Text

Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence
	ML23159A160
Person / Time
Site:	Susquehanna
Issue date:	06/08/2023
From:	Casulli E; Susquehanna, Talen Energy
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	PLA-8054
	Download: ML23159A160 (1)
	v • d • e

TALEN~

Edward Casulli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 ENERGY Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@talenenergy.com June 8, 2023 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: REMOVE CONTROL ROD OPERABILITY SEPARATION CRITERIA AND REPLACE REFERENCE TO BANKED POSITION WITHDRAWAL SEQUENCE WITH THE ANALYZED ROD POSITION SEQUENCE Docket No. 50-387 PLA-8054 and 50-388

References:

1) Framatome Topical Report ANP-10333P-A, Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA), dated March 2018 (ADAMS Accession No. ML18208A448).

2) Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendment Nos. 278 and 260 to Allow Application of Advance Framatome ATRIUM 11 Fuel Methodologies (EPID L-2019-LLA-0153), dated January 21, 2021 (ADAMS Accession No. ML20164A181 [Proprietary]).

3) Susquehanna Steam Electric Station, Unit 2 - Issuance of Amendment No. 268 Re: Change to Certain Technical Specification for Control Rods (Emergency Circumstances) (EPID L-2023-LLA-0003), dated January 15, 2023 (ADAMS Accession No. ML23010A108).

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. The proposed amendment would modify TS 3.1.3, Control Rod Operability, TS 3.1.6, Rod Pattern Control, TS 3.3.2.1, Control Rod Block Instrumentation, TS 3.10.7, Control Rod Testing -

Operating, and TS 3.10.8, Shutdown Margin (SDM) Test - Refueling. The proposed amendment would modify the current requirements on control rod withdrawal order and conditions to

Document Control Desk PLA-8054 protect against a postulated control rod drop accident (CRDA) during startup and low power conditions.

The proposed amendment would remove TS 3.1.3 Limiting Condition of Operation (LCO),

Conditions D and E, eliminating the control rod operability separation criteria and banked position withdrawal sequence (BPWS) group requirements in startup or low power conditions.

The proposed amendment would also modify TS 3.1.6, 3.3.2.1, 3.10.7, and 3.10.8 to replace current reference to BPWS with reference to the analyzed rod position sequence to allow for greater flexibility in control rod operations during various stages of reactor power operation.

These changes would align the plant startup sequences with the calculated control rod reactivity worths during the control rod withdrawal process.

The analyzed rod position sequence is evaluated consistent with NRC approved methodology described in Framatome Topical Report ANP-10333P-A, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA), (Reference 1) which was previously approved for use at Susquehanna as described in Reference 2 and incorporated as approved methods under Units 1 and 2 TS 5.6, Administrative Controls.

The use of the analyzed rod position sequence in lieu of only BPWS was previously approved for Susquehanna, Unit 2, as a one-time only change in Reference 3. The proposed amendment would remove notation of the one-time only allowance and modify the Unit 2 TS sections to apply the analyzed rod position sequence permanently. provides a description and assessment of the proposed changes along with Susquehanna's determination that the proposed changes do not involve a significant hazard consideration. Enclosure 2 provides the existing TS pages marked to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides the existing TS Bases pages marked up to show the proposed changes and is provided for information only.

Susquehanna requests NRC approval of the proposed changes and issuance of the requested license amendment by June 30, 2024. 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.

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.

Document Control Desk PLA-8054 Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager - Nuclear Regulatory Affairs, at (570) 542-1818.

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

Executed on June 8, 2023.

E. Casulli

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. C. Highley, NRC Senior Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PA DEP/BRP

Enclosure 1 to PLA-8054 Description and Assessment

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3. TECHNICAL EVALUATION

3.1 Background

3.2 Proposed Change

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Considerations Analysis 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Enclosure 1 to PLA-8054 Page 1 of 13 SUSQUEHANNA ASSESSMENT

1. Summary Description 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. The proposed amendment would modify TS 3.1.3, Control Rod Operability, TS 3.1.6, Rod Pattern Control, TS 3.3.2.1, Control Rod Block Instrumentation, TS 3.10.7, Control Rod Testing -

Operating, and TS 3.10.8, Shutdown Margin (SDM) Test - Refueling. The proposed amendment would modify the current requirements on control rod withdrawal order and conditions to protect against a postulated control rod drop accident (CRDA) during startup and low power conditions.

The proposed amendment would remove TS 3.1.3 Limiting Condition of Operation (LCO),

Conditions D and E, eliminating the control rod operability separation criteria and banked position withdrawal sequence (BPWS) requirements in startup or low power conditions. The proposed amendment would also modify TS 3.1.6, 3.3.2.1, 3.10.7, and 3.10.8 to replace current reference to BPWS with reference to the analyzed rod position sequence to allow for greater flexibility in control rod operations during various stages of reactor power operation. These changes would align the plant startup sequences with the calculated control rod reactivity worths during the control rod withdrawal process.

The analyzed rod position sequence is evaluated consistent with NRC approved methodology described in Framatome Topical Report ANP-10333P-A, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA), (Reference 1) which was previously approved for use at Susquehanna as described in Reference 2 and incorporated as approved methods under Units 1 and 2 TS 5.6, Administrative Controls.

The use of the analyzed rod position sequence in lieu of only BPWS was previously approved for Susquehanna, Unit 2, as a one-time only change in Reference 3. The proposed amendment would remove notation of the one-time only allowance and modify the Unit 2 TS sections to apply the analyzed rod position sequence permanently.

2. Detailed Description 2.1 System Design and Operation Control Rods are components of the Control Rod Drive (CRD) System, which is the primary reactivity control system for the reactor. In conjunction with the Reactor Protection System, the

Enclosure 1 to PLA-8054 Page 2 of 13 CRD System provides the means for the reliable control of reactivity changes to ensure under conditions of normal operation, including anticipated operational occurrences, that specified acceptable fuel design limits are not exceeded. In addition, the control rods provide the capability to hold the reactor core subcritical under all conditions and to limit the potential amount and rate of reactivity increase caused by a malfunction in the CRD System.

Control rod patterns during startup conditions are controlled by the plant operator and the rod worth minimizer (RWM), so that only specified control rod sequences and relative positions are allowed over the operating range of all control rods inserted to 10% rated thermal power (RTP).

The sequences limit the potential amount of reactivity addition that could occur in the event of a CRDA.

