip system -45 inches Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

SUSQUEHANNA - UNIT 1 3.3-47c Amendment 271, XXX

CREOAS System Instrumentation 3.3.7.1 Table 3.3.7.1-1 (page 1 of 1)

Control Room Emergency Outside Air Supply System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION A.1 REQUIREMENTS VALUE

1. Reactor Vessel Water 1, 2, 3 2 B SR 3.3.7.1.1 -45 inches Level - Low Low, SR 3.3.7.1.2 Level 2 SR 3.3.7.1.4 SR 3.3.7.1.5

2. Drywell Pressure - 1, 2, 3 2 B SR 3.3.7.1.2 1.88 psig High SR 3.3.7.1.3 SR 3.3.7.1.5

3. Unit 1 Refuel Floor High (a) 1 B SR 3.3.7.1.1 25 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

4. Unit 2 Refuel Floor High (a) 1 B SR 3.3.7.1.1 25 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

5. Unit 1 Refuel Floor Wall (a) 1 B SR 3.3.7.1.1 28 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

6. Unit 2 Refuel Floor Wall (a) 1 B SR 3.3.7.1.1 28 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

7. Railroad Access Shaft (b) 1 B SR 3.3.7.1.1 7 mR/hr Exhaust Duct Radiation SR 3.3.7.1.2

- High SR 3.3.7.1.4 SR 3.3.7.1.5

8. Main Control Room 1, 2, 3, 1 C SR 3.3.7.1.1 5 mR/hr Outside Air Intake (a) SR 3.3.7.1.2 Radiation - High SR 3.3.7.1.4 SR 3.3.7.1.5

9. Manual Initiation 1, 2, 3, 1 B SR 3.3.7.1.5 NA (a)

(a) During CORE ALTERATIONS and during movement of irradiated fuel assemblies in the secondary containment.

(b) During movement of irradiated fuel assemblies within the Railroad Access Shaft, and above the Railroad Access Shaft with the Railroad Access Shaft Equipment Hatch open.

SUSQUEHANNA - UNIT 1 3.3-71 Amendment 178, 271, XXX

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Enter the Condition Immediately channels inoperable. referenced in Table 3.3.8.1-1 for the channel.

B. As required by Required B.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.8.1-1.

C. As required by Required C.1 Restore the inoperable 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and channel.

referenced in Table 3.3.8.1-1.

SUSQUEHANNA - UNIT 1 3.3-72 Amendment 178, XXX

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating without met. offsite electrical power.

SUSQUEHANNA - UNIT 1 3.5-8 Amendment 178, 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

SUSQUEHANNA - UNIT 1 3.5-8a Amendment 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ----------- NOTE ---------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND Immediately D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

SUSQUEHANNA - UNIT 1 3.5-9 Amendment 178, 266, 271, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 20 ft 0 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is 20 ft 0 inches; Program.

or

b. Condensate storage tank water level is 49% of capacity.

SUSQUEHANNA - UNIT 1 3.5-10 Amendment 178, 266, 271, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, the piping is filled with water from the the Surveillance pump discharge valve to the injection valve. Frequency Control Program SR 3.5.2.5 Not Used SR 3.5.2.6 -----------------------------NOTES--------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance with penetration flow path actuates to the isolation position the Surveillance on an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.8 -------------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance with can be manually operated. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.5-11 Amendment 178, 266, 271, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------------NOTE-------------------------------

The following SRs must be met but are not required to be performed:

SR 3.8.1.3; SR 3.8.1.14; and SR 3.8.1.9; SR 3.8.1.16.

SR 3.8.1.10; For required Unit 1 AC sources, the following SRs of In accordance with Unit 1 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.9; SR 3.8.1.3; SR 3.8.1.10; SR 3.8.1.4; SR 3.8.1.14; and SR 3.8.1.5; SR 3.8.1.16.

SR 3.8.1.6; SUSQUEHANNA - UNIT 1 3.8-19 Amendment 178, XXX

Definitions 1.1 1.1 Definitions DOSE EQUIVALENT I-131 actually present. The conversion factors that are used for this (continued) calculation of committed effective dose equivalent (CEDE) from inhalation shall be those listed in Table 2.1 of Federal Guidelines Report 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, EPA, 1988, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the CEDE. The conversion factors that are used for the calculation of EDE (or DDE) from external exposure (submersion) shall be those listed in Table III.1 of Federal Guidance Report 12, External Exposure to Radionuclides in Air, Water, and Soil, EPA, 1993, as described in Regulatory Guide 1.183. The factors in the column headed effective yield doses corresponding to the EDE.

DRAIN TIME The DRAIN TIME is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to the top of the active fuel (TAF) seated in the RPV assuming:

a) The water inventory above the TAF is divided by the limiting drain rate; b) The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure for all penetration flow paths below the TAF except:

1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;

2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or SUSQUEHANNA - UNIT 2 1.1-3 Amendment 151, 216, 253, XXX

Definitions 1.1 1.1 Definitions DRAIN TIME 3. Penetration flow paths with isolation devices that can (continued) be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.

c) The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d) No additional draining events occur; and e) Realistic cross-sectional areas and drain rates are used.

A bounding DRAIN TIME may be used in lieu of a calculated value.

EMERGENCY CORE COOLING The ECCS RESPONSE TIME shall be that time interval from SYSTEM (ECCS) RESPONSE when the monitored parameter exceeds its ECCS initiation TIME setpoint at the channel sensor until the ECCS equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

END OF CYCLE The EOC RPT SYSTEM RESPONSE TIME shall be that time RECIRCULATION PUMP TRIP interval from initial signal generation by the associated turbine (EOC RPT) SYSTEM stop valve limit switch or from when the turbine control valve RESPONSE TIME hydraulic oil control oil pressure drops below the pressure switch setpoint to complete suppression of the electric arc between the fully open contacts of the recirculation pump circuit breaker. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

ISOLATION SYSTEM The ISOLATION SYSTEM RESPONSE TIME shall be that RESPONSE TIME time interval from when the monitored parameter exceeds its isolation initiation setpoint at the channel sensor until the isolation valves travel to their required positions. Times shall SUSQUEHANNA - UNIT 2 1.1-3a Amendment 253, XXX

Definitions 1.1 1.1 Definitions ISOLATION SYSTEM include diesel generator starting and sequence loading delays, RESPONSE TIME where applicable. The response time may be measured by (continued) means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

LEAKAGE LEAKAGE shall be:

a. Identified LEAKAGE

1. LEAKAGE into the drywell, such as that from pump seals or valve packing, that is captured and conducted to a collecting tank; or

2. LEAKAGE into the drywell atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be pressure boundary LEAKAGE;

b. Unidentified LEAKAGE All LEAKAGE into the drywell that is not identified LEAKAGE;

c. Total LEAKAGE Sum of the identified and unidentified LEAKAGE;

d. Pressure Boundary LEAKAGE LEAKAGE through a nonisolable fault in a Reactor Coolant System (RCS) component body, pipe wall, or vessel wall.

LINEAR HEAT GENERATION The LHGR shall be the heat generation rate per unit length of RATE (LHGR) fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length.

LOGIC SYSTEM FUNCTIONAL A LOGIC SYSTEM FUNCTIONAL TEST shall be a test of all TEST required logic components (i.e., all required relays and contacts, trip units, solid state logic elements, etc.) of a logic circuit, from as close to the sensor as practicable up to, but not including, the actuated device, to verify OPERABILITY. The LOGIC SYSTEM FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total system steps so that the entire logic system is tested.

SUSQUEHANNA - UNIT 2 1.1-4 Amendment 151, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.

APPLICABILITY: According to Table 3.3.5.2-1.

ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.

OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.

AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.

SUSQUEHANNA - UNIT 2 3.3-47a Amendment 253, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS

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

These SRs apply to each Function in Table 3.3.5.2-1.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 -------------------------------NOTE--------------------------------

A test of all required contacts does not have to be performed.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.3-47b Amendment 253, XXX

RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)

RPV Water Inventory Control Instrumentation APPLICABLE MODES REQUIRED OR OTHER SPECIFIED CHANNELS PER ALLOWABLE FUNCTION CONDITIONS FUNCTION VALUE

1. Not Used

2. Not Used

3. RHR System Isolation

a. Reactor Vessel Water Level - Low, Level 3 (a) 2 in one trip system 11.5 inches

4. Reactor Water Cleanup (RWCU) System Isolation

a. Reactor Vessel Water Level - Low Low, (a) 2 in one trip system -45 inches Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.

