Text

Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2
	ML23333A214
Person / Time
Site:	Susquehanna
Issue date:	11/29/2023
From:	Casulli E; Susquehanna, Talen Energy
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	PLA-8084
	Download: ML23333A214 (1)
	v • d • e

TALEN~

Edward Casulli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 ENERGY Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@talenenergy.com November 29, 2023 Attn: Document Control Desk 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT TO LICENSES NPF-14 AND NPF-22: APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-568, REVISE APPLICABILITY OF BWR TS 3.6.2.5 AND TS 3.6.3.2 Docket No. 50-387 PLA-8084 and 50-388 Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC (Susquehanna), is submitting a request for an amendment to the Technical Specifications (TS) for the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Facility Operating License numbers NPF-14 and NPF-22.

Susquehanna requests adoption of TSTF-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of TS 3.6.3.3, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content. provides a description and assessment of the proposed change. Enclosure 2 provides the existing TS pages marked to show the proposed change. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

Susquehanna requests review of this amendment request under the Consolidated Line Item Improvement Process. Approval of the proposed amendment is requested by June 30, 2024.

Once approved, the amendment shall be implemented within 60 days.

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

Both the Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed the proposed changes.

Document Control Desk PLA-8084 There are no new or revised regulatory commitments contained in this submittal.

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

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

Executed on November 29, 2023.

E. Casulli

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised (Clean) Technical Specification Pages

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

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

Enclosure 1 to PLA-8084 Description and Assessment

1. DESCRIPTION

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

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

4. ENVIRONMENTAL EVALUATION

Enclosure 1 to PLA-8084 Page 1 of 4 SUSQUEHANNA ASSESSMENT

1. Description Susquehanna Nuclear, LLC (Susquehanna), requests adoption of TSTF-568, "Revise the Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.3, "Primary Containment Oxygen Concentration,"

and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

2. Assessment 2.1 Applicability to Safety Evaluation Susquehanna has reviewed the safety evaluation for TSTF-568 provided to the Technical Specifications Task Force in a letter dated December 17, 2019. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-568. Susquehanna has concluded that the justifications presented in TSTF-568 and the safety evaluation prepared by the NRC staff are applicable to Susquehanna Steam Electric Station (SSES), Units 1 and 2 and justify this amendment for the incorporation of the changes to the SSES Unit 1 and 2 TS.

2.2 Optional Changes and Variations Susquehanna is proposing the following variation from the TS changes described in TSTF-568 or the applicable parts of the NRC staffs safety evaluation:

The SSES TS utilize different numbering than the STS on which TSTF-568 was based.

Specifically, SSES Unit 1 and 2 TS 3.6.3.3, Primary Containment Oxygen Concentration, corresponds to STS 3.6.3.2, Primary Containment Oxygen Concentration. This difference is administrative and does not affect the applicability of TSTF-568 to the SSES Unit 1 and 2 TS.

The proposed change to TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," in TSTF-568 is not applicable to SSES and is not included.

Enclosure 1 to PLA-8084 Page 2 of 4

3. Regulatory Analysis 3.1 No Significant Hazards Consideration Analysis Susquehanna Nuclear, LLC (Susquehanna), requests adoption of TSTF-568, "Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2." TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.3.3, "Primary Containment Oxygen Concentration,"

and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

Susquehanna has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.3, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. Primary Containment Oxygen Concentration is not an initiator to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not affected by the proposed change.

Primary Containment Oxygen Concentration is an assumption in the mitigation of some accidents previously evaluated. The Applicability of TS 3.6.3.3 is changed from Mode 1 when thermal power is greater than 15% to Modes 1 and 2. This expands the Applicability of the TS and will not have an effect on the consequences of an accident.

The existing Applicability exceptions are removed and replaced with a longer Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The consequences of an event that could affect the primary containment oxygen concentration are no different during the proposed Completion Time than the consequences of the same event during the existing Completion Times. A note referencing Limiting Condition for Operation (LCO) 3.0.4.c is added to the Actions to permit entering the Applicability with the LCO not met. The note replaces the existing Applicability exceptions. This change is administrative and has no effect on the consequences of an accident.

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

Enclosure 1 to PLA-8084 Page 3 of 4

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

Response: No The proposed change revises the Applicability and Actions of TS 3.6.3.3, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed).

No credible new failure mechanisms, malfunctions, or accident initiators that would have been considered a design basis accident in the Updated Final Safety Analysis Report are created because the Nuclear Regulatory Commission has determined that hydrogen generation is not risk significant for design basis accidents.

Therefore, the proposed change 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 The proposed change revises the Applicability and Actions of TS 3.6.3.3, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the STS format and content. No safety limits are affected. No Limiting Conditions for Operation or Surveillance limits are affected. The Primary Containment Oxygen Concentration Technical Specification requirements assure sufficient safety margins are maintained, and that the design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis.

The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety.