The CRDA is a postulated event in which a high worth control rod is inserted into the core.

Subsequently, it becomes decoupled from its drive mechanism. The mechanism is withdrawn but the decoupled control rod is assumed to be stuck in place. At a later optimum moment, the control rod suddenly falls free and drops out of the core. This results in the insertion of large positive reactivity to the core and causes a localized power excursion.

2.2 Current Technical Specifications Requirements TS 3.1.3 requires each control rod to be operable in Modes 1 and 2. Condition D requires, for two or more inoperable control rods not in compliance with BPWS and not separated by two or more operable control rods, that compliance with the BPWS shall be restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or the control rods shall be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Condition E requires, for one or more BPWS groups with four or more inoperable control rods, that the control rod be restored to operable status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If the Required Actions of Conditions D or E are not met within the specified Completion Times, Condition F requires placing the reactor in Mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . A note identifies Conditions D and E are not applicable when thermal power is greater than 10% RTP.

TS 3.1.6 requires operable control rods to comply with the requirements of the BPWS in Modes 1 and 2 with thermal power less than or equal to 10% RTP. Condition A requires, for one or more operable control rods that are not in compliance with BPWS, that the associated control rod shall be moved to the correct position within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or the control rod shall be declared inoperable within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Condition B requires, for nine or more operable control rods that are not in compliance with the BPWS, withdrawal of control rods shall be suspended immediately, and the reactor mode switch shall be placed in shutdown within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Surveillance Requirement (SR) 3.1.6.1 requires all operable control rods to comply with BPWS in accordance with the Surveillance Frequency Control Program.

TS 3.3.2.1 requires the control rod block instrumentation for each function in Table 3.3.2.1-1 to be operable according to Table 3.3.2.1-1. Condition C requires for the RWM inoperable during

Enclosure 1 to PLA-8054 Page 3 of 13 reactor startup, that control rod movement be suspended other than by scram immediately OR the verification of at least 12 rods withdrawn OR verification by administrative methods that startup with the RWM inoperable has not been performed in the last calendar year immediately, AND verification of movement of control rods is in compliance with BPWS by a second licensed operator or other qualified member of the technical staff during control rod movement.

Condition D requires for the RWM inoperable during reactor shutdown, that movement of control rods is in accordance with BPWS and verified by a second licensed operator or other qualified member of the technical staff. SR 3.3.2.1.8 requires control rod sequence input into the RWM are in conformance with BPWS, prior to declaring the RWM operable following loading of the sequence into the RWM.

TS 3.10.7 allows the requirements of LCO 3.1.6 to be suspended for performance of SDM demonstrations, control rod scram time testing, control rod friction testing, and the Start-up Test Program provided the banked position withdrawal sequence requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence OR the RWM is bypassed; the requirements of LCO 3.3.2.1, Function 2 are suspended; and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or other qualified member of the technical staff.

TS 3.10.8 identifies the reactor mode switch position specified in Table 1.1-1 for Mode 5 may be changed to include the startup/hot standby position, and operation considered not to be in Mode 2, to allow SDM testing provided the specified requirements are met. Requirements related to BPWS include 1) LCO 3.3.2.1 Mode 2 requirements for Function 2 of Table 3.3.2.1-1, with the BPWS requirements of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence or conformance to the approved control rod sequence for the SDM test is verified by a second licensed operator or other qualified member of the technical staff and 2) all control rod withdrawals that are not in conformance with the BPWS shall be made in notch out mode.

2.3 Reason for the Proposed Change As currently required in the identified TS sections, control rod manipulations and separation criteria must comply with the requirements of the BPWS. These BPWS requirements are identified in NEDO-21231, Banked Position Withdrawal Sequence, dated January 1977 (Reference 4). Utilizing the phrase, analyzed rod position sequence in lieu of BPWS will provide greater flexibility in cycle-specific control rod patterns for cases when it is desirable to maintain a control rod fully inserted. This would include situations in which suspected channel bow locations or failed fuel suppression rods requiring rod insertion do not conform to BPWS requirements. The analyzed rod position sequence utilized is developed using NRC approved methods for use at Susquehanna as identified and implemented under Reference 1 and Reference 2, respectively.

Enclosure 1 to PLA-8054 Page 4 of 13 2.4 Description of the Proposed Change The proposed change deletes TS 3.1.3 Condition D and Condition E. TS 3.1.3 Condition F is updated accordingly to address the removal of Conditions D and E. The proposed change to Unit 2 TS 3.1.3 includes deletion of a temporary footnote that was incorporated by Reference 5.

The proposed change revises TS 3.1.6 to replace reference to BPWS with reference to the analyzed rod position sequence. Replacement of this reference is proposed for the LCO statement, Conditions A and B, and SR 3.1.6.1. The proposed change to Unit 2 TS 3.1.6 includes deletion of temporary notes and footnotes that were incorporated by Reference 5.

The proposed change revises TS 3.3.2.1 to replace reference to BPWS with reference to the analyzed rod position sequence. Replacement of this reference is proposed for Required Actions C.2.2 and D.1, and SR 3.3.2.1.8. The proposed change to Unit 2 TS 3.3.2.1 includes deletion of temporary footnotes that were incorporated by Reference 5.

The proposed change revises TS 3.10.7 to replace reference to BPWS with reference to the analyzed rod position sequence. Replacement of this reference is proposed for the LCO statement.

The proposed change revises TS 3.10.8 to replace reference to BPWS with reference to the analyzed rod position sequence. Replacement of this reference is proposed for the LCO statement.

Editorial formatting revisions were made to the applicable TS sections as identified in the enclosed markups.

The proposed TS pages are provided in Enclosures 2 and 3. Conforming changes are made to the TS Bases, and are provided in Enclosure 4 for information only.

3. Technical Evaluation

3.1 Background

General Design Criteria (GDC) 28, Reactivity Limits, of 10 CFR 50, Appendix A requires reactivity control systems to be designed with appropriate limits on the potential amount and rate of reactivity increase to ensure that the effects of postulated reactivity accidents can neither result in damage to the reactor coolant pressure boundary greater than limited local yielding, nor sufficiently disturb the core, its support structures, or other reactor pressure vessel internals so as to impair significantly the capability to cool the core. GDC 28 also requires that these postulated

Enclosure 1 to PLA-8054 Page 5 of 13 reactivity accidents include consideration of rod ejection (unless prevented by positive means),

rod dropout, steam line rupture, changes in reactor coolant temperature and pressure, and cold-water addition.