SUSQUEHANNA - UNIT 2 3.3-47c Amendment 253, XXX

LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS

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

Separate Condition entry is allowed for each channel.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Enter the Condition Immediately channels inoperable for referenced in reasons other than Table 3.3.8.1-1 for the Condition B. channel.

B. One or more required B.1 Restore the inoperable 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months channels associated with channels.

Unit 1 4.16 kV ESS Buses in one Division inoperable for the performance of Unit 1 SR 3.8.1.19.

C. As required by Required C.1 Place channel in trip. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Action A.1 and referenced in Table 3.3.8.1-1.

SUSQUEHANNA - UNIT 2 3.3-72 Amendment 151, 208, XXX

RPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 RPV Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND One low pressure ECCS injection/spray subsystem shall be OPERABLE.

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

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4 and 5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection/spray subsystem injection/spray subsystem to inoperable. OPERABLE status.

B. Required Action and B.1 Initiate action to establish a Immediately associated Completion method of water injection Time of Condition A not capable of operating without met. offsite electrical power.

SUSQUEHANNA - UNIT 2 3.5-8 Amendment 151, 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME < 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C.1 Verify secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.

SUSQUEHANNA - UNIT 2 3.5-8a Amendment 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. DRAIN TIME < 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . D.1 ----------- NOTE ---------------

Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to establish an Immediately additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

AND D.2 Initiate action to establish Immediately secondary containment boundary.

AND D.3 Initiate action to isolate each Immediately secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.

AND Immediately D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.

SUSQUEHANNA - UNIT 2 3.5-9 Amendment 151, 247, 253, XXX

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 20 ft 0 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control

a. Suppression pool water level is 20 ft 0 inches; Program or

b. Condensate storage tank water level is 49% of capacity.

SUSQUEHANNA - UNIT 2 3.5-10 Amendment 151, 247, 253, XXX

RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, the piping is filled with water from the the Surveillance pump discharge valve to the injection valve. Frequency Control Program SR 3.5.2.5 Not Used SR 3.5.2.6 ------------------------------NOTES-------------------------------

1. Operation may be through the test return line.

2. Credit may be taken for normal system operation to satisfy this SR.

Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically isolating a In accordance with penetration flow path actuates to the isolation position the Surveillance on an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.8 -------------------------------NOTE--------------------------------

Vessel injection/spray may be excluded.

Verify the required ECCS injection/spray subsystem In accordance with can be manually operated. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.5-11 Amendment 151, 247, 253, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 --------------------------------NOTE-------------------------------

The following SRs must be met but are not required to be performed:

SR 3.8.1.3; SR 3.8.1.14; and SR 3.8.1.9; SR 3.8.1.16.

SR 3.8.1.10; For required Unit 2 AC sources, the following SRs of In accordance with Unit 2 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.9; SR 3.8.1.3; SR 3.8.1.10; SR 3.8.1.4; SR 3.8.1.14; and SR 3.8.1.5; SR 3.8.1.16.

SR 3.8.1.6; SUSQUEHANNA - UNIT 2 3.8-21 Amendment 151, XXX

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.2.2 --------------------------------NOTE-------------------------------

When Unit 1 is in MODE 4 or 5, the Note to Unit 1 SR 3.8.2.1 is applicable for the performance of required Unit 1 SRs.

For required Unit 1 AC sources, the following SRs of In accordance with Unit 1 Specification 3.8.1 are applicable: applicable SRs SR 3.8.1.1; SR 3.8.1.9; SR 3.8.1.3; SR 3.8.1.10; SR 3.8.1.4; SR 3.8.1.14; SR 3.8.1.5; SR 3.8.1.16; SR 3.8.1.6; and SR 3.8.1.8 (when more than one Unit 1 offsite circuit is required).

SUSQUEHANNA - UNIT 2 3.8-22 Amendment 151, XXX

Enclosure 4 of PLA-7880 Marked-Up Technical Specification Bases Pages Revised Technical Specifications Bases Pages Unit 1 TS Bases Pages 3.3-132, 3.3-133, 3.3-134, 3.3-136, 3.3-137, 3.3-138, 3.3-139, 3.3-207, 3.3-208, 3.3-210, 3.5-17, 3.5-18, 3.5-19, 3.5-21, 3.5-22, 3.5-23, 3.5-24, 3.5-25, 3.5-26, 3.6-23, 3.6-25, 3.6-27, 3.8-40, and 3.8-43 Unit 2 TS Bases Pages 3.3-133, 3.3-134, 3.3-135, 3.3-137, 3.3-138, 3.3-139, 3.3-140, 3.3-208, 3.3-209, 3.3-211, 3.5-17, 3.5-18, 3.5-19, 3.5-21, 3.5-22, 3.5-23, 3.5-24, 3.5-25, 3.5-26, 3.6-23, 3.6-25, 3.6-27, 3.8-41, 3.8-42, 3.8-44, and 3.8-45 (Provided for Information Only)

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation Instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

SUSQUEHANNA - UNIT 1 3.3-132

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses. RPV ANALYSES, LCO, water inventory control is required in MODES 4 and 5 to protect Safety and Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of APPLICABILITY radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulatedconsidered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulatedconsidered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

SUSQUEHANNA - UNIT 1 3.3-133

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1. - Not Used SAFETY

2. - Not Used ANALYSES, LCO, and Core Spray and Low Pressure Coolant Injection Systems APPLICABILITY 1.a, 2.a. Reactor Steam Dome Pressure - Low (Injection Permissive)

(continued)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions.

This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Reactor Steam Dome Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The transmitters are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Steam Dome Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b. Manual Initiation The Manual Initiation push button channels introduce signals into the appropriate ECCS logic to provide manual initiation capability. There is one push button for each of the CS and LPCI subsystems (i.e., two for CS and two for LPCI).

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

A channel of the Manual Initiation Function (one channel per subsystem) is required to be OPERABLE in MODES 4 and 5 when the associated ECCS subsystems are required to be OPERABLE per LCO 3.5.2.

SUSQUEHANNA - UNIT 1 3.3-134

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE Reactor Water Cleanup (RWCU) System Isolation SAFETY 4.a - Reactor Vessel Water level - Low Low, Level 2 (continued)

ANALYSES, LCO, and Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from APPLICABILITY four level transmitters that sense the difference between the pressure due (continued) to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

SUSQUEHANNA - UNIT 1 3.3-136

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS A.1, A.2.1 and A.2.2B.1 and B.2 (continued)

RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action BA.1 directs animmediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires immediate declaration that the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action B.2A.2.2 directs initiating action to calculateion of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves.

E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray SUSQUEHANNA - UNIT 1 3.3-137

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

SUSQUEHANNA - UNIT 1 3.3-137

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE As noted in the beginning of the SRs, the SRs for The following SRs REQUIREMENTS apply to each RPV Water Inventory Control instrument Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

t.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

This SR is modified by a Note that provides a general exception to the definition of CHANNEL FUNCTIONAL TEST. This exception is necessary because the design of instrumentation does not facilitate functional testing of all required contacts of the relay which input into the combinational logic. Performance of such a test could result in a plant transient or place the plant in an undue risk situation. Therefore, for this SR, the CHANNEL FUNCTIONAL TEST verifies acceptable response by verifying the change of state of the relay which inputs into the combinational logic. The required contacts not tested during the SUSQUEHANNA - UNIT 1 3.3-138

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE SR 3.3.5.2.2 (continued)

REQUIREMENTS (continued) CHANNEL FUNCTIONAL TEST are tested under the LOGIC SYSTEM FUNCTIONAL TEST, SR 3.3.5.2.3. This is acceptable because operating experience shows that the contacts not tested during the CHANNEL FUNCTIONAL TEST normally pass the LOGIC SYSTEM FUNCTIONAL TEST, and the testing methodology minimizes the risk of unplanned transients.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

SUSQUEHANNA - UNIT 1 3.3-139

Rev. 3 LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage < 20%)

SAFETY ANALYSES, Loss of voltage on a 4.16 kV emergency bus indicates that offsite power LCO, and may be completely lost to the respective emergency bus and is unable to APPLICABILITY supply sufficient power for proper operation of the applicable equipment.

(continued) Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

One channel of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Function per associated emergency bus is required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) relay controls and provides a permissive to allow closure of the associated alternate source breaker and the associated DG breaker. (one channel input to each of the four DGs.) Refer to LCO 3.8.1, "AC SourcesOperating," and 3.8.2, "AC SourcesShutdown,"

for Applicability Bases for the DGs.

2., 3. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function.

