Text

Proposed License Amendment No. 299 for Unit 1 and Proposed License Amendment No. 269 for Unit 2 for Changes to Technical Specifications 3.6.4.1 Secondary Contaminant and 3.6.4.3 Standby Gas Treatment System
	ML081000566
Person / Time
Site:	Susquehanna
Issue date:	03/28/2008
From:	Mckinney B; Susquehanna
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PLA-6328
	Download: ML081000566 (39)
	v • d • e

Britt T. McKinney PPL Susquehanna LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 ' .

Tel. 570.542.3149 Fax 570.542.1504 btmckinney@ pplweb.com e MAR 2 8 2008 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPl-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED LICENSE AMENDMENT NO. 299 FOR UNIT 1 AND PROPOSED LICENSE AMENDMENT NO.269 FOR UNIT 2 FOR CHANGES TO TECHNICAL SPECIFICATIONS 3.6.4.1 SECONDARY CONTAINMENT AND 3.6.4.3 STANDBY GAS TREATMENT SYSTEM Docket Nos. 50-387 PLA-6328 and 50-388 Pursuant to 10 CFR 50.90, PPL Susquehanna, LLC (PPL), hereby requests approval of the following proposed amendments to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications (TS), as described in the Enclosure. The proposed amendments would change Technical Specification 3.6.4.1 "Secondary Containment" and Technical Specification 3;(.4.3 "Standby Gas Treatment System."

These changes are proposed. in order to reduce unnecessarily restrictive LCO 3.6.4.1 entries that occur in response to routine plant activities and to provide additional time to recover secondary containment vacuum. Together, the changes will alleviate unnecessary burden on the control room operators and on PPL's power distribution affiliate (PPL Electric Utilities).

Also included is a change that removes a one-time Completion Time allowance previously incorporated into both TS 3.6.4.1 and TS 3.6.4.3. The allowance has since expired.

Justification for the change to the Unit 1 and Unit 2 Secondary Containment LCO 3.6.4.1 and Standby Gas Treatment LCO 3.6.4.3 are based upon the evaluation presented in the Enclosure. As demonstrated in the enclosed evaluation, the proposed amendment does not involve a significant hazard consideration.

PPL requests approval of the proposed change to the Unit 1 and Unit 2 Technical Specifications by March 31, 2009. PPL further requests that the approved amendment be issued to be effective immediately upon approval with the implementation to be completed within 30 days. contains the Technical Specification mark-ups reflecting the proposed change.

Changes to the Technical Specification Bases (provided for information) are provided in .

Document Control Desk PLA-6328 This change has been discussed with the SSES NRC Project Manager. The change has also been reviewed by the SSES Plant Operations Review Committee and by the Susquehanna Review Committee. In accordance with 10 CFR 50.91(b), PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.

There are no regulatory commitments associated with the proposed changes.

If you have any questions or require additional information, please contact Mr. Eric J. Miller at (570) 542-3321.

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

Executed on: -- __-_- __

B. T. McKinney

Enclosure:

PPL Susquehanna, LLC Evaluation of Proposed Change to the Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" and TS 3.6.4.3 "Standby Gas Treatment System" Attachments: PPL Susquehanna, LLC Proposed Change to the Unit 1 and Unit 2 TS. 3.6.4.1 "Secondary Containment" and TS 3.6.4.3 "Standby Gas Treatment System" (Mark-ups) PPL Susquehanna, LLC Proposed Change to the Unit 1 and Unit 2 TS Bases 3.6.4.1, "Secondary Containment" and TS Bases 3.6.4.3 "Standby Gas Treatment System (Mark-ups provided for Information Only)

Copy: NRC Region I Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager Mr. R. R. Janati, DEP/BRP

Document Control Desk PLA-6328 bc: M. H. Crowthers GENPL4 D. R. D'Angelo NUCSB2 A. S. Fitch NUCSB3 C. J. Gannon NUCSB3 J. M. Helsel NUCSB3 A. L. Kissinger NUCSB3 R. D. Pagodin NUCSB3 G. F. Ruppert NUCSB3 T. G. Wales (DBD) GENPL4 L. M. Yupco (SRC) NUCSB3 NRA File GENPL4 DCS GENPL4

Enclosure to PLA-6328 PPL Susquehanna, LLC Evaluation of Proposed Change to Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" and TS 3.6.4.3 "Standby Gas Treatment System"

1. DESCRIPTION

2. PROPOSED CHANGE

3. BACKGROUND

4. TECHNICAL ANALYSIS

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

6. ENVIRONMENTAL CONSIDERATIONS

7. REFERENCES

Enclosure to PLA-6328 Page 1 of 19 PPL EVALUATION

Subject:

PPL Susquehanna Evaluation of Proposed Change to Unit I and Unit 2 Technical Specification 3.6.4.1 Secondary Containment and Technical Specification 3.6.4.3 "Standby Gas Treatment System"

1. DESCRIPTION Several changes are proposed. The first change to the PPL Susquehanna (PPL) Unit 1 and Unit 2 Technical Specification 3.6.4.1 "Secondary Containment" proposes a new Required Action option for TS 3.6.4.1 Condition A, to allow additional time to restore secondary containment to OPERABLE when the inoperability is not caused by a loss of secondary containment integrity.

The second proposed change reflects a rnew Actions note to the SSES Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" to allow opening of secondary containment RVAC duct access doors and opening of a secondary containment equipment ingress/egress door (102 door) under administrative controls provided no movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, or operations with a potential for draining the reactor vessel (OPDRVs) are in progress.

The third proposed change modifies the existing note to SSES Unit 1 and Unit 2 Surveillance Requirement SR 3.6.4.1.3 and adds a second note to this same Surveillance Requirement. These changes expand upon the existing SR exception note by adding other types of door access openings that occur for entry and exit of people or equipment.

The fourth change removes a one-time allowance that extended the allowable Completion Time for Secondary Containment inoperable and two SGTS subsystems inoperable in MODE 1, 2, or 3. This allowance was previously incorporated into both Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" and TS 3.6.4.3 "Standby Gas Treatment System" to facilitate Reactor Recirculating Fan Damper Motor work. This allowance has expired (effective through 12/31/2005 only). Note that this is an administrative change and thus, will not be discussed further herein.

If approved, PPL plans to implement the proposed Unit 1 and Unit 2 TS amendments in March 2009.

Mark-ups of the proposed change to the Unit 1 and Unit 2 Technical Specifications (TS) are included in Attachment 1 of this submittal.

Enclosure to PLA-6328 Page 2 of 19

2. PROPOSED CHANGE The three proposed technical changes to the Unit 1 and Unit 2 Technical Specifications 3.6.4.1 and 3.6.4.3 are as follows:

1. Currently, the Required Action for TS 3.6.4.1 Condition A, which addresses secondary containment inoperable in MODE 1, 2, or 3, simply requires restoration of secondary containment to OPERABLE status in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The Required Action is proposed to be revised to add a new option A.2 AND A.3 to both the Unit 1 and Unit 2 Technical Specifications that will be connected with a logical connector OR to the existing Required Action. The alternate option will require SSES to:

A.2 Verify secondary containment boundary integrity (in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ).