The design basis accident that results in a positive reactivity insertion in a Boiling Water Reactor (BWR) is the CRDA which assumes a control rod inadvertently and unknowingly becomes uncoupled from its control rod drive mechanism prior to or during it being withdrawn, and at a later point in time, after the decoupled drive is completely withdrawn, the control rod drops fully out of the core creating a positive reactivity addition and local power excursion. The BPWS limits the potential reactivity increase from a postulated CRDA during reactor startups and shutdowns below the low power setpoint (LPSP) of 10% RTP. CRDA analyses assume that the plant operator follows prescribed withdrawal sequences. These sequences define the potential initial conditions for the CRDA analysis.

Historically, to limit the impact of a CRDA, the BPWS is applied to both reactor startup and shutdown processes. Utilizing rod pattern control systems, such as the RWM, which applies the BPWS constraints, the maximum control rod worth during each step of the startup and shutdown process is reduced. The RWM and plant operator actions function within the constraints of the BPWS to regulate control rod manipulations and thus limit control rod worths. This minimizes the potential reactivity addition should a CRDA actually occur during the evolution. The RWM provides a backup to the plant operator control of the withdrawal sequences to ensure that the initial conditions assumed in the CRDA analysis remain bounding and are not violated. The RWM and plant operator actions are controlled by plant procedures during the evolution.

3.2 Proposed Change This proposed change will allow startup sequence modifications beyond those allowed by the general requirements of the BPWS and will result in an overall reduction in unnecessary reactivity manipulations and associated operational challenges. This change will allow control rods to remain inserted in control cells with suspected channel bow or failed fuel suppression rods. The change will also allow optimization of cycle-specific control rod startup and shutdown sequences that conform to the Susquehanna CRDA requirements. These sequences will be developed to minimize incremental control rod reactivity worth in accordance with the NRC approved methodology in Reference 1. Cycle-specific CRDA results are reviewed and approved in accordance with the 10 CFR 50.59 process.

The Core Operating Limits Report (COLR) contains cycle-specific fuel thermal operating limits and cycle-specific rod block setpoints. TS 5.6.5 defines the contents of the COLR. Rod sequence patterns and control rod separation criteria do not fall within the category of information currently specified by Technical Specifications for incorporation into the COLR.

Enclosure 1 to PLA-8054 Page 6 of 13 The Susquehanna calculation process is used to control the development, approval, and documentation of analyzed control rod sequences. This is consistent with existing process controls used in the development of BPWS compliant sequences. All sequences will continue to be documented in an engineering calculation. Existing administrative controls will continue to provide a back-up methodology to the RWM in assuring compliance with analyzed sequences.

Reference 1 was approved by the NRC for licensing applications and approved for use by Susquehanna by Reference 2. The approved methodology provides flexibility in withdrawal sequences beyond those allowed by the general requirements of the BPWS. The term analyzed rod position sequence is used to indicate that the sequence, regardless of the use of BPWS, will meet the same CRDA technical requirements as BPWS. The sequence will be developed using the same NRC approved methods as those used to support the current CRDA analysis and will be implemented in a manner equivalent to those used in the implementation of BPWS compliant sequences.

TS 3.1.3 Condition D for two or more inoperable control rods not in compliance with the BPWS and not separated by two or more operable control rods is being deleted. This condition is a generic BPWS requirement, which is superseded by the analyzed rod position sequence. The analyzed rod position sequence is evaluated consistent with the Reference 1 methodology, which has no required separation criteria. Any such configurations would be included in or bounded by the analyzed rod position sequence. Section 7.3 of Reference 1 describes selection of initial conditions that represent the most limiting conditions for the CRDA. Inoperable rod locations are defined consistent with those allowed by plant technical specifications in such a manner to maximize the worth of the candidate rods. This is typically done by assigning the out of service rods in close proximity to each other in one half of the core. If necessary, it is also done by using alternate inoperable rod locations to maximize the worth of the dropped rod.

These alternate inoperable locations may not be limited to one half of the core. The selection of the inoperable rods is based on the core size, the rod grouping assignments, and the rod withdrawal sequence. The actual determination of the out of sequence rod is determined on a plant specific basis. Therefore, the elimination of TS 3.1.3, Condition D is appropriate.

TS 3.1.3 Condition E for one or more BPWS groups with four or more inoperable control rods is being deleted. This condition is a generic BPWS requirement, which is superseded by adherence to the analyzed rod position sequence. There are no limitations on the number of inoperable rods in any one BPWS group in the Reference 1 methodology. Section 7.3 of Reference 1 describes selection of initial conditions that represent the most limiting conditions for the CRDA.

Inoperable rod locations are defined consistent with those allowed by plant technical specifications in such a manner to maximize the worth of the candidate rods. This is typically done by assigning the out of service rods in close proximity to each other in one half of the core.

If necessary, it is also done by using alternate inoperable rod locations to maximize the worth of the dropped rod. These alternate inoperable locations may not be limited to one half of the core.

The selection of the inoperable rods is based on the core size, the rod grouping assignments, and

Enclosure 1 to PLA-8054 Page 7 of 13 the rod withdrawal sequence. The actual determination of the out of sequence rod is determined on a plant specific basis. Therefore, the elimination of TS 3.1.3, Condition E is appropriate.

TS 3.1.6 requires that OPERABLE control rods shall comply with the requirements of the banked position withdrawal sequence (BPWS). The replacement of BPWS with analyzed rod position sequence in TS 3.1.6, including SR 3.1.6.1, allows for compliance with the cycle-specific analyzed rod position sequence. Section 4.2 of Reference 1 states that The Banked Position Withdrawal Sequence is an example of a set of restrictions intended to reduce the maximum rod worth that is used by most BWRs. These type of withdrawal sequences are typically enforced with rod pattern control systems. The AREVA CRDA methodology presented herein can be applied to any specified rod withdrawal sequence. Therefore, the use of an analyzed rod position sequence is consistent with the methodology defined in Reference 1.

The analyzed rod position sequence will be controlled using existing controls under TS 3.1.6, as BPWS has been controlled, via the RWM and TS 3.3.2.1. Therefore, the proposed change to TS 3.1.6 is appropriate.

Consistent with the changes to TS 3.1.6 and allowance under the Reference 1 methodology, modification to TS 3.3.2.1 Required Actions C.2.2 and D.1, and SR 3.3.2.1.8 is necessary to permit compliance with the analyzed rod position sequence in lieu of BPWS.