Therefore, power supply to the bus is transferred from offsite power to onsite DG power when there is no offsite power or a degraded power supply to the bus. This transfer will occur only if the voltage of the primary and alternate power sources drop below the Degraded Voltage Function SUSQUEHANNA - UNIT 1 3.3-207

Rev. 3 LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 2., 3. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY (continued)

ANALYSES, LCO, and Allowable Values (degraded voltage with a time delay) and the source APPLICABILITY breakers trip which causes the DG to start. This ensures that adequate (continued) power will be available to the required equipment.

Two Functions are provided to monitor degraded voltage at two different levels. These Functions are the Degraded Voltage LOCA (< 93%) and Degraded Voltage Low Setting (< 65%). These relays respond to degraded voltage as follows: 93% for approximately 5 minutes (when no LOCA signal is present) and approximately 10 seconds (with a LOCA signal present), and 65% (Degraded Voltage Low Setting). The circuitry is designed such that with the LOCA signal present, the non-LOCA time delay is physically bypassed. The Degraded Voltage LOCA Function preserves the assumptions of the LOCA analysis and the Degraded Voltage Low Setting Function preserves the assumptions of the accident sequence analysis in the FSAR.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) per Function (Functions 2 and 3) per associated bus are required to be OPERABLE when the associated DG is required to be OPERABLE. This ensures no single instrument failure can preclude the start of DGs (each logic inputs to each of the four DGs). Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into SUSQUEHANNA - UNIT 1 3.3-208

Rev. 3 LOP Instrumentation B 3.3.8.1 BASES ACTIONS C.1 (continued)

With one channel of the Function inoperable, the Function is not capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition D must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of channels.

D.1 If the Required Action and associated Completion Times of Conditions B or C are not met, the associated Function is not capable of performing the intended function. Therefore, the associated DG(s) is declared inoperable immediately for both Unit 1 and Unit 2. This requires entry into applicable Conditions and Required Actions of LCO 3.8.1 and LCO 3.8.2 for both Unit 1 and Unit 2, which provide appropriate actions for the inoperable DG(s).

SURVEILLANCE As noted at the beginning of the SRs, the SRs for each LOP instrumentation REQUIREMENTS Function are located in the SRs column of Table 3.3.8.1-1.

The Surveillances are modified by a Note to indicate that when a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months provided the associated Function maintains DG initiation capability. Upon completion of the Surveillance, or expiration of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowance, the channel must be returned to OPERABLE status or the applicable Condition entered and Required Actions taken.

SUSQUEHANNA - UNIT 1 3.3-210

Rev. 3 RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 RPV Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses.

ANALYSES RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulatedconsidered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such ase.g., seismic event, loss of normal power, or a single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

SUSQUEHANNA - UNIT 1 3.5-17

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in- depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valves are not required to be closed.

The LCO is modified by a Note which allows a required LPCI subsystem to be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

SUSQUEHANNA - UNIT 1 3.5-18

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES APPLICABILITY RPV water inventory control is required in MODES 4 and 5. Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control, and RCIC System. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

ACTIONS A.1 and B.1 If the required low pressure ECCS injection/spray subsystem is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In this Condition, the LCO controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for restoring the required low pressure ECCS injection/spray subsystem to OPERABLE status is based on engineering judgment that considers the LCO controls on DRAIN TIME and the low probability of an unexpected draining event that would result in loss of RPV water inventory.

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within the required Completion Time, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually initiated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If recirculation of injected water would occur, it may be credited in determining the necessary water volume.

C.1, C.2, and C.3 With the DRAIN TIME less than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months but greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of SUSQUEHANNA - UNIT 1 3.5-19

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES ACTIONS C.1, C.2, and C.3 (continued)

(continued)

Required Actions C.1, C.2, and C.3 are considered to be met when secondary containment, secondary containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

D.1, D.2, D.3, and D.4 With the DRAIN TIME less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , mitigating actions are implemented in case an unexpected draining event should occur. Note that if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action E.1 is also applicable.

Required Action D.1 requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCO. The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a control volume in which fission-products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the secondary containment boundary. With the secondary containment boundary established, one SGT subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment.

SUSQUEHANNA - UNIT 1 3.5-21

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued)

(continued)

The secondary containment penetrations form a part of the secondary containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be automatically or manually isolated from the control room.

One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action D.4 requires that actions be immediately initiated to verify that at least one SGT subsystem is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions D.2, D.3, and D.4 are considered to be met when secondary containment, secondary containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

E.1 If the Required Actions and associated Completion times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF.

Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed SUSQUEHANNA - UNIT 1 3.5-22

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS (continued) and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlledlocked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference

6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME mustshould consider the potential effects of temporary alterations in support of maintenancea single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to preventIf failure of such items temporary alterations from could result and would causeing a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. the penetration flow path may not be excluded from the DRAIN TIME calculation.Reasonable controls include, but are not limited to controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

SUSQUEHANNA - UNIT 1 3.5-23

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS (continued) Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of 20 ft 0 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS subsystem or LPCI subsystem pump, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.SR 3.5.2.2 and SR 3.5.2.3 (continued)

The required CS System is considered OPERABLE if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CS pump. Therefore, a verification that either the suppression pool water level is 20 ft 0 inches or that a required CS subsystem is aligned to take suction from the CST and the CST contains 135,000 gallons of water, equivalent to 49% of capacity, ensures that the CS Subsystem can supply at least 135,000 gallons of makeup water to the RPV.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.4 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS actuationinitiation signal. One acceptable method of ensuring that the lines are full is to vent at the high points.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SUSQUEHANNA - UNIT 1 3.5-24

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued) Not UsedVerifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow path provides assurance that the proper flow paths will be available for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that Ttesting the ECCS injection/spray subsystem may be done through the recirculationtest return line is necessary to avoid overfilling the refueling cavity. Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgment.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SUSQUEHANNA - UNIT 1 3.5-25

Rev. 3 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.8 REQUIREMENTS (continued) The required ECCS subsystem is required to actuate on a manual initiation signal. This Surveillance verifies that a manual initiation signal will cause the required CS subsystem or LPCI subsystem can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls to transfer water from the suppression pool or CST to the RPV to start and operate as designed, including pump startup and actuation of all automatic valves to their required positions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6,"

February 1983.

SUSQUEHANNA - UNIT 1 3.5-26

Rev. 16 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR ensures that the primary containment purge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. If a LOCA inside primary containment occurs in MODES 1, 2, or 3, the purge valves may not be capable of closing before the pressure pulse affects systems downstream of the purge valves, or the release of radioactive material will exceed limits prior to the purge valves closing.

At other times when the purge valves are required to be capable of closing (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are allowed to be open. The SR is modified by a Note stating that the SR is not required to be met when the purge valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open. The vent and purge valves are capable of closing in the environment following a LOCA.

Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.2 This SR verifies that each primary containment isolation manual valve and blind flange that is located outside primary containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

This SR does not require any testing or valve manipulation. Rather, it involves verification that those PCIVs outside primary containment, and capable of being mispositioned, are in the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in the proper position, is low. A second Note has been included to clarify that PCIVs that are open under administrative SUSQUEHANNA - UNIT 1 3.6-23

Rev. 16 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.5 REQUIREMENTS (continued) Verifying the isolation time of each power operated and each automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7. The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the Final Safety Analyses Report. The isolation time and Frequency of this SR are in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.6 For primary containment purge valves with resilient seals, the Appendix J Leakage Rate Test Interval of 24 months is sufficient. The acceptance criteria for these valves is defined in the Primary Containment Leakage Rate Testing Program, 5.5.12.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

If a LOCA inside primary containment occurs in MODES 1, 2, or 3, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times when the purge valves are required to be capable of closing (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

SR 3.6.1.3.7 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. This ensures that the calculated radiological consequences of these events remain within regulatory limits. The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.8 Automatic PCIVs close on a primary containment isolation signal to prevent leakage of radioactive material from primary containment following a DBA. This SR ensures that each automatic PCIV will actuate to its isolation position on a primary containment isolation signal. The LOGIC SYSTEM FUNCTIONAL TEST in SR 3.3.6.1.5 overlaps this SR to provide complete testing of the safety function. The SUSQUEHANNA - UNIT 1 3.6-25

Rev. 16 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.11 REQUIREMENTS (continued) This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of Reference 4 are met. The secondary containment leakage pathways and Frequency are defined by the Primary Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. In MODES other than 1, 2, or 3, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.