AND A.3 Restore secondary containment to OPERABLE status (in 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ).

2. Unit 1 and Unit 2 TS's 3.6.4.1 are proposed to contain a new Actions note as follows:

NOTE Duct access doors and the 102 door may be opened under administrativecontrols provided no movement of irradiatedfuel assemblies in the secondary containment, CORE ALTERATIONS, or operations with a potentialfor draining the reactor vessel (OPDRVs) are in progress.

3. The existing Note to both Unit 1 and Unit 2 Surveillance Requirements SR 3.6.4.1.3 is being revised and a second note is being incorporated to add the following (additions have been underlined):

NOTE

1. Single door access openings between requiredzones within the secondary containment boundary and single door secondary containment access openings may be openedfor entry and exit.

2. Access openings with two doors may be opened to allow passage of equipment requiring both doors to be open.

The first change provides obvious benefits to the Susquehanna station by extending the time available to respond to conditions that do not actually compromise the secondary containment boundary (such as a non-safety related fan trip) before shutdown actions must be enacted. This change will also benefit PPL's power distribution affiliate (PPL Electric

Enclosure to PLA-6328 Page 3 of, 19 Utilities) who must be notified whenever an unscheduled Technical Specification entry occurs that requires a Unit shutdown in 72, hours or less. In response to the possible shutdown, the Transmission Control and the Generation Control' Centers of PPL Electric Utilities must prepare to replace Susquehanna's power (usually both Units) in order to maintain grid stability and adequate electricity supply. The time: extension will relieve the time sensitive pressures that accompany this effort when undertaken in the 4-hour response window that currently exists.

The second and third changes will reduce LCO 3.6.4.1 entries that occur in response to routine plant activities. These changes will reduce an administrative burden currently placed on the control room operators who must enter a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to shutdown LCO for events that do not compromise the safety of operation or the capability of Susquehanna's secondary containment.

The TS Bases Sections B 3.6.4.1 and B 3.6.4.3 have also been'revised based on these changes.

3. BACKGROUND During MODES 1, 2, and 3; during movement of irradiated fuel assemblies in the secondary containment; during CORE ALTERATIONS; and during operations with a potential for draining the reactor vessel, the secondary containment is kept at a minimum negative pressure of 0.25 inches of water gauge with respect to outside. This ensures sufficient boundary tightness to preclude exfiltration from the secondary containment following an accident. During normal operation, this is accomplished by non-safety-related HVAC systems. A secondary containment Dual Unit 4,hour LCO is taken whenever the following occurs:

" Vacuum in the secondary containment becomes less than 0.25 inches of water gauge vacuum for reasons other than expected wind conditions (i.e. - loss of non-safety fans). (This occurred 5 times in calendar year 2007.)

" A planned work/inspection evolution is being performed that will breach the secondary containment boundary under the control of a plant procedure and may or may not cause vacuumin the secondary containment to become less than 0.25 inches of water gauge. (This occurred 14 times in calendar year 2007.)

Equipment ingress/egress through the Unit 2 Truck Bay door (102 door).

Vacuum in the secondary containment is not maintained during openings of this "garage-style" door. (This occurred 12 times in 'calendar year 2007.)

Enclosure to PLA-6328 Page 4of 19

" Personnel ingress/egress through a secondary containment Boundary Door that does not have an air lock. Required vacuum is typically maintained for these short duration door openings. (This occurred 28 times in calendar year 2007.)

" Equipment ingress/egress through an airlock where both doors required opening due to the dimensions of the equipment. Passage through the airlock may or may not cause vacuum in the secondary containment to become less than 0.25 inches of water gauge. (This occurred 5 timfes in calendar year 2007.)

As stated above, each entry creates the administrative burden of Technical Specification entry. Additionally, unplanned entries require notification to, and response by, affiliated electric distribution personnel.

To reduce the impact of Technical Specification 3.6.4.1 entry in response to a loss or degradation of the non-safety related Reactor Building fans, it is proposed that the TS (Condition A) be modified to provide a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time upon a loss of secondary containment as long as the secondary containment boundary integrity can be verified within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

To alleviate the need for entering a Dual Unit 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months LCO in response to routine activities, it is proposed that Technical Specification 3.6.4.1 be changed to allow the following without entering LCO 3.6.4. 1:

planned work/inspection evolutions that will breach the secondary containment boundary under the control of a plant procedure,I

" personnel or equipment ingress/egress thru secondary containment boundary doors with prior concurrence by the Control Room,

" Unit 2 Truck Bay Door (102 Door) openings in accordance with plant procedures.

3.1 Definition of Zone Boundaries The secondary containment is divided into three isolated ventilation zones. 'Zones I and II surround respective Units 1 and 2 primary containment below the floor at elevation 779 ft- I in. and also include stairwells and elevator machine rooms and shafts above elevation 779 ft-i in. Zone III includes Units 1 and 2 secondary containment above the floor at elevation 779 ft-i in. including the refueling floor, but~exciuding the HVAC fan and equipment rooms.

Note: Unlike Unit l's 101 Door, which can be isolated from secondary containment, the Zone 11 secondary containment boundary includes the 102 Door which cannot be aligned

Enclosure to PLA-6328 Page 5 of 19 in another configuration. Maintenance activities for various Unit 2 Reactor Building components require opening of the 102 Door in order to store/stage materials.

3.2 Descriptions 3.2.1 Secondary Containment The following are provided to control fission products within the secondary containment following a design basis accident:

a) A secondary containment that completely surrounds each of the two primary containments.

b) The Standby Gas Treatment System (SGTS).

c) A Recirculation System.

The secondary containment consists of a reinforced concrete structure up to the refueling floor (El. 818 ft-1 in.) and of a metal-sided superstructure above El. 818 ft-1 in.

The secondary containment consists of the three ventilation zones (I, iI, and III) discussed above.

The safety related SGTS is used to maintain the affected zone(s) of the secondary containment at a negative pressure during accident conditions.

3.2.2 Standby Gas Treatment System (SGTS)

The Standby Gas Treatment System is designed to accomplish the following safety-related objectives:

a) Exhaust sufficient filtered air from the Reactor Building to maintain a minimum negative pressure of 0.25 inches of water in the affected volumes following secondary containment isolation for the following design basis events:

(1) Irradiated fuel handling accident in the refueling floor area.

(2) Loss of Coolant Accident (LOCA).

b) Filter the exhausted air to remove radioactive particulates and both radioactive and non-radioactive forms of iodine to limit the dose to the guidelines of 10 CFR 50.67.

Enclosure to PLA-6328 Page 6 of 19 Non-safety-related objectives for design of the SGTS are as follows:

a) Filter and exhaust air from the primary containment for purging and ventilating.

b) Filter and exhaust discharge from the High Pressure Coolant Injection (HPCI) barometric condenser.

c) Filter and exhaust from the primary containment pressure relief line.

d) Filter and exhaust nitrogen from the primary containment for nitrogen purging.

