PLA-5694, Proposed Amendment Regarding Revised Main Turbine Bypass System Requirements

Proposed Amendment Regarding Revised Main Turbine Bypass System Requirements

ML033500447
Person / Time
Site:	Susquehanna
Issue date:	12/05/2003
From:	Shriver B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-5694
Download: ML033500447 (35)

Text

Bryce L. Shriver PPL Susquehanna, LLC %I I Senior Vice President and 769 Salem Boulevard % a a a* . -

ChiefNuclearOfficer Benvick, PA 18603 Tel. 570.5423120 Fax 570.542.1504 blshriverapplweb.com p I l _

DEC 0 5 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OPI-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NO. 258 TO LICENSE NFP-14 AND PROPOSED AMENDMENT NO. 223 TO LICENSE NFP-22:

REVISED MAIN TURBINE BYPASS SYSTEM REQUIREMENTS PLA-5694 Pursuant to 10 CFR 50.90, PPL Susquehanna, LLC (PPL), proposes to amend the Susquehanna Steam Electric Station Units 1 and 2 (SSES) Technical Specifications (TS).

The proposed change revises the Susquehanna Unit I and 2 Technical Specification (TS)

Section 3.7.6 to add a requirement to implement Main Turbine Bypass System inoperable Linear Heat Generation Rate (LHGR) limits if the system becomes inoperable. The proposed change parallels an already existing requirement for Minimum Critical Power Ratio (MCPR).

Licensing analyses that are performed for each core reload determine the impacts of an inoperable Main Turbine Bypass System on MCPR and LHGR limits. Currently, the Unit I and Unit 2 Core Operating Limits Reports (COLR) contain MCPR and LHGR limits when the Main Turbine Bypass System becomes inoperable. The proposed change clarifies TS 3.7.6 to state that both the MCPR and LHGR limits for an inoperable Main Turbine Bypass System are required if the system becomes inoperable. The changes are described in detail in Section 4.0 of the Enclosure to this letter.

The proposed change has been approved by the SSES Plant Operations Review Committee and reviewed by the Susquehanna Review Committee. In accordance with 10 CFR 50.91(b)(1), PPL is sending a copy of this letter to the Pennsylvania Department of Environmental Protection. /

PPL requests NRC approval of this change by August 31, 2004.

If you have any questions, please contact Mr. Duane L. Filchner at (610) 774-7819.

AODI

Document Control Desk PLA-5694 I declare under penalty of perjury that the foregoing is true and correct.

Executed on: I?°6-6 Sincerely, B. L. Shriver Sr. Vice-President and Chief Nuclear Officer

Enclosure:

PPL Evaluation of the Proposed Change Attachments:

Attachment I - Proposed Technical Specification Change (Markups)

Attachment 2 - Proposed Technical Specification Bases Change (Markups)

Attachment 3 - Proposed Technical Specification Change (Camera Ready)

Attachment 4 - List of Regulatory Commitments copy: NRC Region I Mr. S. L. Hansell, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Maiager Mr. R. Janati, DEP/BRP

ENCLOSURE to PLA-5694 PPL Evaluation REVISED MAIN TURBINE BYPASS SYSTEM REQUIREMENTS

1. DESCRIPTION

2. PROPOSED CHANGE

3. BACKGROUND

4. TECHNICAL ANALYSIS

5. REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatoy Requirements/Criteria

6. ENVIRONMENTAL CONSIDERATIONS

7. REFERENCES

Enclosure to PLA-5694 Page 1 of 7 PPL EVALUATION

1.0 DESCRIPTION

This change is a proposed amendment Operating License NPF-14 and NPF-22 for PPL Susquehanna, LLC (PPL), Susquehanna Steam Electric Station Units 1 and 2 (SSES) respectively.

Requested is a change to the Susquehanna Unit 1 and 2 Technical Specification (TS)

Section 3.7.6. The revision adds a requirement to implement Main Turbine Bypass System inoperable LHGR limits if the system becomes inoperable. The proposed change parallels an already existing requirement for MCPR. Licensing analyses are performed for each core reload to determine the impact of an inoperable Main Turbine Bypass System on MCPR and LHGR limits. Currently, the Unit 1 and Unit 2 COLRs contain MCPR and LHGR limits when the Main Turbine Bypass System becomes inoperable.

The proposed change clarifies TS 3.7.6 to state that both the MCPR and LHGR limits for an inoperable Main Turbine Bypass System are required if the system becomes inoperable. The changes are described in detail in Section 4.0.