SR 3.6.1.3.12 The analyses in References 1 and 4 are based on the specified leakage rate. Leakage through each MSIV must be 100 scfh for any one MSIV and 300 scfh for total leakage through the MSIVs combined with the Main Steam Line Drain Isolation Valve, HPCI Steam Supply Isolation Valve and the RCIC Steam Supply Isolation Valve.

The MSIVs can be tested at either > Pt (24.3 psig) or Pa (48.6 psig).

Main Steam Line Drain Isolation, HPCI and RCIC Steam Supply Line Isolation Valves, are tested at Pa (48.6 psig). In MODES other than 1, 2, or 3, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 3.3 gpm when tested at 1.1 Pa, (53.46 psig). The combined leakage rates must be demonstrated in accordance with the leakage rate test Frequency required by the Primary Containment Leakage Testing Program.

As noted in Table B 3.6.1.3-1, PCIVs associated with this SR are not Type C tested. Containment bypass leakage is prevented since the line terminates below the minimum water level in the Suppression Chamber. These valves are tested in accordance with the IST Program. Therefore, these valves leakage is not included as containment leakage.

In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1, 2, and 3.

However, specific leakage limits are not applicable in these other MODES or conditions.

SUSQUEHANNA - UNIT 1 3.6-27

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES LCO LCO 3.8.8, ensures that a diverse power source is available for providing (continued) electrical power support assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and the ability to manually start a DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESS bus(es),

and of accepting required loads during an accident. Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit. An offsite circuit includes all breakers, transformers, switches, automatic tap changers, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESS bus or buses. The offsite circuit consists of the incoming breaker and disconnect to startup transformers (ST) No. 10 and ST No. 20 and the respective circuit path including feeder breakers to the four 4.16 kV ESS buses (A, B, C and D) for both Unit 1 and Unit 2. A detailed description of the offsite power network and circuits to the onsite Class 1E ESS buses is found in the FSAR, Section 8.2.

The required DG must be capable of being manually startedstarting, accelerating to rated speed and voltage, connecting to its respective ESS bus on detection of bus undervoltage, and capable of accepting required loads. This sequence must be accomplished within 10 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESS buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY. In addition, proper sequence operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8.

SUSQUEHANNA - UNIT 1 3.8-40

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DGs that are not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note that specified SRs must be met but are not required to be performed. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4.16 kV ESS bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG.

It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

REFERENCES 1. Final Policy Statement on Technical Specifications Improvements, July 22, 1993 (58 FR 39132).

SUSQUEHANNA - UNIT 1 3.8-43

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 B 3.3 INSTRUMENTATION B 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

Technical Specifications are required by 10 CFR 50.36 to include limiting safety system settings (LSSS) for variables that have significant safety functions. LSSS are defined by the regulation as "Where a LSSS is specified for a variable on which a safety limit has been placed, the setting must be chosen so that automatic protective actions will correct the abnormal situation before a Safety Limit (SL) is exceeded." The Analytical Limit is the limit of the process variable at which a safety action is initiated to ensure that a SL is not exceeded. Any automatic protection action that occurs on reaching the Analytical Limit therefore ensures that the SL is not exceeded. However, in practice, the actual settings for automatic protection channels must be chosen to be more conservative than the Analytical Limit to account for instrument loop uncertainties related to the setting at which the automatic protective action would actually occur. The actual settings for the automatic isolation channels are the same as those established for the same functions in MODES 1, 2, and 3 in LCO 3.3.5.1, "Emergency Core Cooling System (ECCS)

Instrumentation," or LCO 3.3.6.1, "Primary Containment Isolation instrumentation".

With the unit in MODE 4 or 5, RPV water inventory control is not required to mitigate any events or accidents evaluated in the safety analyses.

RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material should a draining event occur. Under the definition of DRAIN TIME, some penetration flow paths may be excluded from the DRAIN TIME calculation if they will be isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation.

SUSQUEHANNA - UNIT 2 3.3-133

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES BACKGROUND The purpose of the RPV Water Inventory Control Instrumentation is to (continued) support the requirements of LCO 3.5.2, Reactor Pressure Vessel (RPV)

Water Inventory Control, and the definition of DRAIN TIME. There are functions that are required for manual initiation or operation of the ECCS injection/spray subsystem required to be OPERABLE by LCO 3.5.2 and other functions that support automatic isolation of Residual Heat Removal subsystem and Reactor Water Cleanup system penetration flow path(s) on low RPV water level.

The RPV Water Inventory Control Instrumentation supports operation of core spray (CS) and low pressure coolant injection (LPCI). The equipment involved with each of these systems is described in the Bases for LCO 3.5.2.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses. RPV ANALYSES, LCO, water inventory control is required in MODES 4 and 5 to protect Safety and Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of APPLICABILITY radioactive material should a draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulatedconsidered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is postulatedconsidered in which an single operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (e.g., seismic event, loss of normal power, single human error). It is assumed, based on engineering judgment, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can be manually initiated to maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

Permissive and interlock setpoints are generally considered as nominal values without regard to measurement accuracy.

The specific Applicable Safety Analyses, LCO, and Applicability discussions are listed below on a Function by Function basis.

SUSQUEHANNA - UNIT 2 3.3-134

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE 1. - Not Used SAFETY ANALYSES, LCO, 2. - Not Used and Core Spray and Low Pressure Coolant Injection Systems APPLICABILITY 1.a, 2.a. Reactor Steam Dome Pressure - Low (Injection Permissive)

(continued)

Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. This function ensures that, prior to opening the injection valves of the low pressure ECCS subsystems, the reactor pressure has fallen to a value below these subsystems' maximum design pressure. While it is assured during MODES 4 and 5 that the reactor steam dome pressure will be below the ECCS maximum design pressure, the Reactor Steam Dome Pressure - Low signals are assumed to be OPERABLE and capable of permitting initiation of the ECCS.

The Reactor Steam Dome Pressure - Low signals are initiated from four pressure transmitters that sense the reactor dome pressure. The transmitters are connected to four trip units. The outputs of the trip units are connected to relays whose contacts are arranged in a one-out-of-two taken twice logic.

The Allowable Value is low enough to prevent overpressuring the equipment in the low pressure ECCS.

The four channels of Reactor Steam Dome Pressure - Low Function are required to be OPERABLE in MODES 4 and 5 when ECCS manual initiation is required to be OPERABLE by LCO 3.5.2.

1.b, 2.b. Manual Initiation The Manual Initiation push button channels introduce signals into the appropriate ECCS logic to provide manual initiation capability. There is one push button for each of the CS and LPCI subsystems (i.e., two for CS and two for LPCI).

There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.

A channel of the Manual Initiation Function (one channel per subsystem) is required to be OPERABLE in MODES 4 and 5 when the associated ECCS subsystems are required to be OPERABLE per LCO 3.5.2.

SUSQUEHANNA - UNIT 2 3.3-135

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES APPLICABLE Reactor Water Cleanup (RWCU) System Isolation SAFETY 4.a - Reactor Vessel Water level - Low Low, Level 2 (continued)

ANALYSES, LCO, and Reactor Vessel Water Level - Low Low, Level 2 signals are initiated from APPLICABILITY four level transmitters that sense the difference between the pressure due (continued) to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. While four channels (two channels per trip system) of the Reactor Vessel Water Level - Low Low, Level 2 Function are available, only two channels (all in the same trip system) are required to be OPERABLE.

The Reactor Vessel Water Level - Low Low, Level 2 Allowable Value was chosen to be the same as the ECCS Reactor Vessel Water Level - Low Low, Level 2 Allowable Value (LCO 3.3.5.1), since the capability to cool the fuel may be threatened.

The Reactor Vessel Water Level - Low Low, Level 2 Function is only required to be OPERABLE when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME.

ACTIONS A Note has been provided to modify the ACTIONS related to RPV Water Inventory Control instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition. Section 1.3 also specifies that Required Actions continue to apply for each additional failure, with Completion Times based on initial entry into the Condition. However, the Required Actions for inoperable RPV Water Inventory Control instrumentation channels provide appropriate compensatory measures for separate inoperable Condition entry for each inoperable RPV Water Inventory Control instrumentation channel.

A.1 Required Action A.1 directs entry into the appropriate Condition referenced in Table 3.3.5.2-1. The applicable Condition referenced in the Table is Function dependent. Each time a channel is discovered inoperable, Condition A is entered for that channel and provides for transfer to the appropriate subsequent Condition.