The airflow diagram for the SGTS is shown on the FSAR Figures in Section 6.2.3.

3.2.3 Recirculation System A common Recirculation system is provided for Units 1 and 2 to perform the following safety-related functions:

a) Mix the atmosphere in the Reactor Building to obtain a lesser and more uniform concentration of radioactivity following a Design Basis Accident (DBA) Loss Of Coolant Accident (LOCA) or a refueling accident.

b) Prevent the spread of radioactivity by the heating-ventilating-cooling systems between Zone III and Zones I or II during and after an irradiated fuel handling accident.

c) Provide mixing of the atmosphere within the Reactor Building. This may involve mixing the atmosphere of all three zones; of Zone I or Zone II and the refueling area (Zone III); or of Zone III alone, particularly in case of the fuel handling accident in b), above.

The Reactor Building Recirculating System is shown on the FSAR Figures in Section 6.2.3.

3.2.4 System Operation When a secondary containment isolation signal is received, the safety-related Reactor Building (RB) Recirculating and SGTS fans start and the normal operating, non-safety related HVAC systems are tripped. The isolated secondary containment zones will align to the Recirculation Plenum by opening of the recirc isolation dampers. The SGTS is

Enclosure to PLA-6328 Page 7 of 19 connected to and draws air from the RB Recirculation Plenum.' The removal of air from the Recirculation Plenum maintains the isolated secondary containment zone at a negative pressure of 0.25 inches of water gauge with respect to outside.

When a LOCA signal is initiated, the secondary containment will receive an isolation signal (normal HVAC is shutdown and isolated). The HVAC systems of the unit with a LOCA signal and Zone III will align to the recirculation system and the Standby Gas Treatment System (SGTS) will begin to draw air from the recirculation system. Note for a Loss of Offsite Power (LOOP), all three zones will isolate and align to the recirculation system. During the time to start the recirculation system and align the isolated zones, the secondary containment pressure will rise and ultimately exceed the -0.25" water gauge (w.g.) pressure requirement. This is due to building heat-up and in-leakage from outside.

The SGTS will re-establish the negative pressure in secondary containment. The time from when negative pressure is lost to the time the SGTS can re-establish the negative pressure is referred to as the draw down time. This draw down time is verified via performance of SR 3.6.4.1.4.

3.3 Configuration Impacts The safety-related means of maintaining the required vacuum in the secondary containment is via the Standby Gas Treatment System (SGTS). SGTS could be started to maintain the required vacuum within secondary containment. However, the Reactor Building recirculation fans will start upon the initiation of SGTS in order to provide mixing. With SGTS and the Reactor Building recirculation fans operating under non-DBA conditions, the areas for concern are as follows:

" The ductwork. for the recirculation plenum cross-connects contaminated plant areas with non-contaminated plant areas thus resulting in the undesired spread of contamination throughout the Reactor Building. Spread' of contamination may cause access issues to certain areas of the reactor building and could result in unnecessary dose to plant personnel

" The non-safety-related Reactor Building fans and SGTS cannot be operated concurrently. The troubleshooting of any potential issues that may exist with the Reactor Building fans would become burdensome to operations since multiple fan and isolation damper configuration changes would be required to accommodate troubleshooting.

3.4 FSAR References Related background in the SSES FSAR is found in Section 1.2. Compliance with NRC design criteria is described in detail in FSAR Sections 3.1 and 3.13. Detailed descriptions can be found in the SSES FSAR Section 6.2.3 Secondary Containment

Enclosure to PLA-6328 Page 8 of 19 Functional Design, Section 6.5.1.1 Standby Gas Treatment System, and Section 6.5.3.2 Secondary Containment.

4. TECHNICAL ANALYSIS The proposed changes have been evaluated. It has been determined that current regulations and applicable requirements will continue to be met and that adequate defense-in-depth and sufficient safety margins are maintained as discussed in this Technical Analysis and in Section 5.2.

SSES Unit 1 and Unit 2 are designed and operated consistent with the defense-in-depth philosophy. The defense-in-depth philosophy in reactor design and operation results in multiple means to accomplish safety functions and prevent release of radioactive material. The impact of the proposed Technical Specification changes were evaluated and determined to be consistent with the defense-in-depth philosophy.

4.1 Change to the Required Actions of Condition A As described in Technical Specification Bases 3.6.4.1, the function of secondary containment is to contain, dilute, and hold up fission products that may leak from primary containment into secondary containment following a Design Basis Accident (DBA).

During normal operation, a vacuum of greater than or equal to 0.25 inch water gauge is maintained throughout the SSES Reactor Building (including those areas that comprise secondary containment) and is verified by Technical Specification Surveillance Requirement 3.6.4.1.1. The non-safety-related Reactor Building fans maintain vacuum in the Reactor Building during normal plant operation. The safety-related means of maintaining the required vacuum in the secondary containment is via the Standby Gas Treatment System (SGTS). When the required vacuum is not maintained, the secondary containment is declared inoperable in accordance with LCO 3.6.4.1. For these circumstances, at least one unit (potentially both units) is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from a required unit shutdown even if the ability of SGTS to create and maintain the required post accident secondary containment vacuum is not affected. SGTS can create and maintain the required post accident secondary containment vacuum when the secondary containment boundary integrity is not affected. If a transient requiring secondary containment occurred while in this condition (i.e. secondary containment inoperable with secondary containment integrity maintained), the safety-related system (SGTS) would initiate and secondary containment would be maintained at the required vacuum. The proposed change would allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to verify that the secondary containment integrity is maintained. If secondary containment integrity is being maintained, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months are proposed to be allowed to re-establish a vacuum of greater than or equal to 0.25 inch water gauge. The 72-hour timeframe allows adequate time to fix equipment issues and is consistent with the fact that secondary containment would stiliperform its safety function

Enclosure to PLA-6328 Page 9 of 19 in the event of a DBA. If secondary containment integrity is compromised for conditions other than those:explained in the notes, a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months completion time applies which is consistent with the current specification. It should be noted that if secondary containment is ,not OPERABLE during movement of irradiated fuel assemblies in the secondary containment, during CORE ALTERATIONS, or during Operations with Potential for Draining the Reactor Vessel (regardless of cause), Technical Specification 3.6.4.1 Condition C is still applicable.

The 72-hour Completion Time (CT) is appropriate since the secondary containment boundary would still perform its design function in a DBA event thereby maintaining release pathways to those assumed in the Design Basis offsite dose analyses. During the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months completion time, secondary containment may not be at the required vacuum and thus, there is the potential for an unmonitored release pathway. During this timeframe, other reactor building equipment (e.g., leak detection, Area Radiation Monitors) would be available to alert Operations personnel of any increase in release rates from plant equipment so that appropriate actions could be taken. This equipment, which is regularly monitored through Technical Requirement Manual surveillances and/or is incorporated into the plant's preventative maintenance program, is located in potentially contaminated areas of the Reactor Building and provides a method of monitoring the potential release to the public. Since the secondary containment would still perform its design function in a DBA event, the release during a DBA event would be monitored via the SGTS vent stack. Therefore, the increase in CT to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months will not impact dose to the public.