An August 31, 2004 NRC approval date is requested.

2.0 PROPOSED CHANGE

Specifically the proposed change revises the Unit 1 and 2 TS Section 3.7.6.

The proposed change adds a requirement to The LCO and ACTION A of TS 3.7.6 to implement revised LHGR limits if the Main Turbine Bypass System becomes inoperable.

The requirement parallels an existing requirement for MCPR.

The LCO for TS 3.7.6 is revised as follows for the Main Turbine Bypass System inoperable:

Enclosure to PLA-5694 Page 2 of 7 Apply the following limits for an inoperable Main Turbine Bypass System as specified in the COLR:

a. LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," and

b. LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)."

Condition A of TS 3.7.6 was also revised as follows:

A. Main Turbine Bypass System inoperable.

AND Requirements of LCO 3.2.2 not met.

OR Requirements of LCO 3.2.3 not met.

Note that the TS Bases also require change. These changes have been included with this submittal for information.

3.0 BACKGROUND

The Main Turbine Bypass System is designed to control steam pressure when reactor steam generation exceeds turbine requirements during unit startup, sudden load reduction, and cooldown. It allows excess steam flow from the reactor to the condenser without going through the turbine, and consists of five valves with a total capacity of approximately 25% of rated steam flow. The system has two modes of operation; fast opening and pressure regulation.

The Main Turbine Bypass System fast opening mode is designed for transients that result in a rapid closure of the turbine control valves or turbine stop valves; Generator Load Reject, Turbine Trip, and Feedwater Controller Failure to High Demand. During turbine control or stop valve closure, reactor pressure and hence power increases rapidly. The fast opening response of the Main Turbine Bypass System is approximately equal to the fast closure of the turbine control and stop valves, and helps limit the pressure and power rise within the reactor.

The Main Turbine Bypass System pressure regulation mode is designed for transients where the steam flow exceeds the steam relieving capacity of the turbine control valves; Control Rod Withdrawal Error and Recirculation Flow Controller Failure to High

Enclosure to PLA-5694 Page 3 of 7 Demand. For these transients, the increase in reactor steam flow is slow and the normal pressure regulation system responds by opening the main turbine bypass valves to maintain reactor pressure.

The Main Turbine Bypass System fast opening and pressure regulation modes are required to be OPERABLE to limit the reactor pressure and power increase during the above transients so that the Safety Limit MCPR and LHGR limits are not exceeded.

With the Main Turbine Bypass System inoperable, modifications to the MCPR and LHGR limits may be applied to ensure that the requirements are met. The MCPR and LHGR limits for an inoperable Main Turbine Bypass System are specified in a unit / cycle specific COLR.

Licensing analyses are performed for each core reload to determine the impact of an inoperable Main Turbine Bypass System on the MCPR and LHGR limits. Both the Unit 1 and Unit 2 current COLRs contain revised MCPR and LHGR limits when the Main Turbine Bypass System becomes inoperable. Currently, TS 3.7.6 requires that the MCPR limits for an inoperable Main Turbine Bypass System are made applicable if the system becomes inoperable. The proposed change adds a similar requirement for LHGR.

4.0 TECHNICAL ANALYSIS

This proposed Technical Specification change adds a requirement to implement LHGR limits for an inoperable Main Turbine Bypass System if the system becomes inoperable.

The proposed change parallels an existing requirement for MCPR.

Reload analyses are performed for each unit / cycle using NRC approved methods documented in TS 5.6.5.b. The results of these analyses are MCPR and LHGR limits that are a function of Main Turbine Bypass System operability. The MCPR and LHGR limits are included in the unit / cycle specific COLRs and POWERPLEX core monitoring system input decks. Plant procedures are already in effect to adjust MCPR and LHGR limits if the Main Turbine Bypass System becomes inoperable.

The proposed change to the TS 3.7.6 does not directly or indirectly affect any plant system, equipment, component, or change the processes used to operate the plant. As discussed above, the reload analyses performed for each unit / cycle generate MCPR and LHGR limits for an inoperable Main Turbine Bypass System that meet all applicable acceptance criteria. The proposed changes do not affect the failure modes of any systems or components. Thus, the proposed change does not create the possibility of a previously unevaluated operator error or a new single failure. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Enclosure to PLA-5694 Page 4 of 7 Since the proposed change does not alter any plant system, equipment, or component, the proposed change will not jeopardize or degrade the function or operation of any plant system or component governed by Technical Specifications. The proposed change to TS 3.7.6 does not involve a significant reduction in the margin of safety as currently defined in the Bases of the applicable Technical Specification sections, because the MCPR and LHGR limits calculated for each unit / cycle preserve the required margin of safety.