SUSQUEHANNA - UNIT 2 3.3-137

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES ACTIONS BA.1, A.2.1 and BA.2.2 (continued)

RHR System Isolation, Reactor Vessel Water Level - Low Level 3, and Reactor Water Cleanup System, Reactor Vessel Water Level - Low Low, Level 2 functions are applicable when automatic isolation of the associated penetration flow path is credited in calculating DRAIN TIME. If the instrumentation is inoperable, Required Action BA.1 directs animmediate action to place the channel in trip. With the inoperable channel in the tripped condition, the remaining channel will isolate the penetration flow path on low water level. If both channels are inoperable and placed in trip, the penetration flow path will be isolated. Alternatively, Required Action A.2.1 requires immediate declaration that the associated penetration flow path(s) to be immediately declared are incapable of automatic isolation. Required Action BA.2.2 directs initiating action to calculateion of DRAIN TIME. The calculation cannot credit automatic isolation of the affected penetration flow paths.

C.1 Low reactor steam dome pressure signals are used as permissives for the low pressure ECCS injection/spray subsystem manual injection functions. If the permissive is inoperable, manual initiation of ECCS is prohibited. Therefore, the permissive must be placed in the trip condition within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . With the permissive in the trip condition, manual initiation may be performed. Prior to placing the permissive in the tripped condition, the operator can take manual control of the pump and the injection valve to inject water into the RPV.

The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is intended to allow the operator time to evaluate any discovered inoperabilities and to place the channel in trip.

D.1 If a manual initiation function is inoperable, the ECCS subsystem pumps can be started manually and the valves can be opened manually, but this is not the preferred condition.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time was chosen to allow time for the operator to evaluate and repair any discovered inoperabilities. The Completion Time is appropriate given the ability to manually start the ECCS pumps and open the injection valves.

SUSQUEHANNA - UNIT 2 3.3-138

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 E.1 With the Required Action and associated Completion Time of Condition C or D not met, the associated low pressure ECCS injection/spray subsystem may be incapable of performing the intended function, and must be declared inoperable immediately.

SUSQUEHANNA - UNIT 2 3.3-138

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE The following SRs apply toAs noted in the beginning of the SRs, the SRs REQUIREMENTS for each RPV Water inventory Control instrument Function are found in the SRs column of Table 3.3.5.2-1.

SR 3.3.5.2.1 Performance of the CHANNEL CHECK ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or something even more serious. A CHANNEL CHECK guarantees that undetected outright channel failure is limited; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL FUNCTIONAL TEST.

Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the instrument has drifted outside its limit.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the channels required by the LCO.

SR 3.3.5.2.2 A CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function.

This SR is modified by a Note that provides a general exception to the definition of CHANNEL FUNCTIONAL TEST. This exception is necessary because the design of instrumentation does not facilitate functional testing of all required contacts of the relay which input into the combinational logic. Performance of such a test could result in a plant transient or place the plant in an undue risk situation. Therefore, for this SR, the CHANNEL FUNCTIONAL TEST verifies acceptable response by verifying the change of state of the relay which inputs into the combinational logic. The required SUSQUEHANNA - UNIT 2 3.3-139

Rev. 2 RPV Water Inventory Control Instrumentation B 3.3.5.2 BASES SURVEILLANCE SR 3.3.5.2.2 (continued)

REQUIREMENTS (continued) contacts not tested during the CHANNEL FUNCTIONAL TEST are tested under the LOGIC SYSTEM FUNCTIONAL TEST, SR 3.3.5.2.3. This is acceptable because operating experience shows that the contacts not tested during the CHANNEL FUNCTIONAL TEST normally pass the LOGIC SYSTEM FUNCTIONAL TEST, and the testing methodology minimizes the risk of unplanned transients.

Any setpoint adjustment shall be consistent with the assumptions of the current plant specific setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.5.2.3 The LOGIC SYSTEM FUNCTIONAL TEST demonstrates the OPERABILITY of the required initiation logic for a specific channel. The system functional testing performed in LCO 3.5.2 overlaps this Surveillance to complete testing of the assumed safety function.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(F), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

SUSQUEHANNA - UNIT 2 3.3-140

Rev. 4 LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 1. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage< 20%)

SAFETY ANALYSES, Loss of voltage on a 4.16 kV emergency bus indicates that offsite power LCO, and may be completely lost to the respective emergency bus and is unable to APPLICABILITY supply sufficient power for proper operation of the applicable equipment.

(continued) Therefore, the power supply to the bus is transferred from offsite power to DG power when the voltage on the bus drops below the Loss of Voltage Function Allowable Values (loss of voltage with a short time delay). This ensures that adequate power will be available to the required equipment.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that power is available to the required equipment.

One channel of 4.16 kV Emergency Bus Undervoltage (Loss of Voltage)

Function per associated emergency bus is required to be OPERABLE when the associated DG is required to be OPERABLE to ensure that no single instrument failure can preclude the DG function. 4.16 kV Emergency Bus Undervoltage (Loss of Voltage) relay controls and provides a permissive to allow closure of the associated alternate source breaker and the associated DG breaker. (one channel input to each of the four DGs.) Refer to LCO 3.8.1, "AC SourcesOperating," and 3.8.2, "AC SourcesShutdown,"

for Applicability Bases for the DGs.

2., 3. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

A reduced voltage condition on a 4 kV emergency bus indicates that, while offsite power may not be completely lost to the respective emergency bus, available power may be insufficient for starting large ECCS motors without risking damage to the motors that could disable the ECCS function.

Therefore, power supply to the bus is transferred from offsite power to onsite DG power when there is no offsite power or a degraded power supply to the bus. This transfer will occur only if the voltage of the primary and alternate power sources drop below the Degraded Voltage Function SUSQUEHANNA - UNIT 2 3.3-208

Rev. 4 LOP Instrumentation B 3.3.8.1 BASES APPLICABLE 2., 3. 4.16 kV Emergency Bus Undervoltage (Degraded Voltage)

SAFETY (continued)

ANALYSES, LCO, and Allowable Values (degraded voltage with a time delay) and the source APPLICABILITY breakers trip which causes the DG to start. This ensures that adequate (continued) power will be available to the required equipment.

Two Functions are provided to monitor degraded voltage at two different levels. These Functions are the Degraded Voltage LOCA (< 93%) and Degraded Voltage Low Setting (< 65%). These relays respond to degraded voltage as follows: 93% for approximately 5 minutes (when no LOCA signal is present) and approximately 10 seconds (with a LOCA signal present), and 65% (Degraded Voltage Low Setting). The Degraded Voltage LOCA Function preserves the assumptions of the LOCA analysis and the Degraded Voltage Low Setting Function preserves the assumptions of the accident sequence analysis in the FSAR. The circuitry is designed such that with the LOCA signal present, the non-LOCA time delay is physically bypassed.

The Bus Undervoltage Allowable Values are low enough to prevent inadvertent power supply transfer, but high enough to ensure that sufficient power is available to the required equipment. The Time Delay Allowable Values are long enough to provide time for the offsite power supply to recover to normal voltages, but short enough to ensure that sufficient power is available to the required equipment.

Two channels of 4.16 kV Emergency Bus Undervoltage (Degraded Voltage) per Function (Functions 2 and 3) per associated bus are required to be OPERABLE when the associated DG is required to be OPERABLE. This ensures no single instrument failure can preclude the start of DGs (each logic inputs to each of the four DGs). Refer to LCO 3.8.1 and LCO 3.8.2 for Applicability Bases for the DGs.

ACTIONS A Note has been provided to modify the ACTIONS related to LOP instrumentation channels. Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into SUSQUEHANNA - UNIT 2 3.3-209

Rev. 4 LOP Instrumentation B 3.3.8.1 BASES ACTIONS C.1 (continued)

With one or more channels of a Function inoperable, the Function is not capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, the channel must be placed in the tripped condition per Required Action C.1. Placing the inoperable channel in trip would conservatively compensate for the inoperability, restore capability to accommodate a single failure (within the LOP instrumentation), and allow operation to continue. Alternately, if it is not desired to place the channel in trip (e.g., as in the case where placing the channel in trip would result in a DG initiation), Condition E must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration or tripping of channels.

D.1 With one channel of the Function inoperable, the Function is not capable of performing the intended function. Therefore, only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed to restore the inoperable channel to OPERABLE status. If the inoperable channel cannot be restored to OPERABLE status within the allowable out of service time, Condition E must be entered and its Required Action taken.

The Completion Time is intended to allow the operator time to evaluate and repair any discovered inoperabilities. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of channels.