The SGTS could be started to restore the required vacuum within secondary containment.

The proposed changes do not include an action to require use of SGTS to reestablish vacuum due to the following issues: Upon start of SGTS, the Reactor Building recirculation fans will also start. The ductwork for the recirculation plenum cross-connects contaminated plant areas with non-contaminated plant areas thus resulting in the undesired spread of contamination throughout the Reactor Building. Spread of contamination may cause access issues to. certain areas of the Reactor Building and could result in unnecessary doseto plant personnel. Furtheir, the non-safety-related Reactor Building fans and SGTS cannot be operated concurrently. Therefore, troubleshooting any potential issues that may exist with the Reactor Building fans would become burdensome to operations since multiple fan and isolation damper configuration changes would be required to accommodate the troubleshooting. Such an effort would divert operator attention from more critical activities. Based on this discussion, it is not prudent to require initiation of SGTS.

As stated in the Background section (first bulldot) of this Enclosure, there were five instances in calendar year 2007 where LCO 3.6.4.1 was entered in response to events that did not entail a compromise to secondary containment integrity.

Enclosure to PLA-6328 Page 10 of 19 4.2 Added Actions Note A proposed note is added to the Technical Specification which would allow duct access doors and the 102 door (truck bay door) to be opened under administrative controls provided no movement of irradiated fuel in the secondary containment, CORE ALTERATIONS, or operations with a potential for draining the reactor vessel (OPDRVs) are in progress.

4.2.1 Duet Access Doors Experience at SSES has determined that a significant contributor to secondary containment in-leakage is leakage through secondary containment isolation dampers. As required by TS SR 3.6.4.1.5, secondary containment in-leakage must be below the values used in the design basis dose analysis. To maintain in-leakage as low as possible (thereby maintaining DBA offsite and control room doses as low as possible), SSES periodically inspects the secondary containment isolation damper blade / seal interface.

This inspection requires removal of the duct access doors (duct breach) which establishes communication between secondary containment and the environment. These inspections support successful completion of Surveillance Requirement 3.6.4.1.5 by ensuring equipment necessary to minimize in-leakage is in good working order. The Zone I and II secondary containment isolation damper inspections are typically performed during an outage (SSES outages are scheduled on a 2 year frequency) when that zone is isolated from the Reactor Building recirculation plenum and 6ntry into the Secondary Containment LCO is not required. The inspection of Zone I and Zone II Recirc isolation dampers are also typically performed during the respective Unit's outage. When performing these inspections, however, entry into the Secondary Containment LCO 3.6.4.1 is required for both Units because communication has been established with the recirculation plenum. This communication affects Zone III as Zone III cannot be isolated from the Reactor Building recirculation plenum. Since Zone III is always required (even during outages) and cannot be isolated from the recirculation plenum, the removal of any duct access doors to facilitate Zone III secondary containment isolation damper inspections causes entry into the secondary containment LCO. Multiple LCO entries and exits are typically needed to perform the damper inspections. Other SSES Technical Specifications contain exceptions for testing or inspection in support. of a Surveillance Requirements (e.g., TS 3.3.4.1). The proposed change is, therefore, consistent with these previously established LCO entry exceptions. Additionally, the access doors are attached by wing nut connections or bolted connections. As is stated in the proposed Tech Spec Bases, administrative controls will be implemented to ensure the capability to close the duct access openings quickly. This action would re-establish the leak tightness of secondary containment.

Enclosure to PLA-6328 Page I I of 19 Regulatory Guide 1.183 indicates that the early in-vessel release phase does not begin until 30 minutes. The dose consequences due to increased leakage during the initial 30 minutes of an event would be minimfal since a gap release is the only fuel release anticipated during this period. The damper inspections ensure secondary containment in-leakage is maintained within limits. The administrative controls will ensure that the doors can be closed well within 30 minutes.

Based on the above discussion, PPL has determined that the proposed action is in the best interest of maintaining dose consequences as low as possible.

As stated in the Background section (second buildot) of this Enclosure, there were fourteen instances in calendar year 2007 where LCO 3.6.4.1 was entered to facilitate planned damper inspections.

4.2.2 102 Door Opening The Unit 2 Truck Bay (102 door) is part of Zone II and unlike the Unit 1 Railroad Bay (101 door), the Truck Bay cannot be isolated from the OPERABLE secondary containment zones. Typically, in preparation for a Unit 2 outage, equipment is shipped to the station long before the outage commences. To maintain equipment in good material condition and assure equipment reliability, it is desirable to avoid prolonged exposure to outside weather conditions. To minimize exposure to outside weather, Unit 2 equipment is brought into the Unit 2 Truck Bay through the Unit 2 Truck Bay door (102 door). This activity occurs routinely and requires entry into the secondary containment LCO each time the door is opened. Due to the limited Completion Time (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) currently provided for the Secondary Containment LCO 3.6.4. 1, multiple, door openings are required-to move equipment into the Unit 2 reactor building. The proposed change will reduce -the number of required LCO entries. The Truck Bay do 'orcan be closed by an electric motor but is also provided with a chain pulley for manual closure in the event of a loss of power or motor failure.

As is stated in the proposed Tech Spec Bases, administrative controls will be implemented to ensure the capability to close the door quickly. This action would re-establish the leak tightness of secondary containment.

Regulatory Guide 1.183 indicates that the early in-vessel release phase does not begin until 30 minutes. The dose consequences&due to increased. leakage during the initial 30 minutes of an event would be minimal since a gap release is the only fuel release anticipated during this period. The administrative controls will ensure that the door can be closed well within 30 minutes.

Enclosure to PLA-6328 Page 12 of 19 As stated in the Background section (third bulldot) of this Enclosure, there were twelve instances in calendar year 2007 where LCO 3.6.4.1 was entered for 102 door openings necessary to accommodate equipment movement into and out of the Reactor Building.

4.3 TS SR 3.6.4.1.3 Note Changes 4.3.1 Note 1 (Single Door Opening)

The SSES design includes secondary containment access with single doors (no airlock).

These doors are routinely used to access equipment (instrumentation, crane controls, etc.). This proposed change will allow secondary containment single doors to be opened for ingress and egress without need for entry into TS LCO 3.6.4.1 Condition A. This change is consistent with the NUREG 1434 "Standard Technical Specifications General Electric Plants BWRP6". The allowance of using secondary containment single doors for ingress and egress will not impact secondary containment performance. Ingress and egress through a single access door would be of short duration.

As is stated in the proposed Tech Spec Bases, administrative controls by individual personnel will ensure the secondary containment function is not degraded.

Regulatory Guide 1.183 indicates that the early in-vessel release phase does not begin until 30 minutes. The dose consequences due to increased leakage during the initial 30 minutes of an event would be minimal since a gap release is the only fuel release anticipated during this period. The administrative controls will ensure that the doors can be closed well within 30 minutes.