TS 3.3.2.1 enforces the use of the BPWS via the RWM. In lieu of use of BPWS, cycle specific analyses may also be performed to develop control rod sequences, referred to as the analyzed rod position sequence. The RWM operability requirements remain unchanged and will enforce the analyzed rod position sequence instead of the BPWS. TS 3.3.2.1 Required Action C.2.2 states that in the event the RWM is inoperable during reactor startup, that movement of control rods is in compliance with the banked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff. Required Action D.1 requires for the RWM inoperable during reactor shutdown, that movement of control rods is in accordance with BPWS and verified by a second licensed operator or other qualified member of the technical staff. SR 3.3.2.1.8 requires verification of the control rod sequences input to the RWM are in conformance with BPWS. Required Actions C.2.2 and D.1, and SR 3.3.2.1.8 are being modified to replace reference to BPWS with reference to the analyzed rod position sequence. This modification ensures consistency between TS requirements and ensures that the use of the RWM to enforce control rod movement under analyzed sequences is maintained.

Cycle-specific control rod patterns will continue to be controlled by the plant operator and the RWM so that only specified control rod sequences and relative positions are allowed over the operating range of all control rods inserted to 10% of RTP. As a result of this proposed change, these sequences will continue to limit the potential amount of reactivity addition that could occur in the event of a CRDA.

TS 3.10.7 and 3.10.8 enforce controls during Special Operations for Control Rod Testing -

Operating and SDM Test - Refueling, respectively. Both TS sections reference the BPWS as the

Enclosure 1 to PLA-8054 Page 8 of 13 enforced pull sequence, and provide administrative controls for rod sequences that do not comply with BPWS during performance of those tests. The replacement of the reference to BPWS with a reference to the analyzed rod position sequence is consistent with the aforementioned technical changes.

4. Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria The proposed amendment has been evaluated to ensure the applicable regulations and requirements continue to be met.

Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2)(ii), paragraph (C), Criterion 3, states that a technical specification limiting condition of operation of a nuclear reactor must be established for a structure, system, or component that is the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

This regulatory requirement primarily applies to ensuring that the limiting system operating parameters and other controls in place (i.e., rod withdrawal limitations) are sufficient to ensure that the CRDA acceptance criteria are not exceeded. This is satisfied by ensuring that the initial conditions and limitations on rod withdrawal represented in the CRDA analyses are sufficiently representative or otherwise bound the most severe conditions allowed by the aforementioned controls.

GDC 28, "Reactivity Limits," of 10 CFR Part 50, Appendix A, requires that the effects of postulated reactivity accidents result in neither damage to the reactor coolant pressure boundary greater than limited local yielding nor result in sufficient damage to impair significantly core cooling capacity.

Conclusion Susquehanna has determined that the proposed amendment conforms to the NRC approved methodology identified in Reference 1 and therefore remains in conformance with the SSES licensing basis and applicable regulatory requirements.

4.2 Precedent In Reference 6, the NRC granted approval to Constellation Energy Generation, LLC, to revise the TS of LaSalle Unit 1 and 2 to remove TS 3.1.3 Condition D for Two or more inoperable control rods not in compliance with analyzed rod position sequence and not separated by two or more OPERABLE control rods. LaSalle applied NRC approved CRDA methodology allowing

Enclosure 1 to PLA-8054 Page 9 of 13 greater flexibility in control rod operations during various stages of reactor power operation and allowing removal of control rod operability separation criterion while operating in these conditions. Similar to LaSalle, SSES proposes applying NRC approved CRDA methodology to remove control rod operability separation criteria from TS 3.1.3, allowing greater flexibility during startup and low power conditions.

In Reference 7, the NRC granted approval to Exelon Generation Company, LLC, to revise the TS of Peach Bottom Units 2 and 3 to replace reference to banked position withdrawal sequence with reference to the analyzed rod position sequence in TS Sections 3.1.3, 3.1.6, 3.3.2.1, 3.10.7, and 3.10.8. Peach Bottom applied NRC approved methodology for developing control rod position sequences allowing shutdown/startup sequence modification beyond those allowed by the general requirements of the BPWS. Similar to Peach Bottom, SSES proposes applying NRC approved CRDA methodology for development of these control rod position sequences and modification to the same TS sections.

4.3 No Significant Hazards Considerations Analysis In accordance with the requirements of 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), requests an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2. The proposed amendment would modify TS 3.1.3, Control Rod Operability, TS 3.1.6, Rod Pattern Control, TS 3.3.2.1, Control Rod Block Instrumentation, TS 3.10.7, Control Rod Testing - Operating, and TS 3.10.8, Shutdown Margin (SDM) Test - Refueling, to allow for greater flexibility in rod control operations during various stages of reactor power operation.

The proposed amendment will modify the current requirements on control rod withdrawal order and conditions to protect against a postulated control rod drop accident (CRDA) during startup and low power conditions. The changes are being implemented to align the plant startup sequences with the calculated control rod reactivity worths, based on the analyzed rod position sequence. The analyzed rod position sequence is developed consistent with the NRC approved Framatome Topical Report ANP-10333P-A, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA), methodology, approved for use in Susquehanna TS 5.6, Administrative Controls. Cycle-specific CRDA results are reviewed and approved under the 10 CFR 50.59 process. This methodology incorporates the characteristics of advanced fuel products and the latest analytical methods into the design basis for the CRDA to meet the requirements for fuel cladding failure thresholds and allow more flexibility during plant startups. The proposed amendment would replace the current reference to Banked Position Withdrawal Sequence (BPWS) with the analyzed rod position sequence.

Susquehanna has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of SSES in accordance with the proposed amendment presents

Enclosure 1 to PLA-8054 Page 10 of 13 no significant hazards. Susquehannas evaluation against each of the criteria in 10 CFR 50.92 follows.

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

Response: No The proposed change will modify TS Sections 3.1.3, 3.1.6, 3.3.2.1, 3.10.7, and 3.10.8.

The proposed change would replace the current references to Banked Position Withdrawal Sequence (BPWS) with reference to the analyzed rod position sequence. The analyzed rod position sequence will continue to minimize the consequences of the CRDA.

Additionally, the analyzed rod position sequence will provide an equivalent level of protection during plant startups and shutdowns and therefore will not increase the consequences of the CRDA.