Operator performance and procedures are unaffected by these proposed changes since the current COLRs contain revised MCPR and LHGR limits for an inoperable Main Turbine Bypass System. The proposed change does not change the way in which the plant is operated. The FSAR already discusses the impact of Main Turbine Bypass System operability on the reload analyses.

Therefore, the proposed action does not involve an increase in the probability or an increase in the consequences of an accident previously evaluated in the SAR. Thus, the proposed changes are in compliance with applicable regulations. The health and safety of the public is not adversely impacted by operation of SSES as proposed.

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION PPL Susquehanna, LLC (PPL) has evaluated whether or not 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 of occurrence or consequences of an accident previously evaluated?

Response: No.

The proposed change to the TS 3.7.6 does not directly or indirectly affect any plant system, equipment, component, or change the processes used to operate the plant. Further, the MCPR and LHGR limits documented in the unit / cycle specific COLRs for Main Turbine Bypass System operable and inoperable are generated using NRC approved methodology and meet the applicable acceptance criteria. The COLR operating limits thus assure that the MCPR Safety Limit and LHGR Limit will not be exceeded during normal operation or anticipated operational occurrences. Thus, this

Enclosure to PLA-5694 Page 5 of 7 proposed amendment does not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to TS 3.7.6 does not directly or indirectly affect any plant system, equipment, or component and therefore does not affect the failure modes of any of these items. Thus, the proposed changes do not create the possibility of a previously unevaluated operator error or a new single failure.

Therefore, this proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Since the proposed changes do not alter any plant system, equipment, component, or the processes used to operate the plant, the proposed change will not jeopardize or degrade the function or operation of any plant system or component governed by Technical Specifications. The proposed change to TS 3.7.6 does not involve a significant reduction in the margin of safety as currently defined in the Bases of the applicable Technical Specification sections, because the MCPR and LHGR limits calculated for Main Turbine Bypass System operable and inoperable preserve the required margin of safety.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based upon the above, PPL Susquehanna, LLC (PPL) concludes that the proposed amendment 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.

Enclosure to PLA-5694 Page 6 of 7 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA Title 10 of the Code of Federal Regulations (10 CFR) establishes the fundamental regulatory requirements with respect to reactivity control systems. Specifically, General Design Criterion 10 (GDC-10), " Reactor design," in Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 states, in part, that the reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded.

The proposed changes to TS Section 3.7.6 will ensure that fuel cladding strain will not exceed 1%. This satisfies the requirements of GDC-10 regarding acceptable fuel design limits.

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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions, which are eligible for categorical exclusion from the requirement to perform an environmental assessment.

A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. PPL Susquehanna, LLC has evaluated the proposed changes and has determined that the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Accordingly, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:

Basis As demonstrated in the No Significant Hazards Consideration Evaluation, the proposed amendment does not involve a significant hazards consideration.

Enclosure to PLA-5694 Page 7 of 7 There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

There is no significant increase in individual or cumulative occupational radiation exposure. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

7.0 REFERENCES

None.

Attachment 1 to PLA-5694 Proposed Technical Specification Changes (Markups)

(Units 1&2)

PPL Rev. 0 Main Turbine Bypass System 3.7.6 3.7

• PLANT SYSTEMS 3.7.6 Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, MINIMUM CRITICAL POWER RA.TIO (MCP), limits for an inopoablo rt1 -Miain Turbine Bypas System, as epecified in the COLR, arc madc opplicablc-

- APPLICABILITY: THERMAL POWER : 25% RTP.

ACTIONS CONDITION REQUIRED ACTION I COMPLETION TIME

• A., Main Turbine Bypass System A.1 Satisfy the requirements of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> inoperable. LCO or restore Main Turbine Bypass System to OPERABLE status.

a AND g Ie Requirements of LCO 3.22 not met.

B. Required Action and B.1 Reduce THERMAL POWER to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion Time < 25% RTP.

not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6:1 Verify one complete cycle of each required main 31 days I turbine bypass valve.

(continued)

SUSQUEHANNA - UNIT I TS / 3.7-15 Amendment 17$,-

210

INSERT 1:

Apply the following limits for an inoperable Main Turbine Bypass System as specified in the COLR:

a. LCO 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)", and

b. LCO 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)".