As stated in the Background section (fourth bulldot) of this Enclosure, there were twenty-eight instances in calendar year 2007 where LCO 3.6.4.1 was entered to facilitate passage through a secondary containment single door opening.

4.3.2 Note 2 (Both Airlock Door Opening)

The proposed change will allow both doors of a secondary containment airlock to be open to allow equipment passage when equipment dimensions necessitate simultaneous door opening. The allowance of opening both airlock doors for equipment passage will not impact secondary containment performance. In the event of a DBA, equipment passage can be manipulated such that one door will be recovered in a short timeframe.

Recovery of one door will restore secondary containment to its design basis configuration assumed in the dose analysis.

As is stated in the proposed Tech Spec Bases, administrative controls by individual personnel will ensure the secondary containment function is not degraded.

Enclosure to PLA-6328 Page 13 of 19 Regulatory Guide 1.183 indicates that the early in-vessel release phase does not begin until 30 minutes. The dose consequences due to increased leakage during the initial 30 minutes of an event would be minimal since a gap release is the only fuel release anticipated during this period.

As stated in the Background section (fifth bulldot) of this Enclosure, there were five instances in calendar year 2007 where LCO 3.6.4.1 was entered because both doors in a secondary containment airlock were simultaneously opened to facilitate equipment passage.

4.4 Risk Discussion This section provides risk insights pertaining to the proposed changes.

Secondary containment does not provide any core damage mitigation and is not credited in PPL's full Level 2 Risk model which includes Core Damage Frequency (CDF) and Large Early Release Frequency (LERF). A loss of secondary containment does not result in a change to the risk model core damage frequency or large early release mitigation results. From a design perspective, secondary containment and SGTS are linked.

Without SGTS, the secondary containment vacuum cannot be established and containment leakage will not be treated before being r:eleased to the environment.

PPL's risk model was peer reviewed in October 2003. This review did not generate. any issues pertaining to the exclusion of secondary containment and SGTS from either the CDF or LERF portions of the model.

4.4.1 Core Damage Mitigation Secondary containment does not provide any core damage mitigation because it does not provide any makeup capability to the reactor vessel nor does it support depressurizing the reactor vessel.

4.4.2 Large Early Release A large release is the result of core damage and containment failure. Containment failure can occur from vessel failure leading to containment failure via over temperature, containment over pressurization, or containment isolation failure.

The majority of failures predicted by PPL's PRA are a result of containment over pressurization. During all over pressurization failures, containment heat removal via the suppression pool has failed. This results in a catastrophic containment failure which is also predicted to fail secondary containment rendering SGTS ineffective.

Enclosure to PLA-6328 Page 14 of 19 For this reason, PPL's full Level 2 Risk model for Susquehanna does not credit secondary containment or SGTS for events that result in a large release. The proposed changes, therefore, do not impact large early release mitigation results.

4.4.3 Defense in Depth The proposed changes do not affect the CDF or LERF. The administrative controls required by the TS Bases for these evolutions will restore the secondary containment boundary in sufficient time to mitigate the consequences of an accident.

4.4.4 External Events Consideration of external events such as flooding and fire do not affect the efficacy of the proposed changes since it has been shown that secondary containment (with SGTS support) is ineffective in mitigating a large release. The CDF and LERF will be the same with or without secondary containment available.

A seismic event has the potential to fail the closed-cooling system water piping. Failure of the closed cooling water primary containment isolation valves was found not to be an issue since the piping is not open to the primary containment atmosphere. However, if a seismic event occurs, the piping integrity can be lost and containment isolation would need to be maintained by the penetration's primary containment isolation valves.

The PPL Risk model uses a probability of 1E-4 for containment isolation failure.

Combined with a seismic frequency of 8.5E-5 per year, this would yield a frequency of 8.5E-9 containment isolation failures per year due to a seismic event.

A seismic event could also cause a loss of offsite power (LOOP). To assess the incremental LERF contribution due to a seismic event, the CDF is divided by the LOOP frequency since the seismic event is assumed to cause a LOOPi and multiplied by the frequency of a seismic event causing a containment isolation failure. This yields:

[(1.6E-6 CDF)/(2.98E-2 LOOP initiation frequency)]*-(8.5E-9 frequency of a seismic event and failing containment isolation), which results in a 4.6E- 13 incremental increase in LERF. This conservatively assumes that all of the CDF is due to a LOOP.

Considering that the base SSES LERF is 1.75E-7, anincrease of 4.6E-13 is insignificant.

4.4.5 Conclusion The proposed changes do not affect the CDF or LERF. Therefore, there is no CDF or LERF increase resulting from the proposed changes to the Secondary Containment Technical Specification.

Enclosure to PLA-6328, Page 15 of 19

5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration This "No Significant Hazards Consideration" evaluates the following changes to the Technical Specifications:

The proposed amendments to the PPL Susquehanna (PPL) Unit 1 and Unit 2 Technical Specification 3.6.4.1 "Secondary Containment" would add a new Required Action option for TS 3.6.4.1 Condition A, to allow additional time to recover secondary containment when the inoperability is not caused by a loss of secondary containment integrity.

The proposed amendments also incorporate a new Actions note to the SSES Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" to allow opening of secondary containment HVAC duct access doors and opening of a secondary containment equipment ingress/egress door under administrative controls.

Additionally, the proposed amendment modifies the existing note to SSES Unit 1 and Unit2 Surveillance Requirement SR 3.6.4.1.3 and adds a second note to this same Surveillance Requirement. The notes expand on those situations where door access openings may occur for entry and exit of people or equipment without invalidating the Surveillance Requirement.

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

Response: No These changes do not involve any physical change to structures, systems, or components (SSCs) and do not alter the method of operation of any SSCs. The current assumptions in the safety analysis regarding accident initiators and mitigation of accidents are unaffected by these changes. No SSC failure modes or mechanisms are being introduced, and the likelihood of previously analyzed failures remains unchanged.

Operation in accordance with the proposed new Required Action option for TS 3.6.4.1 Condition A and the Notes that are being modified and added in both the Unit 1 and Unit 2 Technical Specifications ensures that the secondary containment remains capable of performing its function. The Required Action change, which will permit up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore secondary containment vacuum, only provides this additional time when it can be shown that the vacuum loss has not been caused through compromise of the secondary containment boundary.

Enclosure to PLA-6328 Page 16 of 19 The proposed Note modifications and additions addressing secondary containment access door and duct access door openings will provide relief from TS requirements that must currently be implemented in response to various routine plant activities. These activities can be managed through administrative controls that will ensure doors can be closed quickly (within 30 minutes) to re-establish secondary containment before the early in-vessel release phase begins (Regulatory Guide 1.183).