Control rod patterns during startup and shutdown conditions will continue to be controlled by the plant operator and the Rod Worth Minimizer (RWM) (TS 3.3.2.1), so that only specified control rod sequences and relative positions are allowed over the operating range of all control rods inserted to 10% of Rated Thermal Power (RTP). As a result of this change, these sequences will continue to limit the potential amount of reactivity addition that could occur in the event of a CRDA.

Accidents are initiated by the malfunction of plant equipment, or the failure of plant structures, systems, or components. There are no changes being implemented to plant structures, systems, or components. The proposed changes will ensure that incremental control rod reactivity worths continue to be minimized by implementing rod withdrawal sequences that comply with the analyzed rod position sequence developed in accordance with the NRC approved Framatome Topical Report ANP-10333P-A methodology implemented in Susquehanna TS 5.6. These analyzed rod position sequences will limit the potential reactivity increase for a postulated CRDA during reactor startups and shutdowns below the Low Power Setpoint of 10% of RTP.

The proposed change will continue to ensure that systems, structures, and components are capable of performing their intended safety functions.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Enclosure 1 to PLA-8054 Page 11 of 13

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 does not affect the assumed accident performance of the control rods, nor any plant structure, system or component previously evaluated. The change does not involve a physical alteration of the plant (i.e., no different SSCs will be installed) or a change in the methods governing normal plant operations. The analyzed rod position sequence will be established pursuant to the approved methods controlling normal plant operations. As such, the proposed change does not introduce new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing basis.

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 ensures that analyzed rod position sequences are developed to minimize incremental control rod reactivity worth in accordance with the NRC approved Framatome Topical Report ANP-10333P-A methodology implemented in Susquehanna TS 5.6. Cycle-specific CRDA results are reviewed and approved in accordance with the 10 CFR 50.59 process. The proposed change will not adversely impact the plants response to an accident or transient. All current safety margins will be maintained. There are no changes proposed which alter the set points to which protective actions are initiated and there is no change to the operability requirements for equipment assumed to operate for accident mitigation.

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

Based on the above evaluation, Susquehanna concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions 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,

Enclosure 1 to PLA-8054 Page 12 of 13 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.

5. Environmental Consideration Susquehanna has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment 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 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. References

1. Framatome Topical Report ANP-10333P-A, Revision 0, AURORA-B: An Evaluation Model for Boiling Water Reactors; Application to Control Rod Drop Accident (CRDA),

dated March 2018 (ADAMS Accession No. ML18208A448).

2. Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendment Nos. 278 and 260 to Allow Application of Advance Framatome ATRIUM 11 Fuel Methodologies (EPID L-2019-LLA-0153), dated January 21, 2021 (ADAMS Accession No. ML20164A181 [Proprietary]).

3. Susquehanna Steam Electric Station, Unit 2 - Issuance of Amendment No. 268 Re:

Change to Certain Technical Specification for Control Rods (Emergency Circumstances)

(EPID L-2023-LLA-0003), dated January 15, 2023 (ADAMS Accession No. ML23010A108).

4. General Electric Company Topical Report NEDO-21231, Banked Position Withdrawal Sequence, General Electric Company, dated January 1977 (ADAMS Accession No. ML090771242 (non-public)).

5. Susquehanna Steam Electric Station, Unit 2 - Issuance of Amendment No. 268 Re:

Change to Certain Technical Specification for Control Rods (Emergency Circumstances)

(EPID L-2023-LLA-0003), dated January 15, 2023 (ADAMS Accession No. ML23010A108).

Enclosure 1 to PLA-8054 Page 13 of 13

6. LaSalle County Station, Units 1 and 2 - Issuance of Amendment Nos. 255 and 241 Re:

Revision to Technical Specification to Incorporate Licensing Topical Report NEDE-33885P-A, Revision 1, GNF CRDA Application Methodology (EPID L-2021-LLA-0016), dated February 4, 2022 (ADAMS Accession No. ML21362A721).

7. Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendment Re:

Deletion of Reference to Banked Position Withdrawal Sequence in the Technical Specification (TAC Nos. MD2310 and MD2311), dated June 29, 2007 (ADAMS Accession No. ML071720314).

Enclosure 2 of PLA-8054 Marked-Up Technical Specification Pages Revised Technical Specifications Pages Unit 1 TS Pages 3.1-8, 3.1-9, 3.1-10, 3.1-18, 3.1-19, 3.3-17, 3.3-18, 3.3-19, 3.3-20, 3.10-18, 3.10-20 Unit 2 TS Pages 3.1-9, 3.1-10, 3.1-18, 3.1-19, 3.3-17, 3.3-20, 3.10-18, 3.10-20

Control Rod OPERABILITY 3.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Perform SR 3.1.3.3 for each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery withdrawn OPERABLE control of Condition A rod. concurrent with Formatting change THERMAL POWER only. greater than the low power setpoint (LPSP) of the RWM.

AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A.4 Perform SR 3.1.1.1.

B. Two or more withdrawn B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control rods stuck.

C. One or more control C.1 ----------------NOTE----------------

rods inoperable for RWM may be bypassed as reasons other than allowed by LCO 3.3.2.1, if Condition A or B. required, to allow insertion of inoperable control rod and continued operation.

Fully insert inoperable control 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rod.

AND C.2 Disarm the associated CRD. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SUSQUEHANNA - UNIT 1 3.1-8 Amendment 178, 250, xxx

Control Rod OPERABILITY 3.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. -------------NOTE---------- D.1 Restore compliance with 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Not applicable when BPWS.

THERMAL POWER

> 10% RTP. OR Two or more inoperable D.2 Restore control rod to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months control rods not in OPERABLE status.

compliance with banked position withdrawal sequence (BPWS) and not separated by two or more OPERABLE control rods.

E. -------------NOTE---------- E.1 Restore control rod to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Not applicable when OPERABLE status.

THERMAL POWER

> 10% RTP.

One or more BPWS groups with four or more inoperable control rods.

FD. Required Action and FD.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or, C, D, or E not met.

OR Nine or more control rods inoperable.