INSERT 2:

OR Requirements of LCO 3.2.3 not met.

.~-tJ P0 tV~A~so~J bz OtJLL/

-L0Fvv r*T10r OIJL%- Main Turbine Bypass System 3.7.6 140 Tcc~ntc Ixc ogv SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.6.2 Perform a system functional test. 24 months SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM RESPONSE 24 months TIME is within limits.

SUSQUEHANNA - UNIT 1 3.7-16 Amendment 178

PPL Rev. 0 Main Turbine Bypass System 3.7.6 3.7

• PLANT SYSTEMS 3.7.6 -Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE.

OR 1 - uOv ^ ^ as 21K11t .* SE rob .- -A I n. t fA 1If% ,a . I .

OliRft ter M.

=cr , -bM INIUM B1 AI I I i I I tMtIn*

t lom od t,-

-inoeable Main Turbine Bypass System. ArE specified in the OLR ac aden .

appligable.

APPLICABILITY: THERMAL POWER 2 25% RTP.

ACTIONS CONDITION . REQUIRED ACTION COMPLETION TIME Main Turbine Bypass A.1 Satisfy the requirements of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> System inoperable. LCO or restore Main Turbine Bypass System to OPERABLE.

AND status.

Requirements of LCO 3.2.2 not met.

B. Required Action and B.1 Reduce THERMAL POWER to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

associated Completion Time < 25% RTP.

not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of each required main 31 days I turbine bypass valve.

(continued)

SUSQUEHANNA - UNIT 2 TS/3.7-15 Amendment Xi 185

INSERT 1:

Apply the following limits for an inoperable Main Turbine Bypass System as specified in the COLR:

a. LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)", and

b. LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)".

INSERT 2:

OR Requirements of LCO 3.2.3 not met.

'1i)b - ra e- P% -t i yj orLy Main Turbine Bypass System 3.7.6 No 'Re A LL Ckto4^tc SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.6.2 Perform a system functional test. 24 months SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEMRESPONSE 24 months TIME is within limits.

SUSQUEHANNA - UNIT 2 3.7-16 -Amendment 151

Attachment 2 to PLA-5694 Proposed Technical Specification Bases Changes (Markups)

(Units 1&2)

PPL Rev. 0 Main Turbine Bypass System B 3.7.6 IB 3.7

• PLANT SYSTEMS B 3.7.6 Main Turbine Bypass System BASES BACKGROUND The Main Turbine Bypass System is designed to control steam pressure when reactor steam generation exceeds turbine requirements during unit startup, sudden load reduction, and cooldown. It allows excess steam flow from the reactor to the condenser without going through the turbine. The full bypass capacity of the system is approximately 25% of the Nuclear Steam Supply System rated steam flow. Sudden load reductions within the capacity of the I

steam bypass can be accommodated without reactor scram. The Main Turbine Bypass System consists of five valves connected to the main steam lines between the main steam isolation valves and the turbine stop valve bypass valve chest. Each of these five valves is operated by hydraulic cylinders. The bypass aslves are controlled by the pressure regulation function of the Turbine Electro Hydraulic Control-System, as discussed in the FSAR, Section 7.7.1.5 (Ref. 1). The bypass valves are normally closed, and the pressure regulator controls the turbine control valves that direct all steam flow to the turbine. If the speed governor or the load limiter restricts steam flow to the turbine, the pressure regulator controls the system pressure by opening the bypass valves. When the bypass valves open, the steam flows from the bypass chest, through connecting-piping,.to the pressure breakdown assemblies, where a series of orifices are used to further reduce the steam pressure before the steam enters the condenser.'

APPLICABLE The Main Turbine Bypass System fast opening feature is assumed to function SAFETY for all bypass valves assumed on the safety analysis during the turbine ANALYSES generator load rejection and feedwater controller failure transients, as D)e. e 1e 0. discussed inthe FSAR, Section 15.2.2 (Ref. 2). Opening the bypass valves during the pressurization event mitigates the increase in reactor vessel pressure, which affects the MCPR during the event An inoperable Main The Main Turbine Bypass System satisfies Criterion 3 of the NRC Policy Statement. (Ref.,

7 (continued)

SUSQUEHANNA - UNIT 1 TS / B 3.7-27 Revision 3

PPL Rev. 0 Main Turbine Bypass System B 3.7.6

'-BASES (oontinued)