These changes do not, therefore, result in an increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed changes do not involve a physical alteration of any plant equipment. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There are no setpoints, at which protective or mitigative actions are initiated, affected by this change. This change does not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No alterations in the procedures that ensure the plant remains within analyzed limits are being proposed, and no changes are being made to the procedures relied upon to respond to an off-normal event as described in the FSAR. As such, no new failure modes are being introduced. The change does not alter assumptions made in the safety analysis and licensing basis.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The margin of safety. is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated.' The proposed changes are acceptable because the Completion Time for the new' Required Action to verify secondary containment boundary integrity within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months has been established to be consistent with the current completion time of Condition A. A failure or inability to complete this verification will result in the implementation of LCO 3.6.4.1 requirements in the same timeframe that currently exists. Upon successful completion of this verification, however, the proposed change will provide 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore secondary containment to an operable status through vacuum restoration. When in this condition,

Enclosure to PLA-6328 Page 17 of 19 the secondary containment and SGTS are capable of performing their design basis function.

The Note modifications and additions to TS 3.6.4.1 are also acceptable because the revised Notes provide allowances and exemptions to Technical Specification entry for routine plant activities that can be administratively controlled and quickly restored.

The plant response to analyzed events is not affected by these changes and will, continue to provide the margin of safety assumed by the safety analysis.

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

Based on the above, PPL concludes that the proposed changes do 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.

5.2 Applicable Regulatory Requirements/Criteria SSES FSAR Sections 3.1 and 3.13 provide detailed discussion of SSES compliance with the applicable regulatory requirements and guidance.

The proposed TS amendment:

(a) Does not alter the design or function of any system; (b) Does not result in any change in the qualifications of any component; and (c) Does not result in the reclassification of any component's status in the areas of shared, safety-related, independent, redundant; and physically or electrically separated.

5.2.1 General Design Criteria The following applicable General Design Criteria (GDC) for the secondary containment requires that the secondary containment to be design and maintained so that offsite doses remain below the regulatory guidelines:

GDC 16 - Containment Design The proposed changes will maintain offsite and control room doses below regulatory limits. The changes represent actions that either do not impact secondary containment integrity or are conditions in which secondary containment integrity can be recovered in a

Enclosure to PLA-6328 Page 18 of 19 relatively short time frame and therefore will have an insignificant impact on the dose consequences.

Note that GDC 41, 42 and 43 pertain to SGTS but do not specifically pertain to secondary containment integrity. Compliance with these GDC's is not affected by the proposed changes.

5.2.2 Applicable Regulatory Guides There are no Regulatory Guides that apply specifically to Secondary Containment.

Regulatory Guide 1.183 allows crediting secondary ciontainment in the dose analysis but does not provide specific design requirements. Regulatory Guide 1.52 is applicable to SGTS which supports secondary containment and is discussed below:

Regulatory Guide 1.52:

Regulatory Guide 1.52 is titled "Design, Testing, and Maintenance Criteria for Engineered-Safety Feature Atmosphere Cleanup Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." Regulatory Guide 1.52 addresses the atmosphere cleanup system, including the various components and ductwork, in a postulated design basis radiological accident environment.

The proposed changes associated with secondary containment are intended to minimize the time an operating plant is exposed to a reduction in radiological accident mitigation capability. Conformance with GDC 16, 41, 42, and 43, as well as conformance with Regulatory Guide 1.52 are not affected by these proposed changes.

Thus, the proposed changes do not change the conformance with the above General Design Criteria and regulatory guidance.

Conclusion Based on the analysis provided in Section 4.0: (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. 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.

Enclosure to PLA-6328 Page 19 of 19 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 change and has determined that the proposed change meets 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.

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. REFERENCES

1. Susquehanna Steam Electric Station Final Safety Analysis Report, Docket Numbers 50-387 and 50-388.

Attachment I to PLA-6328 PPL Susquehanna, LLC Proposed Change to Unit 1 and Unit 2 TS 3.6.4.1 "Secondary Containment" and TS 3.6.4.3 "Standby Gas Treatment System" (Mark-ups)

PPL Rev. 3 Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6;4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During, CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS -* ------

.................................. NOTE ------------------------------

Duct access doors and the 102 door may be opened under administrative controls provided no movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, or operations with a potential for draining the reactor vessel (OPDRVs) are in progress.

CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for a one-time outage for OR replacement of the Reactor Building Recirculating Fan Damper Motors, to A.2 Verify secondary containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months be completed by December 31, 2005.1j boundary integrity.

AND A,3 Restore secondary 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment to OPERABLE status.

B. Required Action and B.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 not met.

AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Formatted: Strikethrough SUSQUEHANNA - UNIT 1 TS / 3.6-35 Amendment','/78, Q26

PPL Rev, 3 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

-SR-3.-6.-.-.3 -------------- "NOTE ------------------- { Formatted. Font: Arnal, It pt I. Single door access openings between I Formatted: Bullets and Numbering required zones within the secondary containment boundary and single door secondary containment access openings may be opened for entry and exit.

2. Access openings with two doors may be opened to allow passage of equipment requiring both doors to be open.

. . Verify one secondary containment access door in 31 days 3.64.1.3 each access opening is closed.

SR 3.6.4.1.4 ------------ ..---------------NOTE -----------------------------.--------------- NOTE ----------------

The maximum time allowed for secondary Test each configuration at containment draw down is dependent on the least one time every 60 secondary containment configuration. months.

Verify each standby gas treatment (SGT) 24 months on a subsystem will draw down the secondary STAGGERED TEST BASIS containment to > 0.25 inch of vacuum water gauge in less than or equal to.the maximum time allowed for the secondary containment configuration that is OPERABLE.

SR 3.6.4.1.5 ------ ----- ..........------- NOTE ----------------------------.--------------- NOTE ----------------

The maximum flow allowed for maintaining Test each configuration at secondary containment vacuum is dependent on least one time every 60 the secondary containment configuration, months.

Verify each SGT subsystem can maintain 24 months on a

Ž 0,25 inch of vacuum water gauge in the STAGGERED TEST BASIS secondarycontainment for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate less than or equal to the maximum flow rate permitted for the secondary containment configuration that is OPERABLE.

.rFormatted: Strlkethrough SUSQUEHANNA - UNIT I TS / 3.6-37 Amendment -68,2-66,,2-2-_

PPL Rev. 3 Secondary Containment 3.6.4.1 3.6 CONTAINMENT SYSTEMS 3.6.4.1 Secondary Containment LCO 3.6.4.1 The secondary containment shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS ......................................... NO --TE --------------------------------------------------

Duct access doors and the 102 door may be opened under administrative controls provided no movement of irradiated fuel assemblies in the secondary containment, CORE ALTERATIONS, or operations with a potential for draining the reactor vessel (OPDRVs) are in progress..

CONDITION REQUIRED ACTION COMPLETION TIME A. Secondary containment A.1 Restore secondary 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, 2, containment to OPERABLE or 3. status. Deleted: OR¶ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for a one-time outage tor OR replacement of the Reactor Building Recirculating Fan Damper Motors, to A.2 Verify secondary containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months be completed by December 31, 2005.1 boundary integrity.

AND A.3 Restore secondary 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months containment to OPERABLE status, B. Required Action and B.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 not met.