SUSQUEHANNA - UNIT 1 3.1-9 Amendment 178, xxx

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program Formatting change SR 3.1.3.2 NOT USED only SR 3.1.3.3 -------------------------------NOTE-------------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.1-9 Amendment 178, xxx

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.3.4 Verify each control rod scram time from fully withdrawn to In accordance with notch position 05 is 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR 3.1.3.5 Verify each control rod does not go to the withdrawn Each time the control overtravel position. rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling SUSQUEHANNA - UNIT 1 3.1-10 Amendment 178, 250, 266, xxx

Rod Pattern Control 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Rod Pattern Control LCO 3.1.6 OPERABLE control rods shall comply with the requirements of the analyzed rod position sequencebanked position withdrawal sequence (BPWS).

APPLICABILITY: MODES 1 and 2 with THERMAL POWER 10% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more OPERABLE A.1 -----------------NOTE-----------------

control rod(s) not in Rod worth minimizer (RWM) compliance with the may be bypassed as allowed analyzed rod position by LCO 3.3.2.1, "Control Rod sequenceBPWS. Block Instrumentation."

Move associated control rod(s) to correct position. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR A.2 Declare associated control rod(s) inoperable. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months SUSQUEHANNA - UNIT 1 3.1-18 Amendment 178, xxx

Rod Pattern Control 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more OPERABLE B.1 ---------------NOTE-------------------

control rods not in Rod worth minimizer (RWM) compliance with the may be bypassed as allowed analyzed rod position by LCO 3.3.2.1.

sequenceBPWS. ------------------------------------------

Suspend withdrawal of control Immediately rods.

AND B.2 Place the reactor mode switch 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in the shutdown position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with the In accordance with analyzed rod position sequenceBPWS. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.1-19 Amendment 178, 266, xxx

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Rod worth minimizer C.1 Suspend control rod Immediately (RWM) inoperable movement except by scram.

during reactor startup.

OR C.2.1.1 Verify 12 rods withdrawn. Immediately OR C.2.1.2 Verify by administrative Immediately methods that startup with RWM inoperable has not been performed in the last calendar year.

AND C.2.2 Verify movement of control During control rod rods is in compliance with movement the analyzed rod position sequencebanked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff.

D. RWM inoperable during D.1 Verify movement of control During control rod reactor shutdown. rods is in accordance with movement the analyzed rod position sequence BPWS by a second licensed operator or other qualified member of the technical staff.

SUSQUEHANNA - UNIT 1 3.3-17 Amendment 178, 282, xxx

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One or more Reactor E.1 Suspend control rod Immediately Mode Switch-Shutdown withdrawal.

Position channels inoperable. AND E.2 Initiate action to fully insert Immediately all insertable control rods in core cells containing one or more fuel assemblies.

SURVEILLANCE REQUIREMENTS

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

1. Refer to Table 3.3.2.1-1 to determine which SRs apply for each Control Rod Block Function.

2. When an RBM 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 control rod block capability.

SURVEILLANCE FREQUENCY SR 3.3.2.1.1 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.2 -------------------------------NOTE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after any control rod is withdrawn at 10% RTP in MODE 2.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.3-18 Amendment 178, 230, 242, 266, 282, xxx

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.3 -------------------------------NOTE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after THERMAL POWER is 10% RTP in MODE 1.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.4 Verify the RBM: In accordance with the Surveillance

a. Low Power Range - Upscale Function is not Frequency Control bypassed when APRM Simulated Thermal Power Program is 28% RTP and Intermediate Power Range Setpoint specified in the COLR.

b. Intermediate Power Range - Upscale Function is not bypassed when APRM Simulated Thermal Power is > Intermediate Power Range Setpoint specified in the COLR and High Power Range Setpoint specified in the COLR.

c. High Power Range - Upscale Function is not bypassed when APRM Simulated Thermal Power is > High Power Range Setpoint specified in the COLR.

SR 3.3.2.1.5 Verify the RWM is not bypassed when THERMAL In accordance with POWER is 10% RTP. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.3-19 Amendment 178, 242, 266, 282, xxx

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.6 -------------------------------NOTE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.7 -------------------------------NOTE--------------------------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 Verify control rod sequences input to the RWM are in Prior to declaring conformance with the analyzed rod position RWM OPERABLE sequenceBPWS. following loading of sequence into RWM SUSQUEHANNA - UNIT 1 3.3-20 Amendment 178, 230, 242, 282, xxx

Control Rod Testing - Operating 3.10.7 3.10 SPECIAL OPERATIONS 3.10.7 Control Rod Testing - Operating LCO 3.10.7 The requirements of LCO 3.1.6, Rod Pattern Control, may be suspended to allow performance of SDM demonstrations, control rod scram time testing, control rod friction testing and the Start-up Test Program, provided:

a. The analyzed rod position sequencebanked position withdrawal sequence requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence.

OR

b. The RWM is bypassed; the requirements of LCO 3.3.2.1, Control Rod Block Instrumentation, Function 2 are suspended; and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or other qualified member of the technical staff.

APPLICABILITY: MODES 1 and 2 with LCO 3.1.6 not met.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Suspend performance of the Immediately not met. test and exception to LCO 3.1.6.

SUSQUEHANNA - UNIT 1 3.10-18 Amendment 178, xxx

SDM Test - Refueling 3.10.8 3.10 SPECIAL OPERATIONS 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling LCO 3.10.8 The reactor mode switch position specified in Table 1.1-1 for MODE 5 may be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SDM testing, provided the following requirements are met:

a. LCO 3.3.1.1, Reactor Protection System Instrumentation, MODE 2 requirements for Functions 2.a, 2.d, and 2.e of Table 3.3.1.1-1;

b. 1. LCO 3.3.2.1, Control Rod Block Instrumentation, MODE 2 requirements for Function 2 of Table 3.3.2.1-1, with the analyzed rod position sequencebanked position withdrawal sequence requirements of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence.

OR

2. Conformance to the approved control rod sequence for the SDM test is verified by a second licensed operator or other qualified member of the technical staff;

c. Each withdrawn control rod shall be coupled to the associated CRD;

d. All control rod withdrawals that are not in conformance with the analyzed rod position sequenceBPWS shall be made in notch out mode;

e. No other CORE ALTERATIONS are in progress; and

f. CRD charging water header pressure 940 psig.

APPLICABILITY: MODE 5 with the reactor mode switch in startup/hot standby position.

SUSQUEHANNA - UNIT 1 3.10-20 Amendment 178, 230, 254, xxx

Control Rod OPERABILITY 3.1.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. -----------NOTE------------ D.1 Restore compliance with 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Not applicable when BPWS.