LCO The Main Turbine Bypass System fast opening feature is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, so

'Dele >that the Safety Umit MCPR is not exceeded. With the Main Turbine Bypass System eZ r)Ct a inoperable, modifications to the MCPR limits (LCO 3.2.2, MINIMUM CRITICAL C n A °w8CE ~ . if POWER RATIO (MCPR)O) may be applied to allow this LCO to be met. The MCPR I yvs e r t 2. limit for the inoperable Main Turbine Bypass System is specified in the COLR. An OPERABLE Main Turbine Bypass System requires the bypass valves to open in response to increasing main steam line pressure. Ucensing analysis credits an OPERABLE Main Turbine Bypass System as having the bypass valve fast opening feature in response to turbine control valve or turbine stop valve closure. The cycle specific safety analyses assume a certain number of OPERABLE main turbine bypass valves as an input (i.e., one through five). Therefore, the Main Turbine Bypass System is considered OPERABLE when the number of OPERABLE.

bypass valves is greater than or equal to the number assumed in the safety.

analyses. The number of bypass valves assumed in4he safety analyses is specified in the COLR. This response is within the assumptions of the applicable I analysis (Ref. 2).

APPLICABILITY The Main Turbine Bypass System is required to be OPERABLE at a 25% RTP to ensure that the fuel cladding integrity Safety Umit is not violated during alll

• applicable transients. As discussed in the Bases for; 3.2. , sufficient margin l to these limits exists at c 25% RTP. Therefore, these ruire ents are only necessary when operating at or above this evet)

ACTIONS A.1 If the Main Turbine Bypass System is inoperable and the MCPR limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are not applied, the assumptions of the design basis transient analysis may not be met.

Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System to OPERABLE status or adjust the MCP limits accordingly. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is reasonable, based o the time to complete the Required

• Afction .rj tQnA C1f.ow o. Ilal OF 0.n eeA occPcr

+n+~Vlert',cone_TueAde 3 ticnu (continued)

SUSQUEHANNA - UNIT 1 TS B 3.7-28 Revision 3

PPL Rev. 0 Main Turbine Bypass System B 3.7.6 BASES ACTIONS B.1 (continued)

Action and the low probability of an event occurring during this period roguiring the Main Turbine Bypass System.

If the Main urbine Bypass System cannot be restored to OPERABLE status or the MCPR limits for an inoperable Main Turbine Bypass System are not applied, THERMAL POWER must be reduced to < 25% RTP. As discussed In the Applicability section, operation at < 25% RTP results in sufficient margin to the required limts, and the Main Turbine Bypass System is not required to protect fuel integrity during the applicable transients. The 4-hour Completion Time Is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.6.1 REQUIREMENTS Cycling each required main turbine bypass valve through one complete cycle of l full travel (including the fast opening feature) demonstrates that the valves are mechanicafly OPERABLE and will function wher required. .The 31-day Frequency is based on engineering judgment, is consistent with the.procedural controls governing valve operation, and ensures correct valve positions.

Operating experience has shown that these components usually pass the SR when performed at the 31 day Frequency. Therefore, the Frequency is.

acceptable from a reliability standpoint.

SR 3.7.6.2 The Main Turbine Bypass System is required to actuate automatically to perform its design function. This SR demonstrates that, with the required system nitiation signals (simulate automatic actuation), the valves will actuate to their required position. The 24-month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown the 24-month Frequency, which is based on the refueling cycle, is acceptable from a reliability standpoint.

(continued)

SUSQUEHANNA - UNIT I TS / B3.7-29 Revision 3

-v Main Turbine Bypass System

• B 3.7.6 BASES SURVEILLANCE SR 3.7.6.3 REQUIREMENTS (continued) This SR ensures that the TURBINE BYPASS SYSTEM RESPONSE TIME is in compliance with the assumptions of the appropriate safety analysis. The response time limits are specified in unit specific documentation. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned.trahsient if the Surveillance were performed with the reactor at power. Operating experience has shown the 24 month Frequency, which is based on the refueling cycle. is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section 7.7.1.5.