AND B.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SUSQUEHANNA - UNIT 2 TS / 3.6-35 Amendment P51, 2-03

PPL Rev. 3 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

,SR 3.64.1.3 . .---.--.. '-.--.-."-:-.-.-.---. NOTE---.-.-7-------.. .-----

7:.. Formatted: Font: Aria[, 11 pt 1, Single door access openings between Formatted: Bullets and Numbering required zones within the secondary containment boundary and single door secondary containment access openings may be opened for entry and exit.

2. Access openings with two doors may be opened to allow passage of equipment requiring both doors to be open.

Verify .oneseco ndary containment access door in 31 days ,Foreated: SR 3.6.4.1.3 3 each access opening is closed.

SR 3.6.4.1.4 ---------------- NOTE ------------------------. NOTE-------

The maximum time allowed for secondary Test each configuration at containment draw down is dependent on the least one time every 60 secondary containment configuration. months.

Verify each standby gas treatment (SGT) 24 months on a subsystem will draw down the secondary STAGGERED TEST BASIS containment to Ž_0.25 inch of vacuum water gauge in less than or equal to the maximum time allowed for the secondary containment configuration that is OPERABLE.

SR 3.6,4.1.5 --------------- NOTE ----------------------- -NOTE -------

The maximum flow allowed for maintaining Test each configuration at secondary containment vacuum is dependent on least one time every 60 the secondary containment configuration. months.

Verify each SGT subsystem can maintain 24 months on a

> 0.25 inch of vacuum water gauge in the STAGGERED TEST BASIS secondary containment for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at a flow rate less than or equal to the maximum flow rate permitted for the secondary containment configuration that is OPERABLE.

(Formatted; Strikethrough J SUSQUEHANNA - UNIT 2 TS / 3.6-37 Amendment ,1,1, *, 23, _G5

PPL Rev. -4 SGT System 3.6.4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND C.2.2 Suspend CORE Immediately ALTERATIONS.

AND C.2.3 Initiate action to suspend Immediately OPDRVs.

D. Two SGT subsystems D.1 Restore one SGT subsystem 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in MODE 1, 2, to OPERABLE status.

or 3. ' . Deleted: OR¶

- .1.-1 R11 .

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for a one-time outage for replacement of the Reactor Building E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Recirculating Fan Damper Motors, to associated Completion Time be completed by December 31, 2005.1 of Condition D not met in MODE 1, 2, or 3. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SUSQUEHANNA - UNIT 1 TS / 3.6-43 Amendment Yý8,226

PPL Rev. 4 SGT System 3.6A4.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.1 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.

AND C.2.2 Suspend CORE Immediately ALTERATIONS.

AND C.2.3 Initiate action to suspend Immediately OPDRVs.

D. Two SGT subsystems D01 Restore one SGT subsystem 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1, inoperable in MODE 1, 2, to OPERABLE status.

or 3. Deleted; OR1]

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for a one-time outage for replacement of the Reactor Building E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Recirculating Fan Damper Motors, to associated Completion Time be completed by December 31, 2005.1 of Condition D not met in MODE 1,2, or 3. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

_(continued)

SUSQUEHANNA - UNIT 2 TS / 3.6-43 Amendment /51, 2G3

Attachment 2 to PLA-6328 PPL Susquehanna, LLC Proposed Change to Unit 1 and Unit 2 TS Bases 3.6.4.1 "Secondary Containment" and TS Bases 3.6.4.3 "Standby Gas Treatment System" (Mark-ups provided for Information Only)

PPL Rev. 7 Secondary Containment B 3.6.4.1 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES.

Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for

which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs),

during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

ACTIONS The ACTIONS are modified by one Note. This Note allows duct access openings to be opened under administrative controls. The Note applies to duct openings that create a communication path between a required' secondary containment zone and the environment in support of required surveillances. The administrative controls ensure the duct access opening can be closed quickly when a need for secondary containment is required.

The Note also allows the 102 door to be opened under administrative controls to allow movement of equipment into and out of the reactor building.

The administrative controls will ensure that the door can be closed quickly should secondary containment be required.

A. 1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of ,

maintaining secondary containment during MODES 1, 2, and 3. This time period:also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

A.2 and A.3 With secondary containment inoperable and the secondary containment boundary integrity able to be verified, SGTS is capable of establishing and maintaining the secondary containment at the required vacuum. This ensures the release of radioactive materials to the environment is restricted to those leakage paths and associated leakage rates assumed in the accident analysis. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a sufficient period (continued)

SUSQUEHANNA - UNIT 1 TS / B 3.6-86 Revision/4

PPL Rev. 7-Secondary Containment 8 3.6.4.1 BASES ACTIONS A.2 and A.3 (continued) of time to perform inspections to verify integrity of the secondary containment boundary. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurrin~g during periods where secondary containment integrity may not be capable of being established and maintained is minimal.

With secondary containment integrity verified, SGTS is capable of establishing. and maintaining secondary containment as assumed in the accident analysis. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months completion time provides adequate time to restore the secondary containment to OPERABLE status. This completion time accounts for the low probability of a DBA occurring during this timne period and that the boundary integrity has been verified. Thus SOTS is capable of establishing and maintaining the required secondary containment vacuum, Deleted., A temporary (one-time)

Completion Time isconnected to the Completion Time Requirements 8.1 and B.2 above (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) with an 'OR" connector. The Temporary If secondary containment cannot be restored to OPERABLE status Within the Completion lime is48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months end applies to the replacement ot the required Completion Time, the plant must be brought to a MODE inwhich Reactor Building Recirculating Fan the LCO does not apply. To achieve this status, the plant must be brought to Damper Motors. The Temporary at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may allowed Completion Times are reasonable, based on operating experience, only be used once, and expires on December 31, 2005.

to reach the required plant conditions from full power conditions in an: orderly manner and without challenging plant systems.

(continued)

SUSQUEHANNA - UNIT 1 SUSQEHANA

/ B 3.6-86 UNT1TS Revision /*

PPL Rev. -7 Secondary Containment B 3.6.4.1 BASES SURVEILLANCE SR 3.6.4.1.2 and SR 3.6.4.1.3 (continued)

REQUIREMENTS When an access opening between required secondary containment zones is

,being used for exit and entry, then at least one door (where two doors are provided) must remain closed. The access openings between secondary containment zones which are not provided with two doors are administratively controlled to maintain secondary containment integrity during exit and entry. This Surveillance is modified bylqwo Ntpes. ,The !irst Noe . Deleted: a allows access openings with a single door (i.e., no airlock)secondary within the Deleted: that between required secondary containment boundary (i.e.,

containment zones) and allows access openings with a single door (i.e.

between a required secondary containment zone and the environment) to be opened for entry and exit. The second Note allows opening of both doors in an access opening to be opened concurrently when required to move equipment into and out of the secondary containment that is too large to be moved without the opening of both doors in the access opening..