THERMAL POWER

> 10% RTP. OR Two or more inoperable D.2 Restore control rod to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months control rods not in OPERABLE status.

compliance with banked position OR withdrawal sequence (BPWS) and not D.3 Confirm compliance with the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months separated by two or analyzed rod position more OPERABLE sequence.1 control rods.

E. -----------NOTE------------ E.1 Restore control rod to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Not applicable when OPERABLE status.

THERMAL POWER

> 10% RTP. OR One or more BPWS E.2 Confirm compliance with the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months groups with four or analyzed rod position more inoperable control sequence.1 rods.

DF. Required Action and FD.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A, or C, D, or E not met.

OR Nine or more control rods inoperable.

1 This Required Action is only applicable during the remainder of Unit 2, Cycle 21. Upon completion of Unit 2, Cycle 21, this temporary allowance is no longer applicable and will expire on April 15, 2023.

SUSQUEHANNA - UNIT 2 3.1-9 Amendment 151, 268, xxx

Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program Formatting change only SR 3.1.3.2 NOT USED SR 3.1.3.3 -------------------------------NOTE-------------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.1-9 Amendment 151, 268, xxx

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.3.4 Verify each control rod scram time from fully withdrawn to In accordance with notch position 05 is 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR 3.1.3.5 Verify each control rod does not go to the withdrawn Each time the overtravel position. control rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling SUSQUEHANNA - UNIT 2 3.1-10 Amendment 151, 229, 247, xxx

Rod Pattern Control 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Rod Pattern Control LCO 3.1.6 OPERABLE control rods shall comply with the requirements of the analyzed rod position sequencebanked position withdrawal sequence (BPWS).

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

For Unit 2, Cycle 21 only, OPERABLE control rods may comply with the requirements of the analyzed rod position sequence in lieu of the banked position withdrawal sequence.1 APPLICABILITY: MODES 1 and 2 with THERMAL POWER 10% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 -----------------NOTE-----------------

OPERABLE control Rod worth minimizer (RWM) rod(s) not in compliance may be bypassed as allowed with the analyzed rod by LCO 3.3.2.1, "Control Rod position Block Instrumentation."

sequence.BPWS.2 ------------------------------------------

Move associated control rod(s) 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to correct position.

OR A.2 Declare associated control 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rod(s) inoperable.

1 This Note is only applicable during the remainder of Unit 2, Cycle 21. Upon completion of Unit 2, Cycle 21, this temporary allowance is no longer applicable and will expire on April 15, 2023.

2 During Unit 2, Cycle 21 only, one or more OPERABLE control rods not in compliance with the analyzed rod position sequence requires entry into Condition A. The Required Actions remain unchanged except that Required Action A.1 refers to the correct position per the analyzed rod position sequence in lieu of BPWS. Upon completion of Unit 2, Cycle 21, this temporary requirement is no longer applicable and will expire on April 15, 2023.

SUSQUEHANNA - UNIT 2 3.1-18 Amendment 151, 268, xxx

Rod Pattern Control 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more B.1 ---------------NOTE-------------------

OPERABLE control rods Rod worth minimizer (RWM) not in compliance with may be bypassed as allowed the analyzed rod by LCO 3.3.2.1.

position ------------------------------------------

sequence.BPWS. 1 Suspend withdrawal of control Immediately rods.

AND B.2 Place the reactor mode switch 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in the shutdown position.

1 During Unit 2, Cycle 21 only, nine or more OPERABLE control rods not in compliance with the analyzed rod position sequence requires entry into Condition B. The Required Actions remain unchanged. Upon completion of Unit 2, Cycle 21, this temporary requirement is no longer applicable and will expire on April 15, 2023.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with the In accordance with analyzed rod position sequence.BPWS. 2 the Surveillance Frequency Control Program 2 During Unit 2, Cycle 21 only, verification of compliance with the analyzed rod position sequence may be performed in lieu of compliance with the BPWS to meet SR 3.1.6.1. Upon completion of Unit 2, Cycle 21, this temporary allowance is no longer applicable and will expire on April 15, 2023.

SUSQUEHANNA - UNIT 2 3.1-19 Amendment 151, 247, 268, xxx

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Rod worth minimizer C.1 Suspend control rod Immediately (RWM) inoperable movement except by scram.

during reactor startup.

OR C.2.1.1 Verify 12 rods withdrawn. Immediately OR C.2.1.2 Verify by administrative Immediately methods that startup with RWM inoperable has not been performed in the last calendar year.

AND C.2.2 Verify movement of control During control rod rods is in compliance with movement the analyzed rod position sequencebanked position withdrawal sequence (BPWS) by a second licensed operator or other qualified member of the technical staff.1 D. RWM inoperable during D.1 Verify movement of control During control rod reactor shutdown. rods is in accordance with movement the analyzed rod position sequenceBPWS by a second licensed operator or other qualified member of the technical staff.1 1 During Unit 2, Cycle 21 only, verification of compliance with the analyzed rod position sequence may be performed in lieu of verification of compliance with BPWS to meet Required Actions C.2.2 and D.1. Upon completion of Unit 2, Cycle 21, this temporary allowance is no longer applicable and will expire on April 15, 2023.

SUSQUEHANNA - UNIT 2 3.3-17 Amendment 151, 265, 268, xxx

Control Rod Block Instrumentation 3.3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.1.6 -------------------------------NOTE--------------------------------

Not required to be performed until 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after reactor mode switch is in the shutdown position.

Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.7 -------------------------------NOTE--------------------------------

Neutron detectors are excluded.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.1.8 Verify control rod sequences input to the RWM are in Prior to declaring conformance with the analyzed rod position RWM OPERABLE sequence.BPWS.1 following loading of sequence into RWM 1 During Unit 2, Cycle 21 only, verification of compliance with the analyzed rod position sequence may be performed in lieu of verification of compliance with BPWS to meet SR 3.3.2.1.8. Upon completion of Unit 2, Cycle 21, this temporary allowance is no longer applicable and will expire on April 15, 2023.

SUSQUEHANNA - UNIT 2 3.3-20 Amendment 151, 207, 220, 265, 268, xxx

Control Rod Testing - Operating 3.10.7 3.10 SPECIAL OPERATIONS 3.10.7 Control Rod Testing - Operating LCO 3.10.7 The requirements of LCO 3.1.6, Rod Pattern Control, may be suspended to allow performance of SDM demonstrations, control rod scram time testing, control rod friction testing and the Start-up Test Program, provided:

a. The analyzed rod position sequencebanked position withdrawal sequence requirements of SR 3.3.2.1.8 are changed to require the control rod sequence to conform to the specified test sequence.