E.1 If the Required Action and associated Completion Times of Conditions B, C, or D are not met, the associated Function is not capable of performing the intended function. Therefore, the associated DG(s) is declared inoperable immediately for Unit 2 only. This requires entry into applicable Conditions and Required Actions of Unit 2 LCO 3.8.1 and LCO 3.8.2, which provide appropriate actions for the inoperable DG(s).

SUSQUEHANNA - UNIT 2 3.3-211

Rev. 5 RPV Water Inventory Control B 3.5.2 B 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM B 3.5.2 RPV Water Inventory Control BASES BACKGROUND The RPV contains penetrations below the top of the active fuel (TAF) that have the potential to drain the reactor coolant inventory to below the TAF.

If the water level should drop below the TAF, the ability to remove decay heat is reduced, which could lead to elevated cladding temperatures and clad perforation. Safety Limit 2.1.1.3 requires the RPV water level to be above the top of the active irradiated fuel at all times to prevent such elevated cladding temperatures.

APPLICABLE With the unit in MODE 4 or 5, RPV water inventory control is not required SAFETY to mitigate any events or accidents evaluated in the safety analyses.

ANALYSES RPV water inventory control is required in MODES 4 and 5 to protect Safety Limit 2.1.1.3 and the fuel cladding barrier to prevent the release of radioactive material to the environment should an unexpected draining event occur.

A double-ended guillotine break of the Reactor Coolant System (RCS) is not postulatedconsidered in MODES 4 and 5 due to the reduced RCS pressure, reduced piping stresses, and ductile piping systems. Instead, an event is considered in which ansingle operator error or initiating event allows draining of the RPV water inventory through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common mode failure (an event that creates a drain path through multiple vessel penetrations located below top of active fuel, such ase.g., seismic event, loss of normal power, or a single human error). It is assumed, based on engineering judgement, that while in MODES 4 and 5, one low pressure ECCS injection/spray subsystem can maintain adequate reactor vessel water level.

As discussed in References 1, 2, 3, 4, and 5, operating experience has shown RPV water inventory to be significant to public health and safety.

Therefore, RPV Water Inventory Control satisfies Criterion 4 of 10 CFR 50.36(c)(2)(ii).

SUSQUEHANNA - UNIT 2 3.5-17

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES LCO The RPV water level must be controlled in MODES 4 and 5 to ensure that (continued) if an unexpected draining event should occur, the reactor coolant water level remains above the top of the active irradiated fuel as required by Safety Limit 2.1.1.3.

The Limiting Condition for Operation (LCO) requires the DRAIN TIME of RPV water inventory to the TAF to be 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A DRAIN TIME of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate unexpected draining of reactor coolant. An event that could cause loss of RPV water inventory and result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

One low pressure ECCS injection/spray subsystem is required to be OPERABLE and capable of being manually aligned and started from the control room to provide defense-in- depth should an unexpected draining event occur. OPERABILITY of the ECCS injection/spray subsystem includes any necessary valves, instrumentation, or controls needed to manually align and start the subsystem from the control room. A low pressure ECCS injection/spray subsystem consists of either one Core Spray (CS) subsystem or one Low Pressure Coolant Injection (LPCI) subsystem. Each CS subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool or condensate storage tank (CST) to the RPV. Each LPCI subsystem consists of one motor driven pump, piping, and valves to transfer water from the suppression pool to the RPV. In MODES 4 and 5, the RHR System cross tie valves are not required to be closed.

The LCO is modified by a Note which allows a required LPCI subsystem to be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned (remote or local) to the LPCI mode and is not otherwise inoperable. Alignment and operation for decay heat removal includes when the required RHR pump is not operating or when the system is realigned from or to the RHR shutdown cooling mode. This allowance is necessary since the RHR System may be required to operate in the shutdown cooling mode to remove decay heat and sensible heat from the reactor. Because of the restrictions on DRAIN TIME, sufficient time will be available following an unexpected draining event to manually align and initiate LPCI subsystem operation to maintain RPV water inventory prior to the RPV water level reaching the TAF.

SUSQUEHANNA - UNIT 2 3.5-18

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES APPLICABILITY RPV water inventory control is required in MODES 4 and 5. Requirements on water inventory control in other MODES are contained in LCOs in Section 3.3, Instrumentation, and other LCOs in Section 3.5, ECCS, RCIC, and RPV Water Inventory Control, and RCIC System. RPV water inventory control is required to protect Safety Limit 2.1.1.3 which is applicable whenever irradiated fuel is in the reactor vessel.

ACTIONS A.1 and B.1 If the required low pressure ECCS injection/spray subsystem is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

In this Condition, the LCO controls on DRAIN TIME minimize the possibility that an unexpected draining event could necessitate the use of the ECCS injection/spray subsystem, however the defense-in-depth provided by the ECCS injection/spray subsystem is lost.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for restoring the required low pressure ECCS injection/spray subsystem to OPERABLE status is based on engineering judgment that considers the LCO controls on DRAIN TIME and the low probability of an unexpected draining event that would result in loss of RPV water inventory.

If the inoperable ECCS injection/spray subsystem is not restored to OPERABLE status within the required Completion Time, action must be initiated immediately to establish a method of water injection capable of operating without offsite electrical power. The method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The method of water injection may be manually initiated and may consist of one or more systems or subsystems, and must be able to access water inventory capable of maintaining the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . If recirculation of injected water would occur, it may be credited in determining the necessary water volume.

C.1, C.2, and C.3 With the DRAIN TIME less than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months but greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , compensatory measures should be taken to ensure the ability to implement mitigating actions should an unexpected draining event occur.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that SUSQUEHANNA - UNIT 2 3.5-19

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES ACTIONS C.1, C.2, and C.3 (continued)

(continued)

Required Actions C.1, C.2, and C.3 are considered to be met when secondary containment, secondary containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

D.1, D.2, D.3, and D.4 With the DRAIN TIME less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , mitigating actions are implemented in case an unexpected draining event should occur. Note that if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , Required Action E.1 is also applicable.

Required Action D.1 requires immediate action to establish an additional method of water injection augmenting the ECCS injection/spray subsystem required by the LCO. The additional method of water injection includes the necessary instrumentation and controls, water sources, and pumps and valves needed to add water to the RPV or refueling cavity should an unexpected draining event occur. The Note to Required Action D.1 states that either the ECCS injection/spray subsystem or the additional method of water injection must be capable of operating without offsite electrical power. The additional method of water injection may be manually initiated and may consist of one or more systems or subsystems. The additional method of water injection must be able to access water inventory capable of being injected to maintain the RPV water level above the TAF for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The additional method of water injection and the ECCS injection/spray subsystem may share all or part of the same water sources. If recirculation of injected water would occur, it may be credited in determining the required water volume.

Should a draining event lower the reactor coolant level to below the TAF, there is potential for damage to the reactor fuel cladding and release of radioactive material. Additional actions are taken to ensure that radioactive material will be contained, diluted, and processed prior to being released to the environment.

The secondary containment provides a control volume in which fission products can be contained, diluted, and processed prior to release to the environment. Required Action D.2 requires that actions be immediately initiated to establish the secondary containment boundary. With the secondary containment boundary established, one SGT subsystem is capable of maintaining a negative pressure in the secondary containment with respect to the environment.

SUSQUEHANNA - UNIT 2 3.5-21

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES ACTIONS D.1, D.2, D.3, and D.4 (continued)

(continued)

The secondary containment penetrations form a part of the secondary containment boundary. Required Action D.3 requires that actions be immediately initiated to verify that each secondary containment penetration flow path is isolated or to verify that it can be automatically or manually isolated from the control room.

One SGT subsystem is capable of maintaining the secondary containment at a negative pressure with respect to the environment and filter gaseous releases. Required Action D.4 requires that actions be immediately initiated to verify that at least one SGT subsystem is capable of being placed in operation. The required verification is an administrative activity and does not require manipulation or testing of equipment.

Required Actions D.2, D.3, and D.4 are considered to be met when secondary containment, secondary containment penetrations, and the SGT System are OPERABLE in accordance with LCO 3.6.4.1, LCO 3.6.4.2, and LCO 3.6.4.3.

E.1 If the Required Actions and associated Completion times of Conditions C or D are not met or if the DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , actions must be initiated immediately to restore the DRAIN TIME to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In this condition, there may be insufficient time to respond to an unexpected draining event to prevent the RPV water inventory from reaching the TAF.