2. FSAR. Section 15.2.2.

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

4. Fs ARt S'e C4bo I1. z j S. FsSR 1 Se.4 .15- 4 2.

.C. F5FtR SecAion Is. 4.5 (continued)

SUSQUEHANNA - UNIT 1 TS / B 3.7-30 Revision

INSERT 1:

The Main Turbine Bypass System has two modes of operation. A fast opening mode is assumed to function during the turbine generator load rejection, turbine trip, and feedwater controller failure transients as discussed in FSAR Sections 15.2.2, 15.2.3, and 15.1.2 (Refs. 2, 3, and 4). A pressure regulation mode is assumed to function during the control rod withdrawal error and recirculation flow controller failure transients as discussed in FSAR Sections 15.4.2 and 15.4.5 (Refs. 5 and 6). Both modes of operation are assumed to function for all bypass valves assumed in the applicable safety analyses. Opening the bypass valves during the above transients mitigates the increase in reactor vessel pressure, which affects both MCPR and LHGR during the event. An inoperable Main.

Turbine Bypass System may result in a MCPR and / or LHGR penalty.

INSERT 2:

The Main Turbine Bypass System fast opening and pressure regulation modes are required to be OPERABLE to limit the pressure increase in the main steam lines and reactor pressure vessel during transients that cause a pressurization so that the Safety Limit MCPR and LHGR are not exceeded. With the Main Turbine Bypass System inoperable, modifications to the MCPR limits (LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)') and LHGR limits (LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)') may be applied to allow this LCO to be met. The MCPR and LHGR limits for the inoperable Main Turbine Bypass System are specified in the COLR. An OPERABLE Main Turbine Bypass System requires the bypass valves to open in response to increasing main steam line pressure. Licensing analyses credit an OPERABLE Main Turbine Bypass System as having both the bypass valve fast opening mode and pressure regulation mode. The fast opening mode is required for transients initiated by a turbine control valve or turbine stop valve closure. The pressure regulation mode is required for transients where the power increase exceeds the capability of the turbine control valves.

The cycle specific safety analyses assume a certain number of OPERABLE main turbine bypass valves as an input (i.e., one through five).. Therefore, the Main Turbine Bypass System is considered OPERABLE when the number of OPERABLE bypass valves is greater than or equal to the number assumed in the safety analyses. The number of bypass valves assumed in the safety analyses is specified in the COLR. This response is within the assumptions of the applicable analysis (Refs. 2 - 6).

PPL Rev. 0 Main Turbine Bypass System B 3.7.6 B3.7 - PLANT SYSTEMS B 3.7.6 Main Turbine Bypass System BASES BACKGROUND The Main Turbine Bypass System is designed to control steam pressure when reactor steam generation exceeds turbine requirements during unit startup, sudden load reduction, and cooldown. It allows excess steam flow from the reactor to the condenser without going through the turbine. The full bypass capacity of the system is approximately ?5% of the Nuclear Steam Supply System rated steam flow. Sudden load reductions within the capacity of the steam bypass can be accommodated without reactor scram. The Main Turbine Bypass System consists of five valves connected to the main steam lines between the main steam isolation valves and the turbine stop valve bypass valve chest. Each of these five valves is operated by hydraulic cylinders. The bypass valves are controlled by the pressure regulation function of the Turbine Electro Hydraulic Control System, as discussed in the FSAR, Section 7.7.1.5 (Ref. 1). The bypass valves are normally closed, and the pressure regulator controls the turbine control valves that direct all steam flow to the turbine. Ifthe speed governor or the load limiter restricts steam flow to the turbine, the pressure regulator controls the system pressure by opening the bypass valves.

When the bypass valves open, the steam flows from the bypass chest, through connecting piping, to the pressure breakdown assemblies, where a series of orifices are used to further reduce the steam pressure before the steam enters the condenser.

. ' APPLI CABLE The Main Turbine Bypass System fast opening feature is assumed to function SAFE1 rY . for all bypass valves assumed in the safety analysis during the turbine

' ANAL) (SES generator load rejection and feedwater controller failure transients, as discussed in the FSAR, Section 15.2.2 (Ref. 2). Opening the bypass valves during the Delete pressurization event mitigates the increase In reactor vessel pressure, which affects the MCPR during the event. An inoperable Main Turbine Bypass System may result n M CPR penalty.

Tnsert 1 The Main Turbine Bypass System satisfies Criterion 3 of the NRC Policy Statement. (Ref.3-7 (continued)

SUSQUEHANNA - UNIT 2 TS / B 3.7-27 Revision

PPL Rev. 0 Main Turbine Bypass System B 3.7.6 BASES (continued)

LCO The Main Turbine Bypass System fast opening feature is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, so that the Safety Limit MCPR is not exceeded. With the Main Turbine Bypass System inoperable, modifications to the MCPR limits (LCO 3.22, MINIMUM CRITICAL POWER RATIO (MCPR)") may be applied to allow this LCO to be met.