Opening of~access doors for entry and exit allows sufficient administrative ... Feleted: an--

control by individual personnel making the entries and exits to.assure the secondary containment function is not degraded. , -.. / Deleted: When one of the zones Is not a zone required for secondary The 31 day Frequency for these SRs has been shown to be adequate, containment OPERABILITY, the Note based on operating experience, and is considered adequate in view of the other indications of door and hatch status that are available to the operator.

(continued)

SUSQUEHANNA - UNIT I TS / B 3.6-88a . Revision 2

PPL Rev. 7 Secondary Containment B 3.6.4.1 BASES (continued)

APPLICABILITY In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.

In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations in these MODES.

Therefore, maintaining secondary containment OPERABLE is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs),

during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.

ACTIONS The ACTIONS are modified by one Note. This Note allows duct access openings to be opened under administrative controls. The Note applies to duct openings that create a communication path between a required secondary containment zone and the environment in support of required surveillances. The administrative controls ensure the duct access opening can be closed quickly when a need for secondary containment is required.

The Note also allows the 102 door to be opened under administrative controls to allow movement of equipment into and out of the reactor building.

The administrative controls will ensure that the door can be closed quickly should secondary containment be required.

A.1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.

A.2 and A.3 With secondary containment inoperable and the secondary containment boundary integrity able to be verified, SGTS is capable of establishing and maintaining the secondarycontainment at the required vacuum, This ensures the release of radioactive materials to the environment is restricted to those leakage paths and associated leakage rates assumed in the accident analysis. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a sufficient period of time to perform inspections to verify integrity of the secondary containment boundary. This time period also ensures that the probability of an accident (continued)

SUSQUEHANNA - UNIT 2 TS / B 3.6-85 RevisiorL4"

PPL Rev. 7 Secondary Containment B 3.6.4.1 BASES ACTIONS A.2 and A.3 (continued)

(requiring secondary containment OPERABILITY) occurring during periods where secondary containment integrity may not be capable of being established and maintained is minimal.

With secondary containment integrity verified, SGTS is capable of establishing and maintaining secondary containment as assumed inthe accident analysis. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months completion time provides adequate time to restore the secondary containment to OPERABLE status. This completion time accounts for the low probability of a DBA occurring during this time period and that the boundary integrity has been verified. Thus SGTS is capable of establishing and maintaining the required secondary containment vacuum, Deleted: A temporary (one-time)

Completion Time is connected to the Completion Time Requirements B.1 and B.2 above (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) with an"OR" connector. The Temporary If secondary containment cannot be restored to OPERABLE status within the Completion Time is 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and required Completion Time, the plant must be brought to a MODE in which applies to the replacement of the Reactor Building Recirculating Fan the LCO does not apply. To achieve this status, the plant must be brought to Damper Motors. The Temporary at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may allowed Completion Times are reasonable, based on operating experience, only be used once, and expires on December 31, 2005.

to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

SUSQUEHANNA - UNIT 2 TS / B 3.6-85 Revision/,

PPL Rev. '

Secondary Containment B 3.614.1 BASES SURVEILLANCE SR 3.6.4.1.2 and SR 3.6.4.1.3 (continued)

REQUIREMENTS When an access opening between secondary containment zones is being used for exit and entry, then at least one door (where two doors are provided) must remain closed. The access openings between secondary containment zones which are not provided with two doors are administratively controlled to maintain secondary containment integrity during exit and entry. This Surveillance is modified by _wo Notes. The first Note r 1Deleted: a allows access openings with a single door (i.e., no airlock) within the " Deleted: that secondary containment boundary (i.e., between required secondary containment zones) and allows access openings with a single door (i.e.

between a required secondary containment zone and the environment) to be opened for entry and exit. The second Note allows opening of both doors in an access opening to be opened concurrently when required to move equipment into and out of the secondary containment that is too large to be moved without the opening of both doors In the access opening.

Opening of access doors for entry ande.xit allows sufficient administrative Deleted: an control by individual personnel making the entries and exits to assure the secondary containment function is not degraded. Deleted: When one of the zones Is not a zone required for secondary The 31 day Frequency for these SRs has been shown to be adequate, containment OPERABILITY, the Note allowance would not apply.

based on operating experience, and is considered adequate in view of the other indications of door and hatch status that are available to the operator.

SUSQUEHANNA - UNIT 2 TS I B 3.6-89 Revision 2

PPL Rev. A SGT System B 3.6.4.3 BASES ACTIONS D.1 (continued)

If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT system may not be capable of supporting the required radioactivity release control function. The.4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining the SGT System contribution to secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring SGT OPERABILITY) occurring during periods where SGT is inoperable is minimal.

-o-e-*;*

Deleted; 1 ......

~ ~........

Atemporary (one-time) Completion Time is connected to the Completion E.1 and E.2 Time Requirements above (4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ) with an "OR" connector. The If at least one SGT subsystem cannot be restored to OPERABLE status Temporary Completion Time Is 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and applies to the replacement within the required Completion Time, the plant must be brought to a MODE of the Reactor Building Recirculating in which the LCO does not apply. To achieve this status, the plant must be Fan Damper Motors, The Temporary brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may only be used once, and expires on The allowed Completion Times are reasonable, based on operating December 31, 2005.

experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1, F.2, and F.3 When two SGT subsystems are inoperable, if applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of these activities shall not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel .draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

SUSQUEHANNA - UNIT 1 TS / B 3.6-105 Revision 3

PPL Rev./4 SGT System B 3.6.4.3 BASES ACTIONS D.1 (continued)

If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT system may notbe capable of supporting the required radioactivity release control function. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time provides a period of time to correct the problem that is commensurate with the importance of maintaining the SGT System contribution to secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring SGT OPERABILITY) occurring during periods where SGT is inoperable is minimal.

Deleted: A temporary (one-time)

Completion Time is connected to the Completion Time Requirements E.I'. and E.2 above (4 hour~s) with an "OR" connector. The Temporary If at least one SGT subsystem cannot be restored to OPERABLE status Completion Time is 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and applies to the replacement of the within the required Completion Time, the plant must be brought to a MODE Reactor Building Recirculating Fan in which the LCO does not apply. To achieve this status, the plant must be Damper Motors. The Temporary brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may The allowed Completion Times are reasonable, based on operating only be used once, and expires on December 31, 2005.

experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

F.1, F.2, and F.3 When two SGT subsystems are inoperable, if applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of these activities shall, not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.

Fonmatted: Strikethrough SUSQUEHANNA - UNIT 2 TS / B 3.6-104 Revision,3..

PLA-6328, Proposed License Amendment No. 299 for Unit 1 and Proposed License Amendment No. 269 for Unit 2 for Changes to Technical Specifications 3.6.4.1 Secondary Contaminant and 3.6.4.3 Standby Gas Treatment System

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PLA-6328, Proposed License Amendment No. 299 for Unit 1 and Proposed License Amendment No. 269 for Unit 2 for Changes to Technical Specifications 3.6.4.1 Secondary Contaminant and 3.6.4.3 Standby Gas Treatment System

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Enclosure:

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