Note that Required Actions D.1, D.2, D.3, and D.4 are also applicable when DRAIN TIME is less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

SURVEILLANCE SR 3.5.2.1 REQUIREMENTS This Surveillance verifies that the DRAIN TIME of RPV water inventory to the TAF is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The period of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is considered reasonable to identify and initiate action to mitigate draining of reactor coolant. Loss of RPV water inventory that would result in the RPV water level reaching the TAF in greater than 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months does not represent a significant challenge to Safety Limit 2.1.1.3 and can be managed as part of normal plant operation.

The definition of DRAIN TIME states that realistic cross-sectional areas and drain rates are used in the calculation. A realistic drain rate may be determined using a single, step-wise, or integrated calculation considering the changing RPV water level during a draining event. For a Control Rod RPV penetration flow path with the Control Rod Drive Mechanism removed SUSQUEHANNA - UNIT 2 3.5-22

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS (continued) and not replaced with a blank flange, the realistic cross-sectional area is based on the control rod blade seated in the control rod guide tube. If the control rod blade will be raised from the penetration to adjust or verify seating of the blade, the exposed cross-sectional area of the RPV penetration flow path is used.

The definition of DRAIN TIME excludes from the calculation those penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlledlocked, sealed, or otherwise secured in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths. A blank flange or other bolted device must be connected with a sufficient number of bolts to prevent draining in the event of an Operating Basis Earthquake. Normal or expected leakage from closed systems or past isolation devices is permitted. Determination that a system is intact and closed or isolated must consider the status of branch lines and ongoing plant maintenance and testing activities.

The Residual Heat Removal (RHR) Shutdown Cooling System is only considered an intact closed system when misalignment issues (Reference 6) have been precluded by functional valve interlocks or by isolation devices, such that redirection of RPV water out of an RHR subsystem is precluded. Further, RHR Shutdown Cooling System is only considered an intact closed system if its controls have not been transferred to Remote Shutdown, which disables the interlocks and isolation signals.

The exclusion of a single penetration flow paths, or multiple penetration flow paths susceptible to a common mode failure, from the determination of DRAIN TIME mustshould consider the potential effects of temporary alterations in support of maintenancea single operator error or initiating event on items supporting maintenance and testing (rigging, scaffolding, temporary shielding, piping plugs, snubber removal, freeze seals, etc.). If reasonable controls are implemented to prevent If failure of such itemstemporary alterations from could result and would causinge a draining event from a closed system or between the RPV and the isolation device, the effect of the temporary alterations on DRAIN TIME need not be considered. Reasonable controls include, but are not limited to, the penetration flow path may not be excluded from the DRAIN TIME calculation.controls consistent with the guidance in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 4, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, or commitments to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.

SUSQUEHANNA - UNIT 2 3.5-23

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 (continued)

REQUIREMENTS (continued) Surveillance Requirement 3.0.1 requires SRs to be met between performances. Therefore, any changes in plant conditions that would change the DRAIN TIME requires that a new DRAIN TIME be determined.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.2 and SR 3.5.2.3 The minimum water level of 20 ft. 0 inches required for the suppression pool is periodically verified to ensure that the suppression pool will provide adequate net positive suction head (NPSH) for the CS subsystem or LPCI subsystem pump, recirculation volume, and vortex prevention. With the suppression pool water level less than the required limit, the required ECCS injection/spray subsystem is inoperable unless aligned to an OPERABLE CST.

The required CS System is considered OPERABLE if it can take suction from the CST, and the CST water level is sufficient to provide the required NPSH for the CS pump. Therefore, a verification that either the suppression pool water level is 20 ft. 0 inches or that a required CS subsystem is aligned to take suction from the CST and the CST contains 135,000 gallons of water, equivalent to 49% of capacity, ensures that the CS Subsystem can supply at least 135,000 gallons of makeup water to the RPV.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.4 The flow path piping has the potential to develop voids and pockets of entrained air. Maintaining the pump discharge lines of the required ECCS injection/spray subsystems full of water ensures that the ECCS subsystem will perform properly. This may also prevent a water hammer following an ECCS initiation signalactuation. One acceptable method of ensuring that the lines are full is to vent at the high points.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SUSQUEHANNA - UNIT 2 3.5-24

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.5 REQUIREMENTS (continued) Not UsedVerifying the correct alignment for manual, power operated, and automatic valves in the required ECCS subsystem flow paths provides assurance that the proper flow paths will be available for ECCS operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an initiation signal is allowed to be in a nonaccident position provided the valve will automatically reposition in the proper stroke time. This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.6 Verifying that the required ECCS injection/spray subsystem can be manually aligned, and the pump started and operated for at least 10 minutes demonstrates that the subsystem is available to mitigate a draining event. This SR is modified by two Notes. Note 1 states that Ttesting the ECCS injection/spray subsystem may be done through the test returnrecirculation line is necessary to avoid overfilling the refueling cavity.

Note 2 states that credit for meeting the SR may be taken for normal system operation that satisfies the SR, such as using the RHR mode of LPCI for 10 minutes. The minimum operating time of 10 minutes was based on engineering judgment.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.5.2.7 Verifying that each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated RPV water level isolation signal is required to prevent RPV water inventory from dropping below the TAF should an unexpected draining event occur.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SUSQUEHANNA - UNIT 2 3.5-25

Rev. 5 RPV Water Inventory Control B 3.5.2 BASES SURVEILLANCE SR 3.5.2.8 REQUIREMENTS (continued) The required ECCS subsystem is required to actuate on a manual initiation signal. This Surveillance verifies that a manual initiation signal will cause the required CS subsystem or LPCI subsystem can be manually aligned and started from the control room, including any necessary valve alignment, instrumentation, or controls, to transfer water from the suppression pool or CST to the RPVto start and operate as designed, including pump startup and actuation of all automatic valves to their required positions.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that excludes vessel injection/spray during the Surveillance. Since all active components are testable and full flow can be demonstrated by recirculation through the test line, coolant injection into the RPV is not required during the Surveillance.

REFERENCES 1. Information Notice 84-81 "Inadvertent Reduction in Primary Coolant Inventory in Boiling Water Reactors During Shutdown and Startup,"

November 1984.

2. Information Notice 86-74, "Reduction of Reactor Coolant Inventory Because of Misalignment of RHR Valves," August 1986.

3. Generic Letter 92-04, "Resolution of the Issues Related to Reactor Vessel Water Level Instrumentation in BWRs Pursuant to 10 CFR 50.54(f), " August 1992.

4. NRC Bulletin 93-03, "Resolution of Issues Related to Reactor Vessel Water Level Instrumentation in BWRs," May 1993.

5. Information Notice 94-52, "Inadvertent Containment Spray and Reactor Vessel Draindown at Millstone 1," July 1994.

6. General Electric Service Information Letter No. 388, "RHR Valve Misalignment During Shutdown Cooling Operation for BWR 3/4/5/6,"

February 1983.

SUSQUEHANNA - UNIT 2 3.5-26

Rev. 18 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.1 REQUIREMENTS This SR ensures that the primary containment purge valves are closed as required or, if open, open for an allowable reason. If a purge valve is open in violation of this SR, the valve is considered inoperable. If the inoperable valve is not otherwise known to have excessive leakage when closed, it is not considered to have leakage outside of limits. If a LOCA inside primary containment occurs in MODES 1, 2, or 3, the purge valves may not be capable of closing before the pressure pulse affects systems downstream of the purge valves, or the release of radioactive material will exceed limits prior to the purge valves closing. At other times when the purge valves are required to be capable of closing (e.g., during handling of irradiated fuel),

pressurization concerns are not present and the purge valves are allowed to be open. The SR is modified by a Note stating that the SR is not required to be met when the purge valves are open for the stated reasons. The Note states that these valves may be opened for inerting, de-inerting, pressure control, ALARA or air quality considerations for personnel entry, or Surveillances that require the valves to be open. The vent and purge valves are capable of closing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.1.3.2 This SR verifies that each primary containment isolation manual valve and blind flange that is located outside primary containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed. The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the primary containment boundary is within design limits.

This SR does not require any testing or valve manipulation. Rather, it involves verification that those PCIVs outside primary containment, and capable of being mispositioned, are in the correct position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Two Notes have been added to this SR. The first Note allows valves and blind flanges located in high radiation areas to be verified by use of administrative controls. Allowing verification by administrative controls is considered acceptable since access to these areas is typically restricted during MODES 1, 2, and 3 for ALARA reasons. Therefore, the probability of misalignment of these PCIVs, once they have been verified to be in the proper position, is low. A second Note has been included to clarify that SUSQUEHANNA - UNIT 2 3.6-23

Rev. 18 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.5 REQUIREMENTS (continued) Verifying the isolation time of each power operated and each automatic PCIV is within limits is required to demonstrate OPERABILITY. MSIVs may be excluded from this SR since MSIV full closure isolation time is demonstrated by SR 3.6.1.3.7. The isolation time test ensures that the valve will isolate in a time period less than or equal to that assumed in the Final Safety Analyses Report. The isolation time and Frequency of this SR are in accordance with the requirements of the Inservice Testing Program.