The MCPR limit for the inoperable Main Turbine Bypass System is specified in the COLR. An OPERABLE Main Turbine Bypass System requires the bypass valves to open in response to increasing main steam line pressure. Licensing And a dd .. analysis credits an OPERABLE Main Turbine Bypass System as having the bypass valve fast opening feature in response to turbine control valve or turbine stop valve closure. The cycle specific safety analyses assume a certain number l of OPERABLE main turbine bypass valves as an input (i.e., one thro te -fivl).

Therefore the Main Turbine Bypass System is considered OPERABLE when the I number of OPERABLE bypass valves is greater than or equal to the number '

assumed in the safety analyses. The number of bypass valves assumed in the safety analyses is specified in the COLR. This response is within the assumption4

\of the applicable analysis (Ref. 2).

APPLICABILITY The Main Turbine Bypass System is'required to be OPERABLE at > 25% RTP to ensure that the fuel cladding integrity Safety Umit is not violated during all applicable transients. As discussed in the Bases for4Ge3.2.2 sufficient margin to these limits exists at < 25% RTP. Therefore, these bquire nts are ony necessary when operating at or above this level ACTIONS A.1 ' 8 L If the Main Turbine Bypass System is inoperable and the MCPR limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are not.

applied, the assumptions of the design basis transient analysis may not be met.

Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System to OPERABLE status or adjust the MCP~mits accordingly. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is reasonable; based o the time to complete the Required Action and the low probability of an event urring during this period requiring the Main Turbine Bypass System.

(continued)

SUSQUEHANNA - UNIT 2B TS / B 3.7-28 Revision

PPL Rev. 0 Main Turbine Bypass System B 3.7.6 BASES ACTIONS (continued)

If the Mai Turbine Bypass System cannot be restored to OPERABLE status or the MCPR limits for an inoperable Main Turbine Bypass System are not applied, THERMAL POWER must be reduced to < 25% RTP. As discussed in the Applicability section; operation at < 25% RTP results in sufficient margin to the required limits, and the TI bine Bypass System is not required to protect fuel integrity during theui lpplicable transients. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion l Time is reasonable, b oerating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE S RE~ulRMEN~s REQUIREMENTS SR 3.7.6.1 Cycling each required main turbine bypass valve through one complete cycle of full travel (including the fast opening feature) demonstrates that the valves are mechanically OPERABLE and will function when required. -The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

Operating experience has shown that these components usually pass the SR when performed at the 31 day Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

SR 3.7.6.2 The Main Turbine Bypass System is required to actuate automatically to perform its design function. This SR demonstrates that, with the required system initiation signals (simulate automatic actuation), the valves will actuate to their required position. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown the 24 month Frequency, which is based on the refueling cycle, is acceptable from a reliability standpoint.

(continued)

SUSQUEHANNA - UNIT 2 TS / B 3.7-29 Revision 1

Main'Turbine Bypass System B 3.7.6 BASES SURVEILLANCE SR 3.7.6.3 REQUIREMENTS (continued) This SR ensures that the TURBINE BYPASS SYSTEM RESPONSE TIME is in compliance with the assumptions of the appropriate safety analysis. The response time limits are specified in unit specific documentation. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and because of the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown the 24 month Frequency. which is based on the refueling cycle, is acceptable from a reliability standpoint.

-REFERENCES 1. FSAR. Section 7.7.1.5.

2. FSAR, Section 15.2.2.

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

I

33. F570 , ecti.on 15.7.31 i 4. FSAstk I Seco n l 1. 2.

. 5- SSWY,I Sec ~-o IS. 4. 1)

> C. Fs^<R secOea IS. 4. 5 SUSQUEHANNA - UNIT 2 B 3.7-30 Revision 0

INSERT 1:

The Main Turbine Bypass System has two modes of operation. A fast opening mode is assumed to function during the turbine generator load rejection, turbine trip, and feedwater controller failure transients as discussed in FSAR Sections 15.2.2, 15.2.3, and 15.1.2 (Refs. 2, 3, and 4). A pressure regulation mode is assumed to function during the control rod withdrawal error and recirculation flow controller failure transients as discussed in FSAR Sections 15.4.2 and 15.4.5 (Refs. 5 and 6). Both modes of operation are assumed to function for all bypass valves assumed in the applicable safety analyses. Opening the bypass valves during the above transients mitigates the 'increase in reactor vessel pressure, which affects both MCPR and LHGR during the event. An inoperable Main Turbine Bypass System may result in a MCPR and I or LHGR penalty.