OR

b. The RWM is bypassed; the requirements of LCO 3.3.2.1, Control Rod Block Instrumentation, Function 2 are suspended; and conformance to the approved control rod sequence for the specified test is verified by a second licensed operator or other qualified member of the technical staff.

APPLICABILITY: MODES 1 and 2 with LCO 3.1.6 not met.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Suspend performance of the Immediately not met. test and exception to LCO 3.1.6.

SUSQUEHANNA - UNIT 2 3.10-18 Amendment 151, xxx

SDM Test - Refueling 3.10.8 3.10 SPECIAL OPERATIONS 3.10.8 SHUTDOWN MARGIN (SDM) Test - Refueling LCO 3.10.8 The reactor mode switch position specified in Table 1.1-1 for MODE 5 may be changed to include the startup/hot standby position, and operation considered not to be in MODE 2, to allow SDM testing, provided the following requirements are met:

a. LCO 3.3.1.1, Reactor Protection System Instrumentation, MODE 2 requirements for Functions 2.a, 2.d and 2.e of Table 3.3.1.1-1;

b. 1. LCO 3.3.2.1, Control Rod Block Instrumentation, MODE 2 requirements for Function 2 of Table 3.3.2.1-1, with the analyzed rod position sequencebanked position withdrawal sequence requirements of SR 3.3.2.1.8 changed to require the control rod sequence to conform to the SDM test sequence.

OR

2. Conformance to the approved rod sequence for the SDM test is verified by a second licensed operator or other qualified member of the technical staff;

c. Each withdrawn control rod shall be coupled to the associated CRD;

d. All control rod withdrawals that are not in conformance with the analyzed rod position sequenceBPWS shall be made in notch out mode;

e. No other CORE ALTERATIONS are in progress; and

f. CRD charging water header pressure 940 psig.

APPLICABILITY: MODE 5 with the reactor mode switch in startup/hot standby position.

SUSQUEHANNA - UNIT 2 3.10-20 Amendment 151, 207, 234, xxx

Enclosure 3 of PLA-8054 Revised (Clean) Technical Specification Pages Revised Technical Specifications Pages Unit 1 TS Pages 3.1-8, 3.1-9, 3.1-10, 3.1-18, 3.1-19, 3.3-17, 3.3-18, 3.3-19, 3.3-20, 3.10-18, 3.10-20 Unit 2 TS Pages 3.1-9, 3.1-10, 3.1-18, 3.1-19, 3.3-17, 3.3-20, 3.10-18, 3.10-20

Control Rod OPERABILITY 3.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Perform SR 3.1.3.3 for each 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery withdrawn OPERABLE control of Condition A rod. concurrent with THERMAL POWER Formatting change greater than the low only power setpoint (LPSP) of the RWM.

AND A.4 Perform SR 3.1.1.1. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B. Two or more withdrawn B.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control rods stuck.

C. One or more control C.1 ----------------NOTE----------------

rods inoperable for RWM may be bypassed as reasons other than allowed by LCO 3.3.2.1, if Condition A or B. required, to allow insertion of inoperable control rod and continued operation.

Fully insert inoperable control 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rod.

AND C.2 Disarm the associated CRD. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SUSQUEHANNA - UNIT 1 3.1-8 Amendment 178, 250, xxx

Control Rod OPERABILITY 3.1.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time of Condition A or C not met.

OR Nine or more control rods inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Determine the position of each control rod. In accordance with the Surveillance Frequency Control Program Formatting change SR 3.1.3.2 NOT USED only SR 3.1.3.3 -------------------------------NOTE-------------------------------

Not required to be performed until 31 days after the control rod is withdrawn and THERMAL POWER is greater than the LPSP of the RWM.

Insert each withdrawn control rod at least one notch. In accordance with the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.1-9 Amendment 178, xxx

NO CHANGES - CONTENT ROLLED ACROSS PAGES ONLY Control Rod OPERABILITY 3.1.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.3.4 Verify each control rod scram time from fully withdrawn to In accordance with notch position 05 is 7 seconds. SR 3.1.4.1, SR 3.1.4.2, SR 3.1.4.3, and SR 3.1.4.4 SR 3.1.3.5 Verify each control rod does not go to the withdrawn Each time the control overtravel position. rod is withdrawn to "full out" position AND Prior to declaring control rod OPERABLE after work on control rod or CRD System that could affect coupling SUSQUEHANNA - UNIT 1 3.1-10 Amendment 178, 250, 266, xxx

Rod Pattern Control 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Rod Pattern Control LCO 3.1.6 OPERABLE control rods shall comply with the requirements of the analyzed rod position sequence.

APPLICABILITY: MODES 1 and 2 with THERMAL POWER 10% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more OPERABLE A.1 -----------------NOTE-----------------

control rod(s) not in Rod worth minimizer (RWM) compliance with the may be bypassed as allowed analyzed rod position by LCO 3.3.2.1, "Control Rod sequence. Block Instrumentation."

Move associated control rod(s) to correct position. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR A.2 Declare associated control rod(s) inoperable. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months SUSQUEHANNA - UNIT 1 3.1-18 Amendment 178, xxx

Rod Pattern Control 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Nine or more OPERABLE B.1 ---------------NOTE-------------------

control rods not in RWM may be bypassed as compliance with the allowed by LCO 3.3.2.1.

analyzed rod position ------------------------------------------

sequence.

Suspend withdrawal of control rods. Immediately AND B.2 Place the reactor mode switch in the shutdown position. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 Verify all OPERABLE control rods comply with the In accordance with analyzed rod position sequence. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.1-19 Amendment 178, 266, xxx

Control Rod Block Instrumentation 3.3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Rod worth minimizer C.1 Suspend control rod Immediately (RWM) inoperable movement except by scram.

during reactor startup.

OR C.2.1.1 Verify 12 rods withdrawn. Immediately OR C.2.1.2 Verify by administrative Immediately methods that startup with RWM inoperable has not been performed in the last calendar year.

AND C.2.2 Verify movement of control During control rod rods is in compliance with movement the analyzed rod position sequence by a second licensed operator or other qualified member of the technical staff.

D. RWM inoperable during D.1 Verify movement of control During control rod reactor shutdown. rods is in accordance with movement the analyzed rod position sequence by a second licensed operator or other qualified member of the technical staff.