SR 3.6.1.3.6 For primary containment purge valves with resilient seals, the Appendix J Leakage Rate Test Interval is sufficient. The acceptance criteria for these valves is defined in the Primary Containment Leakage Rate Testing Program, 5.5.12.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

If a LOCA inside primary containment occurs in MODES 1, 2, or 3, purge valve leakage must be minimized to ensure offsite radiological release is within limits. At other times when the purge valves are required to be capable of closing (e.g., during handling of irradiated fuel), pressurization concerns are not present and the purge valves are not required to meet any specific leakage criteria.

SR 3.6.1.3.7 Verifying that the isolation time of each MSIV is within the specified limits is required to demonstrate OPERABILITY. The isolation time test ensures that the MSIV will isolate in a time period that does not exceed the times assumed in the DBA analyses. This ensures that the calculated radiological consequences of these events remain within regulatory limits.

The Frequency of this SR is in accordance with the requirements of the Inservice Testing Program.

SUSQUEHANNA - UNIT 2 3.6-25

Rev. 18 PCIVs B 3.6.1.3 BASES SURVEILLANCE SR 3.6.1.3.11 REQUIREMENTS (continued) This SR ensures that the leakage rate of secondary containment bypass leakage paths is less than the specified leakage rate. This provides assurance that the assumptions in the radiological evaluations of Reference 4 are met. The secondary containment leakage pathways and Frequency are defined by the Primary Containment Leakage Rate Testing Program. This SR simply imposes additional acceptance criteria. In MODES other than 1, 2, or 3, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required.

SR 3.6.1.3.12 The analyses in References 1 and 4 are based on the specified leakage rate.

Leakage through each MSIV must be 100 scfh for anyone MSIV and 300 scfh for total leakage through the MSIVs combined with the Main Steam Line Drain Isolation Valve, HPCI Steam Supply Isolation Valve and the RCIC Steam Supply Isolation Valve. The MSIVs can be tested at either > Pt (24.3 psig) or Pa (48.6 psig). Main Steam Line Drain Isolation, HPCI and RCIC Steam Supply Line Isolation Valves, are tested at Pa (48.6 psig). In MODES other than 1, 2, or 3, the Reactor Coolant System is not pressurized and specific primary containment leakage limits are not required. The Frequency is required by the Primary Containment Leakage Rate Testing Program.

SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 2 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 3.3 gpm when tested at 1.1 Pa, (53.46 psig). The combined leakage rates must be demonstrated in accordance with the leakage rate test Frequency required by the Primary Containment Leakage Testing Program.

As noted in Table B 3.6.1.3-1, PCIVs associated with this SR are not Type C tested. Containment bypass leakage is prevented since the line terminates below the minimum water level in the suppression chamber. These valves are tested in accordance with the IST Program. Therefore, these valves leakage is not included as containment leakage.

In some instances, the valves are required to be capable of automatically closing during MODES other than MODES 1, 2, and 3. However, specific leakage limits are not applicable in these other MODES or conditions.

SUSQUEHANNA - UNIT 2 3.6-27

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.8, "Distribution SystemsShutdown,"

ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a Distribution System Engineered Safeguards System (ESS) bus required OPERABLE by LCO 3.8.8, ensures that a diverse power source is available for providing electrical power support assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and the ability to manually start a DG ensures the availability of sufficient AC sources to operate the plant in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuit(s) must be capable of maintaining rated frequency and voltage while connected to their respective ESS bus(es),

and of accepting required loads during an accident. Qualified offsite circuits are those that are described in the FSAR and are part of the licensing basis for the unit. An offsite circuit includes all breakers, transformers, switches, automatic tap changers, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESS bus or buses. The offsite circuit consists of the incoming breaker and disconnect to startup transformers (ST) No. 10 and ST No. 20 and the respective circuit path including feeder breakers to the four 4.16 kV ESS buses (A, B, C and D) for both Unit 1 and Unit 2. A detailed description of the offsite power network and circuits to the onsite Class 1E ESS buses is found in the FSAR, Section 8.2.

The required DG must be capable of being manually startedstarting, accelerating to rated speed and voltage, connecting to its respective ESS bus on detection of bus undervoltage, and capable of accepting required loads. This sequence must be accomplished within 10 seconds. Each DG must also be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESS buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with engine hot. Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

SUSQUEHANNA - UNIT 2 3.8-41

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES LCO Proper sequencing of loads, including tripping of nonessential loads, is a (continued) required function for DG OPERABILITY. In addition, proper sequence operation is an integral part of offsite circuit OPERABILITY since its inoperability impacts the ability to start and maintain energized loads required OPERABLE by LCO 3.8.8.

APPLICABILITY The AC sources are required to be OPERABLE in MODES 4 and 5 and during movement of irradiated fuel assemblies in the secondary containment to provide assurance that:

a. Systems that provide core cooling are available;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

AC power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.1.

ACTIONS The ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations.

A.1 With one or more required AC Sources (DGs or 4.16 kV ESS buses) inoperable, the remaining required sources may be capable of supporting sufficient required features (e.g., system, subsystem, divisions, component or device), to allow continuation of CORE ALTERATIONS and fuel movement. For example, if two or more 4 kV emergency buses are required per LCO 3.8.8, one 4.16 kV emergency bus with offsite SUSQUEHANNA - UNIT 2 3.8-42

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES ACTIONS A.2.1, and A.2.2, and A.2.3 (continued)

(continued)

Because of the allowance provided by LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A have been modified by a Note to indicate that when Condition A is entered with no AC power to any required ESS bus, ACTIONS for LCO 3.8.8 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit whether or not a 4.16 kV ESS bus is de-energized. LCO 3.8.8 provides the appropriate restrictions for the situation involving a de-energized 4.16 kV ESS bus.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, and 3. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.18, and SR 3.8.1.19 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not required. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with the DGs that are not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note that specified SRs must be met but are not required to be performed. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during the performance of SRs, and to preclude de-energizing a required 4160 V ESS bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG.

It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

SUSQUEHANNA - UNIT 2 3.8-44

Rev. 1 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.2 REQUIREMENTS (continued) This Surveillance is provided to direct that the appropriate Surveillances for Unit 1 AC sources required to support Unit 2 are governed by the Unit 2 Technical Specifications. With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.1.1 through SR 3.8.1.20) are applicable to the Unit 2 AC sources only. Meeting the SR requirements of Unit 1 LCO 3.8.1 will satisfy all Unit 2 requirements for Unit 1 AC sources.

However, six ten Unit 1 LCO 3.8.1 SRs, if not required to support Unit 1 OPERABILITY requirements, are not required when demonstrating Unit 1 sources are capable of supporting Unit 2. SR 3.8.1.8 is not required if only one Unit 1 offsite circuit is required by the Unit 2 Specification. SR 3.8.1.7, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.15, SR 3.8.1.17, SR 3.8.1.18 and SR 3.8.1.19 are not required to be met because DG start and load within a specified time and response on an offsite power or ECCS initiation signal is not requiredsince these SRs test the Unit 1 ECCS initiation signal, which is not needed for the AC sources to be OPERABLE on Unit 2. SR 3.8.1.20 is not required since starting independence is not required with the DG(s) not required to be OPERABLE.

The Frequency required by the applicable Unit 1 SR also governs performance of that SR for Unit 2.

As Noted, if Unit 1 is in MODE 4 or 5, the Note to Unit 1 SR 3.8.2.1 is applicable. This ensures that a Unit 2 SR will not require a Unit 1 SR to be performed, when the Unit 1 Technical Specifications do not require performance of a Unit 1 SR. (However, as stated in the Unit 2 SR 3.8.2.1 Note, while performance of an SR is not required, the SR still must be met).

REFERENCES 1. Final Policy Statement on Technical Specifications Improvements, July 22, 1993 (58 FR 39132).

SUSQUEHANNA - UNIT 2 3.8-45

v t e Letter Sequence Request
EPID:L-2020-LLA-0197, TSTF-582 (Approved, Closed)
Initiation Request Acceptance, Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2020-09-16 [Table View]

ML20245E192

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