INSERT 2:

The Main Turbine Bypass System fast opening and pressure regulation modes are required to be OPERABLE to limit the pressure increase in the main steam lines and reactor pressure vessel during transients that cause a pressurization so that the Safety Limit MCPR and LHGR are not exceeded. With the Main Turbine Bypass System inoperable, modifications to the MCPR limits (LCO 3.2.2, UMINIMUM CRITICAL POWER RATIO (MCPR)") and LHGR limits (LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)") may be applied to allow this LCO to be met. The MCPR and LHGR limits for the inoperable Main Turbine Bypass System are specified in the COLR. An OPERABLE Main Turbine Bypass System requires the bypass valves to open in response to increasing main steam line pressure. Licensing analyses credit an OPERABLE Main Turbine Bypass System as having both the bypass valve fast opening mode and pressure regulation mode. The fast opening mode is required for transients initiated by a turbine control valve or turbine stop valve closure. The pressure regulation mode is required for transients where the power increase exceeds the capability of the turbine control valves.

The cycle specific safety analyses assume a certain number of OPERABLE main turbine bypass valves as an input (i.e., one through five). Therefore, the Main Turbine Bypass System is considered OPERABLE when the number of OPERABLE bypass valves is greater than or equal to the number assumed in the safety analyses. The number of bypass valves assumed in the safety analyses is specified in the COLR. This response is within the assumptions of the applicable analysis (Refs. 2 - 6).

Attachment 3 to PLA-5694 Proposed Technical Specification Changes (Camera Ready)

(Units 1&2)

PPL Rev. 1 Main Turbine Bypass System 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE.

OR Apply the following limits for an inoperable Main Turbine Bypass System as specified in the COLR:

a. LCO 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)," and

b. LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)."

APPLICABILITY: THERMAL POWER > 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Main Turbine Bypass System A.1 Satisfy the requirements of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> inoperable. LCO or restore Main Turbine Bypass System to OPERABLE status.

AND Requirements of LCO 3.2.2 not met.

OR I Requirements of LCO 3.2.3 I not met.

B. Required Action and B.1 Reduce THERMAL POWER to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion Time < 25% RTP.

not met.

SUSQUEHANNA UNIT 1 TS / 3.7-1 5 Amendment 17i, 20

PPL Rev. 1 Main Turbine Bypass System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of each required main 31 days turbine bypass valve.

SR 3.7.6.2 Perform a system functional test. 24 months SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM 24 months RESPONSE TIME is within limits.

SUSQUEHANNA - UNIT 1 TS /3.7-16 Amendment 17, 276

PPL Rev. 1 Main Turbine Bypass System 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Main Turbine Bypass System LCO 3.7.6 The Main Turbine Bypass System shall be OPERABLE.

OR Apply the following limits for an inoperable Main Turbine Bypass System as specified in the COLR:

a. LCO 3.2.2, UMINIMUM CRITICAL POWER RATIO (MCPR)," and

b. LCO 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)."

APPLICABILITY: THERMAL POWER > 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Main Turbine Bypass A.1 Satisfy the requirements of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> System inoperable. LCO or restore Main Turbine Bypass System to OPERABLE status.

AND Requirements of LCO 3.2.2 not met.

OR Requirements of LCO 3.2.3 not met.

B. Required Action and B.1 Reduce THERMAL POWER to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion Time < 25% RTP.

not met.

SUSQUEHANNA - UNIT 2 3.7-1 5 Amendment Xi 15

PPL Rev. 1 Main Turbine Bypass System 3.7.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify one complete cycle of each required main 31 days turbine bypass valve.

SR 3.7.6.2 Perform a system functional test. 24 months SR 3.7.6.3 Verify the TURBINE BYPASS SYSTEM 24 months RESPONSE TIME is within limits.

SUSQUEHANNA - UNIT 2 3.7-1 6 Amendment 10 1 5

Attachment 4 to PLA-5694 List of Regulatory Commitments (Units 1 and 2)

LIST OF REGULATORY COMMITMENTS REGULATORY COMMITMENTS iSK.>: eDate/Event-

.. u:

There are no new commitments associated with this submittal. N/A