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

Based on the above, Susquehanna concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Enclosure 1 to PLA-8084 Page 4 of 4 3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4. Environmental Evaluation The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Enclosure 2 of PLA-8084 Proposed Technical Specification Changes (Mark-Up)

Revised Technical Specifications Pages Unit 1 TS Page 3.6-34 Unit 2 TS Page 3.6-34

Primary Containment Oxygen Concentration 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Primary Containment Oxygen Concentration LCO 3.6.3.3 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2. during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 ----------- NOTE ------------- 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months oxygen concentration not LCO 3.0.4.c is applicable.

within limit. ----------------------------------

Restore oxygen concentration to within limit.

B. Required Action and B.1 Be in MODE 3Reduce 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months associated Completion THERMAL POWER to Time not met. 15% RTP.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.6-34 Amendment 178, 266, xxx

Primary Containment Oxygen Concentration 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Primary Containment Oxygen Concentration LCO 3.6.3.3 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2. during the time period:

a. From 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is > 15% RTP following startup, to

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to reducing THERMAL POWER to 15% RTP prior to the next scheduled reactor shutdown.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 ----------- NOTE ------------- 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months oxygen concentration not LCO 3.0.4.c is applicable.

within limit. ----------------------------------

Restore oxygen concentration to within limit.

B. Required Action and B.1 Be in MODE 3Reduce 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months associated Completion THERMAL POWER to Time not met. 15% RTP.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.6-34 Amendment 151, 247, xxx

Enclosure 3 of PLA-8084 Revised (Clean) Technical Specification Pages Revised Technical Specifications Pages Unit 1 TS Page 3.6-34 Unit 2 TS Page 3.6-34

Primary Containment Oxygen Concentration 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Primary Containment Oxygen Concentration LCO 3.6.3.3 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 ----------- NOTE ------------- 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months oxygen concentration not LCO 3.0.4.c is applicable.

within limit. ----------------------------------

Restore oxygen concentration to within limit.

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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 1 3.6-34 Amendment 178, 266, xxx

Primary Containment Oxygen Concentration 3.6.3.3 3.6 CONTAINMENT SYSTEMS 3.6.3.3 Primary Containment Oxygen Concentration LCO 3.6.3.3 The primary containment oxygen concentration shall be < 4.0 volume percent.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment A.1 ----------- NOTE ------------- 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months oxygen concentration not LCO 3.0.4.c is applicable.

within limit. ----------------------------------

Restore oxygen concentration to within limit.

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 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.3.1 Verify primary containment oxygen concentration is In accordance with within limits. the Surveillance Frequency Control Program SUSQUEHANNA - UNIT 2 3.6-34 Amendment 151, 247, xxx

Enclosure 4 of PLA-8084 Marked-Up Technical Specification Bases Changes Revised Technical Specifications Bases Pages Unit 1 TS Bases Pages 3.6-82, 3.6-83 Unit 2 TS Bases Pages 3.6-81, 3.6-82 (Provided for Information Only)

Rev. 3 Primary Containment Oxygen Concentration B 3.6.3.3 BASES LCO The primary containment oxygen concentration is maintained < 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.

APPLICABILITY The primary containment oxygen concentration must be within the specified limit when primary containment is inerted, except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODE 1 and 2, since this is the condition with the highest probability of an event that could produce hydrogen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus.

Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. As long as reactor power is < 15% RTP, the potential for an event that generates significant hydrogen is low and the primary containment need not be inert.

Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a startup, or within the last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before a shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

ACTIONS A.1 If oxygen concentration is 4.0 v/o at any time while operating in MODE 1 or 2, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 v/o within 7224 hours0.0836 days 2.007 hours 0.0119 weeks 0.00275 months . The 7224 hour0.0836 days 2.007 hours 0.0119 weeks 0.00275 months Completion Time is allowed when oxygen concentration is 4.0 v/o because of the low probability and long duration of an event that would generate significant amounts of hydrogen occurring during this period.

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allowance is acceptable because inerting the primary containment prevents containment access without an appropriate breathing apparatus.

Therefore, the primary containment is inerted as late as possible in the plant startup, after entering Modes 1 and 2, and de-inerted as soon as possible in the plant shutdown. It is acceptable to intentionally enter Required Action A.1 prior to a shutdown in order to begin de-inerting the primary containment prior to exiting the Applicability.

SUSQUEHANNA - UNIT 1 3.6-82

Rev. 3 Primary Containment Oxygen Concentration B 3.6.3.3 BASES ACTIONS B.1 (continued)

If oxygen concentration cannot be restored to within limits within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, power must be reduced to MODE 3 15% RTP within 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months . The 812 hour0.0094 days 0.226 hours 0.00134 weeks 3.08966e-4 months Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.3.1 REQUIREMENTS The primary containment must be determined to be inert by verifying that oxygen concentration is < 4.0 v/o. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. FSAR, Section 6.2.5.

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

SUSQUEHANNA - UNIT 1 3.6-83

Rev.3 Primary Containment Oxygen Concentration B 3.6.3.3 BASES LCO The primary containment oxygen concentration is maintained < 4.0 v/o to ensure that an event that produces any amount of hydrogen does not result in a combustible mixture inside primary containment.